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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.

2017

Allegations: This case was based upon a sworn complaint filed by Paul L. Whalen, specifically alleging violations of KRS 121.180 and 32 KAR 1:020 by Matt Teaford (“Teaford”), Candidate for the Kentucky House of Representatives, District 67, due to Teaford’s alleged failure to file required Election Finance Statements in his capacity as Treasurer of the Campaign Fund of Matt Teaford for State Representative (“Teaford Campaign Fund”).

Despite numerous notices of pre and post election reporting requirements mailed to Teaford, no reports or responses were received.  Teaford failed to keep the Registry apprised of current contact information and appeared to evade the Registry’s attempts to serve notice of this case.  As Teaford ignored several mailings and phone messages left by Registry staff, the sole issue in this case was whether Teaford knowingly failed to file required Election Finance Statements fully disclosing the finances of the Teaford Campaign Fund for the 2016 primary election.

On September 27, 2016, two days before the Registry’s scheduled meeting, Teaford informed the Registry of his withdrawal as candidate from the 2016 general election, filed Election Finance Statements for the 2016 primary election and one statement for the 2016 general election indicating no funds raised or spent.  The Registry verified that Teaford’s withdrawal had been filed with the Kentucky Secretary of State.

At its September 29, 2016 regular meeting, the Registry found probable cause to believe that the Teaford Campaign Fund, by and through Teaford as Candidate and Treasurer, had violated KRS 121.180 and 32 KAR 1:020, by failing to timely report finances of the Teaford Campaign Fund during the 2016 primary election.
 
Conclusion: Teaford signed a Conciliation Agreement acknowledging the violations and paid a $100 civil penalty, which was approved by the Registry Board on February 23, 2017.


2016

Allegations: The Registry conducted an audit of the Campaign Fund of Charles Lovett for Kentucky Secretary of State (Lovett Campaign Fund), in the 2015 primary election, as required by KRS 121.120(4)(k).  A Registry auditor found that the Lovett Campaign Fund had apparently violated KRS 121.120(6)(h), by failing to electronically file all election finance statements required to be submitted to the Registry,  and 121.220(1)-(2), by failing to designate a separate campaign depository to deposit all contributions and disburse all expenditures made in connection with the candidate’s campaign. 
Lovett filed a written response in which he claimed that, because he was unable to attend scheduled campaign finance training, compliance information was not effectively delivered to him and he should not be held liable for the violations.
 
At its regular meeting held September 24, 2015, the Registry found probable cause to believe that the Lovett Campaign Fund, by and through Lovett, had unknowingly violated KRS 121.120(6)(h), by failing to electronically report campaign finances during the 2015 primary election; and further violated KRS 121.220(1) and (2), by failing to designate a primary campaign depository in connection with Lovett 2015.
 
Conclusion: Lovett signed a Conciliation Agreement acknowledging the violations and paid a $100 civil penalty. The Registry Board approved the Conciliation Agreement at its March 23, 2016 meeting.

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.

2015

Allegations: This case is based upon a sworn complaint filed by Lawrence A. Holmes and Jason D. Myers, for and on behalf of Liberty Rehabilitation PSC. Complainants alleged violations of Kentucky’s campaign finance law by Forrest “Ben” L. Waide, candidate for State Representative, District 10. Complainants specifically alleged that Waide used Liberty Rehabilitation bank account funds, credit cards, and employees labor during business hours to support his candidacy, in violation of campaign finance statutes prohibiting corporate contributions to candidates, including KRS 121.025, KRS 121.035, and KRS 121.990.


Waide, by and through counsel, filed a Response to the above-referenced complaint.  Additionally, the Registry received notice that the Office of Attorney General had initiated a criminal investigation of allegations against Waide involving campaign finance violations.

  The Office of Attorney General requested that the Registry defer action until such time as the criminal investigation and/or potential prosecution was complete to which the Registry agreed.
The Office of Attorney General proceeded with its investigation and filed criminal charges against Waide.  Commonwealth v. Forrest Waide, Franklin Circuit Court, Case # 14-CR-215.  On July 29, 2014, Waide was indicted on criminal charges of accepting contributions from a corporation, in violation of KRS 121.150(20), and making unlawful campaign expenditures, in violation of KRS 121.175(1) to which  Waide pled guilty to amended misdemeanor counts, including (1) criminal attempt to commit illegal campaign contributions; and (2) criminal attempt to commit unlawful campaign expenditures.  As a result of his guilty plea, Waide was required to pay restitution in the amount of $5,324.12 to Liberty Rehabilitation at the rate of $224/month; pay for investigative costs of $2,400.00 at the rate of $100/month, payable to the Commonwealth of Kentucky; and to serve a twelve (12) month sentence on each count to run concurrent.  The Court further granted Waide probation for a period of two (2) years.   By check dated August 7, 2015, the Office of Attorney General reimbursed the Registry $1,000.00 for its portion of investigative costs in the matter. 


Conclusion: Office of Attorney General assumed jurisdiction of the case as a criminal matter prior to commencement of an investigation by the Registry.  The facts and issues have been addressed  in a criminal prosecution of Waide with the full cooperation of the Registry, including guidance as necessary related to the campaign finance laws under KRS Chapter 121. There being no further issues or facts to be addressed by the Registry, the General Counsel recommended that the case be dismissed as moot.  The Registry Board approved the Order to Dismiss at its September 24, 2015 meeting.