Summary — what happened
Between 2018 and 2025, a network of independent-expenditure committees moved more than $1.5 million through San Diego city-council and county-supervisor races, with the same development, apartment, and chamber-of-commerce interests recurring across committees that file as separate, independent operations. The flagship vehicle, Community Voices San Diego, was filed on 2018-05-06 as "Community Voices San Diego sponsored by The Lincoln Club of San Diego County"; five months later, on 2018-10-10, the Lincoln Club's name was dropped from the committee's title. E-465 It is run by former Lincoln Club executive Ryan Clumpner, who paid his own consulting firm $134,000+ from PAC funds, and in 2025 it spent $136,000 to support Vivian Moreno's county-supervisor bid. E-465 E-441 Its registered address — 525 B Street, Suite 1420 — is shared by ThreeSixty Public Strategies, the lobbying firm of Mayor Gloria's former communications director Rachel Laing, and by New San Diego PAC, founded by Gil Cabrera (former Ethics Commission chair, later Gloria's Airport Authority appointee). E-465 E-475 E-462
Two patterns recur. First, a fundraise-then-lobby sequence: Laing raised $23,298 for council member Jennifer Campbell, then ThreeSixty lobbied Campbell's office for developer New Urban West; the council approved that developer's 1,200-unit project 8-1 on 2021-09-14, and ThreeSixty ceased lobbying 16 days later. E-475 E-487 E-484 Second, a vote-then-reward sequence around Moreno: she received ~$18,000 from developer-connected lobbyists in her 2018 race (a figure attributed to an opponent's campaign consultant), cast the decisive 2019 vote that blocked the stronger inclusionary-housing proposal, was named Building Owners and Managers Association (BOMA) Public Official of the Year in January 2020, and in 2025 drew the $136,000 Community Voices effort plus ~$100,000 from Lincoln Club PAC co-chair David Malcolm. E-513 E-455 E-438 E-441
Every transaction is on the public record, and every step is legal. The committees' donor overlaps, the address sharing, and the timing sequences are not visible from any single filing — they require assembling corporate records, Cal-Access campaign finance, city lobbying disclosures (EC-603), and Ethics Commission Form 700s side by side. Inferred: the recurring donors and the fundraise/lobby/vote and vote/reward sequences form a coordinated-looking pattern, but no coordination in the FEC/FPPC legal sense (shared polling, scripts, or strategy) is documented, and no ethics or court finding has been issued (a characterization of the financials, not a legal finding).
Timeline
The Lincoln Club model precedes Community Voices. Over the prior decade the Lincoln Club of San Diego County ran a series of IE committees. Three cited here moved roughly $4.88M: "CPR for San Diego (Yes on B)" pension reform ($2,280,802), "San Diegans Against Government Waste (No On D)" ($462,908), and the club's main committee ($2,140,168).
Community Voices is formed under Lincoln Club sponsorship. The committee is filed as "Community Voices San Diego sponsored by The Lincoln Club of San Diego County."
Lincoln Club opposes Campbell in D2. The Lincoln Club funds a committee, "Public Integrity League OPPOSED to Jen Campbell," that spends $200,000 against Jennifer Campbell in the District 2 council race (6 transactions).
Moreno refunds illegal donations. During her 2018 District 8 council race, Moreno agrees to refund illegal contributions from two business entities — Kenamar CT Holdings ($250) and MC Express Trucking ($200). The same Union-Tribune report states she received ~$18,000 from lobbyists for corporations and developers, a figure the paper attributes to research by an opponent's campaign consultant.
The name change. "Sponsored by The Lincoln Club of San Diego County" is dropped from Community Voices' filing; the committee becomes simply "Community Voices San Diego." Former Lincoln Club executive Ryan Clumpner runs the PAC and is paid $134,000+ through his own consulting firm from PAC funds.
The decisive housing vote. Council President Georgette Gomez's inclusionary-housing proposal (set-aside at 50% of area median income) passes the council 5-4; Mayor Kevin Faulconer vetoes it. Overriding the veto requires six of nine votes. Moreno, the swing vote, votes no — the only Democrat to break ranks — and the override fails.
The revised version passes. A revised inclusionary-housing measure sets the threshold at 60% AMI (the level Moreno had advocated) and raises the in-lieu fee from $12.73 to $25 per square foot. The Building Industry Association (BIA) and the San Diego Regional Chamber of Commerce, which opposed the original, endorse the compromise. Moreno votes yes; it passes 7-2.
Moreno removed as committee chair. Gomez removes Moreno as chair of the Land Use and Housing Committee, leaving her chairing no committees.
BOMA award. The Building Owners and Managers Association of San Diego names Moreno its 2020 Public Official of the Year, citing "extraordinary leadership on commercial real estate issues and support for sound housing policy."
ThreeSixty's footprint reaches a second office. Laing, through ThreeSixty, donated $1,200 (the individual maximum) to Sean Elo-Rivera's 2020 council campaign.
Laing fundraises for Campbell. Rachel Laing hosts a June 2021 fundraiser raising $3,125 for Campbell; her total fundraising for Campbell across the cycle is $23,298.
ThreeSixty lobbies Campbell's office. ThreeSixty Public Strategies' EC-603 quarterly lobbying reports show the firm lobbied Campbell's office on behalf of developer New Urban West Inc., with contacts naming staffer Seamus Kennedy, Chief of Staff Venus Molina, and Campbell herself.
The 8-1 vote. The city council approves New Urban West's "The Trails at Carmel Mountain Ranch," a 1,200-unit development (180 units below 60% AMI), by 8-1; Marni von Wilpert casts the only no vote; Campbell votes yes.
Lobbying ceases. ThreeSixty's EC-603 records show it ceased lobbying — 16 days after the approval vote.
New San Diego PAC in D2. New San Diego PAC, founded by Gil Cabrera and filed as a "general purpose" committee, raised $261,000 total. Of $194,000 in expenditures, $171,154 (88%) went to attacking Lori Saldana and $8,550 to promoting Jennifer Campbell — a combined $179,704 on the single District 2 race. An ethics complaint was filed alleging the committee misrepresented its purpose; Cabrera confirmed to the OB Rag that he was founder and sole member.
The party pipeline. New San Diego PAC sent $15,000 to the San Diego County Democratic Party, which then sent mail pieces supporting Kent Lee in District 6; Lee's opponent Tommy Hough documented the chain. Separately, the Municipal Employees Association added $50,000 through an IE committee for Lee and the San Diego Police Officers Association added $16,000 to Lee's campaign.
The fleet's IE spending. San Diegans for Fairness raised $822,000+ (California Apartment Association $175,000, Sycuan $105,000, SD Chamber $85,000, BIA $25,000, Steve Cushman $25,000). Big City San Diego spent $141,000 (Monarch Housing / Sarah Kruer Jager $25,000+). California Progress for All raised $131,000+.
The reward. Moreno ran for county supervisor (District 1 special election) against Paloma Aguirre. Community Voices spent at least $136,000 to support Moreno and oppose Aguirre; David Malcolm, Lincoln Club PAC co-chair, donated ~$100,000 across committees backing Moreno; the BIA backed Moreno through its own IE super PAC.
The recurring interests (cross-committee)
The same industries appear across multiple committees that file as separate, independent operations. Each figure is itemized in the cited filing; the aggregation across committees is the inference (see Caveats).
- California Apartment Association — $175,000 to San Diegans for Fairness alone (one check = 152 maxed individual contributions). E-454 E-435
- Building Industry Association — $25,000 to San Diegans for Fairness, and a separate IE super PAC backing Moreno in 2025. E-454 E-441
- San Diego Regional Chamber of Commerce — $85,000 to San Diegans for Fairness; opposed the original inclusionary-housing proposal, endorsed the weakened version. E-454 E-511
- David Malcolm (Lincoln Club PAC co-chair) — ~$100,000 across committees in the 2025 Moreno race. E-441
- Sycuan — $105,000 to San Diegans for Fairness. E-454 E-435
- Steve Cushman — $25,000 to San Diegans for Fairness (the committee he chaired). E-454
Inferred: these are described as divisions of the same development/apartment/chamber industry covering multiple committees rather than independent unrelated actors — a characterization of the donor pattern, not a legal finding of coordination.
Two documented sequences
| Sequence | Actor | Steps (each cited below) | What is documented |
|---|---|---|---|
| Fundraise → lobby → vote | Rachel Laing / ThreeSixty | $23,298 raised for Campbell E-475 → lobbied Campbell's office for New Urban West, Q2–Q3 2021 E-487 → 8-1 approval 2021-09-14 E-484 → lobbying ceased 2021-09-30 E-487 | Each step is a separate public filing; the disclosure system links none of them. |
| Money → vote → reward | Vivian Moreno | ~$18K developer-lobbyist money 2018 (attributed) E-513 → decisive no vote Sep 2019 E-512E-455 → BOMA award Jan 2020 E-438 → $136K + ~$100K IE support 2025 E-441 | Documented dollars and dates; no agreement or quid pro quo is documented. |
Inferred: the ordering of these steps suggests access or return on contribution, but causation is not established and no ethics body or court has ruled on either sequence (not a legal finding).
The four filing systems
The facts above are split across four government databases that do not cross-reference one another. E-465
- Cal-Access / SD eFile — state and city campaign-finance reports (committee spending, donor names).
- City of San Diego efile (EC-603) — quarterly lobbying disclosures (which official a lobbyist contacted, for which client).
- California Secretary of State — corporate records (e.g., ThreeSixty's agent, New San Diego's founder).
- Ethics Commission (Form 700) — annual statements of economic interests (a lobbyist's client list).
Key players (callback index)
- Ryan Clumpner — former Lincoln Club executive; runs Community Voices PAC; paid his own firm $134,000+ from PAC funds.
- Rachel Laing — Mayor Gloria's former communications director; runs ThreeSixty Public Strategies at 525 B St Ste 1420; raised $23,298 for Campbell, then lobbied Campbell's office for a developer.
- Gil Cabrera — former Ethics Commission chair and Gloria's Airport Authority appointee; ThreeSixty corporate agent; founder and sole member of New San Diego PAC.
- David Malcolm — real-estate developer and Lincoln Club PAC co-chair; ~$100,000 across committees for Moreno in 2025.
- Vivian Moreno — District 8 council member; decisive 2019 no vote on inclusionary housing; BOMA 2020 honoree; subject of the $136,000 Community Voices effort in 2025.
- Jennifer Campbell — District 2 council member; Lincoln Club spent $200K against her in 2018; New San Diego PAC spent $179,704 across the D2 race in 2022 — mostly attacking her opponent ($171,154 against Saldana, $8,550 promoting Campbell).
Caveats
- Sharing a registered address (525 B Street, Suite 1420) does not prove coordination in the FEC/FPPC legal sense (shared polling, scripts, or strategic plans). 525 B Street is a large commercial building; no such coordination is documented. E-465
- Sponsored committees, name changes, and a manager paying his own firm are explicitly permitted under California law; no violation is alleged on those points. E-465
- IE spending is constitutionally protected (Citizens United) and is, by law, independent of the candidate. IE support does not require or imply a candidate's knowledge or consent. E-441
- The ~$18,000 in developer-lobbyist money to Moreno in 2018 originates with an opponent's campaign consultant as reported by the Union-Tribune; MathPolitics has not independently verified it. It is attributed to that source. E-513
- "General purpose" is a legal committee classification that does not require equal spending across races. An ethics complaint was filed against New San Diego PAC; no finding has been issued. E-461 E-462
- The combined "$1.5M+" and the per-industry totals aggregate figures from multiple, legally distinct committees and filings; the per-committee figures (San Diegans for Fairness $822K+, Big City SD $141K, CA Progress for All $131K+, Community Voices $136K, New San Diego $194K expenditures) are itemized in their cited sources.
- The San Diego County Grand Jury's findings on Development Impact Fee mismanagement (cited via DB) document a citywide infrastructure gap accumulated over ~35 years across multiple administrations; the report does not attribute that deficit to the committees in this brief, and neither does this brief.
Reference key
- E-377 Voice of San Diego, "Politics Report: A New IE," 2024-02-03. https://voiceofsandiego.org/2024/02/03/politics-report-roundup/
- E-435 San Diego Union-Tribune, "In final stretch, outside money pours into San Diego mayor and city attorney races," 2024-10-26. https://www.sandiegouniontribune.com/2024/10/26/in-final-stretch-outside-money-pours-into-san-diego-mayor-and-city-attorney-races/
- E-438 Times of San Diego, "Building Owners Honor Councilmember Vivian Moreno as Public Official of the Year," 2020-01-20. https://timesofsandiego.com/politics/2020/01/20/building-owners-honor-councilmember-vivian-moreno-as-public-official-of-the-year/
- E-441 Axios San Diego, "Major outside money flowing into San Diego County supervisor race," 2025-03-24. https://www.axios.com/local/san-diego/2025/03/24/san-diego-county-supervisor-special-election-outside-spending
- E-454 La Prensa San Diego, "PERSPECTIVE: Cushman Becomes Campaign Bagman for Gloria," 2024-10-20. https://laprensa.org/perspective-cushman-becomes-campaign-bagman-gloria
- E-455 San Diego Union-Tribune, "Moreno removed as head of key San Diego housing panel in wake of controversial vote," 2019-12-16. https://www.sandiegouniontribune.com/communities/san-diego/story/2019-12-16/moreno-removed-as-head-of-key-san-diego-housing-panel-in-wake-of-controversial-vote
- E-461 OB Rag, "Here's 2022 Donors to New San Diego PAC — Source of Attack Mailers Against Saldana," 2022-06-01. https://obrag.org/2022/06/heres-2022-donors-to-new-san-diego-pac-source-of-attack-mailers-against-lori-saldana/
- E-462 OB Rag, "Why Is Gil Cabrera — Airport Authority Chair and New San Diego Founder — Publishing Smear Mailers About Saldana?," 2022-05. https://obrag.org/2022/05/why-is-gil-cabrera-chairman-of-airport-authority-board-and-founder-of-new-san-diego-publishing-smear-mailers-about-lori-saldana/
- E-465 OB Rag, "Mayor Gloria Behind Saldana Attack Mailers," 2022-05-25. https://obrag.org/2022/05/mayor-gloria-behind-saldana-attack-mailers/
- E-475 OB Rag, "Developers' Insider Rachel Laing — Mayor's Communications Director — Raising Money for Jen Campbell," 2022-06-01. https://obrag.org/2022/06/developers-insider-rachel-laing-the-mayors-communications-director-has-been-raising-lots-of-money-for-jen-campbell/
- E-478 Tommy Hough Campaign, "Hough Beats Back $200,000 of Opponent Spending in D6 Primary," 2022-06-08. https://tommyhough.com/hough-beats-back-200000-of-opponents-spending-in-primary-success/
- E-484 San Diego Union-Tribune, "San Diego approves 1,200-home Carmel Mountain Ranch project on former golf course," 2021-09-17. https://www.sandiegouniontribune.com/news/politics/story/2021-09-17/san-diego-approved-1-200-home-carmel-mountain-ranch-project-on-former-golf-course-site
- E-487 City of San Diego efile, ThreeSixty Public Strategies EC-603 quarterly lobbying report (lobbied Campbell office for New Urban West Inc., Q2–Q3 2021), filed 2021-11-01. https://efile.sandiego.gov/pdfview?doc_public=Ext_d45926c2-8a55-4348-8003-d6862a50b06d&query=&start_date=2020-09-06T00:00:00.000Z&end_date=2021-11-01T00:00:00.000Z&return_url=public/search/lobbyist
- E-511 KPBS, "Second Time A Charm For New San Diego Affordable Housing Policy," 2019-12-10. https://www.kpbs.org/news/2019/dec/10/revised-inclusionary-affordable-housing-policy/
- E-512 Voice of San Diego, "Gomez Has a Big Choice to Make on Her No. 1 Policy Priority," 2019-09-25. https://voiceofsandiego.org/2019/09/25/gomez-has-a-big-choice-to-make-on-her-no-1-policy-priority/
- E-513 San Diego Union-Tribune, "Moreno will refund illegal business donations in San Diego council race," 2018-10-03. https://www.sandiegouniontribune.com/2018/10/03/moreno-will-refund-illegal-business-donations-in-san-diego-council-race/
- E-1391 SD Open Data / City Clerk, "Public Integrity League OPPOSED to Jen Campbell 2018" (Lincoln Club IE committee, 6 transactions, $200,000). https://seshat.datasd.org/election_committees_transactions/financial_support_2018_datasd.csv#1412378
- E-1602 SD Open Data / City Clerk, "San Diegans Against Government Waste (No On D)" (Lincoln Club committee, $462,908). https://seshat.datasd.org/election_committees_transactions/financial_support_2010_datasd.csv#1329881
- E-1610 SD Open Data / City Clerk, "Lincoln Club of SD County" main committee record ($2,140,168). https://seshat.datasd.org/election_committees_transactions/financial_support_2011_datasd.csv#831561
- E-1613 SD Open Data / City Clerk, "CPR for San Diego (Yes on B)" (Lincoln Club / pension reform, $2,280,802). https://seshat.datasd.org/election_committees_transactions/financial_support_2011_datasd.csv#1335733
- DB MathPolitics database connection/evidence IDs as cited in the full report
council-the-money-machine(e.g. C-116543 Laing→Elo-Rivera $1,200; C-2777 MEA $50K and C-2778 SDPOA $16K to Kent Lee; San Diego County Grand Jury 2024–2025 report "Never Been Challenged" on DIF mismanagement). → view in evidence search
Report #5 · The Council Files (part 1) · condensed AI fact sheet. Chronological; every claim cited; inferences flagged. Source: full report council-the-money-machine (Sections 1–8).
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