You are the General Counsel for Good Deeds Housing, Inc. You were first introduced to the organization when your old law school study partner, James Buddy, who is on the organization’s Board of Directors, invited you to the organization’s annual fundraising dinner. Many of the city’s leading business, government, and religious leaders support the organization. Good Deeds has a spotless reputation in the City. Much of its financial support and ability to get things done is because of its reputation.
Good Deeds develops housing for low income families. It is planning a development in a blighted area of the City but Polly Purebread, one of the key County Supervisors whose support it needs, is in a tough election race. Her opponent will certainly kill the development if he is elected. Purebread desperately needs campaign money for campaign advertising.
Good Deeds’ Executive Director, Mark Charisma, emailed you with a plan to have all employees and their spouses each give $500 to Supervisor Purebread and the company will reimburse them. He is very excited about the plan and wants your advice.
From your research, you’ve discovered that the City has a $500 per donor campaign contribution limit. Separately, under the state’s anti-money laundering law, it is illegal to make political contributions in the name that is not the name of the actual donor. The fine for violating the state law is $5,000 per illegal donation. No one has been convicted of violating the state statute or city ordinance.
Prepare to meet with and advise your client.