Declaratory Rulings


2019 Declaratory Ruling 2019-01: The State Contractor Status of Medical Marijuana Industry Licensees Declaratory Ruling 2019-02: The Use of Campaign Funds to Offset Candidate’s Childcare Costs
Final Declaratory Ruling 2019-02 Letter from FEC Chair Ellen L. Weintraub Comments from Liuba Grechen Shirley Comments from Carrie Robinson

Good Afternoon,

It is my belief that child care expenses incurred by campaign activities must be eligible for reimbursement. If we want to expand those running for office including women or those less affluent this needs to be a priority and as a constituent I urge you to pass this bill. Connecticut is already an expensive state to raise a child and not being able to afford child care as you navigate campaign events, debates, and knocking on doors should not be a further cost constituents of our state should have to endure. I hope you all are on the right side of history with this vote.

Thank you,
Carrie Robinson
Comments from Natalie Held

To Whom it May Concern,

In the year 2019, there is no excuse as to why we shouldn’t pass legislation to more allow women, parents, and diverse candidates to seek positions in public office. For too long now, there have been barriers in place preventing every day people from running. That must stop. Now.

By not allowing candidates to use their campaign finances, that they have raised, towards child care, we are doing a disservice to our country. Running for office is already tilted in favor of the affluent, who are able to run campaigns unencumbered by the challenges others confront, like the cost of child care and working while campaigning. The Federal Election Commission and six other states allow reimbursement of child care expense (Alabama, Louisiana, Arkansas, Texas, etc); the list is growing every month.

Our democracy was created so the people could have a voice. If these people can’t even get their voices heard due to such absurd restrictions, how are we upholding the values of our democracy? If other states like Alabama, Arkansas, Texas, Wisconsin, etc. have allowed the use of these funds for child care, there is no reason why such a liberal, progressive state like Connecticut shouldn’t allow candidates to use their campaign dollars for child care as well.

If we want to see changes in those who run for public office, we must start to make changes to the current laws that exist and hold us back. Running for office shouldn’t be determined by your socio-economic status. Child care is a luxury that not everyone can afford. If someone is willing to dedicate their time to be a public servant, the very least we can do is alleviate the stressors that prevent them from running their campaign.

The CEP was “designed to encourage citizen participation and limit the role of private money in CT’s political process.” That cannot happen if parents dependent on the care of their children can’t afford to run!

I am in support of reimbursing child care expenses through the Citizens Election Program.

Best,
Natalie Held
Fairfield, CT
Comments from Sandy Clarkson

I am in total support of Candidates being allowed to use campaign funds for child care reimbursements while running for office.

Please note -- that to achieve the goal of the Citizens' Election Program, child care expenses incurred by campaign activities must be eligible for reimbursement.

Thanks,
Sandy Clarkson
Comments from Jonathan Perloe

Re: Proposed Declaratory Ruling 2019-02

Members of the State Elections Enforcement Commission:

In the 2018 election candidate for State Representative Caitlin Clarkson Pereira was denied reimbursement by the State Elections Enforcement Commission for childcare expenses. I do not believe this was a fair decision, nor one in keeping with the spirit of the Citizen’s Election Program

Running for office is already tilted in favor of the affluent who are able to run campaigns unencumbered by the challenges others confront like the cost of childcare and working while campaigning. The Federal Election Commission and seven other states allow reimbursement of childcare expenses. Fulfilling CEP’s objective of expanding opportunities for women and less affluent candidates to run for public office can’t be achieved if they’re hamstrung by unfair reimbursement policies.

The CEP was “designed to encourage citizen participation and limit the role of private money in CT’s political process.” That can’t happen if moms (or dads) dependent on daycare can’t afford to run. Please reverse your decision and make it SEEC policy to allow for reimbursement of child care expenses incurred by candidates participating in the CEP.

Sincerely,
Jonathan Perloe
Cos Cob, CT
Comments from Christine Kidd

I'm writing with regards to the SEEC's opinion that disallows childcare expenses to be considered as costs that can be covered by campaign funds. I'm troubled by this finding and hope that the state will opt to reverse it.

As we seek to grow into a more equitable and open democratic system, bringing down barriers to candidates who are parents will be critical -- this is true of mothers, fathers, and others who care for our children. The Federal Election Commission and six other states allow reimbursement of child care expense (Alabama, Louisiana, Arkansas, Texas, etc); the list is growing every month. Connecticut should follow suit, opening the doors for more to run for office and care for their families while doing so.

Christine Kidd
Comments from Katrina Snider

To Whom it May Concern,

In the year 2019, there is no excuse as to why we shouldn’t pass legislation to allow women, parents, and diverse candidates to seek positions in public office. For too long now, there have been barriers in place preventing every day people from running. That must stop. Now.

By not allowing candidates to use their campaign finances, that they have raised, towards child care, we are doing a disservice to our country. Running for office is already tilted in favor of the affluent, who are able to run campaigns unencumbered by the challenges others confront, like the cost of child care and working while campaigning. The Federal Election Commission and six other states allow reimbursement of child care expense (Alabama, Louisiana, Arkansas, Texas, etc); the list is growing every month.

Our democracy was created so the people could have a voice. If these people can’t even get their voices heard due to such absurd restrictions, how are we upholding the values of our democracy? If other states like Alabama, Arkansas, Texas, Wisconsin, etc. have allowed the use of these funds for child care, there is no reason why such a liberal, progressive state like Connecticut shouldn’t allow candidates to use their campaign dollars for child care as well. If we want to see changes in those who run for public office, we must start to make changes to the current laws that exist and hold us back. Running for office shouldn’t be determined by your socio-economic status. Child care is a luxury that not everyone can afford. If someone is willing to dedicate their time to be a public servant, the very least we can do is alleviate the stressors that prevent them from running their campaign. The CEP was “designed to encourage citizen participation and limit the role of private money in CT’s political process.” That cannot happen if parents dependent on the care of their children can’t afford to run! I am in support of reimbursing child care expenses through the Citizens Election Program.

Katrina Snider
Comments from David Farnworth

To Whom it May Concern,

Connecticut is known as a progressive state, in saying that, states like Texas, Alabama, Louisiana and Arkansas are leading the way on this subject. We need to pass legislation to support women, men and diverse candidates of all ages with children to seek positions in public office, that truly represent the population of the state. Childcare is a necessary everyday part of bringing up children, it’s important and it is costly, particularly in a many towns in CT.

The initial ruling to restrict the use of funds towards childcare to only being allowable prior to CEP funds being awarded is a ridiculously artificial hurdle, placed at a time when the candidate needs to ramp up the need to be out meeting the electorate. By allowing candidates to attend meetings, events and knock on doors in order to meet the voters is well known to be the most effective way for candidates to put across their message, giving the electorate the best chance to make a choice that is balanced. We don’t need a compromise ruling we need ruling that gives the democratic process a chance to play out, fairly!

By not allowing candidates to use their campaign finances, that they have raised, towards child care over the full length of their campaign, we are doing a disservice to our state and country. Running for office is already tilted in favor of the affluent, who are able to run campaigns unencumbered by the challenges others confront, like the cost of child care and working while campaigning. The Federal Election Commission and six other states allow reimbursement of child care expense (Alabama, Louisiana, Arkansas, Texas, etc); the list is growing every month. There is no reason why such a liberal, progressive state like Connecticut shouldn’t allow candidates to use their campaign dollars for child care as well.

If we want to see changes in those who run for public office, we must start to make changes to the current laws that exist and hold us back. Running for office shouldn’t be determined by your socio-economic status. Child care is a luxury that not everyone can afford. If someone is willing to dedicate their time to be a public servant, the very least we can do is alleviate the stressors that prevent them from running their campaign.

The CEP was “designed to encourage citizen participation and limit the role of private money in CT’s political process.” That cannot happen if parents dependent on the care of their children can’t afford to run!

I am in support of reimbursing child care expenses through the Citizens Election Program.

Best,
David Farnworth
Comments from Ted Vincent

I am writing to voice my support to allow candidates to use funds for childcare while campaigning for our government representation. I don’t believe otherwise worthy and capable candidates should be restricted from running for election because they have children and need to provide childcare for them while out campaigning. Candidates are allowed to use the money for a myriad of uses, it seems illogical that childcare so the candidate himself/herself can go to meetings or hold campaign events is not allowed.

Thank you,
Ted Vincent
Comments from Petitioner Caitlin Clarkson Pereira

Good evening,

I'm writing this email about the declaratory ruling draft regarding child care reimbursements for candidates.

Since the submission of my petition in October, I appreciate the realization that the money fundraised by the candidate should be available for child care. This money is no different than other money collected by campaigns in states with or without a clean election program.

I am asking SEEC to edit the draft of the declaratory ruling in order to allow candidates to use their fundraised money through the duration of the campaign. There is no legitimate reason that money should be cut off as soon as a candidate is approved for the CEP grant. While it may all sit in the same fund, just as businesses and non-profits do, it is easily possible to have fundraised dollars coded in a different way than the grant dollars.

The most intense time of the campaign is in the fall, so while candidates are allowed to use their fundraised money at some point during the campaign, it is not relevant to the final outcome if it is cut off at the most critical time. If we want more diverse candidates to run and win, they need access to their earned money for child care throughout.

This is low hanging fruit and we are not the trailblazer in this. It has been almost a year since the FEC ruled in favor of allowing campaign related child care expenses to be covered by campaign dollars. Since then, states such as Alabama, Texas, Wisconsin, Arkansas, Louisiana, etc have done the same.

In 2019, there are no excuses for creating road blocks for large portions of our population from running for office. We know there are already enough challenges as it is. Allowing candidates to use their fundraised dollars for child care throughout the campaign is exactly what needs to be done. I believe the members of the commission understand that, and believe it, as well.

Now, let's just make it official.

Thank you so much for your time.

With gratitude,
Caitlin Clarkson Pereira
Comments from Ed Cabellon, Ed.D.

To Whom It May Concern:

During the 2018 election, candidate for State Representative, Caitlin Clarkson Pereira was issued an opinion by the State Elections Enforcement Commission(SEEC) stating that child care expenses could not be covered by any campaign funds. I write to you today to fully support Ms. Pereira and her legal team in their appeal of this ruling, which would make it possible for future candidates in similar situations to feel more confident in their decision to run for office.

Opinions, such as these from the SEEC, continue to restrict folks who may not be from affluent backgrounds to run for public office. The cost of child care should be allowed to be reimbursed for candidates who need this infrastructure to run a full campaign. In fact the Federal Election Commission and six other states allow reimbursement of child care expenses, including Alabama, Louisiana, Arkansas, Texas, etc. I fully support reimbursing child care expenses through the Citizens Election Program (CEP), which would expand opportunities for women and less affluent candidates to run for public office.

Thank you for the opportunity to submit comments to this ruling and taking them in consideration.

Sincerely,
Ed Cabellon, Ed.D.
Comments from David Kozlowski Comments from Morgan Lamandre Comments from Angela Bazin

Good Afternoon,

I am writing to offer my support, and ask that you do the same, on changing the guidelines/laws as it relates to those running campaigns to be permitted to using self-raised funds to be able to reimburse for child care during the course of the campaign for campaign activities. Men and women that are not wealthy, and have to work throughout a campaign, should not have to bear the brunt of the financial cost of child care when running for office. Neither should those who are wealthy enough to be able to afford child care. Regardless of your financial situation, if you are raising funds through your own efforts to run for a public office, to better the situations in life for the many, there should be no restrictions on the use of the funds you raise yourself.

I hope that you strongly consider this, as many people running for office can only attend events, and fully participate in the process if their child care needs are met. And, since public tax dollars go to programs where parents get on the job training, job searching, etc., this isn't that much different that that. Let candidates use the funds they raise in the legal ways they see fit to run their campaigns.

Thank You!
Angela Bazin
Comments from Lieutenant Governor Susan Bysiewicz Resolution and Order Setting Forth Specified Proceedings for Declaratory Rulings Petition for Declaratory Ruling Regarding the Use of Public Funds to Offset Candidate’s Child Care Costs
Declaratory Ruling 2019-03: Secondary Payees and Polling Expenditures