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Ethics Commission

Stipulations and Orders

The Ethics Commission resolves its enforcement actions in a variety of ways, including issuing enforcement orders following administrative hearings, negotiating the terms of stipulated settlements, and concluding minor cases through streamlined programs.


The Commission staff and respondent may resolve an enforcement matter through a negotiated settlement, which typically involves the payment of a monetary penalty to the City's General Fund. All stipulations are submitted to the Ethics Commission for approval.

Date Violation Case Name Case Number
Behested Payments Todd Gloria 2023-16
Campaign Disclosure San Diegans for Transparency & Accountability in Support of Kelvin Barrios for City Council 2020, Sponsored by Laborers' International Union of North America Local 89; and River City Business Services 2024-01
Campaign Disclosure Raul A. Campillo 2023-20
Lobbying Disclosure Midway Village Plus, LLC 2023-08
Lobbying Disclosure Chelsea Investment Corporation 2023-13
Lobbying Disclosure Downtown San Diego Partnership 2023-11
Lobbying Disclosure WalkSanDiego dba Circulate San Diego 2023-14
Campaign Disclosure Marni von Wilpert, Politica Campaign Treasury, LLC 2022-29
Lobbying Disclosure Midway Rising, LLC, and Zephyr Acquisitions Group LLC 2022-20
Campaign Disclosure Tommy Hough 2021-12
Campaign Disclosure The San Diego County Democratic Party 2021-12
Campaign Disclosure Mara Elliott; KM Strategies; Amplify Campaigns; and River City Business Services 2021-07
Misuse of City Position Kelvin Barrios 2020-30
Campaign Disclosure Yes on Measure A - Homes for San Diegans, Sponsored by a Coalition of Civic Nonprofits and Housing Providers 2020-38
Contribution Solicitation Joe Leventhal 2020-36
Campaign Disclosure Success San Diego in Support of Barbara Bry for Mayor 2020; and Gould and Orellana, LLC. 2020-33
Contribution Solicitation Noli Zosa 2020-18
Campaign Advertising Ross Naismith 2020-05
Campaign Advertising Wendy Wheatcroft 2019-38
Campaign Advertising Raul Campillo 2019-34

Administrative Enforcement Orders

In lieu of settling an enforcement matter, a respondent may elect to proceed to an administrative hearing for a determination regarding violations of the City's campaign, lobbying, or ethics laws. Following the hearing, the Commission may issue an Administrative Enforcement Order requiring the respondent to pay a monetary penalty to the City's General Fund.

Date Violation Case Name
04/20/16 money laundering Advantage Towing and Ayman Arekat (Case No. 2013-15): Administrative Enforcement Order; Resolution
07/13/12 campaign violations B.D. Howard (Case No. 2010-42): Administrative Enforcement Order; Resolution
08/16/10 conflict of interest Nancy Graham (Case No. 2008-54): Administrative Enforcement Order; Resolution
05/03/10 campaign disclosure Marti Emerald (Case No. 2008-73): Administrative Enforcement Order; Resolution
07/11/08 campaign violations Luis Acle (Case No. 2006-59): Administrative Enforcement Order; Resolution