ELECTION LAW
Margot Graham
In Republican Governors Association v. Alaska Public Offices Commission, 485 P.3d 545 (Alaska 2021), the supreme court held that the Republican Governors Association violated a campaign finance registration statute that required registration prior to making “expenditures.” (Id. at 553). In advance of the 2018 gubernatorial primary race and before registering with the Commission, the Republican Governors Association reserved more than $1 million in television advertising time. (Id. at 547). Alaska campaign finance law mandates that political organizations must register with the Commission before making a purchase intended to promote the election of a candidate. (Id.). The Republican Governors Association did not register with the Alaska Public Offices Commission before engaging an Alaska media consultant to reserve the television advertising time. (Id.). The superior court affirmed the Commission’s decision that the Republican Governor’s Association violated campaign finance law. (Id. at 549). On appeal, the Republican Governor’s Association argued that the Commission’s definition of “expenditure” was overly broad, their television advertisement buy did not constitute an “expenditure,” and the Association itself was not a group mandated to register with the Commission. (Id. at 553). The supreme court affirmed the lower court’s decision, reasoning that the Commission had a reasonable definition of “expenditure” and its finding that the Republican Governors Association’s purchase of television advertising time constituted an expenditure was supported by evidence. (Id. at 551 and 553). Finally, the court found that the Republican Governors Association was a group under the statute and, therefore, was not exempt from the statute’s registration requirement. (Id. at 553). Affirming the lower court’s decision, the supreme court held that the Republican Governors Association violated a campaign finance registration statute that required registration prior to making “expenditures.” (Id. at 553).
