Summary — what happened
Between 2018 and 2026, San Diego's campaign-finance and disclosure systems recorded a series of facts that are individually public but were never assembled in one place. The San Diego Ethics Commission fined four officials a combined $18,200 — Jennifer Campbell $300 for two missing mailers SDUT-Campbell, Raul Campillo $2,200 for 2020 campaign-reporting violations SDUT-Campillo, Jesus Cardenas the $5,000 statutory maximum for a lobbying-disclosure violation SDUT-Cardenas, and Todd Gloria $10,500 for ten late behested-payment disclosures, some 679 days late Stip23-16. Over the same window the City Auditor reported that $155 million in contract spending across 2017–2023 and two mayoral administrations was altered late, retroactively, or without council approval Audit25-02 SDCA-Hanau; no fine was issued for that. Lobbyist Phil Rath was fined $5,000 by the FPPC and $11,000 by the Ethics Commission — $16,000 — for an Affirmed Housing conflict Rath-FPPC.
Gloria filed 36 of the 40 city Form 803 behested-payment disclosures submitted since January 2023, totaling $450,000+ DB SDUT-803; Sean Elo-Rivera filed zero across his 2020–2026 council tenure eFile-803. Much of Gloria's behested money was directed to For All of Us, a 501(c)(4) the Union-Tribune reported has no incorporation papers, no IRS determination letter, and no bylaws, operating through fiscal sponsor Mission Edge SDUT-FAOU. Gloria appointed Kelly Moden — CEO of cREate Development — chair of the Planning Commission in 2022; in January 2025 the council selected her firm for the $32.7 million 101 Ash Street redevelopment, and the Ethics Commission ruled no conflict because the project never went before the Planning Commission OBR-Ash-Jul OBR-Ash-Jan. The Downtown San Diego Partnership holds $13 million+ in city agreements while its PAC raised $173,124 and routed money to independent-expenditure committees active in council races DSDP-990 DSDP-PAC DB.
Each of these facts lives in a different government filing system — Cal-Access, efile.sandiego.gov, the Secretary of State, the Ethics Commission, and the City Clerk — maintained by different agencies on different schedules, with no system linking donor to PAC to candidate to contract to vote eFile-803 DSDP-PAC Audit25-02. Inferred: the brief characterizes this fragmentation as the mechanism that keeps the aggregate pattern invisible; that is a structural characterization, not a finding of intent or illegality.
Timeline
Rath FPPC fine. The FPPC fines lobbyist Phil Rath $5,000; with a separate $11,000 Ethics Commission fine for the same Affirmed Housing conflict, his total reaches $16,000. He retained his practice.
Laundering complaints rejected. The San Diego Ethics Commission rejects money-laundering complaints against Gloria and the county Democratic Party, ruling the conduct "permissible under state and local law."
Moden appointed. Mayor Gloria appoints Kelly Moden, CEO of cREate Development, as chair of the San Diego Planning Commission.
Planning Commission appointment dispute. When Gloria considers replacing Commissioner Matthew Boomhower, twelve pro-development groups (Circulate San Diego, Climate Action Campaign, Downtown San Diego Partnership, Regional Chamber, BIA, YIMBY Democrats) sign a joint memo urging Boomhower's reappointment; Gloria's proposed replacement is Farah Mahzari, director of government affairs at San Diego Land Lawyers.
For All of Us disclosure. The Union-Tribune reports that For All of Us — the 501(c)(4) receiving many of Gloria's behested payments — has no incorporation papers, no IRS determination letter, and no bylaws, and operates through fiscal sponsor Mission Edge. Its named board includes Gil Cabrera and Steve Cushman; named donors include Sudberry Properties, Manpower, and the Sycuan Band ($5,000 each), all city contractors.
Elliott Form 803. Mara Elliott reports a $100,000 Golden Door resort payment to the Your Safe Place Foundation, which supports a Family Justice Center program in the City Attorney's office; the foundation was listed as legally delinquent by the California Attorney General at the time.
Campillo fine. The Ethics Commission fines Raul Campillo $2,200 for 2020 council-race violations: maintaining two campaign checking accounts, failing to disclose six contributions over $100, and failing to report seventeen expenditures over $500.
Gloria behested fine (Stipulation 23-16). The Ethics Commission fines Gloria $10,500 for failing to timely file Form 803 disclosures for ten behested payments — $1,050 per violation; some filings were 679 days late against a 30-day requirement.
von Wilpert Form 803. Marni von Wilpert reports three $5,000 behested payments to Equality California — from Waste Management (city trash hauler), Falck (five-year ambulance contract), and the San Diego Zoo Wildlife Alliance (Balboa Park, city land).
Contract audit (Report 25-02). City Auditor Andy Hanau publishes a performance audit of contract management covering 2017–2023 and two administrations (Faulconer, Gloria). Findings: 42% of contract alterations — $155 million — were brought to council late, retroactively, or not at all; 13% ($15 million) received no council approval; average unapproved amendment $856,000; a $1.6M water-treatment contract rose to $3M and a $14M Herc Rentals contract rose to $32.5M without council votes. The auditor described the unauthorized spending as "against the law"; the report attributed the cause to "unclear roles and responsibilities" and "unwritten policies."
101 Ash selection. The council selects Moden's firm (Create Dev LLC with partner MRK Partners) in closed session for the 101 Ash Street redevelopment: 253 affordable apartments, 25,000 sq ft retail, 4,000 sq ft childcare, a sixty-year lease, and a $32.7 million developer fee.
Council criticism of vetoes. Council members Kent Lee, Sean Elo-Rivera, Henry Foster III, and Joe LaCava criticize Gloria for $5 million in community-service budget vetoes while his administration allowed $155 million in contracts to bypass council approval, amid a $258 million city deficit.
Campbell fine. The Ethics Commission fines Jennifer Campbell's campaign $300; two of twelve audited mailers could not be produced for inspection, preventing auditors from verifying "Ad paid for by" disclosures.
Cardenas fine. The Ethics Commission fines Jesus Cardenas $5,000 — the statutory maximum — for taking lobbying meetings with a consulting-firm client (Blue Water Government Affairs, which had paid Cardenas more than $10,000) during the twelve-month cooling-off period while serving as chief of staff to Councilmember Stephen Whitburn. Cardenas ran Grassroots Resources while drawing a government salary; he resigned and later pled guilty to felony charges over $176,000 in PPP fraud (an unrelated matter).
Boomhower hearing. At a November 2025 Planning Commission hearing on the Preservation and Progress program, Commissioner Boomhower threatens a public speaker (Bruce Coons, Save Our Heritage Organisation) with potential SLAPP retaliation after Coons cited 101 Ash Street; Deputy City Attorney Corinne Neuffer corrects him on the First Amendment on the record.
Foster Form 803. Henry Foster III reports a $100,000 Airbnb payment to the San Diego Parks Foundation, earmarked for an Encanto skate plaza, while the council was considering a $5,000-per-bedroom vacation-rental tax for the 2026 ballot.
Moreno Form 803. Vivian Moreno reports $20,000 in behested payments to the San Ysidro Women's Club for scholarships: $10,000 from Laborers Local 89, $5,000 from Marathon Petroleum, $5,000 from Carpenters Local 619.
District 2 candidate filings. With Campbell term-limited, DSDP VP Josh Coyne leads the District 2 field with $93,002 raised (including a $30,000 self-loan), nearly twice his nearest rival, with more than 80% of contributions from outside District 2. Disclosed donors include Chris and Jennifer Wahl of Southwest Strategies ($1,500), Robert Gleason of Evans Hotels ($1,600), Marco Sessa of Sudberry Properties ($800), Gil Cabrera ($500), and Phil Rath ($1,500).
Form 700 portal. The FPPC launches an online search portal for Form 700 financial disclosures — one of the five fragmented filing systems, now partially searchable.
Behested-payment disclosures (cross-official)
Form 803 records a payment an official solicits from a third party for a cause; it must be disclosed within 30 days. The brief documents who filed what — disclosure records, not findings of corruption. Recipients are legitimate nonprofits.
- Todd Gloria — $450,000+, 36 of 40 city Form 803s since January 2023. DB SDUT-803
- Sean Elo-Rivera — zero filings across his 2020–2026 council tenure. eFile-803
- Mara Elliott — Golden Door $100,000 to Your Safe Place Foundation (foundation was AG-delinquent at the time). DB
- Henry Foster III — Airbnb $100,000 to San Diego Parks Foundation. eFile-Foster
- Marni von Wilpert — $15,000 ($5,000 each from Waste Management, Falck, San Diego Zoo) to Equality California. DB
- Vivian Moreno — $20,000 (Laborers $10,000, Marathon Petroleum $5,000, Carpenters $5,000) to San Ysidro Women's Club scholarships. DB
Context: behested solicitation is bipartisan standard practice; Kevin Faulconer reported $3M+ via his One San Diego nonprofit. SDUT-803
The Downtown San Diego Partnership ecosystem
The same organization holds city contracts, operates a PAC, and seats industry figures on its board — three roles recorded in three separate filing systems.
- City contracts — $13 million+: $1.9 million Family Reunification Program over two fiscal years ($950,000 in July 2022, $950,000 in May 2023) plus $11 million+/year in Property-Based Improvement District management (funded by property-owner assessments, ratified by council). DSDP-contracts DSDP-PBID DB
- PAC (FPPC 1420259) — $173,124 from 107 contributors: donors include HNTB Holdings PAC ($25,000), Pacifica Hosts ($25,000), UMMC PAC ($20,000), Sempra ($20,000), Irvine Management ($15,000) — external donors, not recycled contract revenue. The PAC gave $20,000 to Community Voices San Diego PAC and $23,000 to the Yes-on-C (Measure C) campaign. DSDP-PAC DB SDEC-MeasureC
- 990 financials: revenue grew from $9.1 million (FY2020) to $15.8 million (FY2024); CEO Elizabeth Brennan compensation $285,000. DSDP-990
- Governance overlap: Frank Urtasun, a Sempra executive, served as DSDP chairman (FY2016–17) and immediate past chair (FY2018). Diana Puetz, VP of Public Affairs at the San Diego Padres, sits on the DSDP board. PAC chair James Lawson (Presidio Public Affairs); vice chair Melanie Woods (California Apartment Association). DB DSDP-PAC-leadership Puetz-bio
Inferred: the brief characterizes these as "overlapping relationships," not a closed financial circuit; it states explicitly that no city contract dollars were traced into the PAC account, and that the PAC's $173,124 is ~1.1% of DSDP's $15.8 million revenue (a characterization of the financials, not a legal finding). DSDP-PAC DSDP-990
Enforcement, in scale
Documented Ethics Commission and FPPC actions, with the scale of the underlying activity where the brief states it. Fine amounts and the audit figure are cited inline above and in the Reference key.
| Official / party | Violation | Fine | Scale of underlying activity |
|---|---|---|---|
| Jennifer Campbell | Two missing audited mailers | $300 SDUT-Campbell | — |
| Raul Campillo | 20+ 2020 campaign-reporting violations | $2,200 SDUT-Campillo | — |
| Jesus Cardenas | Lobbying-disclosure (statutory max) | $5,000 SDUT-Cardenas | — |
| Todd Gloria | 10 late Form 803 disclosures | $10,500 Stip23-16 | $450,000+ behested DB |
| Phil Rath (lobbyist) | Affirmed Housing conflict (FPPC + Ethics) | $16,000 Rath-FPPC | — |
| City contracting (no party) | $155M altered late/without approval | $0 Audit25-02 | $155,000,000 Audit25-02 |
Transparency reforms San Diego lacks
The brief states three reforms present in other cities and absent in San Diego, plus one partial 2026 step. The comparative descriptions of LA/SF/NYC programs are drawn from published municipal disclosure frameworks, not from a primary filing.
- Real-time independent-expenditure disclosure — present in Los Angeles; absent in San Diego (IE spending appears only on Cal-Access quarterly filings). SDUT-watchdog
- A linked donor database connecting donors → PACs → candidates — present in San Francisco; absent in San Diego. SDUT-watchdog
- Small-dollar matching funds — present in New York City; absent in San Diego. SDUT-watchdog
- Form 700 online search — launched by the FPPC on 2026-03-12 (one of five systems, partial). FPPC-700
Inferred: the brief notes these reforms "address infrastructure, not human nature" and does not claim they would have changed any specific San Diego outcome (a characterization, not a finding).
Key players
- Todd Gloria — Mayor of San Diego; filed 36 of 40 city Form 803s ($450,000+); fined $10,500 for ten late disclosures.
- Jennifer Campbell — District 2 councilmember (term-limited); fined $300 for two missing audited mailers.
- Jesus Cardenas — former chief of staff to Councilmember Whitburn; fined the $5,000 maximum for a lobbying-disclosure violation; later pled guilty to unrelated PPP-fraud charges.
- Kelly Moden — CEO of cREate Development and Gloria-appointed Planning Commission chair; her firm was selected for the $32.7M 101 Ash Street project (Ethics Commission found no conflict).
- Phil Rath — lobbyist; fined $16,000 ($5,000 FPPC + $11,000 Ethics) for the Affirmed Housing conflict.
- Gil Cabrera — attorney; For All of Us board member, Gloria appointee, and $500 donor to D2 candidate Josh Coyne.
- Frank Urtasun — Sempra executive and former DSDP chairman (governance overlap).
- Josh Coyne — DSDP VP and District 2 council candidate; led the field with $93,002 raised (80%+ from outside the district).
- Andy Hanau — City Auditor whose Report 25-02 documented the $155M in contract alterations.
Caveats
- Nothing in this brief is alleged to be illegal. The fines documented are for disclosure/paperwork failures; the underlying conduct (soliciting behested payments, industry membership on commissions, business-improvement-district PACs) is legal.
- Behested payments are a disclosure mechanism, not a corruption mechanism; the named recipients are legitimate nonprofits and no documented payment is shown to have changed a vote.
- The $155 million figure aggregates contract alterations over six years and two mayoral administrations; the auditor attributed it to "unclear roles and responsibilities," not a conspiracy, and many alterations were brought to council retroactively rather than permanently hidden.
- The Ethics Commission's no-conflict ruling on Moden / 101 Ash stands as the formal finding (the project did not go before the Planning Commission); attorney Michael Aguirre alleged fraud, but no fraud finding has been issued.
- The DSDP "ecosystem" describes overlapping relationships; no city contract dollars were traced into the PAC account and the brief does not assert a closed financial circuit.
- The Form 803 amounts for Elliott, von Wilpert, and Moreno are sourced from the MathPolitics database record of the underlying City Clerk / FPPC filings (cited
DB), because the live records database does not store a public per-filing URL for those items; the Foster filing has a stored efile.sandiego.gov document URL. - The District 2 donor-network observation reflects San Diego's politically active donor class; without comparison data from other candidates' donor bases, the 80%-out-of-district figure may be unremarkable for a council race.
- Comparative descriptions of Los Angeles, San Francisco, and New York City reform programs are from published municipal frameworks, not a single primary filing.
Reference key
- SDUT-Campbell San Diego Union-Tribune, "San Diego city councilmember Campbell agrees to pay $300 for campaign violation," 2025-09-12. https://www.sandiegouniontribune.com/2025/09/12/san-diego-city-councilmember-campbell-agrees-to-pay-300-for-campaign-violation/
- SDUT-Campillo San Diego Union-Tribune, "Just ahead of March primary, Campillo fined by ethics board for 2020 campaign violations," 2024-01-17. https://www.sandiegouniontribune.com/2024/01/17/just-ahead-of-march-primary-campillo-fined-by-ethics-board-for-2020-campaign-violations/
- SDUT-Cardenas San Diego Union-Tribune, "Jesus Cardenas fined $5,000 for San Diego ethics violation," 2025-09-13. https://www.sandiegouniontribune.com/2025/09/13/jesus-cardenas-fined-5000-for-san-diego-ethics-violation/
- Stip23-16 San Diego Ethics Commission, Stipulation 23-16 (Gloria, $10,500 behested-payment violations), 2024-04-11. https://www.sandiego.gov/sites/default/files/2024-04/stip23-16.pdf
- Audit25-02 San Diego City Auditor, "Performance Audit of the City's Contract Management Process (Report 25-02)," 2024-07-31. https://www.sandiego.gov/sites/default/files/2024-07/25-02-performance-audit-of-the-city-s-contract-management-process.pdf
- SDCA-Hanau San Diego City Auditor Andy Hanau, "City improperly increased contract spending by $155M (2017–2023)" (MathPolitics evidence E-56). DB
- OBR-Audit OB Rag, "Audit: San Diego Mayors Regularly Increased Spending for Contracts Without Council Approval," 2024-08-07. https://obrag.org/2024/08/audit-san-diego-mayors-regularly-increased-spending-for-contracts-without-council-approval/
- ToSD-vetoes Times of San Diego, "San Diego City Council, Mayor Gloria, city budget vetoes," 2025-06-23. https://timesofsandiego.com/politics/2025/06/23/san-diego-city-council-mayor-gloria-city-budget-vetoes/
- ToSD-2020-02 Times of San Diego, "City Ethics Panel Rejects Laundering Complaints vs. Todd Gloria, Democrats," 2020-02-06. https://timesofsandiego.com/politics/2020/02/06/city-ethics-panel-rejects-laundering-complaints-vs-todd-gloria-democrats/
- Rath-FPPC San Diego Reader, "Ticker: Phil Rath fined again," 2018-11-08 ($5,000 FPPC + $11,000 Ethics for the Affirmed Housing conflict). https://www.sandiegoreader.com/news/2018/nov/08/ticker-phil-rath-fined-again/
- Rath-profile San Diego Reader, "Radar: Phil Rath, San Diego's busiest lobbyist," 2020-06-03. https://www.sandiegoreader.com/news/2020/jun/03/radar-phil-rath-san-diegos-busiest-lobbyist/
- SDUT-803 San Diego Union-Tribune, "Mayor Gloria uses his elected office to solicit donations to nonprofits…," 2024-11-26 (Gloria $450K+ behested; Faulconer $3M+ via One San Diego). https://www.sandiegouniontribune.com/2024/11/26/mayor-gloria-uses-his-elected-office-to-solicit-donations-to-nonprofits-now-another-city-leader-is-joining-him/
- eFile-803 City of San Diego eFile, Form 803 Behested Payment Search (Sean Elo-Rivera — zero filings) (MathPolitics evidence E-2844). https://efile.sandiego.gov/public/search/behested?official=sean-elo-rivera
- eFile-Foster City of San Diego eFile / FPPC, Henry Foster III Form 803 (Airbnb $100,000 to San Diego Parks Foundation), 2025-11-28. https://efile.sandiego.gov/pdfview?doc_public=Ext_f046b062-1478-4911-8999-ff2b89c0ac05
- SDUT-FAOU San Diego Union-Tribune watchdog, "For All of Us / Todd Gloria — public disclosure, behested payments," 2023-05-30. https://www.sandiegouniontribune.com/news/watchdog/story/2023-05-30/for-all-of-us-todd-gloria-public-disclosure-behested-payments
- SDUT-charity San Diego Union-Tribune, "Charity set up to support San Diego mayor's office withholds finances, other records from disclosure," 2023-05-30. https://www.sandiegouniontribune.com/2023/05/30/charity-set-up-to-support-san-diego-mayors-office-withholds-finances-other-records-from-disclosure/
- OBR-Ash-Jul OB Rag, "City Council Hands Over Ash Street Tower to Development Team of Kelly Moden, Chair of the Planning Commission," 2025-07-29 (Ethics Commission found no conflict). https://obrag.org/2025/07/city-council-hands-over-ash-street-tower-to-development-team-of-kelly-moden-chair-of-the-planning-commission-no-conflict-of-interest-there-oh-no/
- OBR-Ash-Jan OB Rag, "Company Led by Head of San Diego Planning Commission Selected for Redo of 101 Ash Street," 2025-01-27. https://obrag.org/2025/01/company-led-by-head-of-san-diego-planning-commission-selected-for-redo-of-101-ash-street/
- OBR-Boomhower OB Rag, "San Diego Planning Commissioner Boomhower Goes Too Far," 2025-11-01. https://obrag.org/2025/11/san-diego-planning-commissioner-boomhower-goes-too-far/
- VOSD-PC Voice of San Diego, "Politics Report: An Emerging Dispute Over a Planning Commission Appointment," 2023-01-21. https://voiceofsandiego.org/2023/01/21/politics-report-an-emerging-dispute-over-a-planning-commission-appointment/
- DSDP-contracts City of San Diego, Goods and Services Contracts FY2023 (DSDP entries). https://www.sandiego.gov/purchasing/bids-contracts/contracts2023
- DSDP-PBID Downtown San Diego Partnership / City of San Diego, PBID Renewal — Operating and Management Agreement 2025–2035. https://downtownsandiego.org/clean-and-safe/pbid-renewal/
- DSDP-990 ProPublica Nonprofit Explorer, Downtown San Diego Partnership Form 990 filings 2017–2024 (EIN 95-1729734). https://projects.propublica.org/nonprofits/organizations/951729734
- DSDP-PAC City of San Diego eFile, Downtown San Diego Partnership PAC (FPPC 1420259) campaign-finance filings. https://efile.sandiego.gov/public/search/campaign?state_id=1420259
- DSDP-PAC-leadership Downtown San Diego Partnership PAC, leadership and mission. https://downtownsandiego.org/advocacy/pac/
- SDEC-MeasureC San Diego Ethics Commission, Major Funding 2020 (DSDP PAC to Yes on C / Measure C). https://www.sandiego.gov/ethics/documents/donorsarchive#measurec
- Puetz-bio Academy of Our Lady of Peace Women's Symposium, Diana Puetz bio (Padres VP, DSDP board). https://www.aolpsymposium.org/diana-puetz
- OBR-D2-Dec OB Rag, "San Diego District 2 City Council Candidates: Follow the Money," 2025-12-01. https://obrag.org/2025/12/san-diego-district-2-city-council-candidates-follow-the-money/
- OBR-D2-Feb OB Rag, "Follow the Money: Update on District 2 San Diego City Council Race," 2026-02-01. https://obrag.org/2026/02/follow-the-money-update-on-district-2-san-diego-city-council/comment-page-1/
- SDUT-D2 San Diego Union-Tribune, "These San Diego council races are still wide open, new campaign filings show," 2026-02-03. https://www.sandiegouniontribune.com/2026/02/03/these-san-diego-council-races-are-still-wide-open-new-campaign-filings-show/
- SDUT-watchdog San Diego Union-Tribune watchdog, "Elected officials solicit donations to charity, including ones that support them," 2023-05-30 (behested-payment context; LA/SF/NYC reform comparisons drawn from published municipal disclosure frameworks). https://www.sandiegouniontribune.com/news/watchdog/story/2023-05-30/public-records-disclosures-vital-behested-payments
- FPPC-700 California Fair Political Practices Commission, Form 700 online search portal (launched 2026-03-12). https://www.fppc.ca.gov/transparency/form-700-filed-by-public-officials/form700-search.html
- DB MathPolitics database connection/evidence IDs as cited in the full report (covers the Elliott, von Wilpert, and Moreno Form 803 filings, the Gloria 36-of-40 / $450K+ compilation E-52, the SDCA-Hanau evidence E-56, DSDP totals, and the D2 donor connections). → view in evidence search
Report #8 · The Council Files (Part 4) · condensed AI fact sheet. Chronological; every claim cited; inferences flagged. Source: full report reports/the-council-files/04-the-system.md.
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