August 2, 2019 1:07PM 

# New York Threatens Legislative Crusader With Unregistered-Lobbyist Fines 

By [Walter Olson](https://www.cato.org/people/walter-olson) 

---

<a class="js-popover-trigger cursor-pointer popover-trigger" data-bs-placement="bottom" data-bs-trigger="click" id="popover-trigger"> 

SHARE 

</a> 

As part of a one-woman crusade to call attention to sexual abuse, with the goal of getting New York to ease its law on the filing of abuse lawsuits, Kat Sullivan bought billboards, started a website, and hired a plane to pull a banner. Now, according to [press reports](https://www.mykxlg.com/news/national/woman-could-face-fines-for-billboards-decrying-sex-abuse-law/article_4d410c7f-3ad3-5e55-b691-c0bbc6d8b41b.html), New York’s state ethics agency, the Joint Commission on Public Ethics, has been after her with repeated warnings that she may have exceeded a $5,000 limit on expenditures for advocacy of legislation. From Chris Bragg’s reporting in the [Albany Times-Union](https://www.timesunion.com/news/article/JCOPE-pursues-abuse-victims-lobbying-for-others-14146139.php):

> JCOPE staffers have left eight voicemails for Sullivan over the past year. She has taken part in often lengthy phone calls with investigators more than a dozen times, and has received three official letters. She’s been part of a dozen more email threads with JCOPE staff, totaling 65 pages. She paid a lawyer $1,900 to speak to the agency.…

Sullivan, who also made expenditures in Massachusetts and Connecticut in pursuit of her cause, denies that her New York-related spending exceeded $5,000.

> On July 12, JCOPE sent Sullivan what’s known as a “15-day letter” threatening her with the launch of a formal investigation that could result in fines of up to $25,000 per violation — and there could be many. While the letter says she has until Monday to respond in writing, commissioners “may vote to commence an investigation prior to receiving your written response.”…
> 
> 
> JCOPE spokesman Walter McClure.…\[said\] that JCOPE has procedures for “handling potential unregistered lobbying” and treats all people and entities “allegedly involved in that unregistered lobbying the same way.”
> 
> 
> “We will enforce the law and pursue the required disclosure,” McClure said.

Pssst! Lobbying is speech!

##### Related Tags 

[Constitutional Law](https://www.cato.org/constitutional-law), [Robert A. Levy Center for Constitutional Studies](https://www.cato.org/robert-levy-center-constitutional-studies) 

[![Creative Commons License](/build/cato_2020/images/creative-commons.svg)](http://creativecommons.org/licenses/by-nc-sa/4.0/) 
This work is licensed under a [Creative Commons Attribution-NonCommercial-ShareAlike 4.0 International License](https://creativecommons.org/licenses/by-nc-sa/4.0/).