Created By: Sylvia Scott on 08/27/1999 at 02:08 PM
Category: Campaign Finance Advisory Opinions
July 16, 1999
Mr. Charles C. Barham
Casino Association of Louisiana
P. O. Box 3801
Baton Rouge, LA 70821
Re: Ethics Board Docket No. 99-424
Dear Mr. Barham:
The Louisiana Board of Ethics, at its July 15, 1999 meeting, considered your request for an advisory opinion concerning the participation of riverboat casinos, management employees of casinos, and other casino employees in political campaign activities. The Board reviewed specifically the provisions of R.S. 18:1505.2L and responded to your specific questions as follows:
(1) Can an employee make a campaign contribution?
A: An employee who is not an owner of over 10% of the company and is not an officer, director, trustee, partner, senior management level or key employee may make contributions.
(2) Can the casino make a campaign contribution?
A: The casino may not make a contribution.
(3) Can the management of the casino make a contribution?
A: Senior management level and key employees as defined in R.S. 27:205(19) may not make contributions.
(4) Can an employee place a yard sign at the home supporting a candidate?
A: An employee may place a yard sign at his home supporting a candidate.
(5) Can an employee volunteer time to work on a phone bank, canvas neighborhoods, in favor of a candidate, help in the management or coordination of a candidate’s campaign?
A: An employee may volunteer time to support a candidate.
Docket No. 99-424
(6) Which employees or stockholders are prohibited by law from making campaign contributions?
A: Owners of over 10% of the company and officers, directors, trustees, partners, senior management level and key employees are prohibited by law from making contributions.
(7) Can management and key employee personnel assist a candidate financially or in any other manner?
A: Management level and key employees may not assist a candidate financially, but may assist in other ways such as volunteering time or displaying yard signs.
(8) Can a casino organize a "get out the vote" phone bank if general in nature and does not ask the voter to support a particular candidate or issue?
A: A casino may organize a "get out the vote" phone bank if it acts without the cooperation or consultation of any candidate or the representative of any candidate.
(9) All casinos produce an employee in house newsletter. Within that newsletter, can the casino encourage its employees to vote for or against a specific candidate?
A: A casino may encourage employees to vote for or against a specific candidate in an in-house newsletter if it acts without the cooperation or consultation of any candidate or the representative of any candidate.
(10) The Executive Director of the Casino Association of Louisiana is compensated through the payment of dues by the riverboat casinos who are members of the association. Can the Executive Director of the Casino Association make campaign contributions and/or participate in any other manner in political campaigns?
A: The executive director of the Casino Association of Louisiana may make campaign contributions and otherwise participate in political campaigns, assuming the director does not otherwise fit within the above described prohibited categories.
If you have any other questions, please call me at 922-1400.
LOUISIANA BOARD OF ETHICS
Maris LeBlanc McCrory
For the Board
cc: The Honorable Hillary Crain, Gaming Control Board