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Former FPPC Chair Questions DA Filing Regarding World Cup

Former FPPC Chair Ann Ravel says a recent complaint filed with the District Attorney was out of bounds and should have been filed with the FPPC.

A recent complaint to the Santa Clara District Attorney has gotten the attention of the former chair of the California Fair Political Practices Commission (FPPC), who believes the filers are out of bounds in submitting the claim to the DA.

Ann Ravel, former chair of the FPPC, has challenged a recent complaint that points fingers at 49ers president Al Guido, claiming he had a conflict of interest when he signed contracts for the FIFA World Cup.

While Ravel, an attorney, doesn’t dispute that Guido signed the contracts, she contends that the DA is not the person to field such a complaint since the accusations do not constitute a crime. Such complaints, she said, are best handled by the FPPC.


“There needs to be a lot of proof here and that there is some actual interest in the contract, which is not clear,” Ravel said. “The problem here is that they are making an accusation without sufficient factual information … It is not obvious that this is really going to be a conflict.”

The reasoning for the filing, according to the complaint, is that Guido figuratively signed contracts with both hands to bring the world’s biggest soccer tournament to Levi’s Stadium in 2026.

First, he signed as a representative of the Forty-Niners Management Company (ManCo), which organizes non-NFL events for the City. He also signed as president of the Bay Area Host Committee, the 49ers-affiliated nonprofit that is putting on the World Cup.

Teresa O’Neill, a former Santa Clara City Council member, Tom Shanks, former director of Santa Clara University’s (SCU) Markkula Center for Applied Ethics, and Pedro Hernandez-Ramos, a professor at SCU, penned the letter to Santa Clara District Attorney Jeff Rosen, urging him to intervene.

“These two positions have an intrinsic and unresolvable conflict,” they wrote in the four-page letter.

Not only did the trio implicate Guido, it also claimed the Council majority “aided and abetted” him. According to the letter, “the public’s trust and confidence in their local government is eroding every day.”

But Ravel disagrees with the trio’s assessment.

“It does not strike me as something that is criminal,” she said. “It doesn’t rise to the level of purposeful violation of the law.”

Government Code Section 1090 details such conflicts.

According to the section, it “prohibits an officer, employee, or agency from participating in making government contracts in which the official or employee within the agency has a financial interest.”

The letter is not the first time concern over Guido’s conflict arose. In early 2022, Deanna Santana, then Santa Clara’s city manager, claimed that Guido could essentially negotiate with himself. Two days later, the Council majority fired Santana.

In their letter, the three draw a parallel between Santana’s firing and the 49ers making nearly $750,000 in campaign donations to a PAC that then ran advertisements in support of the campaigns of Vice Mayor Anthony Becker and Council Members Karen Hardy and Raj Chahal.

Just because Guido signed contracts on behalf of both organizations does not mean he has a financial stake in the World Cup, Ravel said. If O’Neill, Shanks and Hernandez-Ramos are going to claim that Guido has a financial interest in bringing the World Cup to Santa Clara, she said, they need to demonstrate it.

They can’t just lob accusations, as Ravel put it, “willy-nilly.”

Typically, violations of California’s conflict of interest laws are punished with fines, but contracts signed under the auspice of such conflict can also become void.

According to the code, “an official can have a ‘financial interest’ in a contract in a variety of ways and it is not limited by the amount of the interest or how closely connected the official’s interest is to the contract … when applicable, officials may be considered to have no financial interest or a ‘remote’ financial interest, so that a contract, or the official’s participation in the contracting process, is not prohibited …”

However, nothing in the complaint details how Guido would stand to benefit from the so-called self-dealing.

In a text message last week, O’Neill declined an interview for this story, writing that the three are “… in a discussion with the District Attorney’s office on the range of legal issues and how to best resolve the concerns that have been raised.”

Calls to Shanks and Hernandez-Ramos went unreturned.

Although Ravel acknowledged a strong urge to have officials act ethically, she said such overreaches add to the general political divisiveness in cities like Santa Clara.

Santa Clara is no stranger to politicking. In 2022, a scurrilous grand jury report alleging similar ethical violations and political back-scratching with the 49ers — released just days before Becker’s bid for mayor — is at the heart of his perjury trial.

“These allegations aren’t sufficient. It is not enough to even file a complaint unless they have more information,” Ravel said. “You can’t just make wild accusations about something and think that the DA needs to handle it, thereby making people think [Guido] is a criminal.”

The Council has previously said it expects to release financial information relating to the World Cup later this year.


  1. Kirk Vartan 4 weeks ago

    Interesting to hear Ann Ravel jump in on this, given her past role. It seems she would understand the laws clearly, but maybe she never dealt with 1090 violations. The mere potential of a financial gain is what is needed for void the contract. That is now a leverage point the city can use. But given the 49er council, why bother. And it seems the city attorney is not looking out for the city, but for the 49er majority on the council…since they have the ability to fire him (like they did Brian Doyle when he spoke out).

    What would be really interesting to hear is Ann Ravel’s explanation about her role int he allegations made by Brian Exline when he attended Santa Clara University. Ms. Ravel was one of his listed attorneys through the McManus firm. I don’t believe this paper did any story on the item. It was an attack on Mayor Lisa Gillmor in an effort to discredit her and block her election. Some specific questions:

    – Who paid the legal fees for Exline? I can’t imagine Ms. Ravel did it pro-bono. If she did, why?
    – What was the outcome of the case? Let me help here a bit. Lisa Gillmor was not only vindicated, I believe all her legal costs were awarded to her by the judge. That tells me there was no case.
    – What is Exline doing now? Oh, he’s a Deputy DA in Fresno. How did he land that right out of college? Worth a look.

    It would be great to see this paper do some investigative analysis on this. Seems like it just disappeared.

  2. Kirk Vartan 4 weeks ago

    Oh, one more thing:
    Why did Brian Exline bring this case about in the first place? What is his connection?
    Again, it would be great to see David or someone do an investigative story on this. I think you would find it pretty interesting. But hey, I know the 49ers spend a lot of money on this paper, so I’m not holding my breath.

  3. Jim 4 weeks ago

    It looks like some people will whine at anything.

  4. Buchser 3 2 weeks ago

    I believe someone needs to do an investigation story on Kirk Vartan.

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