Advisory Opinion No. 1999-9

Application Of Conn. Gen. Stat. §1-86(c)
To Work As A Consultant

Pursuant to Conn. Gen. Stat. §1-86(c), "No person required to register with the state ethics commission under section 1-94 shall accept employment with the general assembly or with any member of the general assembly in connection with legislative action…" In essence, this provision bans registered lobbyists from employment with the Legislature regarding legislative matters.

The Commission has been asked whether the prohibition applies to work as a consultant. The answer is yes. Under the Commission’s regulations, which define employment for purposes of the Code’s ban on improper use of office for personal benefit, the term encompasses "…any work or endeavor, whatever its form, undertaken in order to obtain financial gain (e.g. …independent contractor …)" Regulations of Conn. State Agencies §1-81-14.

There is no discernable reason why an alternative analysis should apply in interpreting "employment" for purposes of §1-86(c ) . To the contrary, whether the work is performed as a state employee or a consultant, no lobbyist should provide compensated services to the General Assembly regarding legislative matters.

By order of the Commission,

Stanley Burdick
Chairperson