SWORN COMPLAINT BEFORE THE TEXAS ETHICS COMMISSION

An individual must be a resident of the state of Texas to be eligible to file a sworn complaint with the Texas Ethics
Commission. The complainant is required to attach to the complaint a copy of one of the following documents:
complainant's driver's license or personal identification certificate issued under Chapter 521
of the Transportation Code, or commercial driver's license issued under Chapter 522 of the
Transportation Code; or
a utility bill, bank statement, government check, paycheck or other government document that
shows the name and address of the complainant and is dated not more than 30 days before
the date on which the complaint is filed.

OFFICE USE ONLY

Docket Number

Date Hand-delivered or Date Postmarked

An individual may also be eligible to file a sworn complaint with the Texas Ethics Commission if the
individual owns real property in the state of Texas. Under this provision, the complainant will be required
to attach to the complaint a copy of a property tax bill, notice of appraised value, or other government
document that shows the name of the complainant, shows the address of the real property in Texas, and
identifies the complainant as the owner of the real property.

Please completely fill out this form. Failure to complete this form properly will
cause your complaint to be noncompliant and rejected.
I. IDENTITY OF COMPLAINANT
1

MS / MRS / MR

COMPLAINANT
NAME

Ms

Kelly

NICKNAME

COMPLAINANT
PHYSICAL
ADDRESS

MI

(with Citizens for a Better Arlington PAC)

LAST

ADDRESS

SUFFIX

APT / SUITE #;

CITY;

STATE;

ZIP CODE

901 Kristin Ct; Arlington, TX 76012

(REQUIRED)

Canon

(REQUIRED)

FIRST

(Full home or business address, including street, city, state, and zip code)

COMPLAINANT
MAILING
ADDRESS

ADDRESS

APT / SUITE #;

CITY;

STATE;

ZIP CODE

Same

(check if same as above)

(Full street or mailing address, including city, state, and zip code)

(REQUIRED)

COMPLAINANT
TELEPHONE
NUMBER

AREA CODE

PHONE NUMBER

5 COMPLAINANT
E-MAIL
ADDRESS

EXT

817-929-3299

kellycanon@att.net

(REQUIRED IF KNOWN)

(REQUIRED)

II. IDENTITY OF RESPONDENT

MS / MRS / MR

6 RESPONDENT
NAME

FIRST

MI

City of Arlington, TX & "Vote Yes! Keep the Rangers" PAC

NICKNAME

LAST

SUFFIX

(REQUIRED)

7 RESPONDENT
POSITION OR
TITLE
(REQUIRED)

8 RESPONDENT
PHYSICAL
ADDRESS
(REQUIRED)

RESPONDENT
MAILING
ADDRESS

Mayor Jeff Williams and City Council Members Collectively;

and "Vote Yes! Keep the Rangers" PAC
ADDRESS

APT / SUITE #;

RESPONDENT
TELEPHONE
NUMBER

STATE;

ZIP CODE

(Full home or business address, including street, city, state, and zip code)
ADDRESS

APT / SUITE #;

CITY;

STATE;

ZIP CODE

Same

(check if same as above)

10

CITY;

Mayor & Council: 101 W. Abram St., Arlington, TX

"Vote Yes! Keep the Rangers" PAC: P.O. Box 1283; Arlington, TX 76004

(Full street or mailing address, including city, state, and zip code)
AREA CODE

PHONE NUMBER

817-459-6122 (Mayor)

(REQUIRED)

EXT

11 RESPONDENT
E-MAIL ADDRESS
(REQUIRED IF KNOWN)

GO TO PAGE 2
Forms provided by Texas Ethics Commission

www.ethics.state.tx.us

Revised 11/12/2015

III. NATURE OF ALLEGED VIOLATION

Page 2

Include the specific law(s) or rule(s) alleged to have been violated. The Texas Ethics Commission has jurisdiction to enforce
only the following laws: (1) Title 15 of the Election Code; (2) Chapters 302, 303, 305, 572, 2004 of the Gov't Code; (3) 334.025
and 335.055 of the Local Gov't Code; (4) Subchapter C, Chapter 159 of the Local Gov't Code, in connection with a county
judicial officer who elects to file a financial statement with the commission; (5) 2152.064 and 2155.003 of the Gov't Code;
(6) 306.005 of the Gov't Code.
Please completely fill out this form. Failure to complete this form properly will cause your complaint to be nocompliant and
rejected.

In accordance with Local Gov't Code 334.025(c), which allows individuals to file complaints with
the Texas Ethics Commission in accordance with Chapter 571 of the Gov't Code, this complaint is
filed against a) the City of Arlington, Texas, and b) the "Vote Yes! Keep The Rangers PAC" for
violation of Local Gov't Code 334.025 (prohibiting false and misleading campaign materials), and
Election Code 52.072(e)(1) (failing to provide the amount of bonds sought to be authorized).

ATTACH ADDITIONAL PAGES AS NEEDED

Forms provided by Texas Ethics Commission

www.ethics.state.tx.us

Revised 11/12/2015

IV. STATEMENT OF FACTS

Page 3

State the facts constituting the alleged violation(s), including the dates on which or the period of
time in which the alleged violation(s) occurred. Identify allegations of fact not personally known to
the complainant, but alleged on information and belief. Please use simple, concise, and direct
statements.
Please completely fill out this form. Failure to complete this form properly will cause your complaint
to be noncompliant and rejected.

On August 2nd, 2016, the City Council of Arlington held its first reading of a proposed ordinance
which adds a Proposition No. 1 to the Nov. 8 election ballot, which is attached as Exhibit E. This
proposal will finance half of a billion-dollar ballpark with a retractable roof.
The ballot language states that the proposal will authorize Arlington "(i) to impose a parking tax"
and "(ii) to impose an admissions tax", neither of which currently exist and are inarguably new. The
ballot also seeks an extension of three other taxes, including "the existing hotel occupancy tax", "the
existing sales and use tax...of one-half of one percent (0.5%)" and "the existing motor vehicle shortterm rental tax", all of which currently pay for previously authorized bonds. These taxes end when
payment on the debt associated with the previously approved bonds is complete, projected to be
2021. Thus, the ballot language creates two previously unknown and clearly new taxes, and creates
three new taxes which will begin anew when the previously authorized bonds are paid, as they are
extended and employed to pay another $500M in new bonds, or for another 20+ years.
The ballot language suggests that the five taxes will be used to directly pay to build the venue
described. However, the City Council minutes, staff report, and Master Service Agreement between
the City and the Rangers' ownership states clearly that the five taxes will service $500M of bonds.
Advertisements by the "Keep the Rangers" and "No New Taxes" campaign are shown in Exhibits
A through H, along with Arlington Council materials showing that the taxes will fund bonds, though
the ballot language does not state that bond financing will be used, and does not state the total value
of those bonds, which all parties understand to be $500M, shown in p.2 of Exhibit G.
Additionally, the campaign for this proposed proposition is alleging that the Texas Rangers
baseball team will leave Arlington if the voters turn it down by voting against it. (We must "Keep the
Rangers".) These assertions are MISLEADING to the average voter, because the current lease with
the Rangers requires them to stay in Arlington until 2024. On Exhibits A through D, the slogan Keep
The Rangers and "No New Taxes" are clearly displayed, which are violations of Local Gov't Code
334.025(b) which prohibits campaign material containing false and misleading information. The City
also has also mislead citizens in public presentations, e.g, Council meetings. (https://
arlingtontx.granicus.com/MediaPlayer.php?view_id=9&clip_id=2064&starttime=2105&autostart=0%
20&embed=1&meta_id=235944, starting at 35 minutes in, and lasting until about 50 minutes in.)
Sec. 334.025. FALSE AND MISLEADING CAMPAIGN MATERIAL. (a) In this section, "campaign material" means a
communication supporting or opposing the authorization of a venue project that: (1) in return for consideration, is published in a
newspaper, magazine, or other periodical or is broadcast by radio or television; or (2) appears in a pamphlet, circular, flier, billboard
or other sign, bumper sticker, or similar form of written communication. (b) A person may not print, broadcast, or publish, or cause
to be printed, broadcast, or published, campaign material that contains false and misleading information. (c) An individual may file a
complaint with the Texas Ethics Commission in accordance with Subchapter E, Chapter 571, Government Code, alleging a violation
of Subsection (b). The commission may impose a penalty in accordance with Chapter 571, Government Code, if the commission
determines that the campaign materials contain false and misleading information. (d) Notwithstanding any other law, the Texas
Ethics Commission has jurisdiction to consider and investigate a complaint filed under this section and to impose a penalty.
----------------------------------------------------------------------------------------------------------------------------------------------------------Sec. 52.072. PROPOSITIONS. (a) Except as otherwise provided by law, the authority ordering the election shall prescribe the
wording of a proposition that is to appear on the ballot....(e) In addition to any other requirement imposed by law for a proposition,
including a provision prescribing the proposition language, a proposition submitted to the voters for approval of the issuance of
bonds or the imposition, increase, or reduction of a tax shall specifically state, as applicable:
(1) with respect to a proposition seeking voter approval of the issuance of bonds:
(A) the total principal amount of the bonds
to beADDITIONAL
authorized, PAGES
if approved;
and
ATTACH
AS NEEDED
(B) a general description of the purposes for which the bonds are to be authorized, if approved;
Forms provided by Texas Ethics Commission

www.ethics.state.tx.us

Revised 11/12/2015

V. LISTING OF DOCUMENTS AND OTHER MATERIALS

Page 4

List all documents and other materials filed with this complaint. Additionally, list all other
documents and other materials that are relevant to this complaint and that are within your
knowledge, including their location, if known.
Please completely fill out this form. Failure to complete this form properly will cause your complaint
to be noncompliant and rejected.

Exhibits (Attached):
A: Screenshot of Keep the Rangers website, mobile version
B: Screenshot of Keep the Rangers website, desktop version
C: Photo of Billboard located on I-30, in Arlington
D: Email message From Arlington Mayor Jeff Williams, promoting the campaign
E: Copy of Ordinance for Proposition 1, approved by unanimous vote on August
2nd, 2016
F: Copy of Finance Report, of Vote Yes! Keep the Rangers PAC, filed with the city
of Arlington, July 15, 2016
G: "Keep the Rangers" Press Release from the City of Arlington
H: Master Agreement (particularly Section 3.3(a), p.22-23, which discussed bonds).
I: Staff Report, City Council Meeting Date: 05-24-16 (states that the proposed taxes
will service $500M of bonds).

ATTACH ADDITIONAL PAGES AS NEEDED

Forms provided by Texas Ethics Commission

www.ethics.state.tx.us

Revised 11/12/2015