The Fair Political Practices Commission has opened a formal investigation into a complaint concerning Sonoma County Supervisor Lynda Hopkins, the latest ethics matter involving her votes. The agency notified Sebastopol resident Adina Flores on Thursday that her sworn complaint had advanced to an investigation and assigned it Case No. 2026-01107.
Flores described the notification in a post on her Substack, writing that she received written confirmation from the FPPC’s Enforcement Division on November 5. The letter said the agency had not determined whether the allegations are valid or whether Hopkins is responsible for a violation. It did not identify the specific allegations under investigation or announce preliminary findings.
The letter was signed by Kendall L.D. Bonebrake and copied attorney Olivia Clark on behalf of Hopkins. The notation indicates Clark is acting on Hopkins’s behalf in the matter, but does not establish who is paying for the representation or whether Sonoma County is involved. Clark is of counsel at Best Best & Krieger LLP, where she advises public agencies on the Political Reform Act, the Brown Act, public records, land use and governmental ethics.
A prior case ended in a fine
Flores’s reporting lays out two prior board votes she has connected to organizations fiscally sponsored by the Tides Center, though the new case has not been publicly described as addressing either one specifically. On December 5, 2023, the Sonoma County Board of Supervisors considered a package of housing and homelessness initiatives that included the Bay Area Housing Finance Authority’s proposed bond measure, the CSAC At Home program, and All Home’s Regional Action Plan, and authorized a collaboration agreement with All Home for technical assistance. According to meeting records cited in Flores’s reporting, Hopkins voted in favor of those resolutions and the related authorization. All Home has identified the Tides Center as its fiscal sponsor.
That earlier finding concerned a separate vote and case. The FPPC has not publicly said whether the new investigation concerns either of the votes Flores has connected to organizations fiscally sponsored by the Tides Center.
Votes cited in Flores’s reporting
One vote Flores has cited occurred on December 5, 2023, when the Sonoma County Board of Supervisors considered housing and homelessness initiatives, including the Bay Area Housing Finance Authority’s proposed bond measure, the CSAC At Home program and All Home’s Regional Action Plan. The board also authorized a collaboration agreement with All Home for technical assistance. Meeting records cited in Flores’s reporting show Hopkins voted for the resolutions and authorization. All Home identifies the Tides Center as its fiscal sponsor.
This is not Hopkins’s first encounter with the state ethics agency. In November 2024, the FPPC fined her $3,000 for a conflict-of-interest violation connected to a December 17, 2019 vote, in which Hopkins approved county tourism impact fund awards that included a $20,000 grant to the nonprofit LandPaths. LandPaths employed Emmett Hopkins at the time of that award, according to The Press Democrat. In that earlier matter, FPPC Case No. 22/207, the commission determined the 2019 vote had a reasonably foreseeable, material financial effect on a source-of-income financial interest, finding Hopkins violated Government Code § 87100. The Press Democrat reported that the commission found Hopkins negligent and concluded she should not have participated in the vote given her husband’s connection to LandPaths — but it also reported the FPPC did not find evidence that Hopkins knowingly voted on a decision she knew presented a prohibited conflict of interest. That 2022 inquiry originated from a complaint Flores filed on February 3, 2022, per the Press Democrat’s reporting.
What the law requires—and what it does not prove
California’s Political Reform Act bars public officials from making, participating in or using their position to influence a governmental decision when they know or have reason to know they have a financial interest in it. Government Code § 87100, published by California Legislative Information, works with § 87103, which defines a financial interest to include a reasonably foreseeable, material financial effect—distinguishable from any effect on the public generally—on the official or an immediate family member.
A fiscal sponsorship relationship alone does not establish a disqualifying financial interest, nor does every decision involving a related organization automatically require recusal. The analysis depends on the specific source-of-income relationship, the decision at issue and whether its financial effect is reasonably foreseeable and material. The FPPC has not publicly said whether Hopkins’s participation in the PODER grant decision created a conflict in this case.
FPPC guidance is fact-specific
In a separate advisory summary, the FPPC said a supervisor whose spouse worked for a county-counsel law firm could take part in a ministerial budget allocation for the firm’s existing contract when the allocation involved no discretion and did not change the firm’s flat monthly payment. The example illustrates that the analysis turns on the particular decision and its financial effect; it does not provide a categorical ruling on nonprofit fiscal sponsorship.
No outcome has been announced in Case No. 2026-01107, and the agency has not provided a timetable for resolving it. The allegations remain unresolved unless and until the FPPC issues findings or closes the case; the commission has said it will notify the complainant when the matter reaches its final disposition. An investigation may end in a violation finding, a warning or advisory disposition, or closure without enforcement action.
