Ask the Experts – It’s Football Time! - State and Federal Communications

October 27, 2011  •  

Ask the Experts – It’s Football Time!

James Warner, Esq.

Q: I am a registered lobbyist who would like to host a state legislator at a college football game.  Are there specific restrictions to this type of gift?

A: The most common gift restrictions are those relating to food and beverage.  Providing tickets or admission to a football game is a different type of gift, referred to as entertainment or hospitality.

Some jurisdictions do not restrict providing entertainment at all.  Pennsylvania does not restrict a lobbyist providing hospitality to an official.  However, Pennsylvania does require the lobbyist’s principal to report the gift of hospitality, even itemizing it if the aggregate of all gifts to the official is more than $650 in a calendar year.

Other jurisdictions allow a lobbyist to provide entertainment up to a certain amount.  In Texas, a lobbyist may provide expenditures for entertainment of $500 or less in a calendar year.  Ohio permits a lesser amount.  Lobbyists may provide Ohio officials gifts worth an aggregate annual value of $75 or less.  Like Pennsylvania, both Texas and Ohio require the gift to be reported.

Louisiana specifically prohibits providing tickets to sporting events except for a very narrow exception.  Other jurisdictions do not specifically mention entertainment or hospitality, but generally restrict these gifts to officials.  Though a big football state, Wisconsin generally prohibits all gifts to officials.

The question reinforces the idea that a lobbyist must understand all of a jurisdiction’s gift restrictions, not just those that pertain to food and beverage.  When considering any dollar value limitation on entertainment or hospitality, be sure to consider the proper method to value the gift in that jurisdiction.  For example, the cost of a football ticket for ethics purposes could be its face value or its fair market value.

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(We are always available to answer questions from clients that are specific to your needs, and we encourage you to continue to call or e-mail us with questions about your particular company or organization. As always, we will confidentially and directly provide answers or information you need.) Our replies to your questions are not legal advice. Instead, these replies represent our analysis of laws, rules, and regulations.


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