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compliant with adopted City policy. The approval of this event in <br /> Anaheim suggests a "rubber-stamp" authorization, potentially <br /> driven by political considerations, such as securing Council votes <br /> for future administrative actions, including the City Manager's- <br /> compensation or contract renewal. <br /> ® Unauthorized Expenditure (Penal Code § 424): If the <br /> expenditure was made without the requisite staff eligibility <br /> determination, City Manager sign-off, or in deliberate <br /> contravention of the policy's clear requirements, it could trigger <br /> concerns regarding misappropriation or unauthorized <br /> disbursement of public funds by both the Councilmember and <br /> the approving staff. <br /> C. Potential Violations of State Law (Immediate City Attorney <br /> Review Required) <br /> The City Attorney must investigate the following potential violations of <br /> State Law. <br /> • Impermissible Gift of Public Funds (Cal. Const. art. XVI, § <br /> 6): Public funds may only be expended for a specific, <br /> identifiable public purpose benefiting the governmental body <br /> making the expenditure. Absent compelling documentation <br /> proving the direct benefit to Santa Ana residents that overrides <br /> the public interest of a neighboring city, the payment risks being <br /> deemed an unconstitutional gift of public funds. <br /> • Misuse of Public Resources (Gov. Code § 8314): This code <br /> section prohibits the use of public resources for campaign <br /> activities. The timing and location of the sponsorship---directly <br /> within the official's Assembly campaign district—requires a full <br /> review of whether the expenditure functioned as de facto <br /> campaign positioning, voter access, or political promotion, <br /> thereby implicating § 8314. <br /> II. Required Actions for Accountability & Recovery <br /> Based on the evidence and the urgent need to restore public trust and <br /> protect taxpayer funds, I demand the following rock-solid actions be <br /> taken immediately: <br /> A. Immediate Document. Release and Administrative Review <br /> • Mandatory Production: The City must immediately obtain and <br /> publicly release the specific approval documents I requested: <br /> the Donation Request Form (DRF), the staff eligibility review <br /> notes, the official City Manager sign-off documentation, the W- <br /> 9/vendor paperwork, and the final payment voucher, (Must be <br /> produced pursuant to my concurrent CPRA Request.) <br /> 3 <br />