Is There a Tribal Campaign Loophole?

March 1, 2002

Dear Senator _______________________

It has been reported that President Bush recently asked congressional leaders if there is a tribal campaign loophole. Tribal representatives are actively denying that any loophole exists. Is there a tribal loophole, and if so, what is it? Consider the following:

LOOPHOLE #1: Tribal governments are the only governments that are allowed to use government funds to actively support issues and candidates in local, state and federal elections. No other government may make campaign contributions, much less use taxpayer dollars to do so.

LOOPHOLE #2: Unless legislation expressly and specifically includes "Indian tribes" as subject to the proposed legislation, Indian tribes are exempt from its requirements. The current, and most past, Campaign Finance Reform legislation does not expressly include "Indian Tribes."

LOOPHOLE #3: Tribal government campaign contributions violate the general rule that campaign contributions must be voluntarily given. Tribal contributions can't represent the political diversity of tribal members.

LOOPHOLE #4: The FEC ruled in Advisory Opinion No. 2000-05 (May 15, 2000), that tribal governments are considered as a "persons" for campaign finance purposes. Tribal government's status as "persons" combines with their attributes of partial "sovereignty" (independent supremacy) and sovereign immunity. This means that tribal governments influence local, state and federal campaigns without effective disclosure and accountability.

LOOPHOLE # 5: While tribal governments are "persons" for purposes of disclosure and accountability, they are not limited to contributions as "individuals." They are treated like PACs who can give without restriction on aggregate contributions. Thus tribal governments can use government funds for essentially undisclosed and unrestricted campaign contributions.

We challenge anyone doubting the above loopholes to quantify the amount of hard, soft, direct and indirect tribal governmental contributions to just the members of the Senate Indian Affairs Committee. We further ask that they document the original source of that money. This is a very small sample of what is happening in the entire country.

The above five significant "tribal loopholes" have significantly corrupted and unbalanced the elected political process. Every tribal member is equally represented along with every other citizen by state and federal elected officials, without the involvement of tribal governments. Even if the Shays-Meehan bill effectively stops the soft money contributions of tribal
governments to political parties, these loopholes will continue. Therefore, if the Shays-Meehan bill can't be amended to correct these loopholes, Citizens Equal Rights Alliance (CERA) respectfully requests that you vote against it.

Sincerely,


Howard B Hanson, Chairman