January 25, 2018

The Honorable Terry Baxter
2395 290th Street
Garner, IA 50438

To Representative Baxter:

This opinion is in response to your request for an opinion from the Iowa Ethics and Campaign Disclosure Board. We issue this opinion regarding the use of campaign funds to travel to Kosovo. We note at the outset that the Board’s jurisdiction is limited to the application of Iowa Code chapters 68A and 68B, Iowa Code section 8.7, and rules in Iowa Administrative Code chapter 351. Advice in a Board opinion, if followed, constitutes a defense to a subsequent complaint based on the same facts and circumstances.


You are the chair of the joint legislative International Relations Committee. You advise the Board you and several other committee members are interested in traveling to Kosovo with the Iowa Sister States organization. Iowa Sister States is a non-profit organization and its mission is to provide international programs that promote the interests of Iowans abroad. The organization facilitates and hosts exchange programs between Iowa and its sister states.

Iowa Sister States is organizing a trip to Kosovo in May. The organization expects to take a large Iowa delegation to Kosovo and will customize participants’ itineraries based on their interests. Details are still being finalized, but Iowa legislators can expect to meet with government officials, including at least one Minister of Parliament, visit with Iowa National Guard members who are stationed in Kosovo, and learn more about Kosovo’s agriculture and commerce. Participants are required to cover the costs of their travel, lodging and food expenses.


May legislators use their campaign funds to pay for the costs associated with this trip?


Iowa Code section 68A.302 sets out the permissible uses of campaign funds for candidates. That section states “[a] candidate and the candidate’s committee shall use campaign funds only for “campaign purposes, educational and other expenses associated with the duties of office, or constituency services, and shall not use campaign funds for personal expenses or personal benefit.” Section 68A.302 then lists ten items that shall not be paid from campaign funds. The Board’s rule 351—4.25 provides a non-exhaustive list of permissible expenditures using campaign funds.

We are of the opinion this trip to Kosovo would be educational and related to your duties of office. However, “meal expenses are not allowable as expenses associated with the duties of office under any circumstances.”i Thus, you may use campaign funds to pay for your travel and lodging for this trip but not your meals.



James Albert, Chair
John Walsh, Vice Chair
Carole Tillotson
Jonathan Roos
Mary Rueter

Submitted by Megan Tooker, Board Legal Counsel

i Iowa Admin. Code r. 351—4.24(2)(b); see also Iowa Code § 68A.302(2)(i) (prohibiting the use of campaign funds for meals, groceries or other food expenses, except for “campaign-related purposes”).