Campaign Finance Violations Complaint against Keep Oro Valley Strong PAC, Danny Sharp, Charlie Hurt, Bill Rodman and Joe Erceg

July 11, 2022

To: Oro Valley Town Clerk

Campaign Finance Complaint

The following are Campaign Finance Violations that the evidence suggests have been committed by Danny Sharp, Bill Rodman, Charlie Hurt, Joe Erceg and Keep Oro Valley Strong PAC.  I believe they have likely colluded in violation of the law and the state Campaign Finance Guide.

1. The same agent has been serving both groups, in direct violation of the Campaign Finance Candidate Guide and state law.

The Campaign Finance Candidate Guide states, “There are certain factors that create a presumption of coordination:  – An agent of the person making the expenditure is also an agent of the candidate whose election or whose opponent’s defeat is being advocated by the expenditure. For example, a political consultant should not advise a candidate and an outside group that conducts expenditures in the candidate’s race.” (p. 67-68, emphasis added.)

ARS 16-922 (C) is the relevant statute and states the following:

“In evaluating whether an expenditure is an independent expenditure, a filing officer or enforcement officer may consider the following to be rebuttable evidence of coordination:

1. Any agent of the person making the expenditure is also an agent of the candidate whose election or whose opponent’s defeat is being advocated by the expenditure…”

This provision has been violated because the same agent has been used by both the PAC and the candidates.  Keep Oro Valley Strong PAC utilizes the same political consultant, “Campaign Associates of Southern Arizona,” as the candidates for which they are advocating.  No candidates have reported in-kind donations from Keep Oro Valley Strong PAC in any of their campaign finance reports, and mailers from the PAC have been represented to the public as an independent expenditure. The consultants’ website is casapolitcal.com.

• Keep Oro Valley Strong PAC paid $8,287.48 in this election cycle so far to Campaign Associates of Southern Arizona.
• Danny Sharp for Mayor paid $4,454.27 to Campaign Associates of Southern Arizona.
• Rodman for Oro Valley paid $1,239.25 to Campaign Associates of Southern Arizona.
• Charlie Hurt for OV paid $3,829.72 to Campaign Associates of Southern Arizona.
• Erceg for OV Town Council paid $3,802.75 to Campaign Associates of Southern Arizona.

2.  Bill Rodman made a donation to Keep Oro Valley Strong PAC of $250.00 on November 12, 2020.  Keep Oro Valley Strong PAC made expenditures advocating for his election and his opponents’ defeat.  This included mailers. These mailers do not identify that they were partially paid for by Bill Rodman. One says, “Not authorized by any candidate or candidate committee.”

Presumably, these mailers were sent out as an “independent expenditure,” and yet there appears to be coordination between the candidate and the “independent expenditure” based on the fact that the candidate actively contributed money to the PAC. Bill Rodman does not identify any in-kind contributions from Keep Oro Valley Strong on his campaign finance reports.

3. William “Bill” Rodman made a contribution to Danny Sharp for Mayor in the amount of $250.00 on July 9, 2021, in the same election cycle in which he became a political candidate.  ARS 16-913 prohibits candidate to candidate transfers.

4. Danny Sharp For Mayor received a contribution of $200.00 on July 8, 2021 from “The Lou Waters Company” and it is filed under “Individuals.”  ARS 16-913 prohibits donations from corporations, LLC’s, or Unions.  The 2022 Candidate Guide for campaign finance states, “A candidate committee is not permitted to accept (and is strictly prohibited from depositing) a contribution from a corporation, LLC, union, or any other business, group, organization or association (with the exception of a partnership) that is not registered as a PAC.” (p. 34.) Additionally, the occupation and employer are not listed here.

I appreciate your prompt attention to these potential campaign finance violations.

Melanie Barrett
Vice Mayor, Oro Valley Town Council
2022 candidate for re-election for Oro Valley Town Council