The L.A. City Ethics Commission website is a marvelous repository of fascinating minutiae. It more than repays the kind of obsessive poring-over in which we here at MK.Org specialize. Today’s subject is the quarterly reports that every qualified candidate has to submit detailing their expenditures. You can find all of Mike Bonin’s here.¹ In particular, take a look at his 3rd quarter report for 2016. On Schedule E, the list of expenditures, note that some items are labeled “Returned contributions.” No reasons are given for the returns, but at least in some cases it’s possible to track down at least some elements of the story via the Google.

For instance, consider the case of Shannon Murphy Castellani. She gave Mike Bonin $700 on June 14, 2016. Exactly four weeks later, on July 12, 2016, she registered with the Ethics Commission as a lobbyist.² Now, section 470(c)(11) of the City Charter forbids candidates from accepting campaign contributions from registered lobbyists. It’s vague on the timing, and I don’t see that it actually explicitly prohibits someone from donating money and then registering as a lobbyist the very next day, but on the other hand, does Mike Bonin want to argue that case in public? Obviously not, so the best thing to do is to return the contribution. Just as obviously, the $700 itself isn’t so important. These people are all zillionaires, after all. It’s the good will that the $700 creates, and that lingers on after the money is returned.

And isn’t it strange that Shannon Murphy just decided that she had to register as a lobbyist on July 12, 2016?³ It’s not like she just got into the lobbying business. Her firm, M Strategic Communications, seems to have been around since at least 2014, or at least that’s when their website first shows up in the Wayback Machine. She admits right there that since 1999 she “has been managing large-scale communications efforts that successfully position elected leaders and influence public policy-making.” That sure sounds like lobbying, no? And, interestingly, the Charter doesn’t just forbid registered lobbyists from contributing, but also persons “required by ordinance to be registered as a lobbyist or lobbying firm.” In other words, if she was lobbying, and she was, she was already prohibited. Perhaps she just figured this out right after her contribution and that inspired both her registration and the return of the money? There’s certainly no way to find out at this point.

However, it’s instructive to consider the case of her partner in crime (and in her lobbying firm), Chris Modrzejewski. He has been registered to lobby the City since 2004 and has registered like clockwork ever since.⁴ He donated almost $8,000 to campaigns between October 2001 and March 2006. Charter section 470(c)(11) was adopted in November 2006, which is presumably why he stopped giving money that year.⁵

But, beginning in June 2007, just eight months after the law was amended to prohibit contributions by registered lobbyists, his wife, Denise Modrzejewski started making contributions. Her pace has only increased over time, and as of August 2016 she’d given over $31,000 to various candidates. The fact that she didn’t start her career as a big-time donor until directly after her husband had to put an end to his⁶ certainly gives the appearance of some kind of evasion, does it not? In fact, just to bring the story full-circle, Denise Modrzejewski gave Mike Bonin $700 on June 22, 2016, just eight days after Shannon Murphy Castellani’s ill-fated contribution. But Mike Bonin didn’t give that one back. Because, evidently, he’s not required to.⁷

The image of Mike Bonin is a cropped screen capture from this really peculiar advert that Mike Bonin made endorsing Eric Garcetti in 2013. And we see how well *that* turned out. It appears here under a claim of fair use. Or whatever…

1. There’s no reason to suspect that Mike’s antics are significantly more sleazy or interesting than those of his colleagues. I’m just focusing on him this morning because why not?
2. Note that she gave the money under the name of Castellani but registered under the name of Murphy. The principle of charity leads us to assume that this is a matter of professional name v. personal name. Also, if it was an attempt at covering up something it wasn’t effective at all, so it doesn’t hurt the argument to assume the best of intentions.
3. Which seems to be the first time in history she ever registered.
4. I can’t find a way to link through to a lobbyist registration search, but you can find the search form here and conduct your own confirmatory research.
5. Except for one outlier donation to an LAUSD school board candidate in 2014. I don’t know if school board elections are covered under the law or not.
6. Except for one outlier. In September 2004 she gave $500 to Rocky Delgadillo‘s reelection campaign. At that point, according to her disclosure, she was an administrative assistant in Rocky Delgadillo’s office.
7. I’d planned to look into more of these returned contributions, but this one ended up being so rich I just don’t have time. I’ll try to get back to the topic at some point.