In March 2021 self-proclaimed LAPD Northeast Division rank and file officers sent an anonymous complaint to the Attorney General of California against their leaders Arturo Sandoval, Cesar Rivas, and Gina Paialii over a couple of 2020 fundraising raffles widely believed to have been rigged by Sandoval. Here’s a copy of their letter.

They allege that Sandoval rigged the first raffle so that he won the big prize, which was half the money collected. Subsequently, due to the fact that everyone thought the first one was rigged, they held a second raffle a few months later. The complaining rank-and-filers don’t have evidence of rigging, though, although who’d be surprised if it were true?

What they do have evidence of, what’s clear on its face, is that Sandoval, Rivas, and Paialii organized the two raffles on their own, without a non-profit organization being involved. This is, as the complainants note, a crime in California. The Penal Code at §320 forbids lotteries,¹ although at §320.5 and §320.6 it has exceptions for appropriate private non-profit organizations, which can hold lotteries for certain enumerated reasons.

The reasons and the criteria aren’t important in this case, though, because the law is very clear that the non-profit must be private, which LAPD is not.² There are a bunch of other requirements as well, including that the private non-profit must register annually with the state as a lottery-conductor³ before engaging in lottery-conducting. So if Sandoval and the others really did organize these lotteries they did violate §320 PC,⁴ which is a misdemeanor.

Something not stated by the authors of the letter, though, is that this isn’t the only crime they committed. The lottery law has a lot of traps for unwary cops in it! And you know how police and prosecutors love to stack up charges! Here’s a list of the laws that Sandoval and his co-conspirators seem to have broken!

§321 PC: Every person who sells, gives, or in any manner whatever, furnishes or transfers to or for any other person any ticket, chance, share, or interest, or any paper, certificate, or instrument purporting or understood to be or to represent any ticket, chance, share, or interest in, or depending upon the event of any lottery, is guilty of a misdemeanor.

§322 PC: Every person who aids or assists, either by printing, writing, advertising, publishing, or otherwise in setting up, managing, or drawing any lottery, or in selling or disposing of any ticket, chance, or share therein, is guilty of a misdemeanor.

§323 PC: Every person who opens, sets up, or keeps, by himself or by any other person, any office or other place for the sale of, or for registering the number of any ticket in any lottery, or who, by printing, writing, or otherwise, advertises or publishes the setting up, opening, or using of any such office, is guilty of a misdemeanor.

§326 PC: Every person who lets, or permits to be used, any building or vessel, or any portion thereof, knowing that it is to be used for setting up, managing, or drawing any lottery, or for the purpose of selling or disposing of lottery tickets, is guilty of a misdemeanor.

And if the raffle is illegal the state government gets to confiscate the money!⁵ The letter goes on to claim that LAPD Internal Affairs Division is too corrupt to handle this or any other investigations honestly, that they must submit the complaint anonymously because they’re scared of Retaliation and Career Suicide,⁶ and that [t]he overall morale at the LAPD Northeast Division can best be described as being in the TOILET.”⁷

These additional allegations are fascinating, of course, but not really important.⁸ What’s important, essential, is the crimes. Any officers involved in setting up and running the lottery are criminals and at the very least ought to be fired. Sadly, we’ll never know if anyone’s even investigating, such is the state of LAPD secrecy.

1. Raffles are lotteries as defined in §319, which says: A lottery is any scheme for the disposal or distribution of property by chance, among persons who have paid or promised to pay any valuable consideration for the chance of obtaining such property or a portion of it, or for any share or any interest in such property, upon any agreement, understanding, or expectation that it is to be distributed or disposed of by lot or chance, whether called a lottery, raffle, or gift enterprise, or by whatever name the same may be known.
2. Being private is necessary for legal lottery-operating but not sufficient. The sufficiency criteria are really complicated, but since LAPD is public none of that matters.
3. At §320.5(h).
4. Not §320.5 as the letter alleges. That section is the exception to §320 that doesn’t apply to LAPD.
5. This is per §325 PC, which states: All moneys and property offered for sale or distribution in violation of any of the provisions of this chapter are forfeited to the state, and may be recovered by information filed, or by an action brought by the Attorney General, or by any district attorney, in the name of the state. Upon the filing of the information or complaint, the clerk of the court must issue an attachment against the property mentioned in the complaint or information, which attachment has the same force and effect against such property, and is issued in the same manner as attachments issued from the superior courts in civil cases.
6. Idiosyncratic italicization in the original.
7. Again, it’s their weirdo capitalization, not mine.
8. The accusations against IAD are important if true, and wouldn’t surprise anyone, but that kind of thing really does need some evidence.