Complainant: Daniel L Sapienza

Respondent: Angela Myers, Larimer County Clerk and Recorder

Complaint Summary

This complaint alleges that Angela Myers, as Larimer County Clerk and Recorder, uses and
has used since 2013, a mobile phone funded solely by Larimer County official funds as the
exclusive phone number of her political campaign, in violation of Section 1-45-117 CRS,
prohibiting any state subdivision from contributing funds to an election campaign.

Complaint has been timely filed

Complainant learned of this violation after receipt of “Re-elect Angela Myers” printed literature
and contribution envelope, both featuring the phone number in question, on September 12,
2018.

Factual Allegations

1. In 2013, Angela Myers was employed in the office of the Larimer County Clerk and Recorder
under Clerk Scott Doyle. Myers was Chief Deputy Clerk, delegated with management of the
Clerk’s office in all matters in the absence of Doyle.
a. See Attachment 1 - Email from Doyle to Larimer County Commissioners, dated
1/29/2013
2. In 2013, Myers’ mobile phone number was 970-227-0348, used in official communications to
reach Myers in urgent situations.
a. See Attachment 1 - Email from Doyle to Larimer County Commissioners, dated
1/29/2013 and
b. Attachment 2 - Email From Myers to BOCC with signature block including cell number,
dated 4/1/2013
3. In 2013, the phone with number 970-227-0348 was paid for by Larimer County through the
county wireless device reimbursement program in the amount of $111 per month, $1,332 per
year.
a. See Attachment 3 - 2013 Reimbursement Form, submitted on 12/19/2012
4. In May 2013, Angela Myers was appointed as Clerk and Recorder by the Larimer Board of
County Commissioners.
5. On October 4, 2013, Myers filed a Candidate Affidavit with the Colorado Secretary of State for
the 2014 election, listing the phone number 970-227-0348 as the candidate’s phone.
a. See Attachment 4 - 2013 Candidate Affidavit for Angela Myers, submitted 10/4/2013
6. On October 4, 2013, a campaign event for Angela Myers took place, hosted by the Larimer
County Republican Party. The phone number 970-227-0348 was posted for RSVPs.
a. See Attachment 5 - Screenshot of Facebook Event dated 10/4/2013
 7. On October 27, 2013, Myers’ campaign filed a Committee Registration Form with the Colorado
Secretary of State, listing 970-227-0348 as the candidate committee phone.
a. See Attachment 6 - 2013 Committee Registration Form, submitted 10/27/2013
8. Between 2013 and 2017, Myers was reimbursed between $1,320 to $1,440 per year for phone
number 970-227-0348 by Larimer County.
a. See Attachment 7 - List of annual payments from Larimer County to Angela Myers,
received from the Larimer County Human Resources Department on September 21,
2018 through CORA Request
9. Between 2013 and 2017, including during her election campaign of 2014, Myers used phone
number 970-227-0348 on re-election materials (printed and digital communications and all
filings with the Colorado Secretary of State) and on official communications as Clerk and
Recorder (in email signature, on press releases from Clerk, and on Larimer County website)
10. On November 13, 2017, Myers renewed her application with Larimer County for
reimbursement for cell phone 970-227-0348 at a rate of $120 per month for the year 2018. As
of September, 2018, Myers has been paid $1,080 for the year.
a. See Attachment 7 - List of annual payments from Larimer County to Angela Myers,
received from the Larimer County Human Resources Department on September 21,
2018 through CORA Request and
b. Attachment 8 - 2018 Reimbursement Form, submitted 11/13/2017
11. On January 22, 2018, Myers filed a candidate affidavit for Clerk and Recorder for the 2018
election, using 970-227-0348 as the candidate and committee phone number.
a. See Attachment 9 - 2018 Candidate Affidavit for Angela Myers, submitted
12. Printed campaign literature to re-elect Myers in the 2018 election feature 970-227-0348 as her
contact information.
a. See Attachment 10 - Photo of printed election campaign literature and
b. Attachment 11 - Photo of printed contribution envelope
13. In September 2018, Myers’ website and a digital invitation to an August campaign event lists
970-227-0348 as the phone number to RSVP.
a. See Attachment 12 - Screenshot of ​www.electangelamyers.com​ and
b. Attachment 13 - Photo of campaign event invitation posted to Facebook by Angela
Myers
14. 2018 emails from Myers to the BOCC and other officials continue to feature 970-227-0348.
a. See Attachment 14 - Screenshot of email from Angela Myers to BOCC, dated June 15,
2018
15. No campaign finance reports filed with the Colorado Secretary of State between 2013 and
September 2018 list payments from Larimer County for the cell phone used for campaign
purposes.
16. As of September 26, 2018, 970-227-0348 remains the phone number of record for both the
Campaign to Reelect Angela Myers and the cell contact for the office of the Larimer County
Clerk and Recorder.
a. See Attachment 15 - Business Card received at the office of the Clerk on September
26, 2018 displaying cell phone number 970-227-0348

Reimbursement for Wireless Device Constitutes a Prohibited Contribution

1. The Fair Campaign Practices Act, CRS 1-45-117(1), states “No agency, department, board,
division, bureau, commission, or council of the state or any political subdivision of
the state shall make any contribution in campaigns involving the nomination, retention, or
election of any person to any public office...”
2. A contribution includes “Anything of value given, directly or indirectly, to a candidate for the
purpose of promoting the candidate's nomination, retention, recall, or election.” CRS
1-45-103(6)(a) and Colorado Const. Art. XXVIII
3. The wireless device with number 970-227-0348 is the exclusive phone for the election
campaign of candidate Angela Myers and is funded solely by Larimer County, paid directly to
Angela Myers in the amount of $120 per month, totalling $7,812 between January 2013 and
September 26, 2018.
4. By authorizing county reimbursement for the exclusive campaign phone, Angela Myers, as
Clerk and Recorder, has made contributions to her election campaign.
See Attachment 1 - Email from Doyle to Larimer County Commissioners, dated 1/29/2013
Attachment 2 - Email From Myers to BOCC with signature block including cell number, dated 4/1/2013

...
Attachment 3 - 2013 Reimbursement Form, submitted on 12/19/2012
Attachment 4 - 2013 Candidate Affidavit for Angela Myers, submitted 10/4/2013
Attachment 5 - Screenshot of Facebook Event dated 10/4/2013
Attachment 6 - 2013 Committee Registration Form, submitted 10/27/2013
Attachment 7 - List of annual payments from Larimer County to Angela Myers, received from the
Larimer County Human Resources Department on September 21, 2018 through CORA Request
Attachment 8 - 2018 Reimbursement Form, submitted 11/13/2017
Attachment 9 - Candidate Affidavit for Angela Myers, submitted 1/22/2018
Attachment 10 - Photo of printed election campaign literature
Attachment 11 - Photo of printed contribution envelope
Attachment 12 - Screenshot of ​www.electangelamyers.com
Attachment 13 - Photo of campaign event invitation posted to Facebook by Angela Myers
Attachment 14 - Screenshot of email from Angela Myers to BOCC, dated June 15, 2018
Attachment 15 - Business Card received at the office of the Clerk on September 26, 2018 displaying
cell phone number 970-227-0348
Attachment 16 - Reimbursement request forms, with accompanying mobile device bills family cell plan
for years 2013 through 2018