CEO 08-26 – October 22, 2008
EXECUTIVE BRANCH LOBBYINGEXECUTIVE BRANCH AGENCY RECEIVING REIMBURSEMENT FOREMPLOYEE'S TRAVEL FROM PRINCIPAL OF LOBBYIST
To: Mr. Thomas Congdon, Assistant General Counsel, Division of Emergency Management (Tallahassee)
Section 112.3215(6)(a), Florida Statutes, would not be violated when an executive branch agency is reimbursed for an agency employee's travel expenses, where theemployee travels in his public capacity and at public expense to speak to the membersof an organization, even though the organization is the principal of an executive branchagency lobbyist.
Would Section 112.3215(6)(a), Florida Statutes, be violated were an executive branchagency to accept reimbursement for an agency employee's travel expenses from a principal of an executive branch agency lobbyist?Your question is answered in the negative.
In your letter of inquiry, you advise that an executive branch agency employee has beeninvited to speak before the members of a principal's organization to discuss emergency managementbest practices as it relates to the principal's membership. The principal has offered to reimburse theexecutive branch agency for its employee's travel expenses, and you question whether this would bepermissible under Section 112.3215(6)(a), Florida Statutes.The pertinent statute reads:Notwithstanding s. 112.3148, s. 112.3149, or any other provisionof law to the contrary, no lobbyist or principal shall make, directly orindirectly, and no agency ofﬁcial, member, or employee shall knowinglyaccept, directly or indirectly, any expenditure.The term "expenditure" is deﬁned in Section 112.3215(1)(d), Florida Statutes, to meana payment, distribution, loan, advance, reimbursement, deposit,
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