The Institute for Public Representation (IPR) at Georgetown University Law Center has filed complaints with the Federal Communications Commission on behalf of two non-profit organizations, the Campaign Legal Center and the Sunlight Foundation, alleging that 11 TV stations failed to disclose legally required information about political ads.
Student Matthew Dulac, L'15
, and Fellow Eric Null, LL.M.'15
of the Communications and Technology Clinic housed within IPR led this investigation under the supervision of Professor Angela J. Campbell
and Andrew Jay Schwartzman
, Benton Senior Counselor at the Communications and Technology Clinic.
The complaints allege violations of the Bipartisan Campaign Reform Act, which expanded long-standing FCC public disclosure requirements for political ads. Due to earlier advocacy efforts of IPR and its clients, the FCC required in 2012 that television stations begin to make their political files available to the public online. Previously, members of the public would have to visit stations in person to inspect these files.
Dulac investigated station compliance by going through the online public files. He found widespread noncompliance with requirements to disclose who paid for the political ads (and the groups' chief executives and boards of directors) and to identify the candidates or national issues referred to in the ads.
IPR found that the parties in violation span network affiliations, station owners, political parties, and areas of the country. For example, WDIV, an NBC affiliate in Detroit, failed to upload its documents in a timely manner, waiting more than two months to upload the purchase contracts that disclosed the rates, dates, and times aired for political ads. WTVD, an ABC affiliate in Durham, NC, ran an ad for U.S. Senate candidate Thom Tillis, but did not provide fundamental details such as Tillis’ name and the election the ad referred to in its disclosures.
The Institute for Public Representation
is a public interest law firm and clinical education program founded by Georgetown Law in 1971. Students and lawyers at IPR act as counsel for groups and individuals who are unable to obtain effective legal representation on matters that have a significant impact on issues of broad public importance. IPR works in the areas of First Amendment and media law, environmental law, civil rights and general public interest matters.
Georgetown Law's clinical program is the largest and most highly regarded in the country, and allows students to learn to practice law by working with real clients confronting complex legal challenges.
Links to the 11 complaints are available here