CHRISTINE GAITER FOR MAYOR
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WFPD Campaign Finance Complaint, Full Transparency Report
Transparency Report · Christine Gaiter for Mayor

Wellington Fire Protection District
Campaign Finance Complaint

A full account of what was filed, what the State found, and what it means with all source documents.

A note from Christine: I believe residents deserve the full picture not a summary shaped by politics. Below is the complete story, the honest outcome, and every document for you to review yourself.
Section 01

What This Is About

In the summer of 2025, the Wellington Fire Protection District (WFPD) paid $14,500 in public funds to a political research firm called Magellan Strategies to conduct a survey of 520 registered voters. The survey tested support for a proposed sales tax ballot measure and included a series of questions (T12 through T20) that presented one-sided arguments in favor of the measure before re-asking respondents how they would vote.

A Wellington resident who received the survey contacted me, saying it made them feel pressured and manipulated. I investigated independently by filing a CORA (Colorado Open Records Act) request, obtaining the invoice, reviewing the full survey, and listening to recorded board meetings. Based on what I found, I filed a campaign finance complaint with the Colorado Secretary of State on July 28, 2025.

The State investigated. Ultimately, the complaint was dismissed, not because the concern was unfounded, but because of a specific legal technicality around timing. Below is the full account.

Key Facts at a Glance

$14,500 of public funds · Magellan Strategies push-poll survey · 32 questions including one-sided persuasion sequence · Survey conducted May 30 through June 10, 2025 · Board voted to place measure on ballot July 16, 2025 · Complaint filed July 28, 2025 · State investigation opened January 29, 2026 · Motion to dismiss filed February 2, 2026

Section 02

Timeline of Events

October 14, 2024
Board First Discusses Survey
At a board meeting, Fire Chief Todd Germain presented a proposal from Magellan Strategies to conduct a voter survey at a cost of $14,500. The stated purpose was to gauge support for a possible sales tax ballot measure.
April 16, 2025
Chief Discusses Campaign Strategy at Board Meeting
At the April board meeting, Chief Germain described planned survey questions and stated the district could argue that a sales tax "allows people from outside the district to help pay for fire services." A director added language used in the survey framing.
May 30 through June 10, 2025
Survey Conducted
Magellan Strategies fielded the 32-question survey to 520 registered voters. Questions T12 through T20 presented a series of pro-ballot-measure statements before re-asking respondents how they would vote, a structure commonly known as a push poll.
June 18, 2025
Chief Discusses Coordinated PR Campaign
At the June board meeting, Chief Germain stated he had met with firefighters and the union and that "we are ready to go with a PR campaign" and "we all feel this is an important measure." The board reviewed survey results showing 65% support and tabled the vote.
July 16, 2025
Board Votes 3 to 1 to Place Measure on Ballot
The board formally voted to move forward with placing the sales tax measure on the November 2025 ballot. This vote, occurring after the survey, became the key legal turning point in the complaint.
July 28 and 29, 2025
Complaint Filed with Colorado Secretary of State
After obtaining the Magellan invoice via CORA request, I filed a campaign finance complaint alleging WFPD violated §1-45-117 C.R.S. by using public funds to promote a ballot measure. The State received and logged the complaint the following day.
August 7, 2025
State Issues Notice of Initial Review, Sufficient Basis Found
The Colorado Secretary of State's Elections Division completed its initial review and formally determined the complaint was timely filed, identified potential violations, and alleged sufficient facts to support a legal and factual basis. WFPD was given 10 business days to cure.
August 21, 2025
WFPD Declines to Cure
Rather than curing the alleged violation, WFPD submitted a Notice of Intent to Cure disputing that any violation occurred. The State was then required to conduct a full investigation.
September 24, 2025
WFPD Submits Sworn Responses and Documents
In response to the State's formal information request, WFPD submitted sworn statements and supporting documents for the Division's review.
January 29, 2026
State Issues Formal Notice of Investigation
After completing its full investigation, the State issued a Notice of Investigation confirming the complaint had survived initial review and that the Division must decide within 30 days whether to file with a Hearing Officer.
February 2, 2026
State Files Motion to Dismiss
The Division filed a Motion to Dismiss, not on grounds that the concern was frivolous, but on a specific statutory timing question: the law only prohibits public spending to influence voters on a measure that has already been referred to the ballot. The survey was conducted before the July 16 referral vote.
Section 03

Why the Complaint Was Dismissed and What It Means

The dismissal came down to a single legal question about the timing of the survey relative to the board's referral vote. Here is what the law says and how the State applied it.

The Law

Colorado's Fair Campaign Practices Act (§1-45-117 C.R.S.) prohibits any government entity from spending public money to urge voters to support or oppose a ballot measure that has been referred to voters. The critical phrase is past tense: "has been referred."

The State's Reasoning

The State determined that because the survey ran from May 30 through June 10, 2025, and the board did not vote to place the measure on the ballot until July 16, 2025, the survey occurred before the measure was formally referred. Therefore, the statutory prohibition had not yet been triggered at the time of the expenditure.

The Division has determined that there is not sufficient information supporting the allegations in the Complaint that Respondent violated section 1-45-117, C.R.S., because the Board had not referred the sales tax measure to the ballot as of the time the survey was conducted.
Colorado Secretary of State, Motion to Dismiss, February 2, 2026

What This Means Honestly

The dismissal does not mean the survey was appropriate, neutral, or a good use of public funds. It means the law as currently written has a gap: a public entity can spend taxpayer money on polling and persuasion research before formally voting to put a measure on the ballot, even when that polling is clearly designed to support a future campaign.

Christine's Honest Assessment

I accept the State's legal finding. I filed in good faith based on legitimate evidence, and the State agreed the complaint had sufficient factual basis to warrant a full investigation. The legal line simply fell on the other side of the survey's timing. I still believe residents should ask whether this is the right use of public funds and whether the law should close this gap.

Section 04

Questions & Answers

These are the most common questions being asked about this matter, answered directly.

Why did you file a complaint for another person?

I didn't. I filed in my own name, as the complainant of record, based on my own independent research. A resident's experience was the tip that prompted me to investigate. I then did the work myself by filing a CORA request, obtaining the invoice, reviewing the survey questions, and listening to board meeting audio. Any citizen has the legal right to file a campaign finance complaint under Colorado law.

Why did you file based on someone feeling manipulated? Was there any evidence?

The "feeling manipulated" was the starting point, not the basis of the complaint. The actual evidence I submitted included: the Magellan invoice showing $14,500 of public funds explicitly spent to measure ballot measure support; the survey itself showing a push-poll structure in questions T12 through T20; and board meeting audio from April and June 2025 in which the Fire Chief described a coordinated PR campaign with the union. The Colorado Secretary of State independently reviewed this and found sufficient factual and legal basis to open a formal investigation.

Why did you reference the investigation in ads against the ballot measure?

The ads referencing the $14,500 expenditure were produced by Stop Wellington Tax Hike, a separate political committee opposing the WFPD sales tax, not my mayoral campaign. The ad in question used the word "allegedly" and referenced a matter of public record. Campaign finance complaints are explicitly public information under Colorado law, and the complaint form itself states this. Referencing a pending government investigation in political speech is both legal and factually grounded.

Does the dismissal mean the complaint had no merit?

No. The State found sufficient factual and legal basis to proceed past the initial review and open a full investigation. The complaint was dismissed at the end of that investigation on a narrow legal question about statutory timing, not because the concern was frivolous or the evidence was weak. The law simply did not reach the survey because it occurred before the board formally voted to refer the measure to the ballot.

Are you saying WFPD broke the law?

No. The State's finding is that they did not violate the law as written. I accept that finding. What I do believe is that spending $14,500 in public funds on a survey explicitly designed to test and build support for a ballot campaign, before formally announcing it, raises legitimate questions about transparency and the appropriate use of taxpayer money, even when it falls within legal limits.

Section 05

Source Documents

All documents in this matter are public record. Review them yourself.

□
Complaint · Filed
Campaign Finance Complaint (2025-31)
Filed July 28 and 29, 2025
Original Filing
□
Invoice · Evidence
Magellan Strategies Invoice, $14,500
Dated June 19, 2025 · BOD Approved
Supporting Evidence
□
Survey · Evidence
Magellan Survey Topline Results
Fielded May 30 through June 10, 2025
32 Questions · 520 Voters
□
State Action · Initial Review
Notice of Initial Review & Opportunity to Cure
Issued August 7, 2025
Sufficient Basis Found
□
State Action · Investigation
Notice of Investigation
Issued January 29, 2026
Full Investigation Opened
⚖️
State Action · Outcome
Motion to Dismiss
Filed February 2, 2026
Dismissed on Timing
Note on Document Access

All State documents (complaint, notices, and motion to dismiss) are public record and can be obtained from the Colorado Secretary of State's Elections Division. The survey results and invoice were obtained via CORA request and are included in the complaint filing.

Section 06

A Response to Fire Chief Germain's Public Statement

Chief Germain posted a public statement to voters following the dismissal. Several claims in that statement are inaccurate or incomplete, and residents deserve a direct response.

Chief Germain's Statement (paraphrased)

The Chief stated that the complaint was dismissed due to "lack of sufficient evidence," that WFPD's only options were to accept or challenge the complaint, that I "repeatedly" and misleadingly stated they were under investigation, and that the Secretary of State's process confirmed they "conducted themselves professionally and lawfully."

"Dismissed due to lack of sufficient evidence"

This is not accurate. The Colorado Secretary of State's own documents tell a different story. On August 7, 2025, the State issued a Notice of Initial Review formally determining that the complaint was timely filed, identified potential violations of Colorado campaign finance law, and alleged, in the State's own words, "sufficient facts to support a legal and factual basis." The complaint survived initial review and proceeded to full investigation.

The dismissal that followed was not based on a lack of evidence. The State's Motion to Dismiss makes the reason explicit: the law prohibits public spending to influence voters on a measure that has been referred to the ballot, and the survey was conducted before the board's July 16 referral vote. That is a legal timing question, not an evidence question. Those are two very different things.

"Our only options were to accept the allegation or challenge it"

There was a third option the Chief did not mention: cure. The State gave WFPD ten business days, until August 21, 2025, to cure the alleged violation and demonstrate substantial compliance with the law. The District declined to do so. Under Colorado law, declining to cure required the State to conduct a full investigation. The extended timeline the Chief references was a direct result of that choice.

"The complainant repeatedly stated we were under investigation"

The District was under investigation. That is not a characterization. It is the title of the document the State issued on January 29, 2026: Notice of Investigation. That document states in plain language that the Division conducted its investigation and must decide whether to file a complaint with a Hearing Officer. Stating that a government agency issued a Notice of Investigation is not misleading. It is factually accurate, and the document is public record.

"Conducted ourselves professionally and lawfully"

The State's narrow legal finding was this: the survey was conducted before the measure was formally referred to the ballot, so the specific statutory prohibition did not apply at that moment in time. The State made no finding that the survey was neutral, that it was an appropriate use of public funds, or that the board's discussions of campaign strategy at the April and June board meetings were proper. The finding was about statutory timing and nothing more.

The Wellington Fire Protection District paid $14,500 in public funds to a political research firm to conduct a survey that presented one-sided arguments in favor of a ballot measure before re-asking respondents how they would vote. Board meetings on record show the Fire Chief describing a coordinated PR campaign with the union. The State found a legal gap in the timing of the statute. That gap is real, and I accept the State's legal conclusion. But acting within the law and acting transparently with public funds are not the same thing. Wellington residents deserve to know the difference.

On the Record

All documents referenced in this response are public record and available for any resident to review. The complaint, the Notice of Initial Review, the Notice of Investigation, and the Motion to Dismiss are all included in the document section of this page.

Section 07

A Final Word

I ran for mayor because I believe Wellington residents deserve local government that is transparent, accountable, and careful with public money. Filing this complaint was an act of civic accountability, not a political attack. I did it the right way: I gathered evidence, used legal channels, and let the State make the determination.

I am genuinely glad to know the District did not violate election law. The law has a gap that WFPD's timing happened to fall into, and I accept the State's finding. But I would make the same decision again, because residents deserved to know how their money was being spent and now they do.

Every document is above. Judge for yourself.

Christine Gaiter, Candidate for Mayor of Wellington

Questions? Reach out directly. I believe in talking to residents, not past them.

Christine Gaiter for Mayor · Wellington, Colorado · Paid for by Christine Gaiter for Mayor
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