Ethics complaints filed against two top St. Louis County officials and the county itself allege county resources were used to promote a sales-tax increase.

Tom Sullivan, longtime activist and critic of St. Louis County government, filed a complaint last week with the Missouri Ethics Commission, accusing St. Louis County, County Executive Charlie Dooley and Council Chairman Skip Mange, R-Town and Country, of neglecting to report expenditures being made by the county to promote a one-eighth-of-a-cent sales-tax increase that would benefit the county’s Department of Parks and Recreation. The sales-tax increase, Proposition P, will be considered April 6 by county voters.

“They’re clearly violating the law,” Sullivan told the Call. “… They conceivably could have spent tens of thousands of dollars. Several county employees have been working on the proposal for months.”

But Mange said that neither he, Dooley nor the county has done anything wrong.

Sullivan filed a second complaint earlier this week to the Ethics Commission after obtaining additional information, including a copy of a detailed four-page Ballot Marketing Plan and Timeline, that he contends proves the county has been running a “full-fledged campaign to promote the passage of Proposition P.”

State law prohibits the direct spending of public money, according to Sullivan’s release, to either support or oppose ballot proposals. Campaign disclosure law also mandates that campaign finance disclosure reports are submitted 40 days before the general election, which was Feb. 26 for the April 6 election. The county submitted no such reports.

“The disclosure law requires that all expenditures made to influence the action of voters, over minimum amounts, must be publicly disclosed,” Sullivan stated in a press release. “An ‘expenditure’ can include time spent by public employees working on the campaign, the value of material produced, the use of equipment, etc.”

Sullivan claims that these types of materials were produced by county workers, but the expenditures were not reported.

The Ballot Marketing Plan and Timeline, of which Sullivan bases his most recent complaint, was developed and is being used to manage the campaign, he claims, outlining campaign goals, tasks and which county employees will carry out those tasks.

“The marketing plan for the proposal mentions in several places that the purpose of the campaign is to persuade voters,” according to Sullivan’s second complaint.

The first page of the “Ballot Marketing Plan and Timeline,” dated Jan. 28, states, “Merit and non-merit employees may work on factual press releases as part of their routine job. Non-merit may work on ‘persuasive’ releases.”

Sullivan also notes in his second complaint that a “considerable effort has been made and continues to be made to ensure county employees get out to vote on the proposal.”

The plan indicates that some type of a “stuffer” will be enclosed with county paychecks March 24 and a bulk e-mail will be sent April 5 to county employees by Chief of Staff Jim Baker as a “reminder to vote.”

“No doubt, it will tell them of … all the benefits of Proposition P, the same as previous e-mails he sent,” the longtime activist stated in a news release.

Dooley and Mange currently serve as co-chairmen of Citizens for Quality Parks, a campaign committee recently formed and designed to promote the parks tax, according to a Feb. 25 parks department press release that announced the formation of the committee.

The release was distributed by the county to citizens, media, groups and also was available on the county’s Web site. The release currently is available on the county parks department Web site,

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Sullivan’s complaint also refers to a flier distributed by the parks department that promotes the tax, identifying individual, community and environmental benefits to the parks tax. The bottom of the flier directed anyone seeking more information to view the parks department’s Web site or call the department at 615-5454.

When Sullivan called the number for more information March 2, he stated in his complaint, he had to leave a message on an answering machine and was later contacted by a public relations firm. When he called the same number at the parks department again the next day, he said, he was told to contact the firm for more information.

“This provides further evidence that what the county was doing was improper,” according to his complaint to the Ethics Commission. “After being caught red-handed, ‘more information’ was no more.”

The complaint also provides copies of a multimedia presentation delivered to the St. Louis County Municipal League Feb. 19 by Dooley, Mange and Lindsey Swanick, acting director of the parks department, and Susan Poling, the department’s planning manager. The presentation included 43 slides, according to the presentation provided in Sullivan’s complaint, “which extolled the benefits of passing the proposal.”

Time county workers spent on the campaign by producing fliers, slide presentations, press releases and material for the Web site all should have been reported under the disclosure law, Sullivan said.

Dooley told the Call he had not received anything from the Ethics Commission notifying him of a complaint and he would not comment on Sullivan’s accusations or the complaint before seeing them in writing.

“I disagree (that the county had violated campaign disclosure law),” Dooley said.

Mange said nothing wrong has been done and Sullivan is attempting to divert attention from the real issues at hand.

“As St. Louis County government, it is perfectly proper for staff to prepare informational documents at the request of a county councilman ..,” Mange told the Call. “As a council member, I am fully authorized under the law to advocate for these kinds of things. To claim county employees are advocating the issue is false … There is a committee that has been formed, which will advocate for the tax. All costs are born by the committee. No county assets have been used to advocate the tax.”

County assets have been used to provide informational materials, including statistics of the parks, their condition, budget information — which is all public record, he told the Call.

“He (Sullivan) is trying to divert people’s attention from the issue to the process. My hope is that voters will zero in on the actual issue … St. Louis County has a safe, quality system of parks for all residents and that’s the issue before the voters …,” Mange said.