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.