San Luis Obispo County places political action committee on notice

April 24, 2026

District Attorney Dan Dow

By KAREN VELIE

San Luis Obispo County District Attorney Dan Dow on Wednesday put the treasure of a political action committee that supports the reelection of Supervisor Jimmy Paulding on notice regarding serious concerns over their compliance with election laws.

The South County Coalition was formed on March 26 by its treasurer Dorothy Hines, a Nipomo woman who served as treasurer for Jimmy Paulding’s 2022 campaign committee. Hines identified the coalition as a county general purpose committee and described its activity as an “advocate for candidates in South San Luis Obispo County.”

In his letter, Dow points out that the coalition’s independent expenditure reports show only support for Paulding’s reelection, which would make the coalition a primarily formed committee with stricter reporting requirements.

In the coalition’s April 13 Form 496 filing, it failed to report that retired attorney Ray Mattison donated $18,000 on March 24, and that attorney Don Ernst donated $22,002 on March 25, a day before the coalition filed its statement of organization.

“The close timing of those substantial contributions and the committee’s campaign spending in support of Mr. Paulding strongly suggests that the committee’s actual purpose and recent activity are directed toward supporting a single identified candidate rather than generally supporting multiple south county candidates,” Dow wrote. “California law does not permit a committee to retain ‘general purpose committee’ status when, in substance, it exists to support a single identified candidate in a single election.”

Dow’s letter directs Hines to immediately:

• Review the committee’s current legal status and determine whether it is in fact primarily formed to support Paulding.
• If so, promptly file an amended Form 410 accurately identifying the committee as a primarily formed committee.
• Immediately review whether all qualifying late contributions have been timely and accurately reported under the rules applicable to primarily formed committees, and if not, file any required amended or supplemental reports without delay.
• Review all advertisements, mailers, and communications paid for by the committee to ensure compliance with applicable sender identification and advertisement disclosure requirements, including any top-donor disclosure rules that may apply.
• Preserve all records relating to committee formation, donor solicitations, contributions received, expenditures made, vendor communications,advertisement approvals, and any communications reflecting the committee’s purpose, candidate targeting, or intended electoral activity.
• Ensure that no filing made with the Secretary of State, county elections office, or the FPPC contains material omissions or inaccuracies regarding the committee’s true purpose, contributors, or expenditures

If Hines determines the coalition is properly classified, she needs to be prepared to substantiate with documentation, according to Dow.

“Please provide written confirmation no later than close of business within five calendar days that the committee has reviewed these issues, identified the steps it will take to comply with California law, and preserved all potentially relevant records,” the letter demands.