COM-09242026-03946
My complaint concerns Councilman Bryan “Bubba” Fish’s employment by Los Angeles County as a full-time “transit advocate,” his campaign for City Council as a transit advocate, and his subsequent participation in Culver City deliberations on transit matters. In my view, these circumstances constitute a conflict of interest. Consider this complaint to be similar to COM-04032026-01024 against Fish.
There is an additional inconsistency that I ask the FPPC to address. You upheld complaint COM-01272026-00232 against Councilmember Dan O’Brien, concluding that, as director of the Culver City Chamber of Commerce—a bona fide association—he may not deliberate on matters related to the Chamber. This apparently includes transit matters such as Save Sepulveda, which could restrict parking for businesses along Sepulveda Boulevard.
Yet you rejected substantially similar complaint COM-04032026-01024 concerning Councilmember Fish.
Please explain the rubric applied. Why may an officer of a bona fide association, whose connection to the matter may be indirect, be barred from deliberating, while a government employee paid specifically to advocate for the subject matter may participate in deliberations on that same subject?
As it stands, the distinction does not appear to advance the goal of keeping government decisions free from individual self-interest. Rather, it appears to permit government officials to advance governmental interests and policy objectives while restricting representatives of private citizens and associations from representing the concerns of their constituents.
My understanding is that the purpose of the Fair Political Practices Commission is to prevent public officials from personally benefiting from governmental decisions. Once the standard is extended to representatives of a class or association, however, it risks chilling civic participation and the ability of citizens to petition their government for redress of grievances.
The landlord-tenant context illustrates the concern. Councilmember Fish, as a renter, may serve on the housing subcommittee and help shape rent-control policy. Yet Councilmember Vera, as a property owner, reportedly had to recuse himself from a discussion concerning protection of landlord information. Whether or not those individual decisions were legally correct, the apparent disparity warrants a clear explanation.
I also understand that existing law may restrict certain government employees from running for elective office, and I believe those restrictions may be relevant to Councilmember Fish. However, that is not my principal concern here.
The central issue is that Councilmember Fish is a government-paid official serving on the City Council while advancing objectives associated with his government employment. The FPPC has upheld his ability to do so while, in my view, denying Councilmember O’Brien the ability to represent ordinary constituents and local businesses affected by government policy.
This raises a serious question of whether the governing standard is being applied evenhandedly. It is an unusually clear opportunity to explain which residents, employees, association representatives, and advocates may run for office and deliberate on issues central to their work, affiliations, and constituents.
I respectfully request a written explanation of the applicable legal standard and how it was applied differently in these two complaints.
