Revolving Door Prohibitions

8/13/2019

The phrase "revolving door" describes the practice of public officials or employees abandoning public service for lobbying positions. Prohibitions on this practice, often refered to as mandatory "cooling-off" or "waiting" periods, forbid individuals from engaging in lobbying activities for a period of time after leaving public service.

Ethics laws in most states set mandatory waiting periods before a public official or employee may register as a lobbyist or engage in lobbying activites. The length of these terms generally vary between six months to two years. For legislators, some states start the clock on the cooling-off period as soon as an individual leaves public service, while others begin at the end of a session or the end of the session for which a legislator was elected to serve. Florida will have the longest cooling off period at six years, set to take effect on December 31, 2022.

Some revolving door laws provide for unique exceptions or nuances. For example, some states exempt lobbying on behalf of an agency or other governmental entity. Restrictions may or may not apply, depending upon the jurisdiction, to uncompensated lobbying or unpaid lobbying with expenses reimbursed. A few states prohibit legislators from representing others before the legislature or agencies if personally involved in the formation of related legislation.

The following table provides the statutory provisions relating to mandatory cooling-off periods for each state's legislators, including D.C., the Virgin Islands, Guam and Puerto Rico. Some provisions may be more broadly applicable, such as for public appointees or employees of the legislative or executive branches. However, the table is intended to be comprehensive for state legislators only.

This table is intended to provide general information and does not necessarily address all aspects of this topic. Because the facts of each situation may vary, this information may need to be supplemented by consulting legal advisors. All content is up to date through 9/30/2019.

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State Legislative Prohibitions on "Revolving Doors"
State Revolving Door Laws

Alabama

No public official shall serve for a fee as a lobbyist or otherwise represent clients before the board, agency, commission, department, or legislative body, of which he or she is a former member for a period of 2 years after he or she was elected or leaves such membership. Also, may not act as attorney for any person other than himself or herself or the state, or aid, counsel, advise, consult or assist in representing any person, in connection with any judicial proceeding or other matter in which the state is a party or has a direct and substantial interest if the former public official participated personally and substantially as a public official in the matter as part of official responsibilities. Ala. Code § 36-25-13.

Excludes former members of the judiciary representing a client in a legal, non-lobbying capacity. Ala. Code § 36-25-13.
Alaska A former member of the legislature may not engage in activity as a lobbyist before the legislature for 1 year after leaving the legislature. Does not apply to volunteer lobbying or a representational lobbyist. Alaska Stat. Ann. § 24.45.121 & AK Const. Art. 2, § 5. A representational lobbyist is a person who attempts to influence legislative or administrative action and receives only reimbursement for travel and other expenses, not compensation or fees for the activity. Alaska Stat. Ann. § 24.45.121.
Arizona A public officer or employee shall not represent another person for compensation before an employing public agency within 12 months or concerning any matter if directly concerned with if personally participated. For 2 years after employment or service, shall not disclose or use for personal profit, without appropriate authorization, any information acquired through official duties. Ariz. Rev. Stat. Ann. § 38-504.
Arkansas A former state official or employee shall not knowingly act as a principal or agent for anyone other than the state if he or she participated while serving in that capacity and the state is a party or has a direct or substantial interest: (1) A judicial, administrative, or other proceeding, application, request for a ruling, or other determination; (2) A contract; (3) A claim; or (4) A charge or controversy. Prohibition extends for 1 year after employment or service. Ark. Code Ann. § 21-8-102.
California A Member of the Legislature, for 1 year after the end of the session during which a member left office, shall not, for compensation, act as agent or attorney for, or otherwise represent, any other person by making any appearance or communication before the Legislature, any committee or subcommittee thereof, any present Member of the Legislature, or any officer or employee thereof, if intended to influence legislative action. Cal. Gov't Code § 87406.
Colorado No statewide elected officeholder or member of the general assembly shall personally represent another person or entity for compensation before any other statewide elected officeholder or member of the general assembly, for 2 years following vacation of office. C.R.S.A. Const. Art. 29, § 4.
Connecticut No state representative or state senator shall engage in the profession of lobbyist until 1 year after the expiration of the term for which such state representative or state senator was elected. Conn. Gen. Stat. Ann. § 2-16a.
Delaware No person who served as a member of the General Assembly shall act as a lobbyist for compensation for a period of 1 year from the time such person is no longer serving in office. Del. Code Ann. tit. 29, § 5837.
District of Columbia No mandatory waiting period by statute found. No public official shall be employed as a lobbyist, if not excluded from registration requirements under D.C. Code Ann. § 1-1162.28, while acting as a public official. D.C. Code Ann. § 1-1162.31.
Florida No member of the legislature or statewide elected officer shall personally represent another person or entity for compensation before the government body or agency of which the individual was an officer or member for 2 years following vacation of office. Excludes representing others before judicial tribunals. West's F.S.A. Const. Art. 2 § 8 & Fla. Stat. Ann. § 112.313. For 2 years, a former legislator may not act as a lobbyist for compensation before an executive branch agency, agency official, or employee. Fla. Stat. Ann. § 112.313.

In November 2018, a constitutional amendment was passed via ballot initiative that will extend revolving door prohibitions to 6 years. The 6-year cooling off period will go into effect on December 31, 2022. West's F.S.A. Const. Art. 12 § 38 & West's F.S.A. Const. Art. 2 § 8.
Georgia Prohibition from registering as a lobbyist or engaging in lobbying for 1 year after leaving office. Ga. Code Ann. § 21-5-75.
Guam No person who is a former legislator shall engage as a lobbyist for 2 years after the end of the last term held by the former legislator as a legislator. 2 G.C.A. § 8101.
Hawaii No former legislator or employee shall represent any person or business for consideration on matters participated in or involving official legislative action within 12 months after termination. Haw. Rev. Stat. Ann. § 84-18.
Idaho No mandatory waiting period by statute found.
Illinois 1 year cooling-off period from termination of state employment regarding state procurement contracts, but no general revolving door prohibition on lobbying applicable to legislators. 5 ILCS 430/5-45.
Indiana A member of the general assembly may not be registered as a lobbyist, beginning on the day the individual ceases to be a member and ending 365 days afterwards. Ind. Code Ann. § 2-7-5-7.
Iowa A person who serves as a member of the general assembly shall not act as a lobbyist during the time in which the person serves, or within 2 years after termination of service. Iowa Code Ann. § 68B.5A.
Kansas No generalized mandatory waiting period by statute found. However, there is a bar on accepting employment for 2 years if participated as a state officer in the making of any contract with the prospective employer. Shall not, for 1 year after expiration of a term, be interested in any contract with the state or represent any person in a court proceeding attacking any legislative action taken or enactment made during any such term as a legislator as being unconstitutional due to error in the legislative process. Kan. Stat. Ann. § 46-233.

Shall not, within 1 year after the end of a term, receive any civil appointment to a state office created by law during the last term for which such person had been elected. Kan. Stat. Ann. § 46-234.
Kentucky A former legislator shall not be a legislative agent, other than for a public agency, until after 2 years since the date the legislator left office. Ky. Rev. Stat. Ann. § 6.757.
Louisiana No former agency head or elected official shall, for 2 years after the termination of service assist another person for compensation in connection with a transaction involving that agency or render any service on a contractual basis to or for such agency. La. Stat. Ann. § 42:1121.
Maine A person who has served as a legislator may not engage in activities that would require lobbyist registration until 1 year after the end of the legislator’s term. Excludes unpaid lobbying activities. Me. Rev. Stat. tit. 1, § 1024.
Maryland A former member of the General Assembly may not assist or represent another party for compensation in a matter that is the subject of legislative action for 1 year from the date the member leaves office. Does not apply to representation of a municipal corporation, county, or state governmental entity. Md Gen Provis § 5-504.
Massachusetts A former state employee or elected official who acts as legislative or executive agent for anyone other than the commonwealth or a state agency before the governmental body, as determined by the state ethics commission with which he has been associated, within 1 year after he or she leaves that body. Mass. Gen. Laws Ann. ch. 268A, § 5.
Michigan A member of the Michigan senate or house who resigns from office shall not make expenditures for or receive compensation or reimbursement for actual expenses for lobbying for the remainder of the term of office from which the person resigned. Mich. Comp. Laws Ann. § 4.416a.
Minnesota No mandatory waiting period by statute found. The House prohibits former state legislators from registering as lobbyists within 1 year from the date they leave office. House Rule 9.35. The Senate and Joint Rules do not appear to have a similar prohibition. (Current as of: 9/30/2019).
Mississippi No public officer or member of the Legislature shall be interested in any contract with the State, or any district, county, city, or town thereof, authorized by any law passed or order made by any board of which he may be or may have been a member, during the term for which he shall have been chosen, or within 1 year after the expiration of such term. Miss. Const. art. 4, § 109 & Miss. Code. Ann. § 25-4-105.
Missouri 6 month prohibition on lobbying for any former legislator based on the expiration of any term of office or after he or she vacates office. Excludes unpaid lobbyists or those who act, serve, or register as a lobbyist for a state department or agency. Mo. Ann. Stat. § 105.455. Term extended to two years by constitutional amendment passed via ballot measure during the November 2018 election.
Montana A public officer or public employee may not, within 12 months following the voluntary termination of office or employment, obtain employment in which the officer or employee will take direct advantage, unavailable to others, of matters with which the officer or employee was directly involved during a term of office or during employment. Mont. Code Ann. § 2-2-105. An individual may not be licensed as a lobbyist and a principal may not directly authorize or permit lobbying by an individual if during the 24 months before applying for a license that individual served as a state legislator. Mont. Code Ann. § 5-7-310.
Nebraska No mandatory waiting period by statute found.
Nevada For 1 year, former public officers or employees of a board, commission, etc. shall not solicit or accept employment from a business or industry whose activities are governed by regulations adopted by the board, commission, etc. Nev. Rev. Stat. Ann. § 281A.550.
New Hampshire No mandatory waiting period by statute found.
New Jersey No person, within 1 year after termination of the office or employment, shall register as a governmental affairs agent. N.J. Stat. Ann. § 52:13C-21.4.
New Mexico For a period of one year after leaving government service or employment, a former public officer or employee shall not represent for pay a person before the state agency or local government agency at which the former public officer or employee served or worked. N.M. Stat. Ann. § 10-16-8.

A state agency or local government agency shall not enter into a contract with or take any action favorably affecting any person or business that is: a) represented by a person who has been a public officer or employee within the preceding year if the value of the contract or action is over $1,000 and the contract is a direct result of an official act by the public officer or employee; or b) assisted in the transaction by a former public officer or employee of the state whose official act, while in state employment, directly resulted in the agency's making that contract or taking that action. A former public officer or employee shall not represent a person in dealings with the government on a matter in which the former public officer or employee participated personally and substantially while a public officer or employee. N.M. Stat. Ann. § 10-16-8.
New York Lobbying restriction for 2 years. No time limit if regarding a matter in which a state officer or employee personally participated or actively supervised. Exception upon prior approval by the state ethics commission or the commission on public integrity. N.Y. Pub. Off. Law § 73.
North Carolina No former legislator may register as a lobbyist for 6 months after leaving office. N.C. Gen. Stat. Ann. § 163A-308.
North Dakota No mandatory waiting period by statute found.
Ohio 12 month prohibition after a public official leaves office against representing in which any matter the official personally participated, or representing anyone on any matter before the general assembly. Ohio Rev. Code Ann. § 102.03.
Oklahoma No mandatory waiting period by statute found. However, no member of the Legislature shall, within 2 years after a term, be interested in any contract with the State, or any county or other subdivision, authorized by law passed during the term for which he shall have been elected. OK Const. Art. 5, § 23.
Oregon A public official who as part of the official's duties invested public funds shall not within 2 years after the public official ceases to hold the position: (a) Be a lobbyist or appear as a representative before the agency, board or commission for which the former public official invested public funds; (b) Influence or try to influence the agency, board or commission; or (c) Disclose any confidential information gained as a public official. Or. Rev. Stat. Ann. § 244.045.

A member of the Legislative Assembly may not, within one year after ceasing to be a member of the Legislative Assembly, receive money or any other consideration for lobbying. Or. Rev. Stat. Ann. § 244.045.
Pennsylvania No former public official or public employee shall represent a person, with promised or actual compensation, on any matter before the governmental body with which he has been associated for one year after he leaves that body. 65 Pa.C.S.A. § 1103. This provision does not apply to attorneys. Shaulis v. Pennsylvania State Ethics Comm'n, 574 Pa. 680, 833 A.2d 123 (2003).
Puerto Rico No mandatory waiting period by statute found.
Rhode Island 1 year prohibition after a legislator severs his or her position with the state. Prohibition does not include representation before a court of law. RI ST § 36-14-5.
South Carolina Public officials and their immediate family may not serve as lobbyists during the time the official holds office and for 1 year after service ends. S.C. Code Ann. § 2-17-15 & S.C. Code Ann. § 8-13-755.
South Dakota No elected officer may be compensated, act, or register as a lobbyist, other than a public employee lobbyist, for 2 years after termination of service. S.D. Codified Laws § 2-12-8.2.
Tennessee 12 month prohibition on members of the general assembly from serving as lobbyists after leaving office. Tenn. Code Ann. § 3-6-304.
Texas No mandatory waiting period by statute found.
Utah A former state official may not become a lobbyist or engage in lobbying that would require registration for 1 calendar year, beginning on the day the state official leaves office. Exceptions: if the former state official engages in lobbying on behalf of himself or a business with which he is associated, unless the primary activity of the business is lobbying or governmental relations. Utah Code Ann. § 67-24-103.
Vermont A legislator or an Executive officer, for one year after leaving office, shall not be a lobbyist in this State. Vt. Stat. Ann. tit. 2, § 266. Exceptions: a person who engages in lobbying solely by testifying before committees of the General Assembly and agencies, etc. and providing information requested by legislators or administrative officials; a person who owns, publishes, or is employed by any news medium while engaged solely in the acquisition or dissemination of news on behalf of the news medium. Vt. Stat. Ann. tit. 2, § 262.
Virginia For 1 year after serving, shall not represent a client for compensation on any matter before the General Assembly or any agency of the legislative branch of government. Va. Code Ann. § 30-103.
Virgin Islands No mandatory waiting period by statute found.
Washington For 1 year after serving, shall not accept employment or receive compensation if engaged in the negotiation or administration of contracts valued over $10,000 with that employer within the past 2 years. For 2 years after serving, shall not have a beneficial interest in a contract or grant authorized or funded by legislative or executive action in which the former state officer participated. Wash. Rev. Code Ann. § 42.52.080.
West Virginia Members of the legislature may not, during or before 1 year following service in the legislature, register as lobbyists. W. Va. Code Ann. § 6B-3-2.

No present or former elected or appointed public official shall, during or after his or her public employment or service, represent a client or act in a representative capacity on behalf of any person in a contested matter involving a party which arose during his or her period of public service and in which he or she personally and substantially participated, unless the appropriate government agency, after consultation, consents to representation. W. Va. Code Ann. § 6B-2-5.
Wisconsin No former state public official, for 12 months following the date on which he or she ends service, may, for compensation, on behalf of another who isn’t a governmental agency, make any appearance before or negotiate with any officer or employee of the department with which he or she was associated. Wis. Stat. Ann. § 19.45.
Wyoming No mandatory waiting period by statute found.