Jake Burdett, Howard County Resident & Progressive Democrats of Howard County President, has filed a formal complaint regarding Howard County Councilmember Christiana Rigby’s attempted use of the Citizens Election Fund (CEF) in the upcoming 2022 election cycle.

The document filed with the Maryland State Board of Elections is six pages long so I will not be copying and pasting the entire document here but will provide some quotes and provide a link to the full complaint in PDF form at the end of this article.

Here are some of the highlights from the complaint:

  • Consider this submission to be a formal complaint regarding Howard County Councilmember Christiana Rigby’s attempted use of the Citizens Election Fund (CEF) in the upcoming 2022 election cycle. As will be detailed further in the complaint, Councilmember Rigby has clearly taken many impermissible contributions, amounting to several thousand dollars worth, in the current 2022 4-year election cycle. This should disqualify her from participation in the Fund, according to its rules.

  • Councilmember Rigby publicly filed her notice of intent to participate in the CEF months ago, and is currently in the process of collecting enough qualifying contributions to apply for certification for use of the fund. Many in the community have already rightly taken issue with her for doing this, considering her several publicly viewable disqualifying contributions, to the point where the controversy was even covered in community blogs questioning the fairness of her participation in the fund. Community members attended the Howard County CEF virtual forum on August 12 via Zoom to ask questions regarding Councilmember Rigby’s clear ineligibility for participation, but were told that questions regarding individual candidates’ usage would not be addressed, and that they should write a complaint to the Board about it instead. It was also stated at this forum that the recording of that Forum would be emailed to attendants or posted publicly after the fact, but this recording was never distributed (please send a link if this is not true!). However, no formal complaint through the proper channels was ever filed against Councilmember Rigby’s attempted invalid use of the CEF, so that is what this complaint serves as, so that the bodies that have the official power to do something about this can perform their legal right.

  • Section IX on Page 14 of the CEF Summary Guide clearly defines what is considered to be an impermissible contribution for CEF candidates to take; it states that “An applicant candidate must not accept the following contributions:”, and lists “▪ A private contribution from a sole proprietor, LLC or LLP.” as one of the several impermissible contributions. As is documented below, and can be independently verified on the MDCRIS state campaign finance database, Councilmember Rigby has taken many such impermissible contributions from LLCs and businesses during the current 4 year election cycle and qualifying period, which should make her ineligible for participation in the CEF.

  • As is pictured above, Councilmember Christiana Rigby has taken 9 impermissible contributions from 8 different businesses/LLCs during the current 4 year election cycle, for a total of $3,444 of impermissible contributions, which should disqualify Councilmember Rigby from participation in the CEF. The language from the CEF Summary Guide on Impermissible Contributions that shows that these contributions are against the actual letter of the rules has already been provided above, but it is also worth pointing out how much of the spirit of the CEF that these contributions go against

  • The fact that Councilmember Rigby would not only try to use the CEF after accepting several impermissible LLC contributions, but that some of those LLC contributions were from developer LLCs – and even the most notorious developer in Howard County: Howard Research & Development Corp. of the Howard Hughes Corporation – seems to be a huge abuse and betrayal of purpose of a Fund that was intended to help candidates that have not accepted donations from those entities, and also a slap in the face of Howard County voters who voted for the CEF to combat developer influence.

  • It is worth touching on, though, where this complaint may go from here according to the due process established by the Howard County CEF rules. While Page 4 of the CEF Rules of Procedure document states that any complaints of allegations of impermissible actions by potential CEF candidates be submitted in writing to the Howard County CEF Commission so that they can evaluate the complaint and alleged violation, the Howard County CEF rules also give the ultimate authority over deciding which candidates are able to be certified for participation in the CEF and which candidates are complying with the rules to the State Board of Elections, rather than the County CEF Commission. This comes from Page 6 of the CEF FAQ Document, in response to the question “Who determines a candidate’s eligibility, eligible contributions and expenditures, amount of matching funds that will be distributed, and the candidate’s compliance with Program regulations?”, to which the answer in the FAQ was “All determinations of candidate eligibility and compliance reside with the State Board of Elections (the Board). The decision by the Board whether to certify a candidate is final. … All questions and disputes pertaining to permissible campaign expenditures are determined by and should be directed to the Board.” For this reason, this complaint is addressed to both the Howard County CEF Commission and the MD State Board of Elections.


I pulled only some of what was sent to the Maryland State Board of Elections. If you would like to read the entire complain here it is: CEF Complaint Against Christiana Rigby


Scott E


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