CASE FILE #3·THE GLORIA FILES·
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The Gloria Files · Case #4

The System

AI Fact Sheet

Every Safeguard Failed. None of Them Were Broken.

Total money traced
$61.8M
San Diego · public-record filings
Report #4 · The Gloria Files (series order 4) · condensed AI fact sheet. Chronological; every claim cited; inferences flagged. Source: full report the-system (Gloria Files Part 4).
Built on reporting by
Jeff McDonald
San Diego Union-Tribune
6 articles
Jennifer Van Grove
San Diego Union-Tribune
2 articles
Ken Stone
Times of San Diego
1 article
Madeline Nguyen
Times of San Diego
1 article
Matt Potter
San Diego Reader
1 article
Morgan Cook
San Diego Union-Tribune
1 article
Scott Lewis
Voice of San Diego
1 article
Will Huntsberry
Voice of San Diego
1 article
City News Service
Times of San Diego
1 article
Reporting cited in this fact sheet. Read the original stories — support local journalism.
Documented fact — traces to a filed public record.
Inference — a reading of the record, not a legal finding.
Scope
$61.8M

San Diego's municipal oversight mechanisms — contract approval, campaign-finance limits, behested-payment disclosure, lease auditing, the revolving door, and planning review — measured against the money that moved through them, 2012–2026, with Todd Gloria's administration as the recurring hub. The brief documents money flows in several legally distinct channels: at least $61.8M in named city contract alterations brought to Council late, retroactively, or not at all (part of a $155M audited total) E-86; a $32.7M no-bid developer fee on the 101 Ash tower E-380; $2.15M+ in 2024 independent-expenditure (IE) spending for Gloria E-332; $450,000+ in behested payments Gloria solicited E-352; and a $3.9B Midway Rising development whose public subsidy could reach an estimated $900M in redirected property-tax increment E-315. Total fines imposed on everyone named in the underlying investigation: $16,000 E-86E-318E-331E-336. Nothing here is alleged to be illegal; the point of the brief is the legal machinery.

Summary — what happened

Between 2012 and 2026, the same set of San Diego oversight mechanisms repeatedly produced documented gaps without producing documented violations. A 2024 City Auditor performance audit found that 42% of contract alterations from 2017 to 2023 — $155 million — were brought to City Council late, retroactively, or not at all; 13% ($15 million) had no Council approval at all. E-86 Named examples include Rehrig Pacific ($30.3M), Dell Marketing ($18.6M), Luth and Turley ($10M), and ADS Corporation ($2.86M across five retroactive alterations). E-86C-2614C-2615C-2616C-2613 Four audits since 2015 made the same findings; no staff were disciplined. E-86 In a separate channel, San Diego bars all organizational, PAC, and union contributions to candidates E-86, so corporate money moved through IE committees: four of them spent $2.15M+ for Gloria's 2024 re-election against a 5-to-1 funding advantage, including $800,000 raised in three weeks by San Diegans for Fairness (chaired by Stephen Cushman, who resigned a city consulting contract the same day) and $450,000 from A Better San Diego, anchored by a single $350,000 donation from a McDonald's-franchise-owner business alliance. E-332E-335C-76C-2601C-2602

The same institutions recur across channels. The Downtown San Diego Partnership holds $3.84M in city contracts plus an $11M/year business-improvement-district management role C-180; its PAC raised $173,124 and distributed it to IE committees supporting Gloria and to a Faulconer committee. E-351 Gloria solicited $450,000+ in behested payments — 36 of 40 Form 803 filings on the city clerk's site since 2023 came from the Mayor's Office E-352 — and was fined $10,500 for filing ten of them late, some 679+ days. E-318 His Planning Commission chair, Kelly Moden, whose firm received a $32.7M no-bid developer fee on the 101 Ash tower, was cleared by the Ethics Commission because the project did not go before the commission she chaired. E-132E-380 The Gloria administration suspended internal audits of Mission Bay leases — $38.88M in annual revenue — for nine months during a $250M budget gap, then reserved the right to do it again. E-329 The full set of fines across the investigation totals $16,000; the documented money flows exceed $340 million. E-86 No safeguard examined produced a finding of illegality. That is the documented pattern: each mechanism operated within the law.

Timeline

2012-12-10 E-370

Bahia Resort lease extension. A 40-year extension of Evans Hotels' Bahia Resort lease on city-owned Mission Bay land is approved in the final week of Mayor Sanders' tenure, with no competitive process.

2012-12-19 E-369C-2719

Evans family profile. Voice of San Diego documents Bill Evans (Evans Hotels) as among the most frequent visitors to council members' offices; the city attorney had urged him to register as a lobbyist. The Evans family later donated $9,200 to Gloria campaigns.

The lobbyist hire. Southwest Strategies hires Diana Palacios while she is Deputy Chief of Staff to Councilman Sherman. By late 2015 she lobbies under her married name; her husband, Stephen Puetz, is Chief of Staff to Mayor Faulconer.

Inferredlobbying the office her spouse runs is a conflict in appearance — documented through lobbying disclosures, not a legal finding; no ethics body has ruled on it.

Contract alterations. Across this window, 42% of city contract alterations ($155M) are brought to Council late, retroactively, or not at all; 13% ($15M) receive no Council approval. The average unapproved amendment is $856,000. Named cases: Rehrig Pacific $30,262,000 (approved 65 days before expiration); Dell Marketing $18,633,600 (49 days before); Luth and Turley $10,000,000 (18 days before); ADS Corporation $2,858,198 (five retroactive alterations); Herc Rentals approved at $14M, grown to $32.5M.

2019-11-08 E-81

The $200 fine. The FPPC fines Gloria $200 through a streamlined enforcement program for the four-committee campaign structure that moved $5.67M (detailed in Report #1).

2020-04-14 E-327

Vendor-gift audit. A city audit finds an employee accepted $3,000+ in gifts from vendors and revised invoices to inflate costs by $37,000 while covertly advising those vendors; a criminal investigation is opened and closed without charges.

2021-10-24 E-82

Ash Street lobbying. Reporting documents the city attorney and mayoral aides meeting with lobbyists over the 101 Ash Street litigation.

2022-03-01 E-364E-372

Lease-management audit. A City Auditor report finds nearly 25% of city leases expired and in holdover (vs. 5% or less in comparable cities), with the city forgoing potentially millions per year — the same pattern flagged by a 2017 Grand Jury report.

2023-05 E-401E-400

General Atomics tour. Gloria tours General Atomics' fusion facilities and praises the company. His father, Phil Gloria, worked at General Atomics as a Production Controller until retirement.

2023-05-30 E-317

For All of Us. The Union-Tribune reports that For All of Us, a nonprofit receiving behested donations solicited by Gloria, has no incorporation papers and operates through fiscal sponsorship that minimizes disclosure (detailed in Report #1/#3).

2024-02-23 E-326

EIFD staff report. A city staff report explains the proposed Enhanced Infrastructure Financing District (EIFD) for Midway Rising: future property-tax growth above a base year — revenue that would otherwise go to the city general fund — would fund district infrastructure for up to 45 years.

2024-03 E-308

Council explores the subsidy. The City Council votes to explore an EIFD for Midway Rising. Zephyr CEO Brad Termini states the project is "not financially feasible without getting some of the infrastructure paid for"; all three final bidding teams had proposed an EIFD.

2024-04-11 E-318

The behested fine. The SD Ethics Commission (Stipulation 23-16) fines Gloria $10,500 for ten late behested-payment disclosures, some filed 679+ days late.

2024-07 E-329

Mission Bay audit suspension begins. The Gloria administration stops internal audits of Mission Bay leases; the suspension runs nine months, through April 2025. The Economic Development Department revokes the City Auditor's access to the reporting software. Over one-third of leases are on expired holdover.

2024-07-28 E-302

Shelter-lease dual roles. Reporting raises conflict-of-interest questions over a shelter-lease negotiator's dual roles.

2024-07-31 E-86E-328

Contract audit published. City Auditor Report 25-02 documents the $155M contract-alteration pattern. Councilmember Marni von Wilpert: "That's against the law." For every dollar cut from community services through budget vetoes, thirty-one dollars in contract amendments bypassed the Council.

2024-09-20 E-335C-2601C-2602

The $350,000 check. A Better San Diego receives a single $350,000 donation from the California Alliance of Family Owned Businesses (McDonald's franchise owners); the committee spends $450,000 total for Gloria.

The $2.15M election. Gloria wins re-election with a 5-to-1 funding advantage: his campaign raises $930,000; four IE committees spend $2.15M+; his opponent raises $193,000. San Diegans for Fairness raises $800,000 in three weeks (chair Stephen Cushman resigned a city consulting contract the same day he began chairing it). California Progress for All spends $131,493 (funded by the Chamber PAC, Sempra, Amazon, East West Bank). Big City San Diego raises $141,000, launched with $25,000 from Monarch Housing Solutions, which was simultaneously pursuing an unsolicited development proposal on city-owned Mission Bay land.

2024-11 E-378

Mission Bay revenue documented. A City Auditor FY2023 performance audit records $38.88M in adjusted Mission Bay lease revenue; top leaseholders include SeaWorld ($13.5M), the Bahia partnership ($3.4M), and Campland ($1.6M). The Mission Bay oversight committee has six of eleven member terms expired.

2025-03-25 E-403

The secret study. Reporting notes the Keyser Marston Associates fiscal analysis of the Midway EIFD — hired summer 2024 — has still not been released.

2025-06-23 E-328

Council slams Gloria. Council members publicly criticize Gloria for cutting community services while $155M bypassed Council.

2025-07-14 E-381E-379C-2725

101 Ash lawsuits. A taxpayer sues over transparency in the 101 Ash $250M proposal; a separate public-records lawsuit is filed. Former City Attorney Michael Aguirre alleges a "prohibited financial interest."

2025-07-29 E-132E-380C-238

The $32.7M no-bid lease. The City Council votes 8-0 to award a 60-year lease on the 101 Ash tower — a $267.6M project with a $32.7M developer fee — to a team led by Kelly Moden, CEO of cREate Development and then chair of the Planning Commission, with no competitive bid. The Ethics Commission later finds no conflict because the project did not go before the Planning Commission.

Inferredthe outcome reflects the commission's review scope, not the absence of a financial interest — a characterization, not a legal finding.
2025-08-13 E-323

The $1.1M net. A developer-funded report projects Midway Rising could yield $178M/year in new local spending; the same report estimates the city's net general-fund gain at $1.1M/year after service costs — roughly $117 per new resident per year across ~9,360 projected residents.

2025-09 E-395

Planning Commission recommends Midway. Planning Commission Report PC-25-043 unanimously recommends Midway Rising; it does not mention the EIFD or the KMA study.

2025-09-12/13 E-331E-336

Two more fines. Councilmember Jennifer Campbell is fined $300 for failing to retain copies of two campaign mailers. Jesus Cardenas is fined $5,000 — the Ethics Commission maximum at the time (since raised to $15,000) — for taking lobbying-client meetings while serving as Councilmember Whitburn's chief of staff; he and his sister later plead guilty to felony charges over $170,000 in PPP fraud.

2025-10-14 E-366C-2716

Mission Bay housing controversy. Reporting documents Monarch Housing Solutions (Sarah Kruer Jager) pursuing an unsolicited Marina Village proposal while having given $25,000 to a Gloria IE committee.

Vacation-rental-tax fight. As the council considers a vacation-rental tax, Airbnb announces $15M in California political spending with San Diego a "top focus." Councilmember Henry Foster III had solicited $100,000 from Airbnb for an Encanto skate plaza, routed to the San Diego Parks Foundation. Airbnb gave $0 directly to Gloria, Elo-Rivera, Moreno, or von Wilpert in the period.

2025-10-21 E-343

Court blow to Midway. A court strikes down the voter-approved height-limit removal a second time on procedural grounds; Gloria extends the exclusive negotiating agreement to December 2026.

2025-11-05 E-306E-15E-19

Density-bonus workaround. The Midway developers move to use state density-bonus law to sidestep the height limit; 250 middle-income housing units had earlier been dropped and replaced with market-rate units.

2025-11-18 E-329

Audit suspension reported. The Union-Tribune reports the nine-month Mission Bay audit suspension; Mission Bay lease revenue was $38.88M in FY2023, ~15.5% of the city's $250M budget gap. City Auditor Andy Hanau issues five recommendations; Gloria's signed response reserves the right to suspend audits again.

2025-12-23 E-104

Solicitations continue. Reporting documents officials continuing to solicit donations to favored charities — Foster ($100K from Airbnb), Moreno ($20K), von Wilpert ($5K).

2026-01-28 E-361E-362

Tax provision killed. The Rules Committee votes 3-2 against the vacation-rental tax ballot measure (Moreno, Lee, Campillo opposed); a later version passes without the vacation-rental provision.

2026-02-12 E-373

Golf-course holdover audit. A new audit finds the same lease-holdover pattern in golf-course leases: Fairbanks Ranch generated $16.7M in revenue while the city received under $1M/year.

2026-02-23 DB

The rebrand. Southwest Strategies rebrands as Bodewell Group; during the transition, a gap appears in EC-603 lobbying disclosure filings.

2026-12-04 E-403E-343

Pending decisions. The Midway Rising / EIFD Council vote remains pending; the ground-lease deadline is December 4, 2026; the KMA fiscal analysis remains unreleased 18+ months after the city hired the consultants.

Cross-channel institutions

The same names recur across legally distinct channels — city contracts, IE committees, PAC donations, and behested payments — that look unrelated on any single filing.

  • Downtown San Diego Partnership (DSDP) — contracts + PAC. Holds $3,844,068 in city contracts plus management of an $11M/year business-improvement district C-180; its PAC raised $173,124 from 107 donors and distributed $70,000 to San Diegans for Fairness, $5,000 to California Progress for All, $20,000 to a 2020 Gloria IE, and $25,000 to a Faulconer IE. E-351C-2690C-2691C-2656
  • Sempra Energy. Appears in the DSDP PAC donor list ($25,000) and the California Progress for All donor list. E-351E-350
  • East West Bank. Appears in California Progress for All donations and in For All of Us behested-payment donations ($5,000). E-350E-352
  • Cushman. Stephen Cushman chaired San Diegans for Fairness (which raised $800,000 for Gloria); the Cushman Foundation separately made a $50,000 behested payment at Gloria's request. C-76C-101

Inferred: these recurrences describe a single institutional ecosystem that both receives city funding and funds the political infrastructure supporting the officeholder — a characterization of the documented flows, not a legal finding of coordination; IE committees are constitutionally protected and no illegal coordination is alleged.

Behested payments — the donor list

Gloria solicited $450,000+ total; 36 of 40 Form 803 filings on the city clerk's site since 2023 came from the Mayor's Office. E-352 Donors to "San Diegans Together Tackling Homelessness":

DonorAmountConnection
Torrey Coast Foundation$75,000C-98
Conrad Prebys Foundation$50,000C-100
Cushman Foundation$50,000C-101
Brutten Family Foundation$50,000C-102
Sycuan Citizens PAC$25,000C-103
Ace Parking$10,000C-104

For All of Us separately received $5,000 each from Sudberry Properties, SP+ Corporation, Marvin K. Brown Auto Center, and East West Bank. E-352 In a separate office, Councilmember Henry Foster III solicited $100,000 from Airbnb (to the San Diego Parks Foundation) while the council was weighing a vacation-rental tax affecting Airbnb's business. E-354C-2706

Fines, in scale

Every fine in the underlying investigation, against the sum at stake. The fine total is $16,000; the documented money flows exceed $340M.

SubjectViolationFineSum at stake
Todd GloriaFour-committee campaign structure (FPPC)$200$5.67M E-81
Jennifer CampbellMissing campaign mailer copies$300E-331
Jesus CardenasLobbying while chief of staff (Ethics max at the time)$5,000E-336
Todd GloriaTen late behested disclosures (679+ days)$10,500$450,000+ E-318E-352

Inferred: the report characterizes this schedule as "a price list, not a deterrent" — an interpretation of the financials, not a legal finding. The current Ethics Commission maximum is $15,000. E-86

Behested-payment law changes

  • SB 760 (signed 2025) exempts officials making "public appeals" for donations from behested-payment reporting unless the payment would have a material financial effect on the official or family. E-344
  • AB 775 (pending) would let officials satisfy reporting with "good faith estimates" instead of exact figures. E-346

Inferred: the report frames both as a narrowing of disclosure requirements; the characterization is the report's, and neither bill is alleged to be unlawful. E-344E-346

Academic context

  • A study of 132 cities across five states found that for every $500 donated by real-estate interests, cities permitted an additional 2.5 multi-family housing units. E-348
  • A peer-reviewed study found companies contributing more to federal candidates subsequently received more federal contracts, controlling for past performance. E-349

These are external research findings cited for context, not findings about San Diego specifically.

Defense-money pattern (federal)

General Atomics' corporate PAC disbursed $634,000 in the 2025–2026 cycle across 389 contributions: top career donor to Republican Brian Bilbray ($85,000 PAC + $17,000 employees), then $7,500 to Democrat Scott Peters in the 2024 cycle after he won the San Diego–area House Armed Services seat. E-388E-394E-387 CEO Neal Blue separately gave $1M+ in individual federal contributions in the 2024 cycle (Team McConnell $250,000, Calvert Victory $150,000). E-397 Congressmember Sara Jacobs is the only San Diego–area Armed Services member taking zero defense PAC money. E-394 Inferred: the report characterizes this as the PAC "giving to whoever holds the San Diego–area House Armed Services seat" — a "money follows the seat" illustration, not a documented finding — and explicitly does not claim Gloria's family connection influenced policy; the personal connection (Phil Gloria) is documented, not a finding. E-400

Key players

  • Todd Gloria — Mayor of San Diego; solicited $450,000+ in behested payments, fined $200 (FPPC) and $10,500 (Ethics), administration suspended Mission Bay audits.
  • Stephen Cushman — chaired the $800,000 San Diegans for Fairness IE; resigned a city consulting contract the same day; Cushman Foundation made a $50,000 behested payment to a Gloria-solicited cause.
  • Kelly Moden — CEO of cREate Development and Planning Commission chair whose firm received the $32.7M no-bid 101 Ash developer fee; Ethics Commission found no conflict.
  • Diana Palacios / Stephen Puetz — lobbyist hired by Southwest Strategies while her husband was the Faulconer chief of staff she lobbied; she later joined the San Diego Padres organization. C-2727
  • Jesus Cardenas — Whitburn chief of staff fined $5,000 for lobbying-client meetings; later pleaded guilty to $170,000 PPP fraud.
  • Brad / Stefanie Termini (Zephyr) — Midway Rising developers; gave $100,000+ to Gloria via a LiUNA IE committee (cross-reference to Gloria Files Reports #1–#3; see Caveats). DB
  • Downtown San Diego Partnership — $3.84M in city contracts + $11M/yr BID role; its PAC funds IE committees supporting the officeholder.
  • General Atomics / Neal & Linden Blue — defense PAC and the Blue brothers; "money follows the seat" federal example.

Caveats

Read this before quoting any figure
  • Nothing here is found illegal. Each safeguard examined operated within the law; the brief documents architecture, not crime. No claim of conspiracy or quid pro quo is made.
  • Aggregated figures. The $155M contract-alteration total and the $2.15M+ IE figure are aggregated from audit and disclosure sources and may not capture every transaction. The "$340M+ in money flows" headline aggregates contracts, subsidies, IE spending, and behested payments documented across all four Gloria Files reports.
  • Characterizations vs. findings. "Money loop," "captured," "designed to fail," "price list," "revolving door," and "no conflict on a technicality" are the report's characterizations of documented financials and relationships, not legal determinations. The Moden, Cushman, and Palacios dual roles are documented through public records; no ethics body has ruled them improper (the Ethics Commission affirmatively found no Moden conflict).
  • Midway subsidy estimate. The ~$900M ($600M–$1.2B) EIFD figure is a MathPolitics estimate based on the Otay Mesa comparable, not an official figure; the official KMA analysis is unreleased. E-315E-313
  • Cross-references. The Termini $100,000+ figure and the $5.67M four-committee structure are documented in Gloria Files Reports #1–#3 and carried here as cross-references; see those reports for itemized sourcing.

Reference key

Report #4 · The Gloria Files (series order 4) · condensed AI fact sheet. Chronological; every claim cited; inferences flagged. Source: full report the-system (Gloria Files Part 4).

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