AO 2010-22: Connecticut Working Families Party qualifies as state party committee

The Connecticut Working Families Party (CT WFP) [FN1] satisfies the requirements for state party committee status under the Federal Election Campaign Act (the Act), even though it is not affiliated with a national political party. 

Background 

The Act defines a “state committee” as “the organization which, by virtue of the bylaws of a political party, is responsible for the day-to-day operation of such political party at the State level, as determined by the Commission.” 2 U.S.C. § 431(15). See also 11 CFR 100.14(a). 

When an organization is not affiliated with a national political party, it must meet three requirements to achieve state party committee status under Commission regulations. 

First, the organization must itself qualify as a “political party.” The Act and Commission regulations define a “political party” as an “association, committee, or organization that nominates a candidate for election to any Federal office whose name appears on the election ballot as the candidate of the association, committee or organization.” 2 U.S.C. §431(16); 11 CFR 100.15. 

Second, the organization must possess an official party structure. 2 U.S.C. § 431(15); 11 CFR 100.14(a). 

Third, the organization must be responsible for the day-to-day operations of a political party at the state level. See 2 U.S.C. § 431(15); 11 CFR 100.14(a). See also AOs 2008-12 and 2007-23. 

Analysis 

The Committee meets the three requirements and thus qualifies as a state committee of a political party within the meaning of the Act and Commission regulations. 

First, CT WFP qualifies as a “political party” because two of its candidates qualify as federal candidates and appeared on the November 2010 Connecticut general election ballot as candidates of CT WFP. [FN2] 

Second, CT WFP’s rules establish an official party structure and CT WFP has qualified for status as a “minor political party” under Connecticut law. 

Finally, the rules of CT WFP identify the role of the Committee and its responsibilities for the day-to-day functions and operations at the state level. The Committee’s responsibility for the operations at the state level is commensurate with the responsibility of other state party committees that the Commission has previously recognized. 

AO 2010-22: Date issued: October 26, 2010; Length: 5 pages. 

Footnotes:

1 CT WFP is registered with the FEC as the Connecticut Working Families Federal PAC d/b/a Take Back Congress CT 

2 Note that both aforementioned federal candidates also appeared on the 2010 ballot as candidates of the Democratic Party. The Commission has concluded, in previous advisory opinions, that a candidate’s association with more than one political party is irrelevant when reviewing a party’s qualification for state committee status. See AO 2007-23 at n.6