America’s Big Game happens Sunday, and some (including Sports Illustrated’s Peter King) speculate this could be the last we see for a year or so.
Lavish SuperBowl parties are going to be in full force across the nation. Many will flock to Dallas to see how they may get in on the action. People will lose their minds and forget all of the rules. However, lobbying watchdogs will not forget. And here at LobbyBlog, neither will we. So, to keep you in compliance this Superbowl weekend, here are some things to remember:
- You may NOT buy any staffer/member/executive branch appointee a ticket to the SuperBowl. With tickets quickly approaching $5,000 each, unless the member/staffer/appointee pays for his/her own ticket, this amount far surpasses the acceptable gift limit for 100 (gifts (over 50 years!)! (Remember, the rule is $50 per occurrence, $100 total per year for gifts, but NO GIFTS FROM LOBBYISTS.)
–> This does not mean it is okay to invite the staffer to pay $25 for a standing-room-only ticket, and grant him full access to your company’s corporate suite, like the Redskins attempted to do a few years back. It is a bad idea. Don’t try it. The fallout will be highly publicized and you WILL go to jail. (Think no one will know? So did Abramoff.)
–> Although exceptions do exist, it is advisable that perhaps a $5,000 SuperBowl ticket is not a good time to try out the personal friendship exemption. However, feel free to take your staffer/member/appointee staff spouse to Cowboys stadium (or surrounding bars/parking lots) Sunday. HLOGA implicitly states that gifts from spouses are exempt.
- The personal friendship exemption is, however, permissible if you are inviting a staffer/member/appointee to your Big Game party, assuming there’s a legitimate history of personal friendship. If there is no such history, personal hospitality alone will not cut it. Make the party potluck, and have your covered guest bring a dish. If it’s the member’s party, costs must come out of his/her personal bank account, not a campaign fund or expense account.
- Meeting at a bar to watch the main event? Go ahead and spring for the pitcher of beer at halftime, whether there are covered officials present or not. Nachos? Margaritas? Go for it, provided they’re of minimal value and offered in a social setting to everyone in the vicinity. (BBQ chicken nachos with sour cream and refried beans are teetering awfully close to the official definition of a meal, however, so you may want to stick with ordinary cheese-and-jalapenos chips.) You may NOT invite only the member/staffer/appointee to the bar and pick up ONLY his/her tab. Unless of course the personal friendship, dating (more than casual), or marriage exemptions qualify as a personal relationship.