Jan. 10, 2000

Shaun R. Floerke
St. Louis Co. Attorney
100 N 5^th Ave. W. Room 501
Duluth, MN 55802-1298

Dear Mr. Floerke,

Thank you for your letter dated Jan. 4 in reply to my complaint about a possible violation of the Campaign Finance Law by the "Put Children First" Committee.

I believe your definition of the term "candidate’s committee" is flawed. You state that as long as a committee (which you agree Put Children First seems to be) has no association with a candidate’s campaign it is not a candidate’s committee. Mr. Floerke, Put Children First did campaign for three candidates: Mike Akervik, Rosie Loeffler-Kemp, and Matt Doyle. I suggest that as long as Put Children First was supporting candidates it was in fact a "candidate’s committee" or a "candidates’ committee." I do not believe the law’s use of the word "candidate" is intended to suggest that a candidate has control over any committee which champions his/her campaign. It is a candidate’s committee by virtue of supporting a candidate or candidates.

Note that the "Put Children First" Committee filled out a campaign finance form. According to your interpretation of the law this should not have been necessary since "Put Children First" did not meet your definition of the term "candidate’s committee." Your reasoning would permit any individual or committee to raise any sum of money from any source so long as they were independent of the candidate or candidates. I do not believe the state legislature intended to permit unlimited fund raising when it drafted this law. To the contrary, this law is quite clearly intended to limit the amount of money raised for candidates.

Note also, that four independent committees submitted campaign finance reports relating to the 1999 Duluth School Board elections. This is strong evidence of a widespread recognition of the responsibility to report and limit campaign-related contributions.

I suggest that Put Children First’s intent to elect certain candidates constitutes all the evidence necessary to treat the organization as a "candidates committee." Put Children First recognized its legal responsibility to report on its activities and filled out a campaign finance report. It should also have abided by the $300.00 contribution limit the law placed on them and which was mentioned on the very form they submitted to the Clerk of the Duluth Schools.

I request that you reconsider your interpretation of the law. In the meantime I intend to ask the appropriate state authorities to review your analysis of the state campaign finance law because your interpretation of the law renders it useless.

Thank you,