Is Santa Clara Moving
in the Right Direction?
87%
Said "Yes" in 2008
40%
Said "Yes" in 2024
The City of Santa Clara once led California in local government ethics.
The Santa Clara Code of Ethics & Values, Behavioral Standards, and comprehensive training programs, all adopted in 2000, were groundbreaking, award-winning, and nationally recognized.
Santa Clara was a role model for many cities tired of win-at-all-costs, crush-the-competition City Council campaigns — and the dysfunction that too often followed them onto the Council dais.
Of all the program's accomplishments, the most important was that residents trusted the City—in large part because they had been involved every step of the way in creating the first consensus-based, integrity-focused code of ethics and values in California.
They also had first-hand experience of the sustained effort of the City organization to make the City's ethics and core values real in everyday work. The 2008 survey showed residents rated all city services as 9 or above on a 10 point scale.
In 2008, ten years into the program, 87% of residents said the City was going in the right direction.
By 2024, that number had dropped by more than half — to 40%.
What happened? And what, if anything, has the City learned?
Building a New 49ers Stadium in Santa Clara
In 2009, Santa Clara reached an agreement to bring the 49ers to town.
In 2010, voters approved Measure J — 14,628 to 10,505, in a city of 116,000 — to build a new stadium.
The 49ers spent $4.3 million supporting the measure.
A new Stadium Authority, separate and distinct from the City, was created to own, build, and run it on behalf of the people of Santa Clara.
People were told that the Stadium Authority, as a separate entity, would be better able to protect — and contribute to — the City's general fund.
After 2011, the City Council, City Manager, and City Attorney were now also serving as the Santa Clara Stadium Authority (SCSA) Board, Executive Director, and Agency Counsel.
Other City staff also had Stadium Authority positions.
The Stadium Authority reimburses the City for their time.
The Council and the Stadium Authority meet concurrently: Same people. Same room. Same agenda document — different agenda.
Confused? Welcome to Santa Clara City Government. We'll discuss Santa Clara's decision-makers throughout this site. It's important to know the key players and what they are up to. Let's do a little test — no wrong answers. Please play along.
So, it's a Tuesday night at Santa Clara City Hall. You find this meeting underway. What are you looking at? (Click one button. No answers are recorded.)
Which Santa Clara City Government Group Is This?
When We Talk About "Government"
On this site, "government" means the people making decisions on behalf of the public — the City Council, City Manager, City Attorney, and other senior officials, acting as individuals and as the city organization.
In Santa Clara, those same individuals may act as the City Council at one moment and the Stadium Authority at the next.
Understanding who is acting, and under which set of responsibilities, is essential to understanding how Santa Clara is governed today.
This complicated structure can make city government feel distant — as if decisions are being made by people disconnected from the everyday realities of the community they serve.
When that happens, trust begins to erode, and people start to feel that city government is something done to them, rather than by them and for them.
Trustworthy government communicates something different. Good government should feel like neighbors — first among equals, supported by professional staff — making decisions with the wisdom, experience, and moral maturity to do the right thing, earning trust because their decisions align in practical ways with the City's core values.
When Dr. Shanks first taught the City Council methods for ethical decision-making, a Council member said, "If we made decisions this way, who could disagree with us?" Dr. Shanks replied: "People can always disagree with your decision's out comes. But they should agree that you tested your biases and the potential outcomes of the decision by using time-tested, well-grounded good governance guiding principles."
It Worked.. Until It Didn't
For more than a decade, Santa Clara’s ethics program worked.
It worked because it was built around two clear goals:
- earning public trust
- creating a high-functioning, ethical workplace
The Code of Ethics & Values defined what ethical leadership looked like in practice — not just in principle — and applied to everyone in City service.
Strong leadership, ongoing training, and an engaged public made those standards real.
It worked because the City treated ethics as central to how it governed.
Then it didn’t.
Beginning around 2008 — and accelerating after long-time City Manager Jennifer Sparacino and her Deputy CM Carol McCarthy retired — priorities changed.
The program wasn't ended by a single decision. It was dismantled piece by piece.
Quietly.
Without a public vote. Without explanation.
By the time most residents noticed, there was little left to save — only public trust to rebuild.
Ten Years Without Ethics Analysis
Santa Clara started to dismantle its program in large part because previous City Council's began to take it from granted. When the 49ers came to town, they bedazzled the Council with celebrity and possibility, and the promise of new dollars coming into the City.
The City's priorities shifted, and Dr. Shanks left when ethics and public trust were no longer priorities.
But to claim it was just a shift in priorities does not honor the truth. In 2006 the 49ers announced their plans to build in Santa Clara. By 2009, discussions were well underway, but was a year before voters would approve the Stadium with Measure J.
Dr. Shanks had grown concerned about the number of ethics issues the newspapers were bringing up that, he believed, the Council was ignoring. In 2009 (and again in 2010 and 2011) he submitted proposals to Senior Staff for a special initiative, called an Ethics Impact Report, in which Staff would be trained to include potential ethical impacts of decisions about the stadium as they came up. They would not make decisions, just flag areas of concern. Not to block the stadium, but to protect public trust.
He wrote, "Few decisions have the potential to impact public trust as Stadium decisions."
Without public discussion, the word came back from somewhere that the city was not interested in making a special point, or any point, about stadium ethics.
After the Civil Grand Jury reported that the 49ers outplayed the City's negotiators and about the 49ers long-term plan to contest property taxes, the benefits of ethics analysis then, and now, can not be stressed enough.
The lesson the City should have learned is that good public decisions require more than legal compliance. They require identifying and addressing the ethical issues involved.
A well-reasoned decision asks:
- Does it honor the law and its purpose?
- Does it do more good than harm?
- Does it treat people fairly?
- Does it protect rights and serve the public interest?
The question is not simply, “Which side should win?” And "why I'm supporting the motion, or not."
It is:
“Is there a better way to act — one that meets more of our ethics standards and fiduciary responsibilities?”
👉 [See How Ethical Decisions Are Made]
A $6 Million Ethics Failure
Here's what happens when ethics is left out of major decision-making.
Something felt off in 2017, but no one identified the reason: it was the first year in nearly two decades that Santa Clara had stopped actively investing in ethics and public trust.
Ethics & public trust did not appear on the list of Council priorities. For the first time, no funds had been allocated in the budget for expert ethics consulting. The City no longer supported campaign ethics commitments, the Vote Ethics resident education and accountability program, or City-sponsored candidate forums.
When five Asian American residents sued the City, there was no ethics infrastructure left to advise the City on the many ethics issues involved.
Plaintiffs argued that Santa Clara's at-large election system had diluted minority voting power for decades. They were right. Asian residents make up more than half of Santa Clara's population — yet in the City's 70-year history, not a single Asian American had ever been elected to the City Council.
This was not simply a legal or statistical issue. It was a defining ethical test — a test of the City's core values in real time. It raised fundamental questions of fairness, rights, justice, harm, and the community's best interests. Every one of those ethics principles pointed in the same direction: move to district elections.
The City went in the other direction. It fought to preserve the status quo at every turn. It failed.
The result: $6 million in public funds spent defending a system the courts ultimately rejected. A fractured relationship with the City's largest demographic. Lasting divisions that contributed to what the 2024 Civil Grand Jury later described as "irreconcilable differences" on the City Council. And the same district elections Santa Clara would have had if it had acted on principle in the first place — $6 million poorer.
Was the City's decision to fight for the status quo the right thing to do for the people of Santa Clara? Was it designed to build public trust?
The ethics infrastructure that might have helped the City ask those questions — and answer them honestly — was gone. The City made a decision without the benefit of ethics analysis. That was a mistake.
Responding to the Attack on Self-Governance
The City appears to have learned very little from its poor decision to fight the Voting Right lawsuit. The City should have learned that legal advice does not always protect public trust; and that decisions will always be flawed unless serious consideration is given to discussing and resolving ethics issues.
It does seem to have learned how to delay, deny, dismiss, make claims that can't be verified, attack the messenger, and even twist facts to support their biases and self-perception that Santa Clara has no public trust problem.
This Council has doubled down on its disregard for ethics, and even after three Civil Grand Jury reports have documented ethics and governance failures, nothing has changed. Now even Senior City staff appears to be "going along to get along."
More than 20 years ago, the former City Manager of Palo Alto affirmed what all the professional public administration associations, including the Internation City Managers Association, which Mr. Grogan well understands, teach their members:
Power, Money, and the Attack on Self-Governance
A Defining Moment for Santa Clara
Despite its hands-off approach to ethical leadership and public trust, Santa Clara has created, perhaps inadvertently, a once-in-a-generation defining moment for ethics and public trust. It's going on right now.
At a time when the City is preparing for global events like the World Cup and managing hundreds of millions of dollars in infrastructure projects, it has also launched four major efforts—all at once:
- A comprehensive Charter review
- A rewrite of the Ethics Code
- Consideration of an independent Ethics Commission
- And a time-sensitive decision to turn full-year operational control of the Stadium, both NFL and Non-NFL seasons, and all City revenues, over to the team for the next 27 years (the Stadium "Put Right")
Each of these decisions could reshape how the City governs itself--and each has the potential to change the City's direction for the better, or to continue down the unethical slippery slope the City is on.
Taken together, they will determine whether Santa Clara strengthens, weakens, or destroys ethical leadership, good governance, and public trust for decades to come. The stakes are that high.
Pressing Questions: People Want to Know
For the past several months as we prepared this website, we have studied the City's approach to these issues. We have found that approach surprising, if not shocking.
We are left with questions the people of Santa Clara deserve to have answered.
.
- Why are these decisions being approached as separate, uncoordinated efforts—when together they can define Santa Clara's system of ethics, governance, oversight, accountability, and public trust for the next decade?
Why did the City take on all of this at once — in a year when it is also hosting the Super Bowl, FIFA World Cup matches, and managing hundreds of millions of dollars in infrastructure projects? Did the City think it had the capacity to do a good job, or was it just trying to remove the source of the ethics criticisim. Weak or no code, no criticism?
Do the City Council and Senior City Staff agree with what former Palo Alto City Manager Jim Keene said in 2008:Building and sustaining an ethical organization is one of the key responsibilities of public sector leaders? If the City doesn't agree with this, these initiatives are a waste of time and money.
4. Why did the City wait eight months to hire an "independent ethics consultant using the City's normal RFP process," then use an "informal RFQ" sent to 7 law firms (no ethics consultants), and then hire an employment lawyer under a new contract which a CPRA act didn't produce? What criteria were used to decide that the Code of Ethics & Values should be replaced, rather than built upon. The Council approved a motion "to review ethics documents," not to "replace the Ethics Code"
5. Who decided to restrict the Charter Review Committee to updating existing language and bringing the Charter up to date — but explicitly prohibiting it from recommending changes to City governance? Why are ethics infrastructure and best practices for ethics oversight being left entirely to the discretion of current and future City Councils, with no charter-level protection?
What happened to the Stadium Put Right? The proposal to hand the 49ers operational control of Levi's Stadium — for both NFL and non-NFL seasons, and all City revenues — for the next 27 years has gone quiet. We doubt it has gone away.
Why did City staff wait seven months after the Council approved hiring an ethics consultant — then skip the public RFQ process entirely, send an informal inquiry to seven law firms and no ethicists, and select a lawyer who was not independent? The consultant they hired had already represented the City in legal cases brought by City employees. She is now conducting both the ethics code revision and the ethics commission study.
And why does every one of these efforts exclude the Stadium Authority? The Stadium was established with integrity as one of its five founding values. Every decision now being made — the ethics code, the Charter Review, the ethics commission — has been structured to leave the Stadium Authority outside the ethics and accountability frameworks that apply to the rest of the City.
We don't have the answers. We asked. We were refused. But the people of Santa Clara are entitled to know — and entitled to askItem 1 - Why did the City take on all of this at once — in a year when it is also hosting the Super Bowl, FIFA World Cup matches, and managing hundreds of millions of dollars in infrastructure projects?
- Item 3
Four Decisions That Will Shape Santa Clara's Future
Comprehensive Charter Reform?
Will the Charter embed a best practices ethics infrastructure, good governance and public trust protections—with assurances of real public engagement—and apply them equally to the City, the Stadium Authority, all other authorities where the City Council exercises power, and other City public/private partnerships?
Or will ethics remain optional, leaving both vulnerable to the whims and shifting political allegiances of whichever City Council is in power?
Independent Ethics Commission?
Will the City create an independent Ethics Commission with full authority over both the City organization and the Stadium Authority, with real independence, resources, staffing and best practices to succeed with ethics and public trust training, advice, enforcement, and oversight?
Or will it establish a weak body, an ethics "program"—or continue with no meaningful oversight at all?
We hope the City's consultant will share the research result that shows the most effective ethics commissions were established by citizen ballot initiatives or referenda.
Universal Ethics Code?
Will Santa Clara restore and strengthen its values-based Code of Ethics & Values—and apply it to City and the Stadium Authority?
Or replace it with a minimal compliance code—or none at all—leaving the Stadium Authority and the City without meaningful standards?
Stadium "Put Right" for the People?
A one-time Stadium "put right" decision to transfer operational control to the 49ers—for both NFL and non-NFL events—and give the 49ers all the revenue from all sources for the next 27 years.
Will the 49er-PAC majority approve what the team wants or get independent analysis of benefits and liabilities and decide for the people?
Can the people believe what their 49er PAC supported Stadium Authority Board members will tell them?
Before debating that question, we suggest everyone read the March 18, 2025 Keyser Marston initial high-level analysis of the 49ers economic impact study.
We were surprised to find this report and astonished when we could only find it as an attachment to the August 2025 City updated response to the 2024 Outplayed report.
Two Questions That Can Change Everything
Every major decision is evaluated for cost, efficiency, and legality.
But two questions are almost never asked:
- THE ETHICS QUESTION: Why, if at all, is this the right thing to do for the people of Santa Clara?
- THE PUBLIC TRUST QUESTION: How, if at all, will this decision build public trust?
When these questions are ignored, even legal and efficient decisions can fail the most important test:
That belief is necessary for public trust.
Now, with so much at stake, these questions are even more important. They have the power to change the City's future--if the public engages, insists, and prevails.
Who Is "the Government" in Santa Clara?
When we refer to “the government” in Santa Clara, we mean the people who have the power to make decisions on behalf of residents and to spend public resources.
That includes the City Council, City Manager, City Attorney, and Finance Director—as individuals and as a group responsible for setting direction, making decisions, and overseeing public funds.
In Santa Clara, it also includes those same officials when they are acting as the Santa Clara Stadium Authority.
The Stadium Authority is a separate legal entity. But it is governed by the same elected and appointed officials who serve the City:
- The City Council serves as the Stadium Authority Board
- The City Manager serves as its Executive Director
- The City Attorney serves as its Counsel
- The City’s senior staff support its operations
The same people. The same decision-makers. Acting under a different legal structure.
WHY THIS MATTERS
When these officials act as the City, they ought to be bound by:
- The City Charter
- The Code of Ethics & Values
- The fiduciary duties to the public's best interests they assume upon election, appointment, or hiring
- Best practices and established expectations of accountability to the people
When those same officials act as the Stadium Authority, those same standards are not always clearly applied, enforced, or even addressed.
This creates a situation where:
The Bottom Line
For the purposes of this site:
Because from the public’s perspective:
- The authority comes from the consent of the governed
- The decisions affect the same residents
- And the responsibility to act in the public’s best interest should be the same
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My Awesome Headline
When we refer to “the government” in this section, we are referring primarily to the City Council, City Manager, and City Attorney—as individuals and as a group making decisions and setting direction for the City.
The analyses and conclusions you will find throughout this site are based on publicly available information, our own communications with City officials, and reporting from reputable news organizations.
A clear pattern emerges from these sources. It describes what City government looks like today through an ethics lens and with a public trust perspective.
How This Government Thinks about Ethics & Trust
When we refer to “the government” in this section, we are referring primarily to the City Council, City Manager, and City Attorney—as individuals and as a group making decisions and setting direction for the City.
The analyses and conclusions you will find throughout this site are based on publicly available information, our own communications with City officials, and reporting from reputable news organizations.
A clear pattern emerges from these sources. It describes what City government looks like today through an ethics lens and with a public trust perspective.
See for Yourself
To understand what this Council really thinks about ethical leadership, one another, the public, and the Ethics & Values Program it has been dismantling, we encourage residents to watch—or read the transcript of—the July 11, 2023 Council meeting.
The agenda item was whether to establish an independent ethics commission, as recommended by the Santa Clara County Civil Grand Jury in Unsportsmanlike Conduct (October 2022).
The Council had already rejected the recommendation once for its January 2023 official response. It was brought back for discussion and reconsideration six months later.
The discussion was the final 50 minutes of a six-hour meeting. Only the Council and senior staff were present in Council Chambers.
Very few members of the public, if any, watched online. No media covered it.
City staff made no formal recommendation—an unusual occurrence.
As you watch or read, keep in mind that some statements reflect individual opinions or incomplete information, and may not fully reflect the City’s ethics program as it was actually designed and implemented. A question to guide your thinking:
Watch the meeting or read the transcript.
Draw your own conclusions.
Read what was missing from the agenda report →
See the Candidate Guide to Running for Office →
What Happens When Ethics Is Ignored
Over the past several years, a clear pattern has emerged in Santa Clara’s most important decisions.
These examples show what happens when ethics and public trust are left out of decision-making.
Each of these decisions would likely have been very different if the City had asked—and answered honestly—two questions:
Why, if at all, is this the right thing to do for the people of Santa Clara?
How, if at all, is this likely to build public trust?
For additional details for each numbered story below, click on the + (plus) sign on the left. To close the details, click on the - (minus) sign.
1. A Council Majority Elected with Outside Money...Lots of It
49er-funded PACs have spent over $10 million in the last three elections helping to elect five of their preferred candidates to a 7 seat Council/Stadium Authority Board.
The 2022 Civil Grand Jury report found that these five members "can--and do--vote in a manner favorable to the Team." Rather than discuss the conflicts of interest, the majority denied vehemently that there was a 5-person voting bloc. Then voted to approve the formal response to the Graqnd 4-2, with one member absent for the vote.
Trust requires independence. Week after week, Council (and even senior staff) behave as if they are 49ers employees, supporting everything the Team wants--with no recusals, no Agency Counsel (City Attorney) advisories or warnings, no Executive Director/City Manager directives about Stadium Authority ethics.
2. Campaign "Limits" That Unfairly Limit One Side
Almost all candidates running for election in Santa Clara agree to spend no more than about $25,000 on their campaigns. Candidates get some incentives to join the program and stay within limits.
But here's the problem: Independent expenditures don't count toward the spending cap. That what the 49er PACs spend their money on. It's legal for them to spend as much money as they like--and the 49er-PAC supported candidates can still claim "I didn't take any special interest money" and "I didn't spend more than $25,000." It's like a college student who tells his parents that he stayed within his budget, but fails to mention his fairy godmother who spent 20 times his parent's budget on things she figured he needed.
The only people the voluntary campaign cap hurts are opponents of the 49er candidates.They are caught between a rock and a hard place: if they don't accept the cap, they get dinged in public opinion; if they do accept the cap, they get dinged throughout the campaign by the unlimited 49er spending.
Trust requires honesty in how elections are conducted. What we see instead misleads voters.
3. No Plan to Protect Santa Clara's Self-Government
Self-government is a fundamental principle in our democracy. In self-governing cities, residents—not a single powerful corporation—decide who governs, what information voters receive, and whose interests City Hall serves.
THE FACTS: For three elections since 2020, 49er-funded PACs have spent $10+ million to secure 5 of 7 Council and Stadium Authority seats. The upcoming 2026 election has three open seats: Mayor, District 2, and District 3.
Santa Clara has detailed plans for disasters that might happen—earthquakes, floods, fires. But there is no plan for a disaster the city knows will happen, because it has happened in each of the last three elections. The Levi's Stadium lease runs through 2054, with options to 2074. That's potentially 15 more election cycles.
WAIT & SEE:
Will 49er PACs now try to buy the mayor's office, elected at-large to speak for all the people? She has been a clear team critic?
Will the PACs keep their hold on District 2 & 3?
Who are the PAC-selected candidates?
How are they selected?
Who, if anyone, will run against them?
How much money, if any, will the PACs spend?
What's the 49er attack strategy?
Have all candidates signed the State Code of Fair Campaign Practices?
Is anybody publicly repudiating any of the attacks, including what will happen if they continue to attack?
What are the facts, if any, behind the attacks and the rebuttals?
TRUSTWORTHY LEADERS WOULD:
Address the threat head-on and on-going.
No silence or going dark.
Publish a timeline.
Set a planning deadline.
Engage residents, experts, and ethical campaign specialists to develop an effective response that builds public trust—before the damage is done.
WHAT WE ARE GETTING NOW:
Nothing. No planning. No public discussion. No asking for public input on what to do to honor first amendment rights and at the same time build public trust that the voters choose who governs, information that gets sewnt out, and how City Hall act. None of that is included in the regular 5-2 votes for the 49ers agenda.
4. Independent Voices Removed--and Not Replaced
5. "Innocent Until Proven Guilty" Still Destroys Public Trust
THE FACTS: In October 2022, Councilmember Anthony Becker leaked a confidential Civil Grand Jury report—"Unsportsmanlike Conduct," which was sharply critical of the Council majority's relationship with the 49ers—to the team's top lobbyist, Rahul Chandhok.
This gave the 49er crisis communication team four days to mount a campaign to discredit the the report as a "political hatchet job," to claim the District Attorney and the Civil Grand Jury were motivated by politics, to point out all the "errors" in the report and its methodology, and to claim the Mayor had already leaked the report to the S.F. Chronicle. There were also reports that the 49ers had hired opposition researchers to dig up dirt on the Civil Grand Jurors.
The District Attorney launched an investigation, which led to Rahul Chandook being granted immunity, testifying that Mr. Becker had leaked the report to Mr. Chandhook and the Silicon Valley Voice. Later, Mr. Becker was asked if he had leaked the report and he liked about it under oath. Mr. Becker pleaded not guilty, waived his right to a speedy trial, and twenty months later, he was convicted of felony perjury and a misdemeanor for failing to due his duty.
THE TIMELINE:
April 2023: Becker indicted on felony perjury and misdemeanor failure to perform duty. He refused to resign.
April 2023 – December 2024: His colleagues made him Vice Mayor and let him vote on every 49ers issue for 20 months—citing "innocent until proven guilty." That's a legal standard. Public trust asks: Can this Council Member act independently?
July 11, 2023: Three months after indictment, Becker participates in the Council's last substantive discussion of ethics, an hour-long conversation at the end of the meeting. No public present. Staff made no recommendation. The agenda item was unclear — revisit the ethics commission they'd already rejected.
What followed revealed what this Council really believed/believes about ethics, the former ethics program, Santa Clara residents, public trust, and themselves. Becker moved to reject the commission because it would "just be used as a political weapon."
November 5, 2024: Lost re-election bid.
November 6, 2024: Trial began—the day after he lost.
December 5, 2024: Convicted. Jury deliberated less than three hours.
December 6, 2024: Resigned—one day after conviction, 11 days before his term ended.
April 4, 2025: Sentenced to 40 days in a county work program picking up trash.
The 49ers had spent over $3 million supporting his campaigns.
After his conviction, Becker told his probation officer the whole thing was "about politics."
The DA said: "Some may have grown used to public officials lying. Committing perjury to the civil grand jury is not a white lie, an exaggeration, or politics. It is a crime and a serious abuse of the public trust."
TRUSTWORTHY LEADERS WOULD: After indictment, at the very least, he should recuse himself from 49ers-related votes to protect the integrity of City decisions. Having supported him through two elections, and having met dozens of times with him, could anyone, including the 49ers, think he could make an independent judgment about them. Demand his resignation to protect public trust.
WHAT WE GOT: They made him Vice Mayor. They let him vote on every 49ers issue for 20 months. During depositions, one colleague testified Becker had told him that he leaked the report. During the trial, that colleague changed his testimony and said he must have been “confused.” Two colleagues spoke at his sentencing asking the judge for no jail time.
6. 'If You Don't Feel You Have a Conflict..."
THE FACTS: During state-required ethics training, the City Attorney's office told council members: "If you feel like you are not being influenced by personal interests, why should you remove yourself?"This directly contradicts the "appearance of impropriety" standard cited on the same training slide.
WHY THIS MATTERS: The appearance standard exists because the public cannot see inside officials' minds. We can only see their actions. When officials who received $10+ million in PAC support vote on 49ers matters without recusal, it looks like a conflict—regardless of how they feel inside.
Every ethicist knows we are terrible judges of our own bias. That's why appearance standards exist—because the public can only see what you do, not what you feel. "I don't feel conflicted" is exactly what conflicted people say.
TRUSTWORTHY LEADERS WOULD: Teach the actual standard: Appearance of conflict damages public trust as much as actual conflict, because appearances are all the public has.
WHAT WE'RE GETTING NOW: Training that gives conflicted officials permission to vote anyway.
7. Replacing the Ethics Code with "Just Follow the Law."
THE FACTS: In July 2023, the Council approved hiring a consultant to "review ethics documents."
8-month unexplained delay before City staff created an RFQ for a document review of current ethics document and recommendations for next steps.
City posted RFQ on normal posting site; send separate letter to eight law firms; hired LCW and lawyer the City worked with frequently before. Rushed responses and contract by March 2024. October 15, 2025 public records request for the contract was delayed five times until January 16 when it was closed. Contract sent was a 2021 contract and an extension in 2024. Neither was for the ethics RFQ. Also requested and not sent were communications with the consultant changing “review ethics documents” to “replace ethics code.”
1 year of work behind closed doors
Zero public input
March 2025: Consultant presented a "replacement" code—not a review at 10 a.m. on a weekday morning at a public meeting of the Governance & Ethics Commission which typically has one or two members of the public in chamber or participating virtually.
WHAT THE REPLACEMENT CODE DOES:
Covers only City Council (not the elected Police Chief, elected City Clerk, commissioners, or staff)
Reduces 8 values to 6
Eliminates all behavioral standards
Requires only that Council "obey the law"
Does not apply to Stadium Authority
If approved, it's unclear whether anyone else remains covered by any ethics code at all.
RECORDS REQUESTS: A public records request for the contract and communications showing how "review" became "replace" was delayed six times over three months and closed without providing the documents.
TRUSTWORTHY LEADERS WOULD: Follow the open, inclusive process that made the original code a state model. Engage stakeholders. Build consensus.
WHAT WE'RE GETTING NOW: A closed-door rewrite that abandons 25 years of progress.
8. Running a Billion-Dollar Public Asset as An 'Ethics Free Zone.'
THE FACTS: The Stadium Authority manages Levi's Stadium—a $1.3 billion public asset generating hundreds of millions in annual revenue.
It has never adopted an ethics code.
Three Civil Grand Jury reports recommended ethics reforms for stadium governance. The recommendations have not been implemented.
The same five council members who vote as a bloc for 49ers interests on City Council also control the Stadium Authority.
TRUSTWORTHY LEADERS WOULD: Apply the same ethical standards to stadium governance. Include good governance protections in the Charter Review. Establish independent oversight.
WHAT WE'RE GETTING NOW: A decade of operating a billion-dollar public asset with zero ethical guardrails. The same conflicts. The same closed-door decisions. The same 5-2 votes.
9. Rewriting the Charter--But Excluding the Stadium Authority
THE FACTS: The City is conducting a Charter Review—the first comprehensive update in years. But the Stadium Authority, which manages a $1.3 billion public asset, has been excluded from the scope of the review.
Three Civil Grand Jury reports documented governance failures tied to the Stadium Authority. The same five council members who vote as a bloc for 49ers interests on City Council also control the Stadium Authority. The Authority has operated for over a decade without an ethics code, without independent oversight, and without meaningful public accountability.
A Charter Review that ignores the Stadium Authority is like a home inspection that skips the foundation. Voters are being asked to approve changes to how the City operates while the entity at the center of the City's biggest governance failures gets a pass.
TRUSTWORTHY LEADERS WOULD: Include the Stadium Authority in any comprehensive Charter Review. Address the governance failures documented by three Grand Juries. Give voters a complete picture before asking for their approval.
WHAT WE'RE GETTING NOW: A Charter Review designed around the problem, not through it.
10. Failing to Protect Ethics & Public Trust Programs
THE FACTS: Over 14 years, successive councils have quietly dismantled Santa Clara's nationally recognized ethics program—without a single public hearing, without resident input, and without anyone officially announcing what they were doing. Resident confidence collapsed from 91% to 40%.
The ethics code, the training program, the core values, the ethics consultant position and idependent advice, the Campaign ethics program, Vote Ethics —all either eliminated, weakened, or ignored. None of these required a public vote to cancel. That's the problem.
Charter-level protection means voters—not a council majority—decide whether ethics and public trust infrastructure stays or goes. Without it, the next council can finish what this one started: a City Hall culture that practices politics without principle, government without ethics, and, ultimately, a City without trust.
TRUSTWORTHY LEADERS WOULD: Embed a values-centered ethics Code for everyone, including the Stadium Authority and other public/private partnerships, training, expertise, advice, ownership, a development plan, funding, and other components of a best practices public trust regime. This also includes an independent, funded, staffed ethics or public trust commission, with subpoena power and a robust set of sanctions. It should also include a smaller appeals Board.
WHAT WE'RE GETTING NOW: No plans to include ethics in the Charter. No public trust protections. The same approach that produced 14 years of decline—and hoping nobody notices.
Four Decisions Will Shape What Happens Next
Now the same City Council that made the ethically questionable decisions we listed above faces four decisions that present a genuine opportunity to rebuild public trust — perhaps the most significant opportunity in a generation.
But the 49er PAC majority and senior City staff, who have enabled them for the past three years, are approaching these decisions the same way they have approached ethics, accountability, and public participation since they were elected in 2020: hire a consultant they control, structure the process to limit public input, and reach a predetermined conclusion.
The window to change that outcome is open at this moment in mid-March 2026. It will not stay open long.
Why Public Trust Now
For four years, residents have complained. Three Civil Grand Jury reports have documented ethics and governance failures. An ethics expert has been raising the alarm publicly since 2022. The City's own survey shows 60% of residents believe Santa Clara is going in the wrong direction.
Nothing changed. If anything, the complaints and reports have only sped up what we can only describe as an anti-ethics and anti public trust agenda.
We hope there is another explanation: gross incompetence,
Someone realized the easiest way to stop ethics complaints is to eliminate the ethics code — so they are replacing Santa Clara's comprehensive, values-centered Code with a follow-the-law compliance document, drafted behind closed doors by a law firm.
Someone realized the more they rejected an independent ethics commission, the more the Civil Grand Jury would keep recommending one — so now they are studying it, asking questions that cities of every size have already answered, until they can say: we studied it, and it's just not right for Santa Clara.
That is what this site does. Here is what we promise:
We will be fact-based. Our analyses ask what a reasonable person would conclude with access only to what the public can access: what does this document actually say, and what does it mean for public trust? We follow the evidence. We correct errors when we find them.
We will cover what is happening — the ethics code revision, the ethics commission study, the Charter Review — through an ethics lens, so residents are informed about what their government is doing, or failing to do.
We will tell you what the documents mean — not just what they say. Grand Jury reports, contracts, meeting transcripts, public records. Translated into plain language, analyzed for their ethics and public trust implications.
We will create space for genuine democratic dialogue — because the City has been steadily removing opportunities for residents to speak to their government, much less to one another. That space needs to exist somewhere.
We will not tell you what to think — but what to think about, how to think it through, and how to turn thought into practical and effective action for the common good.
We will be honest about what we don't know — and rigorous about what we do.
The Bulldozer Is Already In the Yard
Twenty-five years ago, a long-time Santa Clara resident on the ethics ordinance committee pulled Dr. Shanks aside after one of the committee meetings. He didn't want Dr. Shanks to be disappointed if other residents didn't respond to the request to participate in the ethics development process.
"You've got to understand," he said. "Santa Clara residents won't respond to City Hall unless there's a bulldozer with the City's name on it in their front yard. It's already knocked down the fence and it's on its way to the front door. Then they'll respond."
After working on this site for the past five months, we believe that bulldozer has arrived. It has already knocked down your front fence, and it's on its way to your front door. There is no time to lose.
The people are the only force with the political power to change a city's direction. Thomas Jefferson understood what this moment requires:
Whenever the people are well informed they can be trusted with their own government; that whenever things get so far wrong as to attract their notice, they may be relied on to set them to rights.
Article II Section 1 of California's Constitution makes it law:
All political power is inherent in the people. Government is instituted for their protection, security, and benefit, and they have the right to alter or reform it when the public good may require.
The public good needs your attention. Public Trust Now is here to help.
What You Can Do
Santa Clara was once a role model for ethical leadership and public trust. Residents can help the City become that again. Here's how to start.