Los Angeles City Ethics Commission
200 North Spring Street, 24th Floor
Los Angeles, CA 90012
ethics.commission@lacity.org
Re: Formal Ethics Complaint Against Councilmember Traci Park (CD11) for Repeated Violations of L.A. Administrative Code Sec. 49.5.5 (Misuse of City Position, City Staff, and City Resources for Campaign Activity)
To the Los Angeles City Ethics Commission:
I am writing to formally request an investigation into Councilmember Traci Park (Council District 11) for what appears to be a clear, repeated, and documented pattern of violations of Los Angeles Administrative Code Section 49.5.5 — Misuse of City Position or Resources. The evidence set forth below consists of publicly available social media posts demonstrating that Councilmember Park has used her official City platform, City staff, and City resources to advance her personal reelection campaign on multiple occasions.
A central and recurring violation across multiple incidents is the suspected use of City staff and City equipment to produce campaign content for Councilmember Park’s personal reelection Instagram account (@traciparkforla). The evidence for this is the simultaneous or near-simultaneous publication of content from the same event to both her official City council account (@councilwomantracipark) and her campaign account. In each instance, someone — almost certainly a City staff member using City equipment and City time — was responsible for capturing, editing, and publishing that content. When the same session of content production feeds both a City account and a campaign account, the City resources used to produce it have been misused for campaign purposes in violation of Sec. 49.5.5(B)(4).
Incident 1: City Employee Carol Williams Participating in Campaign Events
Perhaps the most direct evidence of a violation of Sec. 49.5.5(B) and (C) involves Carol Williams, who is identified on the CD11 office staff directory as a City of Los Angeles Homeless Outreach Liaison, a paid City agency employee. (https://cd11.lacity.gov/about/team-traci) Ms. Williams is readily identifiable by her distinctive red hair.
Photographic evidence places Ms. Williams at multiple Traci Park campaign events:
First, Ms. Williams appears in a group campaign photo in which attendees are holding “Traci Park” campaign signs, standing alongside Councilmember Park at what is clearly a campaign rally or canvassing event. (https://www.instagram.com/p/DT9GAb7AYWD/?hl=en&img_index=1)
Second, and more seriously, Ms. Williams appears to be actively working a campaign merchandise and volunteer table — this is a pinned post that appears at the beginning of Park’s campaign Instagram feed — wearing a teal campaign-colored shirt and handling campaign t-shirts and campaign signs that read “Traci Park — For Los Angeles Council District 11 — Vote by June 3rd.” This constitutes direct participation in campaign activity by a City agency employee in apparent violation of Sec. 49.5.5(B). (https://www.instagram.com/traciparkforla/reel/DWZQ44rETgA/?hl=en)
Under Sec. 49.5.5(C), a person shall not induce or coerce another person to engage in activity prohibited under Subsection B. The presence of a City Homeless Outreach Liaison — a subordinate City employee — actively working a campaign merchandise table raises the serious question of whether Councilmember Park directed, induced, or permitted a City employee under her office’s supervision to engage in prohibited campaign activity. The Commission is respectfully asked to investigate whether Ms. Williams was participating in these campaign events on City time, and whether she was directed to do so by Councilmember Park or her office.
Incident 2: Direction of City Staff to Solicit Campaign Signage from Businesses
It has further been reported that Councilmember Park’s CD11 office staff, including Carol Williams and Michael Amster, have been dispatched during regular City business hours to pressure small businesses across the district to display her campaign signage in their windows. This constitutes a misuse of City staff time for campaign purposes and potentially implicates coercion of private parties in violation of Sec. 49.5.5(C).
Incident 3: Sea Lion Release Event
Official account post: https://www.instagram.com/councilwomantracipark/reel/DXr7vW1E7MR/
Campaign account post: https://www.instagram.com/traciparkforla/reel/DXr35SGl-Qu/?hl=en
Identical video content from the same public event was published at approximately the same time to both Councilmember Park’s official City council account (@councilwomantracipark) and her personal campaign reelection account (@traciparkforla). The near-simultaneous publication to both accounts from the same event session is strong evidence that City staff, using City equipment and City time, were responsible for capturing and producing the content. Under Sec. 49.5.5(B)(4), City officials may not use City equipment, resources, or staff to produce or distribute campaign material. When a single production session — captured on City time with City equipment by City staff — results in content being published to a campaign account, those City resources have been directly misused for campaign purposes. There is no legitimate governmental purpose that explains the simultaneous publication of the same content to a campaign account.
Incident 4: CicLAvia West LA Event
Official account post #1: https://www.instagram.com/councilwomantracipark/p/DXp5ByCGTY3/
Official account post #2: https://www.instagram.com/councilwomantracipark/reel/DXmgXtrk5qN/
Campaign account post: https://www.instagram.com/traciparkforla/p/DXmqbsIoP8S/?hl=en
Content from the CicLAvia West LA event was again published simultaneously to both the official City council account and the campaign account. As with the Sea Lion Release Event, the simultaneous dual-account publication is evidence that City staff using City equipment and City time produced content that was then distributed to a campaign account in violation of Sec. 49.5.5(B)(4).
This incident carries an additional aggravating element: the official City council account caption explicitly states “Such a great day on the Westside with @ciclavia and Team CD11!” — directly naming City Council District 11 staff as present and participating. This confirms that taxpayer-funded City employees were deployed at the event where the campaign content was simultaneously produced. “Team CD11” is referenced in campaign content across multiple incidents, establishing a systemic pattern rather than an isolated occurrence.
Incident 5: Baywatch Filming Visit at Venice Beach — April 22 (Weekday)
Official account post: https://www.instagram.com/councilwomantracipark/reel/DXdVpj3kyUa/
Campaign account post: https://www.instagram.com/traciparkforla/p/DXcrDoFko9S/?hl=en
On April 22 — a weekday — Councilmember Park visited the Baywatch television production set at Venice Beach and published content from that visit to both her official City council account and her campaign account. The campaign account post was published during the middle of the business day and was publicly called out by a constituent commenter: “Uh, I thought you’re not supposed to campaign during business hours. Clearly a campaign post, done on a weekday, during the middle of the day.”
The simultaneous publication of content to both accounts from the same visit is consistent with the pattern established across other incidents: City staff, using City equipment on City time, produced content that was then used for campaign purposes. The official City council account post leveraged her City-verified title to amplify the same appearance, garnering over 450 likes and 47 comments — significant public reach generated through a City platform for what was simultaneously a campaign activity. There is no identifiable official City business purpose served by visiting a commercial television production set during working hours.
Incident 6: Bundy Triangle Night Market — March 27/28
Official account post: https://www.instagram.com/p/DWaTBSdE3d9/
Campaign account post: https://www.instagram.com/traciparkforla/p/DWb7ERKFAot/?hl=en
On March 27–28, Councilmember Park attended the Bundy Triangle Night Market and published content to both her official City council account (March 27) and her campaign account (March 28). The two posts are identifiably from the same visit: Councilmember Park is wearing an identical outfit in both — the same green dress, denim jacket, and distinctive scarf — confirming a single production session. As with the other cross-posting incidents, this is evidence that City staff using City equipment and City time produced content that was subsequently used for campaign purposes, in violation of Sec. 49.5.5(B)(4).
Two additional elements are notable here. First, the campaign account post explicitly states “Thank you @all_myvintage for the incredible scarf,” referencing a vendor gift received during the same visit documented on the official City account. The receipt of a gift from a vendor at an event attended in an official City capacity, which then appears in campaign content, may warrant separate review under the City’s gift disclosure requirements. Second, a branded “Traci Park” campaign tote bag is visible in the campaign account photo, indicating that campaign materials were physically present at an event simultaneously being documented through the official City council platform.
Incident 7: VeniceFest / VeniceLoveFest — March 21/22
Official account post #1: https://www.instagram.com/councilwomantracipark/reel/DWK_Ipqk5eH/
Official account post #2: https://www.instagram.com/councilwomantracipark/reel/DWKsbILk1bb/
Campaign account post: https://www.instagram.com/traciparkforla/reel/DWM_A4LEiO5/?hl=en
On March 21–22, Councilmember Park attended the VeniceFest/VeniceLoveFest event and again published content to both accounts. Both posts feature the same “VENICE” hoodie, confirming a single production session. The dual-account publication pattern again points to City staff producing content on City time and equipment that was then distributed to the campaign account in violation of Sec. 49.5.5(B)(4).
This incident introduces two additional aggravating elements. First, the official City council account post depicts Councilmember Park leaning out of a City of Los Angeles Sanitation Department vehicle — a City-owned asset bearing the official City of Los Angeles seal — constituting the use of a City vehicle in connection with content that simultaneously fed campaign promotion, in direct violation of Sec. 49.5.5(B)(4). Second, the campaign account post again explicitly references “Team CD11” — the third documented instance in which City Council District 11 staff are credited in campaign content — confirming the systemic deployment of City employees at events where campaign content is simultaneously produced.
Incident 8: Baywatch Set Visit (Second Visit) — March 19/20
Official account post: https://www.instagram.com/councilwomantracipark/reel/DWF4Lick5q0/
Campaign account post: https://www.instagram.com/traciparkforla/reel/DWHiBMxAeAe/?hl=en
On March 19, the official City council account published content from the Venice Lifeguard Tower/Baywatch production set. The following day, the campaign account published content from the same visit — identifiable by the matching navy and white outfit — with overtly electoral messaging: “My economic plan is happening in real time. We’re creating actual jobs, launching new businesses, and putting the Westside on the world stage.” As with the other cross-posting incidents, the dual-account publication from a single event session is evidence that City staff used City equipment and City time to produce content that was then repurposed for campaign messaging in violation of Sec. 49.5.5(B)(4).
This is the second documented instance of Councilmember Park visiting the Baywatch production set and using the same appearance to generate both official City council content and personal campaign content. The repetition reinforces that the dual-account strategy is deliberate and systematic. A commenter on the campaign post tags @councilwomantracipark alongside campaign hashtags #tracipark and #better11, directly linking the two accounts to the same production session.
The conduct described above implicates multiple subsections of Sec. 49.5.5:
The Ethics Commission’s own published guidance is unambiguous: political activity includes “posting comments on social media or other Internet sites,” and City officials may not engage in such activity “in any manner that implies the City official is speaking on behalf of the City,” including by “using a City title or position.” Posting campaign content from an account bearing her official City title, and producing that content using City staff and City equipment, does exactly that.
Councilmember Park is not an uninformed officeholder who stumbled into these violations. Before entering electoral politics, she spent approximately twenty years as a municipal attorney at Burke, Williams and Sorensen, a firm specializing in representing public entities, including in employment discrimination defense. Burke, Williams and Sorensen maintains a full-service employment law practice representing public and private employers, with attorneys skilled in advising employers on preventing employer-employee disputes, and the firm prides itself on a special expertise in the impact of emerging technology, including social media, on the relationship between employers and their employees. In plain terms: Councilmember Park spent two decades at a firm that trains public agency employers on precisely the rules she is now violating, including the restrictions on employees engaging in political activity on employer time, using employer equipment, and the liability exposure that results.
The conduct documented in this complaint is not the kind of violation that results from confusion about gray areas. The prohibition on using City staff, City equipment, and City time for campaign activity is foundational public sector employment law, the exact body of law Councilmember Park advised clients on for the bulk of her professional career. Burke’s employment law seminars and training programs for public agencies specifically cover preventing workplace disputes and compliance with California employment law and regulations, including the rules governing political activity by public employees that Councilmember Park is alleged to have directed her own staff to violate. A former municipal employment attorney who counseled public agencies on these very compliance obligations cannot credibly claim she did not understand them when she took office. The Commission should treat her legal background as an aggravating factor, not a mitigating one.
The Ethics Commission has a strong and recent record of holding City officials accountable for this type of conduct. The use of City staff on City time for campaign purposes is precisely the pattern that triggered scrutiny of former Councilmember Jose Huizar, whose former staffers filed lawsuits alleging he directed City employees to plan and work on a family member’s campaign during City time — conduct that ultimately contributed to a broader federal investigation. While Huizar’s case escalated to federal RICO charges, the initial ethics violations were of the same character as those documented here.
Former Councilmember Kevin de León faced fines of up to $18,750 for ethics violations the Commission described as reflecting “a pattern of conduct” — an aggravating factor that applies with full force here given the eight documented incidents spanning multiple weeks. The Commission recently fined former CBS CEO Leslie Moonves the maximum penalty of $15,000 for inducing a City official to misuse his City position for private advantage, demonstrating the Commission’s willingness to impose maximum penalties when the gravity of the conduct warrants it.
Penalties for violations occurring on or after January 8, 2025 now reach up to $15,000 per violation, or three times the amount of money at issue, whichever is greater. Each cross-posting incident, each deployment of City staff at a campaign event, each instance of City equipment used to produce campaign content, and each direction of City employees to perform campaign tasks during working hours may constitute a separate penalizable violation.
I respectfully request that the Ethics Commission
The residents of Los Angeles — and particularly of Council District 11 — deserve assurance that their tax dollars, their elected representative’s official City platform, and City staff are not being weaponized for personal political gain. Los Angeles has endured far too many City Hall ethics scandals in recent years. This Commission exists precisely to prevent that pattern from continuing, and the documented evidence in this case provides a clear and compelling basis for action.
I am prepared to provide additional documentation, screenshots, and supporting information upon request.
Respectfully submitted
