Campaign advertisements in local newspapers that include the name and the picture of a first selectman candidate can violate Connecticut General Statutes §9-621(a), if the advertisements do not explicitly include the "paid for by" and the "approved by" language that the statute requires. David Reed filed a complaint against Mark Murdoch, the campaign treasurer for the campaign to elect Patrice Carson as first selectman of the Town of Somers. Reed's complaint alleged that Carson's election advertisements in local newspapers did not include the "paid for by" and the "approved by" language required by C.G.S. §9-621(a). The campaign paid $542 to place the advertisements, which included the candidate's name and picture and the slogan, "Right Choice. Right Time. Right Now. Experienced. Knowledgeable. Professional." C.G.S. §9-621(a) provides, "[N]o candidate . . . shall make or incur any expenditure .  . . for any written, typed or other printed communication, . . . which promotes the success or defeat of any candidate's campaign for . . . election . . .  unless such communication bears upon its face (1) the words `paid for by' . . . and (2) the words `approved by.' " The State Elections Enforcement Commission found that the advertisements constituted printed communications that promoted the success or defeat of the first selectman candidate's campaign. "Although the communications included both the name and a picture of the candidate," wrote the commission, "they contained no attribution identifying who paid for the communications, as prescribed by §9-621 a)." The State Elections Enforcement Commission ordered the respondent treasurer to pay a civil penalty of $100.

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