Vacancies in several state and local elected public offices throughout the state have triggered “special elections” in these jurisdictions in early 2025.
If you choose to make a contribution in connection with one of these special elections, you may be required to file a report within 24 hours. Specifically, if you make a contribution of $1,000 or more within the 90 days before the election to one of the candidates running in one of the special elections, or to an “independent expenditure PAC” supporting or opposing one of these candidates, you will be required to file a report within 24-hours (FPPC Form 497) – though these 24-hour reports are only required if you have by that point in time contributed a total of $10,000 or more to California state and local candidates and committees in 2025 (and thereby qualified as a “Major Donor”). We are sending our clients and colleagues this Alert because, in our experience, contributors often miss these 24-hour reports when special elections are scheduled in the beginning of an odd-numbered year.
Here are some notable special elections scheduled so far in 2025:
Jurisdiction |
Special Election |
Election Date |
Current Contribution Limit |
AD 32 |
State Assembly |
February 25 |
$5,900 |
SD 36 |
State Senate |
February 25 |
$5,900 |
Fresno |
City Council District 5 |
March 18 |
$5,900 |
San Jose |
City Council District 3 |
April 8 |
$700 |
San Diego County |
Board of Supervisors District 1 |
April 8 |
$1,100 |
Oakland |
Mayoral Recall |
April 15 |
$600 (set to increase to $650 at end of January) |
Oakland |
City Council District 2 |
April 15 |
$600 (set to increase to $650 at end of January) |
Irvine |
City Council District 5 |
April 15 |
$650 |
This chart does not reference every special election scheduled for 2025. In addition, a handful of local jurisdictions will hold regular elections during 2025.
If Rutan and Tucker files your Major Donor reports, please notify us of your contributions on or before the day they are made so we can determine whether a 24-hour report is required (and please let us know if you have made any other contributions so far in 2025 so that we can determine if you have reached the Major Donor threshold).
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Feel free to contact a Rutan and Tucker, LLP attorney or Political Compliance Specialist if you have any questions regarding these campaign reporting laws and limitations.