Missouri Ethics Commission v. Philip Levota

CourtMissouri Court of Appeals
DecidedDecember 14, 2021
DocketWD84233
StatusPublished

This text of Missouri Ethics Commission v. Philip Levota (Missouri Ethics Commission v. Philip Levota) is published on Counsel Stack Legal Research, covering Missouri Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Missouri Ethics Commission v. Philip Levota, (Mo. Ct. App. 2021).

Opinion

In the Missouri Court of Appeals Western District

MISSOURI ETHICS COMMISSION, ) Respondent, ) WD84233 v. ) ) PHILIP LEVOTA, ) FILED: December 14, 2021 Appellant. )

APPEAL FROM THE CIRCUIT COURT OF COLE COUNTY THE HONORABLE PATRICIA S. JOYCE, JUDGE

BEFORE DIVISION THREE: LISA WHITE HARDWICK, PRESIDING JUDGE, GARY D. WITT AND EDWARD R. ARDINI, JR., JUDGES

After the Missouri Ethics Commission (“MEC”) determined that Philip

LeVota violated campaign finance laws and issued two $10,000 civil fees against

him, LeVota appealed to the Administrative Hearing Commission (“AHC”). The

AHC disagreed with the MEC and found that LeVota did not violate campaign

finance laws and was not subject to a civil fee. The circuit court reversed the

AHC’s decision. On appeal, the MEC seeks review of the AHC’s decision,

contending that the AHC erred in finding that LeVota could not be held liable

because he was not associated with a continuing committee and did not use

committee contributions for impermissible purposes. The MEC further argues

that the AHC erred in finding that the MEC needed to include an argument as an affirmative defense and in stating that it was reviewing the MEC’s order of only

one $10,000 fee. For reasons explained herein, we affirm the AHC’s decision that

LeVota did not violate Section 130.034, RSMo 2016,1 but reverse the AHC’s

decision finding LeVota not liable for violating Section 130.031.2. We remand the

case to the circuit court with directions to remand the case to the AHC. The AHC

is directed to remand the case to the MEC. The MEC is directed to order the

appropriate penalty for LeVota’s violation of Section 130.031.2.

FACTUAL AND PROCEDURAL HISTORY

In April 1998, the Show-Me Council (“Council”), a continuing committee as

defined by Section 130.011(10),2 was formed and registered with the MEC. The

MEC statement of committee organization for the Council listed Chris Whiting as

its treasurer and LeVota as its chairman. In January 2000, the Council filed an

amended statement of committee organization listing LeVota as its treasurer. No

other officers were listed on the form. According to LeVota, he ceased being

chairman of the Council at that time and was only the Council’s treasurer. In July

2003, the Council filed another amended statement of committee organization

1 All statutory references are to the Revised Statutes of Missouri 2016.

2 Section 130.011(10) defines a “continuing committee,” in pertinent part, as:

[A] committee of continuing existence which is not formed, controlled or directed by a candidate, and is a committee other than a candidate committee or campaign committee, whose primary or incidental purpose is to receive contributions or make expenditures to influence or attempt to influence the action of voters whether or not a particular candidate or candidates or a particular ballot measure or measures to be supported or opposed has been determined at the time the committee is required to file any statement or report pursuant to the provisions of this chapter.

2 listing LeVota’s wife, Katherine Stepanek, as the Council’s treasurer. Again, no

other officers were listed on the form. According to LeVota, he has not held any

position with the Council since that time.

Since its formation, the Council has maintained a bank account at UMB with

Whiting and LeVota as signatories on the account. When Stepanek attempted to

become a signatory after she became the Council’s treasurer, she was unable to

do so because UMB required Whiting to be present. Stepanek has never been

made a signatory on the Council’s account.

$4,000 and $950 Withdrawals from the Council’s Account

In 2013, the Committee for Research Treatment and Cures (“CRTC”)

approached LeVota to assist as a campaign consultant with a ballot issue. The

CRTC was to pay LeVota $4,750 for his services. On November 1, 2013, the CRTC

wrote a check to the Council for $4,750. On the CRTC’s itemized expenditures

form that it filed with the MEC, it listed the purpose of this expenditure to the

Council as “leaflet distribution and endorsement support.” The CRTC’s check was

deposited in the Council’s bank account.

LeVota subsequently submitted an invoice to the Council for $4,950. The

invoice, dated November 15, 2013, stated that it was “[f]or campaign efforts

relating to support for Jackson County’s Ballot Question 1 on the November 5,

2013 ballot. Consisting of direction and consultation with the Translational

Research Committee and the Committee for Research Treatments and Cures’

efforts.” On September 30, 2014, LeVota withdrew $4,000 in cash from the

3 Council’s account. LeVota then purchased a cashier’s check, made payable to

Chase Card Services, for that amount and listed himself as the remitter. He used

the check to pay his business credit card. On May 4, 2015, LeVota wrote a check,

made payable to “cash,” on the Council’s account for $950. According to LeVota,

Stepanek authorized both the $4,000 and $950 withdrawals as payment to him for

the services he provided as a vendor.

The Council did not file quarterly disclosure reports with the MEC listing the

CRTC’s $4,750 contribution or the Council’s $4,000 and $950 expenditures to

LeVota. Instead, the Council filed committee statement of limited activity reports

on January 13, 2014, October 13, 2014, and July 7, 2015. Each of these reports

contained a certification by Stepanek that, for the quarter covered by the report,

“neither the aggregate amount of contributions received nor the aggregate

amount of expenditures made by the committee exceeded five hundred dollars.”

$360 Withdrawal from the Council’s Account

On January 17, 2014, LeVota withdrew $360 in cash from the Council’s

bank account and donated it to the Season of Sharing (“SOS”) Foundation. The

SOS Foundation is a charity that passes out money to people in Kansas City

around Christmastime. A news article about the SOS Foundation, which was

posted online on December 16, 2015, described the SOS Foundation as a “brand

new local nonprofit that will help those in need around the holidays.” The SOS

Foundation was incorporated by LeVota and another person as a nonprofit public

corporation on September 16, 2016. The SOS Foundation credited the Council for

4 the $360 donation on its “Official Donation Receipt For Income Tax Purposes”

form, dated January 30, 2014. According to LeVota, Stepanek authorized the $360

withdrawal from the Council’s account and donation to the SOS Foundation.

MEC’s Audit of the Council, Consent Order, and Complaint Against LeVota

In 2015, a citizen filed a complaint with the MEC alleging campaign finance

violations in an Independence City Council election. The complaint named three

entities: the Council; Stepanek, as the Council’s treasurer; and LeVota. While

investigating this complaint, the MEC initiated an audit of the Council due to

compliance issues found while conducting the investigation. Following the audit,

the MEC filed a 12-count complaint; nine counts were against the Council and

Stepanek, and three counts were against LeVota.

In January 2017, the Commission entered a consent order against the

Council and Stepanek resolving the nine counts against them. The Council and

Stepanek stipulated to seven violations, including four related to the transactions

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Bluebook (online)
Missouri Ethics Commission v. Philip Levota, Counsel Stack Legal Research, https://law.counselstack.com/opinion/missouri-ethics-commission-v-philip-levota-moctapp-2021.