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Administrative Actions

While not all Registry administrative actions are presently available online, copies of specific past Registry actions may be requested under the Kentucky Open Records Act.  Information pertaining to administrative actions finalized by the Registry since May 2015 may be found below.  If additional information regarding past Registry actions is required, you may contact the Registry’s Office of General Counsel.

2016

Allegations: This case was based on a sworn complaint filed by Steve Robertson, former Chairman of the Republican Party of Kentucky (Robertson).  Robertson’s complaint alleged violations of Kentucky’s campaign finance law by Governor Steve Beshear (Beshear), the Gubernatorial Slate Campaign Fund of Beshear-Abramson 2011 (Beshear-Abramson 2011), and Charles Geveden, Deputy Secretary of the Justice and Public Safety Cabinet (Geveden), acting for and on behalf of Beshear and Beshear-Abramson 2011. The case presented the following issues: (1) Did Geveden violate KRS 121.150(22) by soliciting campaign contributions from state employees on behalf of Beshear-Abramson 2011; and (2) Even if Beshear-Abramson did not authorize Geveden’s solicitations, did Geveden violate KRS 121.320(1) by requesting non-merit employees under his supervision to make campaign contributions to Beshear-Abramson 2011 in specific dollar amounts based on the employees’ respective state government salaries?

No named Respondent or counsel for made an appearance at the Registry March 23, 2016 meeting, nor was any Respondent ordered to appear before the Registry Board.  The alleged violations of KRS 121.150(22) were ordered dismissed.  However, the Registry Board found probable cause to believe Geveden violated KRS 121.320(1) by requesting non-merit employees under his supervision to make campaign contributions to Beshear-Abramson 2011 in specific amounts, depending on the individual employee’s position or salary, Geveden’s request that a subordinate employee solicit campaign contributions from employees under the subordinate’s supervision, and Geveden’s attempt to provide the subordinate with a list of employees, the employees’ respective salaries, and an expected contribution amount per employee.

Conclusion: Geveden signed a Conciliation Agreement acknowledging the violations and paid a $3,000 civil penalty. The Registry Board approved the Conciliation Agreement at its September 29, 2016 meeting.

Allegations: This case was based on a sworn complaint letter filed by Kayla Porter (Porter), alleging violations of certain corporate prohibitions (KRS 121.025, KRS 121.035, and KRS 121.310) by Jim Crick (Crick), acting in his capacity as Vice President for Enrollment Management for the Sullivan University System, Inc. (Sullivan, Inc.), and A.R. Sullivan (Sullivan), as Chancellor of Sullivan, Inc.  Porter’s complaint described a two-day training summit for Sullivan, Inc. admissions staff, in which Sullivan expressly advocated for the defeat of sitting Attorney General Jack Conway (Conway) and Crick solicited Sullivan employees for $25 contributions to the Campaign Fund of Todd P’Pool for Attorney General (P’Pool), which Crick stated he would collect at the workplace and deliver to the P’Pool campaign.  The case specifically presented the following issues: (1) Did Sullivan, in his official capacity as Chancellor of Sullivan, Inc., violate any provision of the campaign finance law prohibiting corporate contributions to a candidate by advocating against Conway’s election at a Sullivan, Inc. sponsored event; and (2) Did Crick, acting in his official capacity as Vice President for Enrollment Management for Sullivan, Inc., violate any provision of the campaign finance law prohibiting corporate contributions to a candidate by soliciting and collecting campaign contributions for P’Pool in the Sullivan, Inc. workplace?

The Registry dismissed all alleged violations by Sullivan and Sullivan, Inc., but found probable cause to believe that Respondent Crick unknowingly violated KRS 121.035(2), due to his solicitation and receipt of campaign contributions from corporate employees in the workplace and delivery of campaign contributions to the P’Pool campaign.

Conclusion: Crick signed a Conciliation Agreement acknowledging the violation and paid a $500 civil penalty. The Registry Board approved the Conciliation Agreement at its September 29, 2016 meeting.

Allegations: The Registry conducted an audit of the gubernatorial slate campaign of Gatewood B. Gatewood (Gatewood), Candidate for Governor, and Elizabeth Anderson (Anderson), Candidate for Lieutenant Governor, in the 2015 general election, as required by KRS 121.120(4)(k). A Registry auditor found that the gubernatorial slate campaign, Gatewood/Anderson 2015, had apparently violated KRS 121.120(6)(h), by failing to electronically file all election finance reports required to be submitted to the Registry, and KRS 121.220(1) and (2), by failing to designate a separate campaign depository to deposit all contributions and disburse all expenditures made in connection with a candidate’s campaign. Don Vazmina (Vazmina) was named as a Respondent due to his appointment as Treasurer of the Campaign Fund of Gatewood-Anderson Gubernatorial Slate (Gatewood/Anderson 2015).
Gatewood filed a response in which he admitted to the violations. Gatewood also appeared before the Registry, and requested the Registry Board to hold him solely responsible. He stated that the violations were an act of neglect, based on his assumption that he would spend less than $1,000 in the campaign.
On March 23, 2016, the Registry Board dismissed the allegations against Anderson and Vazmina, as requested by Gatewood, and found probable cause to believe that Gatewood/Anderson 2015, by and through Gatewood, had unknowingly violated KRS 121.120(6)(h), by failing to electronically report campaign finances during the 2015 general election; and further violated KRS 121.220(1) and (2), by failing to designate a primary campaign depository in connection with Gatewood/Anderson 2015.
Conclusion: Gatewood signed a Conciliation Agreement acknowledging the violations and paid a $100 civil penalty. The Registry Board approved the Conciliation Agreement at its September 29, 2016 meeting.