Complaint against Ryan Sheldon for State Senate

From approximately April 2026 through July 2026, the Ryan Sheldon for State Senate campaign used goods, services, software subscriptions and digital assets that were paid for with campaign funds of Heilala for Governor (Matt Heilala, candidate for Governor). This was a continuing course of conduct, not a single transaction. The items the two campaigns later chose to address are examples of it, not the whole of it. The public record establishes the pattern. Heilala for Governor's amended Thirty Day Report (Exhibit A) states it was amended to "reflect reimbursement check received from Ryan Sheldon for State Senate," and records a July 17, 2026 reimbursement of $1,534.76 for "Campaign Digital and Media Assets Used (AI Image Editor - $119.70, GoDaddy - $366.52, Chatcut - $100.00, and Base44 - $948.54)." The same report shows Heilala for Governor paying Base44 (website/app development software) on April 2, April 14 and April 28, 2026, totaling $1,840.40, and ChatCut (video editing software) on April 2, May 2 and June 2, 2026 (Exhibit B). Respondent registered as a candidate on or about April 30, 2026 (Exhibit C). Two discrepancies in the filings themselves show the reimbursement does not capture the full extent. First, the reimbursement credits $948.54 for Base44 against $1,840.40 that Heilala for Governor paid Base44 in the same period. Second, the reimbursement names a GoDaddy charge of $366.52, yet no expenditure to GoDaddy appears anywhere in Heilala for Governor's 2026 reports; the reports instead carry five unitemized "Website Services" charges between February and July 2026 (Exhibit B). Either the vendor was misdescribed or the charge was not reported. Under AS 15.13.112(b)(7), a candidate's campaign contributions may not be used to make contributions to another candidate. The only exception is a shared campaign activity reimbursed within seven days of payment. These charges were paid in April, May and June 2026 and were not reimbursed until July 17, 2026. Goods and services furnished to Respondent's campaign at another campaign's expense are a contribution under AS 15.13.400, and Heilala for Governor was a source not authorized by law to make it. Respondent therefore accepted contributions prohibited by AS 15.13.072(a)(1). On information and belief, the assets and services Respondent's campaign used at Heilala for Governor's expense extend beyond the four items itemized on July 17, 2026. The two campaigns used the same vendors during the period, among them AT Publishing (signs), Sticker Mule, and Best Buy (Exhibits B and C), and Heilala for Governor had previously reimbursed Respondent for equipment and campaign supplies (Exhibit D).

Respondent's Thirty Day Report, covering February 2 through July 17, 2026 and filed July 20, 2026 (Exhibit C), lists no non-monetary contribution from Heilala for Governor. Its only related entry is a July 17, 2026 expenditure of $1,534.76 to "Heilala, Matt" with the purpose "Reimbursement." Respondent's Seven Day Report and 24 Hour Report likewise report nothing (Exhibit C). The report therefore omits the date, source, description and value of each in-kind contribution Respondent's campaign received when it used assets paid for by Heilala for Governor, and identifies the counterparty as an individual rather than the campaign whose funds were used. AS 15.13.040(a) requires each candidate to report the total amount of all contributions and, for each contributor, the name, address, date and amount contributed. A later cash reimbursement does not substitute for reporting a contribution when it was received, and a reimbursement that covers only part of what was used leaves the remainder unreported entirely.

AS 15.13.114(a) requires a candidate who receives a contribution given in violation of AS 15.13.072 or 15.13.074 to return it immediately upon discovery. Respondent was simultaneously being paid "Campaign Consulting" fees by Heilala for Governor in the same months, $10,000 each on February 10, March 6, March 31 and May 3, 2026 and $3,500 on July 1, 2026 (Exhibit D), and knew or should have known from the outset that his Senate campaign was using assets purchased with Heilala for Governor's funds. Reimbursement was not made until July 17, 2026, the last day of the Thirty Day reporting period and roughly three months after the first Base44 charges, and, as set out in Count 1, it did not cover the full value received.