• Superior Court
  • 2011-146 and 2011-147
  • Mar 21 2012 (Date Decided)
  • Cashman, Chair

An individual who allegedly spends more than $1,000 in support of a referendum is required to file an independent expenditure statement for individuals, also known as a Form 22, pursuant to Connecticut General Statutes §9-612(d). The complainant, Ronna Stuller, alleged that the respondents distributed postcards and sponsored online advertisements in the New London patch, in support of a referendum in New London. The complainant alleged that the communications lacked sufficient "paid for by" information, in violation of C.G.S. §9-621(c). Allegedly, one of the respondents, Edward DeMuzzio, admitted that he paid more than $1,000 for unattributed postcards and advertisements and asserted that he acted independently. There was no evidence that DeMuzzio acted with other individuals. Other respondents, Jay Levin and George Sprecace, apparently spent less than $1,000 to produce lawn signs that supported the referendum and that included their names. Attribution requirements do not apply to lawn signs that are smaller than 32 square feet, and these lawn signs were smaller than 32 square feet. Although the lawn signs, which were produced by the same printer, featured the same design, these respondents claimed that they acted independently of any other person or group. The State Elections Enforcement Commission found that the complainant failed to prove any violations took place. The respondent who spent more than $1,000 properly filed a Form 22 statement, pursuant to C.G.S. §9-612(d). The complainant failed to establish that the respondents acted together, as a group, to support the referendum. The respondents were not required to register as a committee or to file financial disclosures, other than the Form 22 that was filed. No "paid for by" information was required, pursuant to C.G.S. §9-621(c), and some of the respondents exceeded legal requirements when they voluntarily included their names on the lawn signs that they produced independently. The State Elections Enforcement Commission dismissed the complaint.