Failure to file a financial disclosure statement, after receipt of notice from the State Elections Enforcement Commission, constitutes a per se violation of Connecticut General Statutes §9-608. In 2006, the respondent, Stephanie Savoy, became the treasurer of the Naugatuck Republican Town Committee. On Oct. 11, 2011, Savoy did not file a financial disclosure statement. On October 21, Elections Officer Nancy Staniewicz wrote Savoy and informed her that the State Elections Enforcement Commission had not received the October 11 financial disclosure statement. Staniewicz requested that Savoy file the statement and pay $100 within 21 days. On December 22, Evelyn Gratacos wrote Savoy and informed her that the State Elections Enforcement Commission had not received the October 11 financial disclosure statement. Gratacos asked Savoy to file the financial disclosure statement and to pay a fine of $200, on or before Jan. 9, 2012. Savoy filed the October 11 financial disclosure statement, which covered the period between July 1 and Sept. 30, 2011 and which indicated that there were no receipts or expenditures, on January 9. Savoy did not pay the $200 fine. The State Elections Enforcement Commission found that Savoy violated C.G.S. §9-608 both because she failed to file the financial disclosure statement on October 11 and because she did not file the statement within 21 days of receipt of notice from the State Elections Enforcement Commission. C.G.S. §9-623(b)(4) provides, "[t]he penalty for any violation of section . . . 9-608 . . . shall be a fine of not less than two hundred dollars or more than two thousand dollars or imprisonment for not more than one year, or both." Any harm that resulted from the lack of disclosure was minimal. There was no evidence that Savoy has a history of prior campaign finance violations. The State Elections Enforcement Commission ordered the respondent to pay $250, because she violated C.G.S. §9-608.

VIEW FULL CASE