Last Friday, a district court upheld a long-standing ban on federal political contributions made by federal contractors.  In practice, the universe of those directly affected by this ban, and the opinion upholding it, is relatively small.  Corporations are already prohibited from contributing to candidates and parties.  The prohibition therefore generally applies only when the federal government has contracted with individuals and certain other non-corporate entities.  Generally speaking, it would not bar contributions made by employees of government contractor corporations.

The opinion could have two broader implications.  First, the court concluded that the ban was justified because it served the government’s interest in avoiding corruption and the appearance of corruption.  In future battles over state and federal pay-to-play laws that prohibit employees of government contractors from making contributions, this conclusion may be cited by regulators for the proposition that since the appearance of corruption justifies a ban on contributions from individual contractors, it should also justify a ban on contributions from employees of corporate contractors.  Whether that will be enough to overcome the serious constitutional concerns posed by pay-to-play laws is not yet clear.

Second, the opinion did give federal contractors a consolation prize.  Although it did not ultimately reach the issue, the court explained that there is “substantial doubt” as to the constitutionality of the provision insofar as it would prevent contractors from contributing to SuperPACs and making independent expenditures in connection with federal elections.

Photo of Zachary G. Parks Zachary G. Parks

Zachary Parks advises corporations, trade associations, campaigns, and high-net worth individuals on their most important and challenging political law problems.

Chambers USA describes Zachary as “highly regarded by his clients in the political law arena,” noting that clients praised him as their “go-to outside…

Zachary Parks advises corporations, trade associations, campaigns, and high-net worth individuals on their most important and challenging political law problems.

Chambers USA describes Zachary as “highly regarded by his clients in the political law arena,” noting that clients praised him as their “go-to outside attorney for election law, campaign finance, pay-to-play and PAC issues.” Zachary is also a leading lawyer in the emerging corporate political disclosure field, regularly advising corporations on these issues.

Zachary’s expertise includes the Federal Election Campaign Act, the Lobbying Disclosure Act, the Ethics in Government Act, the Foreign Agents Registration Act, and the Securities and Exchange Commission’s pay-to-play rules. He has also helped clients comply with the election and political laws of all 50 states. Zachary also frequently leads political law due diligence for investment firms and corporations during mergers and acquisitions.

He routinely advises corporations and corporate executives on instituting political law compliance programs and conducts compliance training for senior corporate executives and lobbyists. He also has extensive experience conducting corporate internal investigations concerning campaign finance and lobbying law compliance and has defended his political law clients in investigations by the Federal Election Commission, the U.S. Department of Justice, Congressional committees, and in litigation.

Zachary is also the founder and chair of the J. Reuben Clark Law Society’s Political and Election Law Section.

Zachary also has extensive complex litigation experience, having litigated major environmental claims, class actions, and multi-district proceedings for financial institutions, corporations, and public entities.

From 2005 to 2006, Zachary was a law clerk for Judge Thomas B. Griffith on the United States Court of Appeals for the District of Columbia.