Editorial Standards and Subject Notification Policy

This policy applies to:

1. (a) Any Institute publication that names a specific individual officeholder, candidate, public employee, public contractor, or affiliated private entity by name;
2. (b) Any Institute publication that makes a specific factual claim about the conduct, votes, compensation, contracts, relationships, or fiscal decisions of any individual described in (a);
3. (c) Any Institute investigation, dashboard, briefing, or supporting research document released to the public, to media, or to any third party.

This policy does NOT apply to:

1. (a) The Institute’s general methodological publications (the Six-Pillar Audit Framework paper, The Lag-Lead Trap, Productivity Parity, The Florida Laboratory, Fifty Cities Already, and successor methodology papers), which describe the Institute’s analytical framework and do not name individuals as subjects of investigation;
2. (b) Citation of named officials’ public statements, quoted verbatim from the public record;
3. (c) Citation of named officials’ voting records as recorded in official meeting minutes;
4. (d) Citation of named officials’ public compensation as published by the employing jurisdiction.

The Institute applies a three-tier Subject Notification protocol, calibrated to the nature of each finding. The tier governs what notice, if any, is provided to a named individual before publication.

A Tier One finding is a claim derived entirely from audited or authoritative public financial records or from primary public-meeting documentation, including but not limited to:

• Comprehensive Annual Financial Reports (CAFR / ACFR) and the underlying audited financial statements;
• Adopted, amended, or proposed governmental budgets;
• Official meeting minutes and recorded roll-call votes;
• Compensation disclosures and public-employee salary records as published by the employing jurisdiction;
• Procurement and contracting records lawfully obtained under public-records law;
• Campaign finance disclosures filed with state or federal regulators;
• Statements made by the named individual on the public record, in a public meeting, or in a recorded public forum, quoted verbatim with citation to the source recording or transcript.

For Tier One findings, the Institute does not provide pre-publication notification beyond what the public record itself constitutes. The underlying record is the named individual’s response, contemporaneously created by the official process in which the individual participated.

Fiduciary Objection

The Institute treats a recorded vote, including a recorded abstention or absence on a roll-call vote, as the named individual’s affirmative statement of position on the underlying matter. Where the public record demonstrates that fellow members of a deliberative body recorded objection — by vote, by formal dissent, or by entered comment — and the named individual did not, the Institute reports that asymmetry as a matter of record. The fiduciary standard applicable to public officeholders includes the duty to object on the record when fiscal irresponsibility is present; the absence of recorded objection is itself a fact about the official’s conduct, and the Institute reports it as such.

Tier One findings remain subject to the Institute’s Correction Policy (Section IV) and may be amended or corrected upon receipt of credible factual challenge after publication.

A Tier Two finding is a claim that extends beyond the literal content of a public record to characterize the conduct, intent, motive, pattern, or relationships of a named individual, including but not limited to:

• Findings that infer a pattern across multiple discrete decisions;
• Findings that characterize an individual’s apparent intent or motive;
• Findings that describe a relationship between a named individual and a third party that is not formally documented in a single public record but is supported by multiple records taken together;
• Findings that compare a named individual’s public statements to their voting record;
• Findings that connect campaign contributions to specific official decisions;
• Findings that characterize the effect of an official decision on constituent welfare or financial position.

For every Tier Two finding, the Institute provides written notice to each named individual not less than ten (10) business days prior to publication. The notice contains:

1. (a) The specific factual claim that will be published, in the exact wording proposed;
2. (b) Each primary source document upon which the claim is built, with sufficient citation to enable independent verification;
3. (c) A clear statement of the ten-business-day window for the individual to submit factual corrections;
4. (d) The mailing address and email address at which corrections may be received;
5. (e) Notice that the absence of a response will itself be noted in the published finding as a matter of record.

The Institute considers in good faith any factual correction submitted within the ten-business-day window. Corrections that demonstrate material factual error result in the claim being amended, withdrawn, or substantially revised prior to publication. Submissions that constitute characterization, framing, rhetorical objection, or political response rather than factual correction are noted in the Institute’s working file but do not result in pre-publication revision of the claim.

The Institute reserves the right to publish, alongside the Tier Two finding, an accurate summary of any factual response received from the named individual, in the interest of complete disclosure to the reader.

If no response is received within the ten-business-day window, the Institute publishes the finding as drafted and includes, on the face of the published document, the following statement:

[Name] was provided written notice of this finding on [Date], with a ten-business-day window for factual correction. As of publication, no response has been received.

A Tier Three finding is a claim that connects evidence across multiple records to allege a specific course of conduct that is not stated verbatim in any single record, including but not limited to:

• Findings alleging procurement-steering, bid-rigging, or favoritism;
• Findings alleging that an individual or entity received benefit from an official action in a manner that constitutes a conflict of interest, whether or not legally actionable;
• Findings alleging coordination, collusion, or concerted action among two or more named individuals;
• Findings alleging that an official action was undertaken for a reason other than the publicly stated rationale;
• Findings alleging that a private entity received public benefit in a manner inconsistent with the entity’s publicly disclosed status or purpose.

For every Tier Three finding, the Institute applies all the Tier Two procedures with the following enhancements:

1. (a) The notification window is fifteen (15) business days, not ten;
2. (b) The notice itemizes each individual evidentiary element supporting the inference, separately, and identifies the connecting reasoning;
3. (c) The named individual is offered the opportunity to provide additional contextual records, documents, or facts that the Institute may not have located, and the Institute commits to reviewing in good faith any such material received;
4. (d) The Institute’s working file on each Tier Three finding is retained in full for not less than seven (7) years following publication, in accordance with standard practice for investigative research subject to potential legal challenge;
5. (e) Tier Three findings receive secondary review by Institute counsel prior to publication.

The Institute’s research is conducted by a multi-disciplinary collective of forensic accountants, public-records specialists, civil and legal counsel, data analysts, and political-research veterans. Many Institute researchers maintain active careers in fields in which visible political-accountability work would create professional conflict or operational compromise.

The Institute therefore attributes its publications to the institutional name, not to individual researchers. The standard the Institute holds itself to is that the research is verifiable independently of who conducted it. Every factual claim in every Institute publication is cited to a primary public document that any reader, journalist, or opposing party may obtain and examine.

The Institute’s commitment to its researchers, and to its readers, is that the citations are what make the work credible. The bylines are not.

This attribution practice does not relieve the Institute of any responsibility for the accuracy or completeness of its published findings. The Institute, as the corporate publisher, accepts full institutional responsibility for every claim it publishes under its name.

The Institute maintains a public Corrections Log accessible from every investigation page. The log records:

1. (a) The original published claim;
2. (b) The factual error identified;
3. (c) The corrected claim;
4. (d) The date of the correction;
5. (e) The source of the correction (named individual, third-party researcher, internal review, or other).

Corrections to material findings are appended to the original publication at the point in the document where the error appeared, in addition to being listed in the Corrections Log. The original incorrect text is not silently deleted; it is struck through and the corrected text is added immediately below, so that the reader sees both what was originally published and what was corrected.

The Institute does not unpublish corrected findings. The historical record of the correction is itself part of the Institute’s commitment to transparency.

The Institute applies the following standing rules to prevent conflicts of interest in its research:

1. (a) No Institute researcher may participate in an investigation of a jurisdiction in which they hold elected office, appointed office, paid public employment, or active candidacy;
2. (b) No Institute researcher may participate in an investigation of an individual to whom they are related by blood, marriage, or domestic partnership, or with whom they have a material financial relationship;
3. (c) Institute donors do not receive advance notice of investigations, do not direct the selection of investigation subjects, and have no editorial control over Institute publications. The Institute will not investigate a community or individual at the direction of a donor;
4. (d) The Institute does not accept funding from any government entity, political party, candidate committee, political action committee, or 501(c)(4) or 501(c)(3) directly engaged in candidate political advocacy;
5. (e) Any actual or perceived conflict of interest discovered during an investigation is disclosed on the face of the published finding, and the Institute reassigns the investigation to an unconflicted researcher.

This policy was formally adopted by the Institute upon the publication date of this document and applies to all forward Institute publications.

Findings published by the Institute or by Institute-affiliated investigations prior to the formal adoption of this policy were derived entirely from audited public financial records, official meeting minutes, and publicly recorded statements — the categories described in Section II, Tier One — and would not have required pre-publication notification under this policy had it been formally in effect.

The Institute applies the Tier Two and Tier Three protocols, in their full form, to every forward investigation and every forward finding, without exception.

The Local Government Accountability Institute is a Wyoming nonstock nonprofit corporation organized under section 501(c)(4) of the Internal Revenue Code. All publications, communications, and disclosures of the Institute are governed by the law of the State of Wyoming, the federal law of the United States, and the law of the jurisdiction in which the individual subject of any publication resides or holds office, as applicable.

This policy is not a contract and confers no third-party rights. It is a statement of institutional standard, published to enable the public, the press, and the named subjects of Institute research to know in advance the standard against which the Institute may be held.

Institute publications are factual research products based on primary public records. They are not endorsements of, or coordinated with, any candidate, party, political action committee, campaign committee, or advocacy organization.

The Institute does not control, authorize, or coordinate the use third parties may make of Institute publications. Third parties — including candidates, journalists, citizens, advocacy organizations, and political committees — may cite, quote, or reference Institute publications under standard principles of fair use and public-records reporting. The rhetorical, persuasive, or political use third parties make of Institute findings is the responsibility of those third parties and is not directed by, endorsed by, or attributable to the Institute.

The Institute disclaims all liability for downstream characterizations, framings, or implications added by third parties beyond what the Institute has itself published. The Institute’s responsibility extends only to the accuracy, completeness, and fairness of what the Institute itself publishes under its institutional name.

The Institute does not coordinate with, take direction from, or share unpublished research with any candidate, campaign, political party, or political action committee. Where any third party publicly cites, quotes, or relies upon Institute findings, the Institute makes no representation about and accepts no responsibility for the manner of that citation, quotation, or reliance.