The TL;DR is that I believe that in the course of her consultancy with the Venice Beach BID, Tara Devine qualified as a lobbyist within the meaning of the Los Angeles Municipal Lobbying Ordinance, was therefore required to register with the Ethics Commission, and failed to do so, putting her in violation of the law. If you know what all those terms mean, you may want to go straight to the complaint (Warning: 23MB PDF). For a detailed explanation of the background, though, read on!
The key is found in Section 48.07, which states that “An individual who qualifies as a lobbyist shall register with the City Ethics Commission within 10 days after the end of the calendar month in which the individual qualifies as a lobbyist.” After all, anyone can search the Ethics Commission’s database and see that Tara Devine has never registered as a lobbyist. So the question is whether Tara Devine is “An individual who qualifies as a lobbyist.” This turns out to be a fairly complicated thing to determine.
The first place to start when interpreting any law is with the definitions. In the case of the Municipal Lobbying Ordinance (henceforth “MLO”) they are found at LAMC §48.02. In particular, we will find that the word “lobbyist”:
means any individual who is compensated to spend 30 or more hours in any consecutive three-month period engaged in lobbying activities which include at least one direct communication with a City official or employee, conducted either personally or through agents, for the purpose of attempting to influence municipal legislation on behalf of any person.
And in order to see whether this applies to Tara Devine, we need to understand the following terms:
- Lobbying activities
- Municipal legislation
- Attempting to influence
And once we understand what those three phrases mean, we have to show that Tara Devine was paid for 30 or more hours lobbying on behalf of someone else. The details, as always, are after the break!
Continue reading How I Reported Shadowy BID Consultant Tara Devine To The City Ethics Commission For Failing To Register As A Lobbyist Based On Her Work For The Venice Beach Property Owners Association