BILL ANALYSIS                                                                                                                                                                                                    �



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          ASSEMBLY THIRD READING
          AB 2191 (Norby)
          As Amended  April 24, 2012
          2/3 vote 

           ELECTIONS           7-0                                         
           
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          |Ayes:|Fong, Donnelly, Bonilla,  |     |                          |
          |     |Hall, Logue, Mendoza,     |     |                          |
          |     |Swanson                   |     |                          |
          |-----+--------------------------+-----+--------------------------|
          |     |                          |     |                          |
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           SUMMARY  :   Provides that candidates for political party central 
          committees who receive contributions and make expenditures of 
          less than $1,000 in a calendar year are not required to file 
          campaign disclosure reports.  Specifically,  this bill  :  

          1)Provides that an elected member of, or a candidate for 
            election to, a county central committee of a qualified 
            political party who receives contributions of less than $1,000 
            and who makes expenditures of less than $1,000 in a calendar 
            year is not required to file any campaign statements required 
            by the Political Reform Act (PRA).  Prohibits a local 
            government agency from imposing any filing requirements on 
            such members and candidates.

          2)Prohibits a local jurisdiction from imposing contribution 
            limitations or prohibitions on elected members of, or 
            candidates for election to, a county central committee of a 
            political party, or on a committee primarily formed to support 
            or oppose a person seeking election to a county central 
            committee of a qualified political party.

           FISCAL EFFECT  :  Unknown.  This bill is keyed non-fiscal by the 
          Legislative Counsel.

           COMMENTS  :  According to the author, "As written, the �PRA] 
          places a costly and time consuming burden on thousands of 
          political party volunteers in California.  The PRA defined any 
          person who appears on the ballot as someone running for 
          'elective office.'  The intent of this action was to capture all 
          governmental elected officials, and it succeeded.  This action 








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          also lumped in thousands of political party volunteers into new 
          expensive and cumbersome reporting requirements.  Political 
          volunteers serve no governmental function.  They do not handle 
          any public money, they don't vote on policy or budget issues, 
          and they conduct no public business."  The author argues that in 
          light of the fact that central committee members do not conduct 
          public business, they should not be subject to the same campaign 
          disclosure provisions of the PRA as other elected officials and 
          candidates.

          The campaign disclosure requirements of the PRA are designed to 
          ensure that public officials perform their official duties in an 
          impartial manner and to protect against disproportionate 
          influence over governmental decisions by campaign contributors.  
          Although elections for county central committee for political 
          parties are publicly conducted, state courts have held that the 
          elective offices of political parties are not public offices, 
          because those offices do not involve the exercise of the 
          sovereign functions of government.  (See Moore v. Panish (1982) 
          32 Cal.3d 535, 545, Azevedo v. Jordan (1965) 237 Cal.App.2d 521, 
          528, and Stout v. Democratic County Central Committee (1952) 40 
          Cal.2d 91, 94.)  Because central committees do not exercise the 
          sovereign power of the government, it is unclear whether the 
          purposes of the PRA are served by requiring candidates for 
          central committee to comply with the PRA's disclosure 
          provisions.

          On the other hand, the California Constitution explicitly 
          requires that the Legislature provide for partisan elections for 
          county central committees.  Even though central committees do 
          not exercise governmental powers, the fact that the Constitution 
          guarantees publicly conducted elections for these offices seems 
          to weaken the argument that candidates for such offices should 
          not be subject to the same disclosure requirements as all other 
          candidates who appear on the ballot in California at a 
          publicly-conducted election.  
           
          Although there are hundreds of candidates for county central 
          committees statewide in each even-numbered year, it is 
          relatively rare for candidates for county central committees to 
          raise and spend more than a nominal amount of money for their 
          campaigns.  Even candidates who do not raise or spend large 
          amounts of money on their campaigns, however, may be required to 
          file certain campaign disclosure documents.  Because of the 








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          number of candidates statewide for county central committee, 
          these requirements can result in hundreds of pages of campaign 
          disclosure reports being filed in each election year that 
          disclose little or no campaign activity.

          In at least a few situations, however, candidates for central 
          committees have raised and spent significant amounts of money.  
          For instance, at the June 2010 primary election, at least six 
          candidates for central committee in San Francisco made 
          expenditures of over $30,000.  In many cases, candidates who 
          raised and spent significant amounts of money on their campaigns 
          for central committee also ran for other elective offices in San 
          Francisco within a year of the campaign for central committee.  
          This may suggest that, in some cases, candidates for central 
          committee in San Francisco are using their campaigns to help 
          raise their profiles for subsequent campaigns for public office. 
           If that is the case, there may be a rationale for requiring 
          candidates for central committee to comply with the disclosure 
          requirements in the PRA, since people may be making 
          contributions to candidates for central committee with the 
          intention of helping those candidates get elected to public 
          office at a subsequent election.

          California voters passed an initiative, Proposition 9, in 1974 
          that created the Fair Political Practices Commission and 
          codified significant restrictions and prohibitions on 
          candidates, officeholders and lobbyists. That initiative is 
          commonly known as the PRA.  Amendments to the PRA that are not 
          submitted to the voters, such as those contained in this bill, 
          must further the purposes of the initiative and require a 
          two-thirds vote of both houses of the Legislature.

          Membership on a county central committee has been considered an 
          elective office under the PRA since Proposition 9 was adopted in 
          1974.  As a result, an argument could be made that excluding 
          certain candidates for central committee from the requirement to 
          file campaign disclosure reports does not further the original 
          purposes of the PRA.  To the extent that this bill does not 
          further the purposes of the PRA, the Legislature has no 
          authority to enact its policies without submitting it to the 
          voters.

          On the other hand, because this bill maintains campaign 
          reporting requirements for candidates for and members of county 








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          central committees that raise and spend more than $1,000 in a 
          calendar year, an argument can be made that the bill furthers 
          the purposes of the PRA, since it would significantly reduce 
          burdensome reporting requirements that result in little or no 
          campaign activity being reported, while ensuring that candidates 
          for central committee who have significant amounts of campaign 
          activity will continue to file campaign disclosure reports.
           

          Analysis Prepared by  :    Ethan Jones / E. & R. / (916) 319-2094 
          FN: 0003442