Staff: Neal Bucknell, Senior Commission Counsel and Kristin Hamilton, Special Investigator. Respondents are represented by Nicholas Sanders of The Political Law Group, LLP. Committee for Transparent Justice – No on Measure P (“No on P Committee”) was a Sonoma County recipient committee, primarily formed to oppose Measure P in the 2020 election. Sonoma County Deputy Sheriffs’ Association (“DSA”) qualified as a major donor committee in 2020 by virtue of its financial support for the No on P committee. Sonoma County Deputy Sheriffs’ Association PAC (“PAC”) is a Sonoma County general purpose committee, which was sponsored by the DSA. Michael Vail was president of the DSA, principal officer of its PAC, and principal officer of the No on P committee. Cody Ebert was the treasurer for both the PAC and the No on P committee. The DSA, its PAC, the No on P Committee, Vail, and Ebert failed to file required 24-Hour Reports, in violation of Government Code Sections 84203 and 84204 (1 count). The No on P Committee, Vail, and Ebert filed campaign statements and reports, but the name of the committee on these filings did not include the required reference to the committee’s sponsors—and they filed statements of organization, which did not include required identifying information regarding the No on P committee’s sponsors—in violation of Government Code Sections 84102 and 84106 (1 count). The DSA, its PAC, the No on P Committee, and Vail paid for advertisements, which did not include the required reference identifying the DSA and its PAC as the sponsors of the committee (and some of the ads failed to state “Paid for by”), in violation of Government Code Sections 84102, 84106, 84504.1, 84504.2, 84504.3, and California Code of Regulations, title 2, section 18419, subdivision (b)(1) (2 counts). Total Proposed Penalty: $11,000.
