One of the stated legislative goals in creating Connecticut’s Citizens’ Election Program (CEP) was to move political candidates and their campaigns away from the allegedly corrupting influence of big money donors and corporate interests. And while participation in the program may have decreased money from these sources, it has not reduced the amount of money being spent on political campaigns or ended criticism of election funding.

Particularly for candidates from parties in minority districts, qualifying for a CEP grant has increased the amount of money available to campaigns and, by extension, increased expenditures.

In 2022, a candidate running for state representative had to raise $5,800 in small dollar donations between $5 and $290 from qualified contributors, 150 of whom must live in the district they’re running to represent. By meeting that threshold, a candidate could receive up to $33,175 in public money from CEP to fund their general election campaign; that’s up to a 472 percent return on the money that the candidate fundraised. 

Candidates running for state representatives are eligible to receive the smallest CEP grants available.  They also have to raise the least amount of money of any office type to qualify. A state senator must raise $17,300 and is eligible to receive up to $112,795 in the general election—up to a 552 percent return on fundraising dollars.

For a candidate with the backing of a major party, and all the resources that come along with that, raising a few thousand dollars in qualifying donations is seemingly an easy task—with a big payoff.

And that, according to some critics of the program, is a problem. Stratford resident Dave Mullane, for example, believes the discrepancy between the amount a candidate raises in order to qualify for a CEP grant and receives in a CEP grant can lead parties to run long-shot candidates who have no hope of winning in non-competitive districts in order to reward party loyalists. His efforts have unfolded through various legal and procedural challenges and have made him a controversial figure in his hometown of Stratford and beyond.

While it is true spending patterns for both winning and losing candidates have changed and increased since CEP grants first became available, it’s hard to identify exactly what corruption might look like, and what is simple growing pains of a relatively new clean election effort.

Part two of CII’s investigation examines some of the questions raised, how enforcement by the SEEC operates, and the impact of CEP on campaign spending.

Dave Mullane first began closely tracking the political goings on in Stratford in 2017 when he noticed that Tom Malloy—cousin of former governor Dannel Malloy—was living at a different address than the one at which he was registered to vote.

According to a complaint Mullane filed with the State Elections Enforcement Commission (SEEC) in 2017, Malloy moved from an address on Sekelsky Drive in Stratford to an address owned by his sister on Lilibeth Drive in Stratford in July 2014 but did not update his voter registration and continued to vote from his previous address.

Malloy later moved to Woodbury, to a property he was building on while residing with his sister, but, according to Mullane, registered to vote in Stratford at the Lilibeth Drive address in June 2017. According to Mullane, Malloy did this to be able to maintain eligibility for his position on the Stratford Housing Authority, of which he was then president.

After bringing the matter to the attention of the Stratford Ethics Commission and getting nowhere, Mullane decided to make a formal complaint to the SEEC. Before doing so, Mullane communicated with Susan Pawluk, the town clerk, and Lou Decilio, Stratford’s Republican registrar of voters.

Attached to the complaint on Malloy’s residency Mullane filed with the ethics commission on January 16, 2018, are email exchanges between Mullane, Pawluk, Decilio, and Ted Bromley, an employee of the Secretary of State’s office.

Mullane turned to Bromley after a Freedom of Information Act request for Malloy’s voting records from Pawluk’s office was unsuccessful; Pawluk informed Mullane the records had been destroyed.

In a December 5, 2017, email Bromley was able to confirm Malloy’s residences and voting records between 2015 and 2018.

But those records conflict with what Mullane was told about where Malloy lived and voted by Pawluk.

On November 28, 2017, Pawluk sent an email to Mullane that stated the registrars were able to locate records showing Malloy voted from the Lilibeth Drive address in person on August 12, 2014, and absentee on November 4, 2014, and November 3, 2015.

Decilio also responded to Mullane’s email stating Malloy had voted in Stratford on August 12, 2014; November 4, 2014; November 3, 2015; and from Woodbury on November 8, 2016. He also stated Malloy “exercised his constitutional right to vote in each of the above locations legally. He consistently voted in the location he was registered.”

Referring to inquiries Mullane made using the pseudonym Kenneth McCormick, based on a character from the television show South Park, Decilio continued, stating allegations of “corruption, conspiracy, and voter fraud are absolutely false and malicious in nature.”

Mullane’s SEEC complaint also notes that he visited the Selesky Drive address and spoke to the owner, who stated she had never met and didn’t know anyone from the Malloy family. She gave a signed statement, attached to the SEEC complaint, stating the Malloys should not have been listed as voters at that address.

The complaint also states that Malloy was put back on the Stratford voter rolls in June 2017 by Decilio personally. Mullane believed this was done for political reasons having to do with the sale of town property. 

Mullane’s complaint states he believed Pawluk and her office needed to be investigated because he believed she provided him with false information on Malloy’s voting records. He also questioned Decilio in his capacity as registrar over Malloy being put back on Stratford’s voting rolls in June 2017 despite records indicating he lived in Woodbury.

Asked about the allegations, Decilio noted that the registrar’s office is dependent upon information provided by voters when registering.

“The Town of Stratford has approximately 35,000 registered voters, at the time there were 4 people working in our office and we would process between 6,000 to 8,000 additions, changes and removals on a yearly basis. Mr. Mullane’s accusation [are] absolutely false, we processed the card Mr. Malloy signed. That makes adding or changing him wholly accurate based on the information Mr. Malloy supplied.” Decilio stated.

Allegations of election corruption are investigated by the SEEC. The agency, which oversees Connecticut’s elections, not only administers CEP grants and maintains campaign finance records but investigates possible violations of the state’s election laws. The commission also issues decisions “in the areas of campaign finance and election administration, including contribution limits and sources, such as the lobbyist and contractor contribution and solicitation ban, campaign disclosure reporting, the Citizens Election Program, the process of voting, the right to be or remain an elector, and the federal Help America Vote Act.” 

Decisions can result in a complaint being dismissed if no violation of law is found or being resolved either through a consent agreement or by a final decision made after a hearing.

Ideally, those cases are settled quickly, to prevent election officials who are guilty of wrongdoing from interfering further in elections. While trying to determine the average time it takes the SEEC to resolve complaints, CII was only able to locate the commission’s final decisions. Not all of these list the date the complaint was filed.

But in Mullane’s case, the SEEC took over two years to produce a finding. 

Mullane filed his complaint on December 6, 2017. The SEEC voted to authorize an investigation based on the complaint on February 14, 2018 and issued its final decision on February 13, 2020. 

The investigation confirmed many of Mullane’s allegations, including that, after moving to Woodbury, where he registered to vote on October 6, 2016, Malloy switched his voter registration back to his sister’s address in Stratford on June 20, 2017. It also found that, while living at the Lilibeth Drive address Malloy voted from his previous address on Selesky Drive. Malloy also did not dispute any of these points during the SEEC’s investigation and signed a consent agreement with the SEEC.

While the commission found Malloy voted at an address where he did not reside while he lived on Lilibeth Drive, they also determined that his violations were “ministerial in nature” since both addresses were within the voting precinct and took no further action. 

They also found he violated the law by registering to vote at Lilibeth Drive while living in Woodbury. Malloy never voted during that period, but the SEEC found his registration may have been to maintain Stratford residency and his position on the Stratford Housing Authority.

Malloy was fined $300 dollars. The commission considered his public service “an aggravating factor, insofar as there is appropriately a greater expectation of knowledge and understanding in someone so intimately involved in the political landscape that registering to vote where you do not reside is not permissible.” They also stated his political experience created a “greater level of expectation” that he should have known registering to vote at an address where he did not reside was illegal.

The commission’s decision did not make any reference to Pawluk’s or Decilio’s alleged role in the incident. 

Between the time Mullane filed the complaint and the SEEC made its final ruling, Mullane contacted the agency several times, including in the months leading up to the 2018 election. Malloy emailed Gilbert Oyola, a lead legal investigator with the SEEC, on September 7, 2018, inquiring about the status of the complaint.

“My concern is that there is an upcoming election in November and Pawluk and Decilio appear to have committed some wrongdoing regarding their official positions and the election process that they should be safeguarding and not manipulating. I feel that they should not be involved in anything related to elections until my complaint is resolved.” Mullane wrote. He also notes that his town councilman had told him that the town would not take action against Pawluk or Decilio until the SEEC made his ruling.

Mullane also noted that he had sent a letter to the secretary of the state about the matter but had not received a response.

Oyola responded the same day, noting the SEEC’s practice was not to comment on active investigations and that because the commission met once a month, determining a timetable by which the investigation might be complete was difficult.

Mullane followed up, repeating his concerns about Pawluk and Decilio taking place in the upcoming election. “What I get from your email is the investigation is in progress, there is no known timeline for its completion and there are no safeguards in place for Stratford voters at this time. With the election just 2 months away wouldn’t it be best for the Clerk and Registrar to sit this one [out] if the matter can be solved?” Mullane wrote.

Mullane received a response from Kevin Ahearn, a lawyer in the SEEC’s law enforcement unit, who noted that registrars of voters are elected officials and not subject to removal or suspension by a municipality.

“In general, the removal and/or suspension of an election official is treated as an extraordinary act under the General Statutes and the Connecticut Constitution.” Ahern wrote, also noting that the secretary of the state has sole power of discretion over suspension, which has never been used.

Mullane continued to press the matter in other avenues, forwarding his concerns to Ronald Ing, Stratford’s director of human resources, who forwarded the matter to the town attorney. He also reached out to Richard Marcone, Stratford’s Democratic registrar of voters, who declined to comment due to the matter already being investigated by the SEEC.

A report prepared by the SEEC for fiscal year 2020-2021, the most recent year for which it was available, noted that the SEEC docketed 185 new cases during that time period. Of those cases, 121 were the result of a citizens’ complaint and the rest were referred by state or local election officials or by the commission’s decision to initiate an investigation. Stratford was one of 14 towns with more than one complaint.

In the same year, the SEEC closed 172 docketed cases, 112 of which were from previous years and 60 of which were newly docketed. According to the agency, 44 of the commission’s decisions in those cases resulted in monetary sanctions, 22 resulted in reprimands or orders to comply, and 102 were dismissed because no violation was found or there was insufficient evidence to make a determination. 

Along with investigating allegations of election corruption, the SEEC is also tasked by state statute with conducting post-election reviews of the campaign finance reports.

The SEEC has the power to “inspect or audit at any reasonable time and upon reasonable notice the accounts or records of any treasurer or principal treasurer.” Audits must be completed no later than two months before the day of an election if they were initiated in the absence of a complaint and involve a committee with a candidate from a previous election. The commission cannot initiate an audit without a complaint within two months prior to election day if it involves a committee with a candidate from a previous election.

State statute also requires the SEEC to randomly audit no more than fifty percent of candidate committees post-election or primary. The audit is conducted by a lottery that “takes into account the selection frequency of a district served by the office of a state senator or state representative, as applicable, for the immediately preceding three regular elections for such office and increases or decreases the likelihood that such district will be selected for audit based on such selection frequency.” All candidates for state-wide office are audited.

Lotteries are conducted by random number generators, with the results determining which districts are audited. All candidate committees in selected districts are subject to audit. The number of candidates in a district can determine how many districts are audited as the number of candidates audited per district is subtracted from the total number of candidates state statute dictates should be audited (less than half). The SEEC also keeps track of how frequently districts have been selected for audit within the last couple of electoral cycles. 

Whether a campaign has been selected for audit is noted in the type of report committees file upon termination. When audit findings reveal improprieties in campaign finances, the SEEC initiates an investigation and final findings and settlements are documented in a searchable database on the commission’s website that catalogues their decisions.

Unless a campaign is selected for audit through the SEEC’s lottery or a complaint is made, the finances of campaigns are not officially reviewed and any abuse of CEP funds may not be caught.

In 2021, a federal grand jury indicted state senator Dennis Bradley and his campaign manager Jessica Martinez with multiple offenses related to an attempt to defraud CEP during the 2018 election. According to the indictment, Bradley and his co-conspirators violated CEP rules by “holding a March 15, 2018, campaign event at Dolphin’s Cove restaurant in Bridgeport, then engaged in a scheme to trick SEEC into awarding his campaign undeserved CEP grants by making misrepresentations and omissions to disguise the nature of that event,” including by altering the dates on donation cards used to certify that a candidate has raised enough qualifying funds to obtain a CEP grant.

Bradley also allegedly used personal funds on the event, prohibited under CEP rules, and then tried to claim it was not a campaign event but a thank you party for clients of the law firm at which he worked. The case, which is still pending, is among the highest profile cases of CEP corruption that has been caught to date.

To date in 2023, the SEEC has reached a final decision in nine matters either brought before it as a complaint or resulting from its own investigations. In five of those cases, the SEEC has found some kind of violation of election law. Of those relating to CEP, the offenses are relatively minor, having mostly to do with improper use of expenditure codes and failure to include proper financial disclosure statements on flyers.

Stratford’s state legislative seat races demonstrate some of CEP’s effects on the landscape of campaigns. Senate District 23, which contains Stratford, has been a Democrat dominant district since 2016, although the margin by which the party is dominant has consistently narrowed. House District 121 is also a Democrat dominant district, but party dominance has grown marginally since 2016. 

2012 marked the first election where all candidates participating in either the primary or the general for Senate District 23 applied for and received CEP. It was also the first time since at least 1787, the earliest year for which the secretary of the state’s office maintains election records, a primary was held in the district.

Democrats held a three-way primary between candidates Andres Ayala, Jr.; Ernest Newton; and Edwin Gomes. Ayala was the victor, receiving 42.5 percent of the vote. Ayala also spent the least amount of money of the three candidates—roughly $94, 500 according to a post-primary itemized statement that accompanied his request for a CEP grant in the general election. Gomes, who received 22.7 percent of the vote, spent roughly $96,600 and Newton, who received 34.7 percent of the vote, spent the most in the primary race: just under $98,5000.

By the end of the general election, Ayala’s expenditures totaled just under $197,000. He received 91.6 percent of the vote. In 2010, Gomes, who received the nomination without a primary challenger that cycle, received 97.5 percent of the vote and expended roughly $20,100. Gomes applied for a CEP grant but does not appear to have received one.

Ayala’s Republican opponent in 2012 was Casimir Mizera, whose campaign expenses totaled approximately $55,250. He received 8.4 percent of the vote. Milton Johnson, the Republican candidate for the seat in 2010, spent just over $1,155. Johnson filled out a form saying he intended to abide by the CEP rules but never submitted a grant application.

With the introduction of CEP grants, spending by general election candidates tripled.

Prior to the introduction of CEP, spending in the District 23 state senate race averaged roughly $27,580 per candidate between 2000 and 2008.

That number does not reflect the expenditures of several candidates who either were exempt from filing campaign finance reports because they spent under $1,000 or who were exempt from forming a candidate committee because their campaigns were funded by a political action committee or town committee.

Starting in 2008, when CEP grants first became available to legislative candidates, through the most recent general election in 2022, the average for campaign expenditures rose to approximately $91,446. 

That number does not reflect expenditures from candidates who were exempt from filing spending reports because they spent under $1,000, as well as a candidate who incurred expenses on his behalf, rather than a candidate committee, and did not seek reimbursement. 

The difference in spending between campaign victors and losers also increased after CEP grants became available. From 2000 through 2006, expenditures for victorious campaigns averaged around $76,058 per candidate. For second and third-place finishers, expenditures averaged just $1,453. (That figure includes a $1,000 estimate spending for a candidate who did not have to file campaign finance reports because he intended to spend under $,1000 but does not include spending levels for a candidate whose campaign was funded by a PAC.) That’s a difference of approximately $75,000 between first and second place finishers.

Post-CEP, the average expenditure per campaign for victors rose to $133,188. The average expenditure per campaign for second and third-place finishers was $29,787. (That figure includes an estimated $2,000 of spending for two candidates who indicated they would spend under $1,000 and the self-funded spending of a candidate who did not seek reimbursement.)

Though spending has risen across the board for both winning and losing candidates, it has increased by approximately 75 percent for winners since CEP grants became available. For losers, expenditures have increased by 1,949 percent. These spending levels also reflect a number of candidates from all parties that have chosen not to participate in the CEP program.

At the same time spending has increased, the margin of victory for winning candidates has grown. Between 2000 and 2006, victorious candidates on average finished 60.45 points ahead of the next highest performing candidate. From 2008 through 2022, that average grew to 79.33 points.

But that number has also decreased in recent cycles. In 2014, Ayala ran unopposed, securing 100 percent of the vote. Since then, the margin of victory for District 23 has steadily increased, with victor Herron Gaston securing the seat in a three-way race in November 2022 with 76.2 percent of the vote.

As an influx of CEP cash has flooded campaign coffers, campaign expenditures have changed, both the nature of the types of expenses campaigns are making and the timing at which they are made.

One of Mullane’s allegations against CEP is that the amount of money qualifying candidates can receive—up to $112,795 as of 2022 for state senate races—allows candidates to use that money for corrupt purposes, redistributing chunks of cash to campaign loyalists who are given campaign roles.

As a candidate for statewide office both before and after the implementation of CEP, Mizera’s campaign filings paint a picture of how campaign spending in statewide offices has changed pre and post CEP grants being awarded. That spending does not appear to have violated CEP policy, as written.

In 2000, Mizera ran for House District 121 and spent a grand total of $1,185 over the course of his campaign. That money was divided between six expenditures, the majority of which went to campaign printing—$551.20—and reimbursements for food—$478.51.

Fast forward to 2010, the next time Mizera ran for House District 121 and the number and levels of expenditures increased significantly—especially after the campaign received a general election CEP grant worth $26,000.

Prior to the campaign receiving the grant on October 12, the majority of their expenditures were spent on fundraising deposits–$2,000 to a restaurant for a fundraiser—and a $500 deposit to a web developer. In total, the campaign spent $2,705 in the reporting period preceding the grant award.

Post reception of the grant, the campaign began spending money with greater frequency. It continued to spend money on things like campaign literature, website development, and advertising but spent at much higher levels.  In total, between October 1 and December 31, 2010, when the campaign committee filed its termination paperwork for the cycle, it spent $13,371.61 on expenditures related to media and promotion, including lawn signs, printing, website development and maintenance, printing and postage of palm cards and mailers, and robocalls.

That figure represents the amount the campaign spent on professional services outside the campaign and does not reflect campaign personnel hired to perform other tasks, such as data coordination and graphic design.

Besides the difference in the overall amount of spending pre and post CEP, the increase in the number of campaign personnel, including campaign personnel contracted to do specific tasks, is the greatest change in the nature of campaign filings.

In 2010, Mizera’s campaign paid 20 workers $10,466 for a variety of tasks, including literature distribution, data coordination, design of campaign literature, coordinating campaign activity, and “various campaign activities.” A number of those workers, including Norma Aldrich, the deputy campaign treasurer, and Lou Decilio, the campaign coordinator and treasurer, also received payments as part of their contracts.

Payments to campaign workers make up, if not the majority of expenditures, the majority of line items for expenditures on campaign finance reports. This marks a significant change from pre-CEP filings, when records of such work are largely absent and, with much lower levels of spending, similar tasks were presumably carried out by volunteers. Mizera’s post-CEP campaign spending for his House campaign is very similar to spending during his multiple candidacies for Senate District 23. 

Mizera ran for the Stratford senate seat in 2012, when he was a general election candidate who did not face a primary challenger, and in 2018, when he narrowly lost the Republican primary. During both elections his campaign received CEP grants: $91,790 through a general election grant in 2012 and $39,410 in 2018 through a primary grant. 

Over the course of Mizera’s 2012 campaign, roughly 73 percent of expenditures went to payments for campaign workers. Other major expenditure sources included printing and mailing costs for campaign literature and rent and food for campaign events.

In 2018, 25 percent of Mizera’s campaign expenditures went to campaign workers. 

The change in pattern and type of expenditures between Mizera’s campaigns pre and post CEP is not unique to him.

Democrat Edwin Gomes has run for the District 23 Senate Seat a number of times, winning elections in 2006, 2008, 2010, and 2016. He lost a three-way primary to Ayala in 2012 and did not run during the 2014 election, or from 2018 to the present.

Gomes’ 2006 campaign occurred before CEP grants were available to legislative candidates. As with Mizera’s pre-CEP campaigns, the expenditures are largely bereft of payments to campaign workers, particularly lower level campaign workers. The majority of expenditures denote banking expenses and the largest expenses are for the printing of campaign materials and other types of promotion. They also include contributions to other candidates’ committees, a practice that is now banned under CEP.

With the introduction of CEP in 2008—Gomes received $83,025 in late October—not only did the number of expenditures grow considerably, from approximately 32 over the course of his campaign in 2006 to approximately 163 over the course of his 2008 campaign—but the types of expenditures change as paid campaign workers start appearing under the committee’s expenditures.

Roughly 56.4 of expenses in Gomes’ 2008 campaign went to campaign workers, many of whom are listed as “consultants.” That figure does not include expenditures that went to reimburse workers for travel expenses incurred as part of the campaign.

Expenditures to consultants account for 79 percent of total campaign spending during Gomes’ 2010 campaign, 76 percent of his 2012 primary campaign, and 72.5 percent of his 2016 campaign. 

Gomes received CEP in most of his campaigns. In addition to the amount received during his 2008 campaign, Gomes received a $80,550 primary grant during his 2012 campaign and a $84,450 primary grant during his 2016 campaign. In that same campaign, he also received a general election grant of $95,710.

Across both candidates’ campaigns, the vast majority of these expenditures went to low level workers performing tasks like door knocking, dropping off campaign literature, answering phones or performing other tasks at campaign headquarters, and standing outside polling places at election day. 

Across Gomes’ campaigns, the most common expenditures for campaign workers went to consultants, phone bankers, canvassers, and election day workers. Across Mizera’s campaigns, the most common expenditures for workers involved literature drops, election day workers, and “various campaign activities.”

In both candidates’ campaigns, most expenditures to campaign workers don’t amount to more than a few hundred dollars, frequently falling well below $500. Especially for hourly workers, the average payment is significantly lower than $500, often amounting to less than $100 for an hour or two of work. Many workers also receive more than one payment over the course of the campaign, and sometimes more than once within the same reporting period.

The exception to this is payments to higher level staff, such as treasurers, campaign managers, and their deputies. Payments for these workers tend to average between $1,000 and $2,000.

Across Gomes’ campaigns, the average expenditure for campaign worker pay fell below $500.

Mizera’s campaigns spent more on average per worker and also employed fewer workers than Gomes. Higher worker expenditures, of $1,000 or more, were more frequent in Mizera’s campaigns than Gomes’.

The SEEC does regulate payments to campaign workers who receive more than $100 in payment for services performed to a campaign. SEEC rules require the treasurer of a campaign receiving CEP funds to maintain internal records about payments to professional campaign staff, including but not limited to: “a written agreement, signed before any work or services for which payment in excess of $100 is sought is performed, which sets forth (i) the nature of the work to be performed or services to be rendered” or “contemporaneous records and/or invoices created by the close of the reporting period but in no event later than the date of the primary or election to which the expenditures relates, which set forth the nature and detail of the work performed or services rendered.”

The SEEC also provides sample forms on its websites that campaigns can use as a template for keeping track of payments to campaign workers. Sample forms include fee arrangements for work or services, wage records, and reimbursement forms. In the case of the first two forms, campaigns must collect information on the worker’s name and contact information, including their address; duties to be performed; the salary or wages to be paid, and whether these are to be paid hourly, daily, weekly, or monthly; work conditions, such as the hours; and information on how long through the campaign the worker will remain on the payroll.

According to a lawyer for the SEEC, these forms are not publicly viewable because they contain personal financial information but are reviewed in the case a campaign is selected for post-election audit or if a complaint against a campaign is made. 

It is worth noting that much of the same information the SEEC suggests be collected on these forms, minus information on how much and how frequently workers are paid, is publicly available in other campaign filings. For instance, donations collected as evidence of support for a CEP grant require a candidate’s committee to collect a person’s contact information, such as address, and work information. These are publicly viewable in campaign finance reports hosted online by the SEEC.

In short, the information that would allow for a clear understanding of whether these campaign finance standards are being exploited is not available for review. What we can ascertain is that the number of public campaign workers increased dramatically since elections preceding CEP, where there are few expenditures for campaign staff, and language around expenditures to workers can be vague and inconsistent, with candidates altering the language they use to describe tasks performed between campaigns.

In Mizera’s case, Senate District 23 was selected for audit in both 2012 and 2018. Decilio, who served as treasurer for both campaigns, noted this in response to allegations the campaign has been abusing CEP funds.

“Casimir Mizera has run for local and state office on numerous occasions. EVERYTIME, he has run for a state office he has participated in the Citizens Election Program and EVERYTIME after those campaigns he has been audited by the State Elections Enforcement Commission. Mr. Mizera’s campaign had to provide ALL receipts, ALL contracts and any other documentation that pertained to spending Grant Fund money. EVERY audit completed by the State has given Casimir Mizera a clean bill of health and confirmed all grant fund money was spent within the guidelines of the Citizens Election Program.” Decilio stated.

Another criticism of CEP relates to what campaigns do with funding that has not been spent at the end of the campaign. In many cases, campaigns have not spent all of the funds that they were awarded and critics of the program point to this as another way in which CEP funding can be abused, namely by allowing campaigns to hand out bonus payments to workers.

The SEEC has guidance on what campaigns with surplus funds can spend them on, which includes paying outstanding bills, making photocopies of campaign finance records in anticipation of post-election review, paying for moving expenses out of campaign headquarters, and paying for thank you notes and advertising or hosting thank you parties. What campaigns can spend on thank you notes and thank you parties is limited.

Campaigns are also permitted to make a post-election payment of up to $1,000 for services rendered to the campaign treasurer, as well as to the deputy treasurer. In the case the payment is split between the two, the aggregate expense cannot exceed $1,000.

All remaining funds must be returned to the Citizens Election Fund (CEF). Gomes’ 2008 campaign did not make a surplus payment to the treasurer and returned $5,3405 to the CE. In 2010, when his campaign applied for but did not receive CEP, Gomes’ campaigned availed itself of a rule that allows candidates to donate surplus funds to charity rather than the CEF and made a $132.18 donation to The Witness Project of CT. In 2012, Gomes returned $2,907.85 to the CEF. In 2016, his campaign made a $1,000 bonus payment to treasurer Melanie Jackson and did not make any contributions to the CEF. A $38.09 expenditure noting a discrepancy between the bank and the SEEC’s campaign finance tracking system is noted as the campaign’s final expenditure, paid to his campaign committee.

Mizera’s 2010 campaign transferred $241.33 to the CEF. In 2012, the campaign transferred $4,728.44 to the CEF and in 2018 returned $238.67. Decilio received a surplus as treasurer of $1,000 that year.

There is no real baseline for what normal political campaign behavior and spending looks like. Even when candidates are running for re-election in the same district, their campaign strategy is likely to differ from past elections because campaigns are driven by candidates and their opponents, the issues voters care about at that point in time, and the resources available to them. 

And that makes understanding what corrupt campaign behavior looks like even more difficult. The implementation of CEP not only increased the amount of funding available to political candidates, it created new standards for how campaigns must report campaign spending. With more details about how and when campaign finances are spent, routine campaign spending can look nefarious, especially when the types of spending that are now dominating campaign finance reports were not previously recorded. This has been the case with spending on campaign workers.

But understanding whether new spending patterns are a sign of corruption, or simply a sign that campaigns are adapting to CEP’s new rules, is a lot more difficult.

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