2014-097 - Laserfiche WebLink

0 STATE OF LOUISIANA • ,og'�pU' DEPARTMENT OF STATE CIVIL SERVICE ,FQ� (Ij _ LOUISIANA BOARD OF ETHICS cy 1' �;1i P.O.BOX 4368 In X44,, BATON ROUGE,LA 70821 _'-0, (225)219-5600 `°„ FAX:(225)381-7271 1-800-842-6630 www.eth i s s,state.I a.us March 25, 2014 James Donohue,Counsel for Lane Grigsby P.O. Box 1629 Baton Rouge,LA 70821-1629 RE: Ethics Board Docket No. 2014-097 Dear Mr. Donohue: The Louisiana Board of Ethics, at its March 21, 2014 Board meeting considered your request for an advisory opinion regarding whether campaign contributions made to a candidate by your client, Lane Grigsby, in his own name, must be aggregated with contributions, to the same candidate, by his limited liability company, Cajun Industries, LLC. You stated that Mr. Lane Grigsby owns the majority membership interest in Cajun Industries, LLC ("Cajun"), a Delaware Limited Liability Company which is licensed to and is doing business in the State of Louisiana. Pursuant to the company's Operating Agreement, Cajun's membership is divided into Class A and Class B Membership Interests. Mr. Grigsby holds a 1% sharing ratio of the Class A Interest and a 72% sharing ratio of the Class B Interest, amounting to a 73% total sharing ratio. The remaining 27% of the Class B Interest is divided among three other members. The Class A Interest grants Mr. Grigsby 100% of the voting rights for decisions relating to Cajun's business operations. For purposes of authority to make political contributions, Cajun's Operating Agreement provides the Class B Members with voting rights to authorize political contributions on behalf of Cajun. Pursuant to his percentage of ownership of the Class A and B Interests, Mr. Grigsby holds 73% of the voting rights to authorize political contributions made by Cajun. Mr. Grigsby, in his individual capacity, desires to make the maximum campaign contribution to a candidate for Major Office under La. R.S. 18:1505.2(H)(1)(a)(i). Cajun also desires to make the maximum campaign contribution to the same candidate pursuant to a duly authorized vote of the Company Members. The Board concluded, and instructed me to advise you that the Campaign Finance Disclosure Act will not prohibit Mr. Grigsby and Cajun, individually, from making the maximum contribution to the same candidate. La. R.S. 18:1505.2(F) provides that no profit or nonprofit corporation, labor organization, or trade, business, or professional association shall make any campaign contribution or expenditure unless specifically authorized to do so whether by: vote of the board of directors of the corporation, of the executive board of the labor organization or of the trade, business, or professional association at a regular or special meeting thereof; by the president, vice president, secretary, or treasurer of a corporation or labor organization whom the board has specifically empowered to authorize such contributions or expenditures, or for a corporation, by any other person designated by resolution of the Board of directors of a corporation to authorize contributions or expenditures, or by a vote of the labor organization. AN EQUAL OPPORTUNITY EMPLOYER