Opinion Nos. CP99-02 and CP99-03

BEFORE THE NEVADA COMMISSION ON ETHICS

IN THE MATTER OF THE REQUEST FOR OPINION CONCERNING

ALLEGATIONS THAT GENE McGILLIVRAY, Reporter, The Wendover Times,

IMPEDED THE SUCCESS OF THE CAMPAIGN OF

WAIT SANDERS, Candidate for the Office of Mayor of West Wendover, Nevada

 

This Opinion is in response to requests for opinion filed pursuant to NRS 294A.345 and 281.477 with the Nevada Commission on Ethics (Commission) by Wait Sanders against Gene McGillivray.  Request Nos. CP99-02 and CP99-03 were combined for purposes of hearing and adjudication. A hearing on the opinion requests was held on May 27, 1999.  The Commission heard testimony from Mr. Sanders, Mr. McGillivray, John C. Johnson, Jr., Josephine Thaut and Howard Copelan.  At the conclusion of the hearing the Commission publicly deliberated the matter and rendered its decision.  The Commission now issues the Findings of Fact, Conclusions of Law and Opinion which follows.

 FINDINGS OF FACT

1.   Mr. Sanders is the incumbent and candidate for Mayor of West Wendover, Nevada.  Mr. McGillivray is the candidate for same mayoral race.  The general election is scheduled for June 8, 1 999.  

2.   Mr. McGillivray is a reporter for The Wendover Times, a weekly free publication.  Randy Croasmun is the publisher.  The paper employs three workers: Mr. Croasmun, his wife and Mr. McGillivray.  

3.   In the April 2 through 9, 1999 issue of The Wendover Times, Mr. McGillivray wrote an article entitled "Private Morals Do Affect Public Policy" which contain many statements regarding Mr. Sanders, two of which are as follows:

[E]stablishing various businesses in order to cash checks without funds, (according to the Secretary of State for Nevada he has had at least 20 "businesses"). 

and, 

[C]ausing at least half a dozen lawsuits to be filed against him and the city.

 

4.   Mr. McGillivray testified that the number of businesses owned by Mr. Sanders was verified by Paula Walther of the Nevada Department of Taxation. Ms. Walther    told him that Mr. Sanders had over twenty businesses filed with the Secretary of State's office. Because Ms. Walther had provided accurate information in the past, Mr. McGillivray did not feel it necessary to contact the Secretary of State's office directly. 

5.   Mr. Sanders testified that he currently owns twelve businesses. These companies have no subsidiaries. 

6.   Mr. McGillivray testified that he contacted the judicial and municipal courts to verify the number of complaints naming Mr. Sanders as a defendant. 

7.   Mr. Sanders testified that he has been named in only four recent law suits.  Three have not been resolved. The one resolved case names Mr. Sanders individually, not as Mayor. 

8.   Mr. McGillivray testified that he wrote the article shortly before April 2, 1999.  The paper was printed on April 2, 1999 and ran through April 9, 1999 or until no more issues were left on the newspaper stands. Any remaining issues left on the stands would have been removed between 7:00 p.m. and 10:00 p.m. on April 10, 1999 and replaced with the new issue. 

9.   Mr. Sanders filed his bid for candidacy at 3:00 p.m. on April 9, 1999.  He had not officially announced that he would run for office prior to April 9, 1999.  He had not received campaign contributions until after April 9, 1999. 

10.   Mr. McGillivray decided to run for Mayor on April 8, 1999 and filed on April 9, 1999 at 4:45 p.m.  His decision was motivated by another's failure to file for candidacy. 

11.    Mr. McGillivray did not repeat the article or its contents in any campaign literature. 

12.    The April 23 through April 30, 1999 issue of The Wendover Times included the following article written by Mr. Croasmun entitled "Who Got What Award?":  

Referring to the glowing reports to cover an all expense paid trip to

Washington D.C. for West Wendover Mayor Sanders and his entourage, for a week at taxpayers' money, the following should be revealed to the public.

 

Sanders, who had not received any award from a Jerusalem Fund raves on about how humble he felt to be the recipient of it. Sanders did however, receive a letter from someone who had nominated him for this "award."

 

Senator Bryan and his press secretary David Lemmon are not aware of the Senator being involved in any way shape or form.  In fact the press secretary stated that it was impossible for Sanders to have had a photograph taken with the Senator the week prior to Sanders arriving in Washington.

 

He did state that Sanders had given them a copy of a letter in which someone had nominated Sanders for a Israeli award.

 

So begins the campaign. 

13.    Mr. Sanders testified that the Washington, D.C. trip was authorized by the West Wendover City Council in order to negotiate 14,000 acres of Air Force property in West Wendover that was opposed by Tooele County, Utah.  The purpose of this trip was discussed at the West Wendover City Council meeting on April 6, 1999. Mr. McGillivray attended that meeting.  On April 11, 1999, Mr. Sanders was accompanied on this trip by City Manager Keyth Durham and Economic Development Coordinator Chris Melville.  They returned on April 16, 1999. 

14.   On April 6, 1999, Mr. Sanders was notified of his nomination for the Theodore Hertzel Award, an award presented by Israel's Prime Minister in cooperation with the Jerusalem Mayor and the Jerusalem Fund of Aish HaTorah.  While he had not officially received the award, Mr. Sanders claims that it was general knowledge that there was only one nominee and the nominee was the recipient.  The award is to be given in August 1999. 

15.   Mr. Sanders and company arrived in Washington, D.C. on April 11, 1999.  Mr. Sanders received the invitation to the Israeli embassy on April 13, 1999 and visited the embassy on April 15, 1999. 

16.   Shortly before the April 11, 1999 trip, the High Desert Advocate published a generic file photo of Senator Bryan with Mayor Sanders with a story announcing that Mayor Sanders had been nominated for the award.  At no time did the Mayor claim he had his picture taken with the Senator the week prior to their trip to Washington, D.C. 

17.   Mr. McGillivray testified that while the April 23 through 30 issue of The West Wendover Times article was written by Mr. Croasmun, Mr. McGillivray provided investigatory material to Mr. Croasmun.  His investigation consisted of calling Senator Bryan's office and verifying that Mr. Sanders had not visited his office.  This investigation was requested by Mr. Croasmun and was initiated by the photograph published in the High Desert Advocate.  Mr. McGillivray stated that the photograph looked suspicious, as if it had been altered, and the term "file photo" was not indicated on the photograph. 

ANALYSIS, LEGAL CONCLUSIONS AND OPINION

The Commission has jurisdiction over these matters and these parties pursuant to NRS 294A.345 and 281.477 because they are both candidates as defined in NRS 294A.005. 

At issue in these matters is NRS 294A.345(l)(b), which provides:  

1.  A person shall not, with actual malice and the intent to impede the success of the campaign of a candidate, cause to be published a false statement of fact concerning the candidate, including, without limitation, statements concerning:

 

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(b) The profession or occupation of the candidate. (Emphasis added.) 

According to NRS 281.477(7), the person who makes the request (in this case Mr. Sanders) bears the burden of proving the elements of the offense under NRS 294A.345 by clear and convincing evidence.  

The Commission concluded that Mr. Sanders did not meet his high burden of proof against Mr. McGillivray.

Regarding the April 23 through April 30, 1999 publication of The Wendover Times, the evidence established that while Mr. McGillivray provided the information for the article, he did not write the article nor cause the writer to form an implication that Mr. Sanders mislead the citizens of West Wendover by traveling to Washington, D.C. for his own personal business.  Mr. McGillivray stated that he had given Mr. Croasmun, publisher of the paper and writer of the article, all of the information he had gathered, including the primary purpose for the trip.  Taken at face value, the article expressed factual truths that a) Mr. Sanders traveled to Washington, D.C. with an "entourage" at tax payers expense, b) he had not received an award from the Jerusalem Fund, even though he claimed he had and c) he did not meet with Senator Bryan. Unfortunately, Mr. Croasmun chose to ignore the real purpose of the trip in his article and gave it a misleading slant.  Mr. Sanders did not travel for personal reasons, but in his official capacity as Mayor in an attempt to negotiate 14,000 acres of Air Force property in West Wendover.  Despite the fact that a reader would come to an incorrect conclusion regarding the Washington, D.C. visit, there is no evidence that Mr. McGillivray encouraged or coerced Mr. Croasmun to write the article as he had. 

The April 2 through April 9, 1999 article required closer inspection.  There was a jurisdictional question as to whether Mr. Sanders or Mr. McGillivray were candidates at the time the article was published.  The Commission reviewed and applied the statutes defining "candidate" and "publish" in order to assist in its determination. 

NRS 294A.005 defines "candidate" as any person:

 

1. Who files a declaration or affidavit of candidacy;

2. Who files an acceptance of candidacy;

3. Whose name appears on an official ballot at any election; or 4. Who has received contributions in excess of $1 00.

 

NRS 294A.345(5)(b) defines "publish" as:

[T]he act of printing, posting, broadcasting, mailing, speaking or otherwise disseminating. 

The testimonial evidence revealed that Mr. McGillivray was not a "candidate" at the time that he wrote the April 2, 1999 piece, nor did he intend to run for mayor at that time.  Further, Mr. Sanders had not officially announced his bid for re-election prior to April 9, 1999. The question remains as to whether, by virtue of a weekly publication, the article was considered disseminated on April 9, 1999, the date that both gentlemen filed as candidates. 

Mr. McGillivray wrote the article on or before April 1, 1999. The article was printed in The Wendover Times on April 2, 1999 to remain on the newspaper stands until between 7:00 p.m. to 10:00 p.m. on April 10, 1999 or until all the newspapers had been removed by consumers.  No one could testify whether any copies of the publication remained on the news stands on April 9, 1999. 

Mr. Sanders filed his candidacy for mayor on April 9, 1999 at 3:00 p.m.  He had not received any campaign contributions prior to April 9, 1999. 

Mr. McGillivray filed on April 9, 1999 at 4:45 p.m.  He had no intention of running for mayor prior to April 8, 1999 or at the time he wrote the article.  He had not received any campaign contributions prior to April 9, 1999. 

The Commission reviewed the facts and determined that "disseminating", as used in NRS 294A.345(5)(b) for the purposes of defining "publish", is to be applied to the date that the April 2, through April 9, 1999 newspaper was placed on the news stands.  There is no evidence that any issues of the paper remained on the stands when the gentlemen filed their bids on April 9, 1999.  Because of the vagueness of whether the information was available for public consumption on April 9, 1999, the Commission determined that dissemination occurred on April 2, 1999 for purposes of this opinion request. 

Because Mr. McGillivray and Mr. Sanders were not candidates at the time that the article was disseminated, the Commission determined that the requirements for NRS 294A.345 were not satisfied.  Therefore, the Commission did not have jurisdiction to review this matter. 

CONCLUSION

Based upon the record, the Commission concluded that Mr. McGillivray did not violate NRS 294A.345(l)(b) with regard to the April 2 through April 9, 1999 Wendover Times article because he and Mr. Sanders did not meet the statutory requirement of candidate at the time Mr. McGillivray's article was published. 

With regard to the April 23 through April 30, 1999 Wendover Times article, the Commission concluded that since Mr. McGillivray did not author or influence the author of the article to mislead the public or have any control over the article's contents, he did not violate NRS 294A.345(l)(b). 

Because no violations were found, no sanctions were considered by the Commission. 

COMMENT

It is specifically noted that the foregoing Opinion applies only to these specific facts and circumstances.     The provisions of the Nevada Revised Statutes quoted and discussed above must be applied on a case-by-case basis, with results which may vary depending on the specific facts and circumstances involved. 

DATED:  June 30, 1999. 

NEVADA COMMISSION ON ETHICS 

By:  /s/  Mary E. Boetsch, Chairwoman