HomeMy WebLinkAbout19- Dismissal Decision - Commissioner of Political Practices BEFORE THE COMMISSIONER OF
POLITICAL PRACTICES OF THE STATE OF MONTANA
In Re City of Bozeman DISMISSAL
No. COPP 2018-CFP-057
On December 3, 2018, the City of Bozeman self-filed a formal Campaign
Finance and Practices complaint with the Commissioner of Political Practices
(COPP), naming itself as both the Complainant and Respondent in the matter.
The COPP complaint contained multiple attachments pertaining to a district
court complaint filed in Montana's 18th Judicial District Court in Gallatin
County by Roger Koopman, Paul Johnson, and Does 1-5. Koopman, et al. V. City
of Bozeman, et al., Cause No. 18-1215-C. The Koopman lawsuit—which the City
incorporated by reference as the basis for the COPP complaint—alleged that the
City of Bozeman, through its elected officials and employees: clearly advocated
for the passage of a municipal bond issue; used public time and resources to
advocate for the passage of this bond issue; and coordinated expenditures,
communications, and other activities supporting the bond issue with a ballot
issue committee, Bozeman Citizens for Safety (BCFS).
City of Bozeman u. City of Bozeman
Page 1
SUBSTANTIVE ISSUES ADDRESSED
Proper filing as an incidental committee; reporting electioneering
communication expenditures; use of public resources by public employees;
coordination of committee expenditures.
FINDINGS OF FACT
The foundational facts necessary for this Decision are as follows:
Findine of Fact No. 1: Montana's 2018 General election was held on
November 6, 2018. Absentee ballots were mailed out in Gallatin
County on October 12, 2018. "Electioneering" communication
reporting period went into effect on August 13, 2018, sixty days prior
(see Admin. R. 44.11.605(2)(b)). (Commissioner's Records.)
Finding of Fact No. 2: On July 23, 2018, the Bozeman City
Commission adopted and approved Resolution No. 4936, submitting
to Bozeman voters a bond issue for a Bozeman Public Safety Center
(BPSC). This issue appeared on the ballot for Bozeman voters during
Montana's 2018 General election, held on November 6, 2018.
(Commissioner's Records.)
Finding of Fact No. 3: The City of Bozeman (the City) filed a C-2
Statement of Organization as an incidental political committee with
COPP on June 22, 2018. The stated purpose was, "Inform public of
impact of passage or failure of Bozeman Public Safety Center ballot
issue on City operations[.]" The C-2 listed Brian LaMeres as the
Treasurer. Mr. LaMeres is currently employed as a Controller in the
Finance Department for the City of Bozeman. (Commissioner's
Records.)
Findinz of Fact No. 4: The City of Bozeman filed an initial C-4
committee finance report using CERS1 on August 8, 2018, dated
May 1 through August 3. The City reported $7,694.97 in "Staff time
on educating regarding Bozeman Public Safety Center *See
attachment[.]" The submitted attachment broke this staff time down
in more detail. The report also included two expenditures totaling
$772.33 and two debts totaling $10,631.87; and copies of invoices
received from The Nest Collective provided with the C-4 report to more
1 CERS is an acronym for Campaign Electronic Reporting System, the e-filing system used by
candidates and political committees to submit campaign finance reports and other required
forms to COPP.
City of Bozeman u. City of Bozeman
Page 2
fully describe the services provided to the City. (Commissioner's
Records.)
Findiniz of Fact No. 5: The Nest Collective is a Bozeman, Montana
business described as a full service communications firm. (Nest
Collective website, http://www.thenestbzn.com/.)
Finding of Fact No. 6: The City of Bozeman entered into a Professional
Services Agreement with The Nest Collective on June 11, 2018 to
"assist the City of Bozeman with development of strategy, messaging,
and create an educational campaign for the City of Bozeman Public
Safety Building[.]" The agreement concluded November 6, 2018.
(Commissioner's Records.)
Finding of Fact No. 7: The City filed a periodic C-4 committee finance
report on October 2, 2018, dated August 4 through September 27.
This report disclosed $17,482.30 in "Staff time on educating regarding
Bozeman Public Safety Center *See attachment[.]" The attachment
broke this staff time down in more detail. The City also reported
making five expenditures totaling $7,514.72 and reported three debts
in the amount of $5,230.05; it included copies of invoices received
from The Nest Collective to more fully describe the services provided
to the City. (Commissioner's Records.)
Finding of Fact No. 8: Bozeman Citizens for Safety (BCFS) filed a C-2
Statement of Organization as a ballot issue committee with COPP on
October 5, 2018, describing the purpose of the committee as "City of
Bozeman Public Safety Bond- Support[.]" The C-2 listed Carson
Taylor as the committee's Treasurer, Chris Mehl as Deputy Treasurer,
and Terry Cunningham as an Additional Officer. (Commissioner's
Records.)
Findiniz of Fact No. 9: The Bozeman City Commission is comprised of
Mayor Cyndy Andrus, Deputy Mayor Chris Mehl, Commissioner I-Ho
Pomeroy, Commissioner Jeff Krauss, and Commissioner Terry
Cunningham. (City of Bozeman website, https://www.bozeman.net
/izovernment/city-commission.)
Finding of Fact No. 10: BCFS timely filed a C-6 Committee Finance
report on October 5, 2018, dated June 2 through October 1. The
report disclosed BCFS received contributions from three City of
Bozeman elected officials with the required occupation and employer
information: Chris Mehl (via loan); Terry Cunningham; and Cyndy
Andrus. This report also disclosed BCFS received financial
contributions from an additional three City of Bozeman employees,
and one incidental political committee, the Bozeman Police Protective
City of Bozeman u. City of Bozeman
Page 3
Association.2 BCFS reported making two expenditures: $703.25 to
Super Cheap Signs on August 23 for "150 yard signs and stakes" and
$63.29 to Super Cheap Signs on August 24 for "Shipping signs and
stakes[.]" (Commissioner's Records.)
Finding of Fact No. 11: The City timely filed a periodic C-4 committee
finance report on October 25, dated September 28 through October
20, 2018. The report disclosed $7,810.39 in "Staff time on educating
regarding Bozeman Public Safety Center *See attachment[;]" as
before, the attachment broke staff time down in more detail. The City
also reported three debts totaling $4,998.50; and included copies of
invoices received from The Nest Collective to more fully describe the
services provided to the City. (Commissioner's Records.)
Finding of Fact No. 12: BCFS timely filed a C-6 periodic committee
finance report on October 26, dated October 2 through October 24,
2018. This report disclosed BCFS received financial contributions
from one City of Bozeman elected official including the required
occupation and employer information: City Commissioner Jeff
Krauss. BCFS reported making three expenditures: $106.25 to The
Nest Collective, Inc. on October 10 for "Yard sign design[,]" $501.00
to Townsquare Media on October 15 for "Radio ads, KMMS AM & FM
Oct 16-23[,]" and $81.25 to Peak Recording on October 15 for "Radio
spot production[.]" (Commissioner's Records.)
Findine of Fact No. 13: BCFS timely filed a closing C-6 committee
finance report on November 19, dated October 25 through November
16, 2018. The report disclosed BCFS received financial contributions
from one City of Bozeman elected official including the required
occupation and employer information: City Commissioner I-Ho
Pomeroy. BCFS reported one expenditure: $744.96 to Chris Mehl on
November 16 for "Loan repayment, $744.96 of$800.00 total to Chris
Mehl. Remaining loan amount was forgiven[.]" (Commissioner's
Records.)
Finding of Fact No. 14: BCFS 2018 committee finance records indicate
the committee received a total of nine contributions, including four
who identified their employer as the City of Bozeman. COPP identified
four contributors as City of Bozeman elected officials.
(Commissioner's Records.)
Findine of Fact No. 15: The City timely filed a closing C-4 committee
finance report on November 21, dated October 21 through November
21, 2018. This report disclosed $967.86 in "Staff time on educating
2 As of December 2018, the Bozeman Police Protective Association has not filed either a C-2
Statement of Organization or any C-4 financial reports with COPP.
City of Bozeman v. City of Bozeman
Page 4
regarding Bozeman Public Safety Center[,]" with the attachment
breaking down this staff time in more detail. The City report included
seven expenditures totaling $3,511.80. (Commissioner's Records.)
Finding of Fact No. 16: The City hand-delivered a response to this
Complaint to COPP on December 6, 2018. This response laid out
three basic points about the City in regards to this matter: (1) that all
City of Bozeman public meetings, distributed materials, and any other
activities were purely educational in nature, and did not advocate for
or encourage passage of the BPSC issue; (2) where City of Bozeman
elected officials or employees advocated for passage of the BPSC issue,
they did so on their own time, in their capacity as an individual
citizen; and (3) that the City did not coordinate any official activities
with BCFS, nor did any City of Bozeman employees or elected officials
assist BCFS while acting in their official capacity. The response also
explained that the City contracted The Nest Collective, LLC, to help
develop and distribute educational materials, which often included
the BPSC logo, the slogan "Keep Bozeman Safe" or "Bozeman is Safe.
Let's Keep it that Way[,]" and a text block containing the "Paid for by"
attribution, information on the date of the election, and a link to a
website containing additional information. The City's December 6
response included nine affidavits from various city officials or
employees, discussed infra.
An associated email received by COPP that same day from
Randy Cox, the City's legal representation, provided a list of all City
of Bozeman elected officials or employees who worked with The Nest
Collective on the education effort: Chuck Winn, Assistant City
Manager; Andrea Surratt, City Manager; Anna Rosenberry, Assistant
City Manager; Chris Mehl, Deputy Mayor; Cyndy Andrus, Mayor; Greg
Sullivan, City Attorney; J. Colleen Herrington, Municipal Judge; Jim
Veltkamp, Deputy Police Chief; Josh Waldo, Fire Department Chief;
Karl Seel, Municipal Judge; Melody Mileur, Communications
Coordinator; Steve Crawford, Police Department Chief; Tanya
Andreasen, Neighborhoods Coordinator; Scott Mueller, Deputy
Chief/Fire Marshall; Mike Maltaverne, Deputy Fire Chief; and Karen
Stambaugh, Assistant City Attorney. (Commissioner's Records.)
Findiniz of Fact No. 17: An affidavit from Cyndy Andrus was among
those included in the City's response. Mayor Andrus swore that she
understood the difference between education and advocacy regarding
the BPSC issue and had been trained by Bozeman City Attorney Greg
Sullivan "as to the line between what I may do as a public official and
what I may do as a private citizen[.]" Mayor Andrus stated she
attended or gave numerous informational presentations regarding the
BPSC to the public in her capacity as Mayor, time which she properly
City of Bozeman v. City of Bozeman
Page 5
tracked and was reported on City of Bozeman financial reports.
Andrus further stated she did not publicly advocate for the BPSC
beyond writing a Letter to the Editor for the Bozeman Daily Chronicle
expressly supporting the issue. On November 4, 2018, the Chronicle
published this letter, which was signed "Cyndy Andrus, Mayor of
Bozeman[.]" Andrus' affidavit stated this letter was written "on my
own time, using my own personal computer[,]" but that, in error, it
was provided to the Chronicle using her City email account. While
Mayor Andrus stated she was aware of the BCFS committee,
personally contributed $100.00 to that committee and "picked up
some yard signs from Chris Mehl's front porch on one occasion and
on one occasion Chris Mehl dropped off yard signs on my front
porch[,]" she asserted she had no other involvement or interactions
with BCFS. (Commissioner's Records.)
Finding of Fact No. 18: Steve Crawford, the Bozeman Police Chief, also
provided an affidavit. Chief Crawford swore that he developed an
"understanding of the difference between advocacy and education by
receiving guidance from the Bozeman City Attorney, Greg Sullivan[.]"
Chief Crawford stated he engaged in educational activity regarding
the BPSC issue in his capacity as Police Chief, time which he properly
tracked and was reported on City of Bozeman financial reports. In
particular, Chief Crawford stated he assisted The Nest Collective with
an educational video, and that he co-wrote an educational piece about
the BPSC for the Bozeman Daily Chronicle, which piece was on
October 7, 2018. Chief Crawford also stated that he was aware of the
existence of the BCFS committee and that, "Terry Cunningham
contacted me from his private email inquiring if I would participate in
the production of a video" for BCFS, Chief Crawford declined to
participate and did not have any other involvement or interactions
with the committee. (Commissioner's Records.)
Finding of Fact No. 19: City Commissioner Terry Cunningham also
provided an affidavit. Commissioner Cunningham swore, "I am and
have been well aware of the line that exists between what I can do as
a private citizen and what I can do as a public official. I learned,
through a series of conversations and presentations by the City
Attorney's office and, in particular, Greg Sullivan the City Attorney,
that there was a prohibition against use of public time, resources,
equipment, or money to solicit support for or opposition to the
passage of a bond issue[.]" Commissioner Cunningham estimated he
attended "8 to 15 public presentations" on the BPSC issue in his role
as a City Commissioner, but that he did not promote the issue at any
of these events. Commissioner Cunningham stated that this time was
properly tracked and was reported on City of Bozeman financial
reports.
City of Bozeman v. City of Bozeman
Page 6
Cunningham further stated he did engage in support of the
BPSC as a private citizen, specifically with the formation of the BCFS
committee. According to Cunningham, the word "Citizens" was
included in the BCFS name specifically to "distinguish between roles
as elected officials and private citizens[,]" and no BCFS decisions were
made on City time or with City resources. Commissioner
Cunningham also wrote a Letter to the Editor expressly supporting
the BPSC issue, which the Bozeman Daily Chronicle published on
October 19, 2018, signed "Terry Cunningham, City Commissioner,
Bozeman[.]" Cunningham stated "[t]here was no City resources, time,
supplies, or anything else involved in my advocacy letter[.]"
(Commissioner's Records.)
Findine of Fact No. 20: City Commissioner Jeff Krauss provided an
affidavit. Commissioner Krauss swore, "I have long understood that
it is prohibited for me to advocate for or against a ballot issue while
using local government...resources[,]" and that "[o]ther than my
comments from the City Commission dais during discussion of
placing the bond issue on the November 2018 ballot, I did not
participate in my official capacity at any City-arranged community
events regarding the Bozeman Public Safety Center[.]" Krauss did
expressly support the BPSC issue on multiple radio appearances, but
he stated such appearances were conducted "[o]n my own time and
in my individual capacity[.]" Krauss also expressly supported the
BPSC issue via a Facebook post made to his personal page, which was
Boosted for approximately$20.00. Per Krauss, this post was reported
as an in-kind contribution to BCFS, and he donated an additional
$100.00 of his own personal funds to the committee, plus placed two
BCFS yard signs on his personal property. (Commissioner's Records.)
Findine of Fact No. 21: Deputy Mayor Chris Mehl also gave an
affidavit. Deputy Mayor Mehl swore, "In my capacity as a City official,
I well understand the line between education and advocacy that City
officials and employees should not cross while working on City time,
on City property, or using City resources[,]" and that he "learned
about that line and the kinds of activities that are and are not
permissible both from the Bozeman City Attorney, Greg Sullivan, as
well as from the experience afforded by many years in public life[.]"
Deputy Mayor Mehl stated he was involved in the City's education
efforts regarding the BPSC issue in his official capacity as deputy
Mayor, but never advocated for the measure in his official capacity or
at City events. Deputy Mayor Mehl also stated this time was properly
tracked and was reported on City of Bozeman financial reports.
Mehl further stated that, as a private citizen, he engaged in
support of the BPSC, specifically with the formation of the BCFS
City of Bozeman v. City of Bozeman
Page 7
committee. Mehl stated that he filed the committee's C-2 Statement
of Organization with COPP. Mehl denied any BCFS activities were
coordinated with the City, stating, "All time I devoted to advocacy with
BCFS was on my own time, using my own resources and except for
response to an occasional request for a yard sign I did not discuss any
BCFS activity with any City officials or employees[.]" Mehl stated that
no BCFS materials were stored on City of Bozeman property, and that
neither the yard signs or radio advertisements produced and paid for
by BCFS were discussed or coordinated with the City.
(Commissioner's Records.)
Finding of Fact No. 22: City Commissioner I-Ho Pomeroy also provided
an affidavit. Commissioner Pomeroy swore, "I understand the
difference between education regarding a ballot issue and advocating
for or against that issue. I have received advice from the Bozeman
City Attorney Greg Sullivan and Assistant City Attorney Karen
Stambaugh regarding where the line is[.]" Commissioner Pomeroy
stated she attended multiple educational events regarding the BPSC
in her official capacity as a City Commissioner, but never advocated
for its passage at these events. Commissioner Pomeroy stated this
time was properly tracked and was reported on City of Bozeman
financial reports. Commissioner Pomeroy also stated she did not
work or meet with The Nest Collective regarding the City's educational
efforts. Commissioner Pomeroy stated she was aware of the existence
of the BCFS committee, and contributed $100.00 to the committee in
addition to placing BCFS signs on her personal property and on the
property of the private business she owns. (Commissioner's Records.)
Finding of Fact No. 23: Greg Sullivan, the Bozeman City Attorney, also
provided his affidavit. Mr. Sullivan swore, "I worked closely with City
officials and employees to advise them on the requirements of the
Disclose Act. In addition, the Bozeman City Attorney's Office worked
closely with staff from the Commissioner's office" and ultimately
registered the City of Bozeman as an Incidental Political Committee,
as "the thresholds for reporting expenditures as required by the
Disclose Act were going to be exceeded" by the City's educational
activities regarding the BPSC. Mr. Sullivan stated that all time spent
by City of Bozeman employees or elected officials was properly tracked
and reported on financial reports. Mr. Sullivan also stated he
provided training to City of Bozeman employees and officials providing
guidance on the prohibition against use of public time, facilities, or
other resources to advocate for the BPSC. (Commissioner's Records.)
Attached to Mr. Sullivan's affidavit were copies of three email
messages exchanged between Mr. Sullivan and Commissioner Jeff
Mangan asking for guidance regarding proposed educational
City of Bozeman u. City of Bozeman
Page 8
materials on the BPSC put together by the City. With the first, dated
June 26, 2018, Mr. Sullivan provided an attachment detailing a
proposed BPSC presentation prepared by The Nest Collective;
Commissioner Mangan responded "Looks fine. Add an attribution
(Paid for by City of Bozeman, Jane Doe treasurer, + address)[.]" The
second email, dated August 31, 2018, Mr. Sullivan provided an
attachment detailing a proposed utility bill insert; Commissioner
Mangan responded, "It looks fine, Greg[.]" The final message, dated
September 28, 2018, Mr. Sullivan provided an attachment detailing a
proposed banner; Commissioner Mangan responded, "Add the
appropriate attribution/s as you've already noted. Looks fine tome[.]"
(Commissioner's Records.)
FindinLy of Fact No. 24: Andrea Surratt, Bozeman City Manager,
provided an affidavit as well. Ms. Surratt swore that, "Based on my
long experience in city government which includes involvement with
several ballot issues, and on guidance from Bozeman's City Attorney,
I understand the prohibition on advocating for a ballot issue or a
candidate while on City property, on City time, or utilizing City
resources[.]" Ms. Surratt stated she was heavily involved with the
City's education efforts regarding the BPSC in her official capacity as
City Manager, and that she worked directly with The Nest Collective
on all educational outreach, but that she did not advocate for the
BPSC at any meetings, gatherings, etc. Attached with Ms. Surratt's
affidavit was a copy of the signed, final contract between the City of
Bozeman and The Nest Collective, dated June 11, 2018. Ms. Surratt
stated she was aware of the existence of the BCFS committee and
contributed $150.00, but had no further involvement or
communications with the committee. (Commissioner's Records.)
Findine of Fact No. 25: An affidavit from Josh Waldo, the Bozeman
Fire Chief, was provided. Chief Waldo swore, "In my capacity as Fire
Chief, and for educational purposes, I gave public presentations
regarding facts and information" pertaining to the BPSC issue. Chief
Waldo stated this time was properly tracked and reported on City of
Bozeman financial reports. Chief Waldo further stated, "I understood
the distinction between education and advocacy regarding bond
issues ... I received training on the distinction from the Bozeman City
Attorney, Greg Sullivan[,]" and he never advocated for the BPSC while
acting in his official capacity. Chief Waldo appeared in an education
video prepared by The Nest Collective and stated he assisted with
writing the script for the video but had no further involvement with
The Nest Collective. Chief Waldo stated he was aware of the existence
of the BCFS committee but chose not to make any financial
contributions to the committee, and that "I received on my personal
email account an email from Terry Cunningham's personal mail
City of Bozeman v. City of Bozeman
Page 9
account discussing the possible production of a video by Bozeman
Citizens for Safety, requesting my participation[.]" Chief Waldo stated
that he declined to participate in the video and had no further
affiliation with BCFS beyond placing two BCFS yard signs on his
personal property. (Commissioner's Records.)
Finding of Fact No. 26: The City of Bozeman's December 6 response
included 57 pages of printed materials (pictures of fliers, buttons,
PowerPoint presentations, handouts, banners, t-shirts, and other
materials) paid for and distributed by the City as part of its
educational efforts regarding the BPSC, as well as a video featuring
Chief Crawford and Chief Waldo. The documents included a copy of
a Volunteer How-To Guide distributed to volunteers participating on
behalf of the City at educational events. The guide reminded these
volunteers: "When you're sitting at this table you are here as a
representative of the city[,]" and "what this means is that you cannot
`advocate' (i.e. `solicit support'). You can only `educate' ... The Q&A
included has examples of how to respond to questions that does not
cross the line into advocacy[.]" (Commissioner's Records.)
Finding of Fact No. 27: BCFS emailed a response to this Complaint to
COPP on December 7, 2018. This response stated that BCFS
designed, purchased, and distributed 150 yard signs as well as
produced a thirty second radio ad to support the BPSC issue, both
purchased using BCFS-raised funds. These activities, the response
stated, were not coordinated in any way with the City, being "acts of
advocacy ... created and actuated by Citizens without consultation
with the City or its Committee[.]" The response additionally stated
that no BCFS materials were ever stored on City of Bozeman property.
(Commissioner's Records.)
Finding of Fact No. 28: On December 18, 2018, BCFS Deputy
Treasurer/Bozeman Deputy Mayor Chris Mehl spoke with COPP via
telephone. Mr. Mehl clarified that he served as the main point of
contact between The Nest Collective and the BCFS ballot issue
committee regarding the design of the yard signs supporting the
BPSC. Mr. Mehl stated that communications between himself (on
behalf of BCFS) and The Nest Collective were almost exclusively
carried out via email, using his private Hotmail account. Copies of
emails between Mr. Mehl and The Nest Collective were also provided
to COPP. Mr. Mehl also stated that he did attend multiple meetings
between The Nest Collective and the City of Bozeman regarding the
City's educational BPSC campaign in his capacity as Deputy Mayor.
He stated that, to the best of his knowledge, Bozeman City Manager
Andrea Surratt was the main point of contact between the City and
The Nest Collective, and that she (in consultation with The Nest) is
City of Bozeman u. City of Bozeman
Page 10
the one who set the meeting agendas, worked closely with The Nest to
develop the educational campaign, etc. (Commissioner's Records.)
Finding of Fact No. 29: On December 18, 2018, BCFS Treasurer
Carson Taylor spoke with COPP via telephone. Mr. Taylor stated that,
as far as he was aware, BCFS Deputy Treasurer Mehl was the only
BCFS officer to communicate with The Nest Collective regarding the
design of the pro-BPSC yard signs. Treasurer Taylor also stated that,
beyond the yard sign design, he was not aware of BCFS
communicating with or approaching The Nest Collective for any
reason. Treasurer Taylor stated BCFS' only activities were the
purchase and design of yard signs and the radio ads, all reported on
C-6 reports as expenditures of the committee. (Commissioner's
Records.),
Findinz of Fact No. 30: On December 18, 2018, Commissioner
Mangan and COPP's Investigator spoke via telephone with Kendra
Callantine, Becky Edwards, and Robyn Egloff of The Nest Collective.
This discussion focused on several topics regarding The Nest
Collective's communications or collaborations with both the City and
BCFS. According to Nest employees: Chuck Winn, Andrea Surratt,
and Melody Miluer were the primary points of contact between The
Nest Collective and the City of Bozeman, and that NEST were the ones
in charge of setting the agenda at any meetings; Chris Mehl attended
approximately 75% of the meetings held between the City and The
Nest Collective, and while he participated by asking questions and
providing feedback, he did not organize the meetings, set the agenda
for what would be discussed, or serve as a direct point of contact
between The Nest Collective and the City; Mr. Mehl did, however, serve
as the primary point of contact between the BCFS committee and The
Nest Collective when Nest was contracted to handle design of BCFS's
pro-BPSC yard signs; all communications between The Nest Collective
and Mr. Mehl regarding the BCFS yard signs was handled via email,
using Mr. Mehl's personal Hotmail account; and that The Nest
Collective treated the City of Bozeman and BCFS as totally separate
clients (as per their normal arrangements), with separate client
folders to store billings, mockups of potential materials,
communications, etc. (Commissioner's Records.)
Finding of Fact No. 31: On December 19, 2018, City Attorney Sullivan
emailed COPP regarding use of the BPSC logo. Mr. Sullivan's email
stated that "sometime in mid-August of 2018 I [Sullivan] was asked
[by Mehl] whether a non-city entity such as a citizens group could use
the logo and materials created by the City in the citizens group's effort
to support the Bozeman Public Safety Center. I responded the City
does not restrict how others use materials produced by the City ... in
City of Bozeman u. City of Bozeman
Page 11
light of the fact the materials are in the public domain ... I responded
the City does not copyright or trademark its logos and there is,
therefore, no limitations on its fair use[.]" (Commissioner's Records.)
Finding of Fact No. 32: On December 20, 2018, the City provided a
signed affidavit from Chuck Winn, Assistant City Manager. Mr. Winn
swore, "Based on my thirty-four years in City government, which
includes involvement with several ballot issues, and on guidance from
Bozeman's City Attorney, I have a good understanding of the
prohibition on advocating for a ballot issue or a candidate while on
City property, on City time, or utilizing City resources[.]" Mr. Winn
further swore that he worked with The Nest Collective on
"implementing" the City's BPSC educational campaign but did not
advocate for the project at any event he attended in his employment
or professional capacity. Mr. Winn also stated that he was aware of
the existence of the BCFS committee and contributed $100.00 to the
committee but did not otherwise participate in any BPSC advocacy
activity. (Commissioner's Records.)
Finding of Fact No. 33: Bozeman City Controller, Brian LaMeres, also
provided an affidavit on December 20, 2018. Mr. LaMeres swore that
he helped track all City employee or elected official time spent working
on the BPSC educational campaign to ensure this time was included
on financial reports filed with COPP. He also swore that he gathered
"information on the City's spending during the applicable reporting
period on invoices from The Nest Collective and other outside vendors,
including whether those bills were still outstanding or had been
paid[.]" (Commissioner's Records.)
Finding of Fact No. 34: Melody Mileur, the City of Bozeman
Communications Coordinator, provided an affidavit as well.
Ms. Mileur swore, "Immediately upon starting my job with the City,
the City Manager tasked me with working to develop branding and
messaging" for the BPSC, and that she "began attending regular team
meetings with The Nest Collective ... and other staff members and
elected officials of the City who were also working on developing
educational presentations and other materials[.]" Ms. Mileur swore
she understood the difference between education and advocacy, and
that the City attorney advised her and others on the prohibition on
advocacy while on City time or property. Ms. Mileur stated she
regularly met with The Nest Collective to discuss educational
materials, and that she was responsible for posting materials on
social media platforms and the City's website, in consultation with the
City Attorney. (Commissioner's Records.)
City of Bozeman v. City of Bozeman
Page 12
Findine of Fact No. 35: On December 19, 2018, BCFS Officer Terry
Cunningham emailed COPP a copy of the script used in the
committee's radio ads, as well as an audio copy of the ads.
Mr. Cunningham also stated all email correspondence pertaining to
the ad was carried out on his personal email account (and provided
representative emails from that account), and that the script for the
ad was typed up on his personal computer. The ad stated (in full):
Why should you vote "yes" for the Bozeman Public Safety Center?
Bozeman's police force is in an unsafe, cramped facility that won't survive a
seismic event.
Fire station #1 is also inadequate and overcrowded.
Our municipal courts don't provide proper security for judges and crime
victims.
Voting yes for the Bozeman Public Safety Center will allow our first
responders to keep the community safe. One facility, built on land the city
already owns, is an efficient solution for Bozeman's future.
Paid for by Bozeman Citizens for Safety.
(Commissioner's Records.)
Finding of Fact No. 36: A review of Bozeman City Commission minutes
and meeting video establish that the issue of a local public safety
center was discussed or options formally adopted on six City of
Bozeman City Commission meeting agendas: November 13, 2017;
December 15, 2017; January 22, 2018; April 23, 2018; May 7, 2018;
and July 23, 2018, when the Commission passed a resolution
adopting Resolution 4936, submitting the 36.9 million bond issue to
the electorate. (Commissioner's Records.)
Findinsz of Fact No. 37: The COPP provided a copy of the campaign
finance complaint to the parties in the Koopman lawsuit and invited
them to provide additional information. While the response submitted
addressed their position on the campaign finance complaint, no
additional evidence or information was provided. (Commissioner's
Records.)
BACKGROUND
Following a public presentation of Gallatin's County's Law and Justice
Center feasibility study at the November 13, 2017 City of Bozeman Commission
meeting, the Bozeman City Commission set into motion a series of public
City of Bozeman v. City of Bozeman
Page 13
meetings that would ultimately lead to a July 23, 2018 adoption of a resolution
formally "submitting to the qualified electors of the [City] the question of issuing
general obligation bonds for [the BPSC]" (FOF Nos. 2, 36).
Meanwhile, Commissioner Mangan participated in a May 10, 2018,
presentation to the Montana League of Cities and Towns focusing on
requirements that may be placed on local governments by the 2015 Montana
Disclose Act. COPP routinely provides guidance and educational materials to all
candidates, committees, and the public upon request and the League had invited
the Commissioner to present as part of a panel that included Bozeman City
Attorney Greg Sullivan and a Deputy City Attorney from Great Falls.3 Following
the presentation, Mr. Sullivan sought guidance from Commissioner Mangan and
COPP regarding a potential bond measure that was expected to be placed on the
November 2018 general election ballot. COPP provided information to
Mr. Sullivan that including filing as an incidental committee, guidance on
electioneering communications and election communications, recommendations
on the maintenance and reporting of staff time records involved in the
development and presentation of electioneering communications and related
reportable expenses.
The Koopman lawsuit, filed November 19, 2018,4 asserts that, absent
advocacy activity, the City of Bozeman would not have been required to file as a
political committee with COPP. This district court complaint contends, amongst
3 The presentation was held in Billings, MT.
4 As noted above, the City's COPP complaint incorporated, and attached, a copy of the
Koopman district court complaint.
City of Bozeman v. City of Bozeman
Page 14
various allegations, "[t]he fact that the City filed as a political committee is one
example demonstrating that they were actively urging voters to support the
bond[,]" and "political committees support (or oppose) elections, by legal
definition (MCA § 13-1-101(7), (23) (31)(a))." (Cmplt., at 5.)
That contention is only partially correct. The Commissioner examines
Mont. Code Ann § 13-1-101(31), where a definition of a political committee is
found:
(a) "Political committee" means a combination of two or more
individuals or a person other than an individual who receives a
contribution or makes an expenditure:
(i) to support or oppose a candidate or a committee organized to
support or oppose a candidate or a petition for nomination;
(ii) to support or oppose a ballot issue or a committee organized
to support or oppose a ballot issue; or
(iii) to prepare or disseminate an election communication, an
electioneering communication, or an independent expenditure.
(b) Political committees include ballot issue committees, incidental
committees, independent committees, and political party
committees.
(c) A candidate and the candidate's treasurer do not constitute a
political committee.
(d) A political committee is not formed when a combination of two
or more individuals or a person other than an individual makes an
election communication, an electioneering communication, or an
independent expenditure of $250 or less.
Of the four distinct types of political committees (id., (b)), three types
(independent, ballot issue, and political party) are clearly defined as inherently
"supporting" or "opposing" candidates or ballot issues up for election (id., (a)).
Incidental committees, however, are separate and distinct in this regard. Defined
under Mont. Code Ann. §13-1-101(23)(a), incidental committees are not formed
exclusively to support or oppose candidates or ballot issues, but rather become
"incidentally" involved in an election by receiving a contribution or making an
City of Bozeman v. City of Bozeman
Page 15
expenditure. Incidental committees may support or oppose candidates or ballot
issues; however, a group may become an incidental committee under Montana
law without supporting or opposing anything.
By definition, support or opposition by itself is not the only trigger for
required registration with COPP. The preparation and/or dissemination of
electioneering communications meeting or exceeding a threshold of $250.00 by
a person other than an individual would qualify as an incidental political
committee, including local governments. Id., at (31)(d). As defined by Mont.
Code Ann. § 13-1-101(16):
(a) "Electioneering communication" means a paid communication
that is publicly distributed by radio, television, cable, satellite,
internet website, newspaper, periodical, billboard, mail, or any
other distribution of printed materials, that is made within 60 days
of the initiation of voting in an election, that does not support or
oppose a candidate or ballot issue, that can be received by more
than 100 recipients in the district voting on the candidate or ballot
issue, and that:
(i) refers to one or more clearly identified candidates in that
election;
(ii) depicts the name, image, likeness, or voice of one or more
clearly identified candidates in that election; or
(iii) refers to a political party, ballot issue, or other question
submitted to the voters in that election
(Emphasis supplied.) In this matter, absentee ballots were first mailed out in
Gallatin County on October 12, 2018 (FOF No. 1). Any City of Bozeman paid
public material or advertisements (including the costs of producing the
communication) clearly mentioning the BPSC ballot issue which were produced
or distributed after August 13, 2018 (id.) would have qualified as electioneering
communication expenditures.
City of Bozeman u. City of Bozeman
Page 16
The record demonstrates that just such electioneering communications
existed: The City of Bozeman produced materials specifically referencing the
BPSC ballot issue after August 13, 2018 that fall under the definition quoted
above which, cumulatively, cost $250.00 or more to produce and distribute.5
The electioneering communications meant the City was required to file as an
incidental committee. Mont. Code Ann. §§ 13-1-101(16), (23), (31)(d). The City
of Bozeman did so on June 22, 2018, stating as its purpose to "inform public of
impact of passage or failure of Bozeman Public Safety Center ballot issue on City
operations" (FOF No. 3), and then filed its initial committee finance report on
August 8, 2018 (FOF No. 4). The City subsequently filed C-4 committee finance
reports disclosing the City's expenditure activities on October 2, October 25, and
November 21, 2018 (FOF Nos. 7, 10, 11, 15).
The City recognized that its activity, while educational in nature, would
require registration with COPP as an incidental political committee, and filed all
necessary registration and financial reports. Registration as an incidental
committee was proper as the City became "involved" in an election but was not
a committee formed to support or oppose any specific candidates or ballot issues.
In other words, the contention in the Koopman lawsuit that political committees
"support (or oppose) elections, by legal definition[,]" is only partially true.
The Koopman district court complaint also references a ballot issue
committee, Bozeman Citizens for Safety (BCFS). BCFS is a separate entity not
5 As evidenced by the City of Bozeman incidental committee's first reported debt to "The Nest
Collective" on June 30, 2018. (See City of Bozeman C-4 (Aug. 8, 2018) (summarized in FOF
No. 4).)
City of Bozeman u. City of Bozeman
Page 17
associated with the City of Bozeman; BCFS filed with COPP as a ballot issue
committee on October 5, 2018 and filed its initial committee finance report on
the same day (FOF Nos. 8, 10).
DISCUSSION
The campaign finance complaint alleges6 the City of Bozeman advocated
(supported) the passage of the Bozeman Public Safety Center ballot issue, that
city officials, elected officials, and city employees used public time and resources
to support the measure, and that the City coordinated with a ballot issue
committee to support the passage of the ballot measure. The Commissioner
examines each of these allegations.
#1. Did the City of Bozeman's "Educational Campaign" and all
associated "educational" materials actually advocate for the passage
of the BPSC bond issue?
Within the Koopman district court complaint are allegations that the City
of Bozeman, through its employees and elected officials, violated state law by
waging a promotional campaign disguised as educational activities. In
particular, Koopman and Johnson contend that materials produced and
distributed by the City regarding the BPSC "were the functional equivalent of
advocacy.... Any person reading, or hearing, the message would clearly know
they were being urged to vote in favor of the bond[.]" (Cmplt., at 6.) By using
key phrases such as "Bozeman is Safe. Let's Keep it that way[,]" and "Vote
November 6th" on its materials, the Koopman complaint asserts that the City
6 As noted in the opening, the City incorporated by reference the "entirety the Complaint filed
in the referenced civil action, for the Commissioner's review[.]"
City of Bozeman v. City of Bozeman
Page 18
crossed the line from educational or informational activity into issue advocacy,
activity that is prohibited under Mont. Code Ann. § 13-35-226(4).
Section 13-35-226(4), Mont. Code Ann., prohibits public employees from
supporting or opposing candidates or ballot issues up for election while at their
place of employment or on the job, stating in relevant part, "A public employee
may not solicit support for or opposition to any political committee, ..., or the
passage of a ballot issue while on the job or at the place of employment." This
statute makes clear that the City's employees could not use City time, resources,
or equipment to advocate for passage of the BPSC bond issue.
To determine if the City's materials crossed the line from education to
advocacy, they must be reviewed, and their content scrutinized. While Montana
law does not define advocacy, it does define "support" and "oppose":
"Support or oppose", including any variations of the term, means:
(a) using express words, including but not limited to "vote",
"oppose", "support", "elect", "defeat", or "reject", that call for the
nomination, election, or defeat of one or more clearly identified
candidates, the election or defeat of one or more political parties,
or the passage or defeat of one or more ballot issues submitted to
voters in an election; or
(b) otherwise referring to or depicting one or more clearly
identified candidates, political parties, or ballot issues in a manner
that is susceptible of no reasonable interpretation other than as a
call for the nomination, election, or defeat of the candidate in an
election, the election or defeat of the political party, or the passage
or defeat of the ballot issue or other question submitted to the
voters in an election.
Mont. Code Ann. §13-1-101(50). As presented or otherwise produced, no official
City of Bozeman material (see FOF No. 26) used the language set out in
subsection (a) in reference to the BPSC ballot issue. Thus, the question is
City of Bozeman v. City of Bozeman
Page 19
whether the content of the City's materials can be reasonably interpreted as
anything other than a call for passage of the BPSC?
In response to direct queries from the City of Bozeman (FOF No. 23), this
test has already been applied on three occasions by the Commissioner. In each
query, the City sought guidance from COPP in the determination of whether or
not material presented would be considered an electioneering communication
and if, in the estimation of the Commissioner, it would advocate for passage of
the BPSC. These reviews suggested that, in the Commissioner's estimation, the
proposed materials were indeed potential electioneering communications (id.) as
they did not appear to support the BPSC ballot issue though they clearly referred
to it. Mont. Code Ann. § 13-1-101(16)(a)(iii). If the materials had appeared to
support the ballot issue, the Commissioner would have provided additional
guidance to Mr. Sullivan.
As part of the investigation, COPP reviewed all of the documentary
materials provided with the City's official response (FOR No. 26), as well as
viewed a provided YouTube video. The Koopman district court complaint
suggested the material provided to the public by the City was advocacy, claiming
terms such as "keep," "solution," "needs," "now," and "vote on November 6" were
indicative of an advocacy campaign. (Cmplt., p. 20 ¶58-60.) The district court
complaint also cited the directional use of an "arrow pointing" to "Bozeman
Public Safety Center" along with the use of the word "Vote" constituted expressed
advocacy. (Cmplt., pp. 13, 18, ¶¶60,98.) In its response to the campaign finance
complaint, the City contends the "information contained in the materials is
City of Bozeman v. City of Bozeman
Page 20
susceptible to more than one interpretation, and therefore is not the functional
equivalent of express advocacy[.]" The Commissioner further examined the
communications to determine if, in the view of COPP, they met the definition of
an election communication or electioneering communication.?
While Montana's Disclose Act was not in effect until October of 2015,8 the
issue of advocacy has been addressed by numerous prior COPP decisions. See
e.g., Juve v. Roosevelt County Commissioners, COPP 2014-CFP-063; In Re Griffin
and Lewis and Clark County, Nov. 19, 2009 (Commissioner Unsworth). The
Griffin decision reviewed two advertisements where a county encouraged a vote
on a bond issue: the "narrative ad" which "urged the reader to `vote November 7
on the Road Improvement Mill Levy[,]"' and a so-called "block ad" which
"concluded with two statements: `Your vote is your voice! Vote November 7,
2006."' Griffin, at 6. The Commissioner held:
Although each ad explained and provided justification for the
county's request for the mill levy, neither ad expressly advocated
for the passage of the mill levy.
Like the City of Bozeman's materials, the ads in Griffin used "vote" language or
highlighted the importance of voter participation ("your vote is your voice"). The
City's communications also contain common elements such as identification of
the BPSC and the BPSC logo, utilized a voter participation call to action (such as
"make your voice heard") or contained a statement of need or concern (such as
7 Regardless of classification as either an election or electioneering communication, the City
of Bozeman would still be responsible for reporting the expenditure. Mont. Code Ann. §§ 13-1-
101(18), 13-37-225, 13-37-232.
8 The 2015 Montana Disclose Act added the definition of an "electioneering communication."
Mont. Code Ann. § 13-1-101, Compiler's Comments.
City of Bozeman v. City of Bozeman
Page 21
"keep Bozeman safe"), and included the city website, bozeman.net, where
additional information was available to assist a voter in making an informed
decision. The Commissioner's investigation did not reveal any communication
or material from the City of Bozeman which called for the election or defeat of
the ballot issue.
Asking a citizen to "vote" is neither a call to support or oppose, but rather
a call to participate by casting a vote. The citizen can also choose not to vote or
participate in the election. The same can be applied to other terms identified by
the Koopman district court complaint: a voter can choose to keep or not keep;
can determine if an issue is a solution, or not a solution; determine if an issue
is a need or is not a need; and so on. Statements such as "Let's Keep Bozeman
Safe" encourage discussion and debate on a local issue; for example, Gallatin
County Attorney Marty Lambert and Gallatin County Sheriff Brian Gootkin both
publicly provided an alternate viewpoint, stating "safety is not going to be
enhanced. It's going to be harmed[,]"9 and that"separating police officers ... does
not make you safer; it actually does the opposite[.]"lo
Finally, the Koopman district court complaint alleged the use of an arrow
was a directional symbol pointing to "Vote Nov. 6," and therefore constituted
express advocacy. (Cmplt., at 13, ¶60.) In reviewing the materials, the Koopman
allegation appears to be referring to the design of the background/s that is
9 Gallatin County Attorney Marty Lambert, Letter to the Editor, Bozeman Daily Chronicle,
October 18, 2018.
io Gallatin County Sheriff Brian Gootkin, Letter to the Editor, Bozeman Daily Chronicle,
October 15, 2018.
City of Bozeman v. City of Bozeman
Page 22
consistent across numerous City of Bozeman materials and communications,
including the background design of the City of Bozeman's website, including the
site's homepage.11 Even assuming the background was indeed meant as an
arrow, the act of pointing to "vote" does not in itself indicate anything other than
the act to vote. If the Koopman district court complaint is suggesting a form of
subliminal messaging, the majority, if not all, of the "arrows" appear to be
pointing downward. One could just as easily suggest it was meant to "vote down"
the measure.
In reviewing all of the included material, the Koopman district court
complaint, the response by the City, and all of the available records, the
Commissioner determines that no City of Bozeman BPSC materials had content
materially different from those previously reviewed at the request of Mr. Sullivan.
The reviewed BPSC materials are classified as electioneering communications,
assuming they met the reach (received by more than 100 recipients in the
district), were utilized after August 13, 2018, and were paid (FOF No. 26). As
electioneering communications, these materials cannot be interpreted as
advocating for the BPSC measure but instead serve as educational material
meant to inform Bozeman voters.
The City made a large scale, good-faith effort to ensure all materials did
not elicit support or opposition. Subsequent COPP reviews of all BPSC materials
produced by the City have determined those materials would be considered
electioneering communications that did not advocate for or against the BPSC.
ii https://www.bozeman.net/home.
City of Bozeman u. City of Bozeman
Page 23
Additionally, numerous affidavits referenced City Attorney Sullivan's training for
employee and elected official to ensure such persons did not use public time,
facilities, equipment, or resources to support or oppose the measure (FOF Nos.
17-25, 32-34).
There is insufficient evidence to conclude the City engaged in an advocacy
program urging support for the BPSC issue using public time, resources, or
equipment to produce and distribute election communications. The allegation
is hereby dismissed.
#2. Did the City of Bozeman, its elected officials, or employees utilize
public time, resources, or other materials to advocate for passage of
the BPSC beyond the City-sanctioned educational campaign?
The Koopman district court complaint also alleges the City of Bozeman,
again through its elected officials and employees, utilized public time, resources,
and other materials to urge support for the BPSC.
The complaint referenced the City's inclusion of "staff time" on C-4
financial reports filed with COPP to conclude that "the Defendants...used public
funds and public resources to support passing the bond[.]" (Cmplt., at 8, ¶30.)
The materials produced and distributed by the City were electioneering
communications that do not support or oppose the ballot issue (supra, at Issue
#1), and the costs of such electioneering communications are required to be
reported to COPP. Mont. Code Ann. § 13-37-225. Such costs include
"expenditure[s] for ... salaries[.]" Id., § 13-37-232(2)(b); see also Admin. R. Mont.
44.11.202(6), 203(2)(b). The requirement for political committees to report staff
time on financial reports is well established. Daubert v. Montanans for Clean
City of Bozeman v. City of Bozeman
Page 24
Water, February 27, 1997 (Commissioner Argenbright); Heffernan v. Montana
Chamber of Commerce, June 2000 (Commissioner Argenbright); Harrington v.
Cap the Rate, July 3, 2012 (Commissioner Murray); Fisher V. MT Assoc.
Realtors/Realtors for Better Gov't, COPP 2017-CFP-002, at 3-4. The City of
Bozeman followed Montana campaign finance reporting requirements by timely,
properly, and thoroughly reporting expenditures, including time of City
personnel involved in those activities.
The Commissioner now examines the particular actions and activities of
City of Bozeman employees.12 As noted above, any use of public time, resources,
or other, related materials by City employees while on the job, or otherwise acting
in their official capacity, meant to promote the BPSC could be a violation of Mont.
Code Ann. § 13-35-226(4).
The City of Bozeman made it clear to its employees the prohibitions on
advocating for the success or failure of the BPSC ballot issue (FOF Nos. 17-22,
24-25, 32-34). The City took these prohibitions seriously (id.). Bozeman City
Attorney Greg Sullivan provided trainings touching on educational versus
advocacy efforts, and what activity was and was not allowed, to all City of
Bozeman officials or employees involved with the BPSC effort (FOF No. 23).
Additionally, the City provided a "Volunteer How-To" form to individuals
volunteering for the City at educational gatherings (FOF No. 26). The form
explained that all volunteers were serving as representatives of the City of
12 The analysis here is focused on the alleged conduct of the City employees (and not elected
City officials) as the prohibitions of Mont. Code Ann. § 13-35-226(4) applies only to public
employees. (See also infra, at "1. Areas of Limitation" (further explaining distinction).)
City of Bozeman v. City of Bozeman
Page 25
Bozeman and were limited to providing educational materials or other
information regarding the BPSC and repeatedly stated that advocating for the
BPSC was not allowable in such a setting, and reminding that all outreach was
to be educational only (id.). The City also provided affidavits from several City
employees involved, or alleged to have been involved in key aspects of the bond
matter, and each employee attested that they did not promote, support, or
advocate for the BPSC while acting in their official capacity (FOF Nos. 17-22, 24-
25). Statements from additional employees expressly denied that any advocacy
activity occurred while on City time or on City property (FOF No. 32-34).
While City employees may have personally supported or advocated for
passage of the BPSC in some fashion, in each instance the employee attested
that their efforts were limited to and carried out in their capacity as citizens, not
employees, and any advocacy activities were carried out off work hours, using
their own time, money, or equipment (FOF Nos. 24, 25, 32). This distinction is
important because Mont. Code Ann. § 13-35-226(4) "does not restrict the right
of a public employee to...express personal political views[.]" As long as the
employee was not operating in an official employment capacity, officially
representing the City of Bozeman, or otherwise utilizing City time or resources,
the individuals were free to express their personal opinion or position regarding
the BPSC and advocate for its passage or failure as they saw fit. The Koopman
district court complaint contains neither factual evidence nor specific examples
refuting the sworn statements of these employees; neither was any such evidence
uncovered as a result of COPP's investigation. The Commissioner therefore
City of Bozeman v. City of Bozeman
Page 26
determines the employee's BPSC advocacy activities occurred solely in
individuals'personal capacities and were allowable under Mont. Code Ann. § 13-
35-226(4).
Taken together, it becomes clear that the City of Bozeman and its
employees engaged in a collective effort to limit official BPSC activities to
educational only. Any advocacy efforts undertaken by individuals who were also
employed by the City of Bozeman were done on their own time, utilizing their
own private resources, and carried out in their personal, not professional,
capacity. The allegations of City employees using public time, resources, or other
materials to advocate for the BPSC issue are hereby dismissed.
1. Areas of Limitation
Within the Koopman district court complaint, there are repeated references
to Mont. Code Ann. § 2-2-121, the statute regarding the rules of conduct for
public officers and public employees. Koopman and Johnson argue the law was
routinely violated by the City of Bozeman, its employees, and elected officials to
advocate for passage of the BPSC. (See e.g., Cmplt., at 14.)
While Mont. Code Ann. § 2-2-121(3) does prevent elected officials or public
employees from using public time, resources, or other materials to advocate for
or against the election or nomination of a candidate or ballot issue, the specific
statute referenced falls under Montana's Code of Ethics rather than campaign
financial law (as does all of Chapter 2). As the City of Bozeman is a local
government entity, Mont. Code Ann. § 2-2-144 clearly assigns the enforcement
of these prohibitions to the City of Bozeman's Board of Ethics, not the
City of Bozeman v. City of Bozeman
Page 27
Commissioner of Political Practices. Compare id. with Mont. Code Ann. § 2-2-
136 (enforcement for state officers, legislators, and state employees). Any alleged
breaches of Montana's Code of Ethics by the City's elected officials or employees
would need to be presented to the City of Bozeman's Board of Ethics.
Further, COPP's jurisdiction under Mont. Code Ann. § 13-35-226(4) is
limited to City of Bozeman employees, not its elected officials. The statue clearly
references "a public employee" but makes no mention of "public officers," such
as an elected official. These terms are separately defined: a "public employee" is
"any temporary or permanent employee of a local government," as distinguished
from a "public officer" which is "any elected officer of a local government." Id.,
at § 2-2-102(7)(b), (8)(a). Thus, the Commissioner finds the provisions of Mont.
Code Ann. §13-35-226(4) do not apply to any City of Bozeman elected officials
identified by the Koopman complaint.
#3. Did Bozeman Citizens for Safety coordinate its BPSC advocacy
activities with the City of Bozeman?
A third allegation made by the Koopman district court complaint contends
that the City of Bozeman, through its employees and elected officials,
coordinated activities with a ballot issue committee, Bozeman Citizens for Safety
(BCFS), in an effort to support the passage of the bond. Koopman and Johnson
contend that the City, by default, coordinated with BCFS to support the City's
education campaign because the City and BCFS engaged a common vendor to
provide services and because City elected officials were listed as officers of BCFS.
"To illustrate[,]" the complainants write, "the City paid Nest Collective (Nest)
thousands of dollars for messaging, a logo and graphic design. BCFS paid Nest
City of Bozeman v. City of Bozeman
Page 28
just over $100.00. This alone establishes that the City supported BCFS[.]"
(Cmplt., at 3.)
As an initial matter it must be remembered that coordination between
political committees is not prohibited; rather, if coordination occurs it must be
reported. There must first, though, be coordination which means:
made in cooperation with, in consultation with, at the request of,
or with the express prior consent of a candidate or political
committee or an agent of a candidate or political committee.
Mont. Code Ann. § 13-1-101(10). Simply put, activities must be discussed,
planned, or otherwise authorized between two or more individual candidates or
committees to be considered coordination. Rule 44.11.602, ARM provides
additional guidance when examining this allegation.
The fact that Mehl and Cunningham were elected City officials who were
also, privately, officers of a ballot issue committee does not inherently prove that
BCFS (or the ballot issue itself) was supported by the City, nor that any
coordination or coordinated activities occurred.
BCFS filed a C-2 Statement of Organization with COPP as a ballot issue
committee with the stated purpose to support the BPSC (FOF No. 8). BCFS listed
Bozeman elected officials Chris Mehl and Terry Cunningham as committee
officers (id.). While communications made by or through an agent in the course
of their involvement in a committee is one factor that can indicate coordination,
the existence of"personal or professional relationships" does not itself establish
coordination. Admin. R. Mont. 44.11.601(2)(b), (4)(a).
City of Bozeman v. City of Bozeman
Page 29
The City of Bozeman reported expenses in total of $99,648.00, both
expenditures and in-kind contributions towards its efforts13. By comparison
BCFS spent a total of$1,455.04 on its efforts,14 which included expenditures for
two separate election communications: 150 yard signs and 11 radio ads (FOF
Nos. 27, 29). As to the yard signs, the reports reflect payment of about $100 to
The Nest Collective as a paid vendor for the design of yard signs on October 10,
2018 (FOF No. 12). The Nest Collective, meanwhile, entered into a Professional
Services Agreement with the City of Bozeman (FOF No. 6), which lasted from
June 11 through November 6, 2018. Retaining the aid services of the same
vendor (here, The Nest Collective) is one factor that can reflect coordination.
Admin. R. Mont. 44.11.602(2)(c).
The City's representative for any authorization or approvals under its
Agreement with Nest was Chuck Winn, Assistant City Manager, who could
designate that authority as needed. The City also identified 16 city employees
and officials who worked with Nest in some capacity on the education effort (FOF
No. 16). Of these, only three provided authorizations of work and work product
for the City's education effort: Mr. Winn, Andrea Surratt, City Manager, and
Melody Mileur, Communication Coordinator (FOF No. 30). In other words,
neither Mehl nor Cunningham were Nest's points of contact for the City, nor did
either official have authority to approve Nest's work for the City. The remaining
13 Total of City of Bozeman incidental committee reported expenditures and in-kind
contributions on its 2018 campaign finance reports
14 See Bozeman Citizens for Safety ballot issue committee's total reported expenditures per
2018 campaign finance reports.
City of Bozeman v. City of Bozeman
Page 30
13 employees and officials would attend meetings, discuss ideas, messaging,
etc.; officials among this group of 13 was Deputy Mayor Mehl, and Mehl
apparently attended 75% of such meetings. Thus, while Mr. Mehl participated
in City meetings with Nest, he had no authority to influence the City's decisions
the way an agent would—ultimately, this fact weighs neither for or against
coordination. Admin. R. Mont. 44.11.602(2)(a), (e).
Mr. Mehl was, however, also an Officer of the BCFS ballot issue committee
(FOF No. 8), and he was the main contact with regard to Nest's design of a yard
sign for the BCFS ballot issue committee, which contact occurred almost
exclusively by email (FOF No. 30). So while Mr. Mehl was not an agent of the
City with regard to Nest's work, he was certainly BCFS's agent. Id. COPP thus
carefully reviewed these email discussions from Mr. Mehl's private Hotmail email
account (FOF No. 21, 28, 30). That review yielded no evidence of coordination
such as the sharing of information, content, timing, etc. Admin. R. Mont.
44.11.602(1), (2)(a)-(b). Nor is there evidence that Mehl received or gave any
information to the City or Nest regarding BCFS's yard sign or radio ad (FOF Nos.
28, 30). Id. These facts thus weigh significantly against coordination. Further,
while the City and BCFS both used Nest for design, BCFS stated it "engaged in
no communications with the City about either of these decisions or expenses[.]"
Rather, the committee asserted that BCFS, and BCFS alone, was responsible for
engaging Nest, and that this activity was carried out independent of the City, the
City's personnel, or the City's educational efforts. Neither Mehl nor Cunningham
had the authority to bind or act on behalf of the City of Bozeman either
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individually or together. Thus, in this instance, the fact of having used the same
vendor, in the absence of any other indicia of coordination, is insufficient to find
a violation.
The Koopman district court complaint specifically alleges the use of the
Bozeman Public Safety Center logo on yard signs by the ballot issue committee
also provides evidence of coordination. (Cmplt., at 3, 10.) City Attorney Greg
Sullivan responded, in August 2018, to questions from Mehl about the use of
City of Bozeman education materials by outside entities and the use of the BPSC
logo (FOF No. 31). Mr. Sullivan explained that such materials, including the
logo, were in the public domain and the City does not copyright or trademark its
logos and there was no limitation on fair use (id.). While communications which
"replicate[d], reproduce[d], rebpulish[ed]... in whole or in substantial part, any
material designed, produced and paid for" by the City may indicate coordination
(Admin. R. Mont. 44.11.602(2)(d)), there is a specific exception for "statements,
images, or other information that is appropriated from a public source" (id., at
(3)(e)). Thus, the use of an uncopyrighted logo, available in the public domain
by the ballot issue committee is expressly not evidence of coordination. Id., at
(3)(e).
The second election communication of BCFS were the radio ads. While
Terry Cunningham was not among the City staff who met with Nest regarding
the City's BPSC educational campaign, he was involved in conceiving of,
recording, and distributing the BCFS'pro-BPSC radio ad (FOF Nos. 19, 35). The
radio ad did not reference Mr. Cunningham's elected title nor those of any other
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City of Bozeman elected officials who participated,15 nor did it reference the City
Commission (id., 35). In short, the script and other evidence fail to reveal any
information which might indicate coordination between BCFS and the City.
Admin. R. Mont. 44.11.602.
Having considered the various factors which might reflect coordination
(Admin. R. Mont. 44.11.602), the Commissioner finds no evidence to suggest
either Mehl or Cunningham coordinated the City's educational campaign with
BCFS' advocacy activities to enhance the ballot committee's pro-BPSC message.
To the contrary, all evidence suggests Mehl and Cunningham carried out BCFS
activities using personal accounts, time, and facilities, and that not only did
BCFS acted interpedently in its election communications, but the City also acted
independently in its electioneering communications. A review of 2018 City of
Bozeman commission meeting minutes could find no City vote or authorization
of support for the BCFS ballot issue committee, including sign or radio ad
expenditures. Affidavits provided by City personnel identified as primary
contacts for Nest expressly stated they did not coordinate with the BCFS. Nest
personnel maintained separate communications, design, and billing records,
and separate files were kept for both the City of Bozeman and the BCFS
committee (FOF No. 30). Affidavits of Mehl and Cunningham similarly attest
they did not coordination with the City (FOF Nos. 19, 21).
is While not at issue in the radio ad, referencing ones official title in itself is not improper.
51 A.G. Op. 1 (2005. McGrath).
City of Bozeman v. City of Bozeman
Page 33
Where evidence has been provided to corroborate the arguments made by
both the City of Bozeman and BCFS disputing coordination, the Koopman district
court complaint provided no such evidence to support its allegations, nor did it
provide additional material to support the allegations in response to this COPP
Complaint (FOF No. 37). These allegations thus rely on only the associations
between the City and BCFS. As established from the above analysis, the
associations mentioned do not themselves rise to the level of coordination, and
no evidence points to any coordinated activities occurring, and therefore the
allegation of coordination between the City of Bozeman and BCFS are hereby
dismissed.
CONCLUSION
The COPP Complaint contained three main allegations concerning the City
of Bozeman: that all BPSC materials produced and distributed by the City clearly
advocated for passage of the bond issue, that City employees used public time
and resources to advocate for passage of the BPSC, and that the City coordinated
activities with the BCFS ballot issue committee to advocate for the BPSC. From
the investigation into this matter, and as set out above, the Commissioner has
determined that the City's BPSC materials were electioneering communications,
not election communications, that no City employees used public time or
resources to advocate for the BPSC, and that the City did riot coordinate any
BPSC activities with the BCFS group. Based on the totality of available
documents, emails, interviews, committee financial reports, and other evidence,
the allegations are hereby dismissed.
City of Bozeman u. City of Bozeman
Page 34
DATED this )&day of January 2019.
J rey A.
Commissioner of Political Practices
Of the State of Montana
P.O. Box 202401
1209 8th Avenue
Helena, MT 59620
Phone: (406)-444-3919
City of Bozeman u. City of Bozeman
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