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Webinar: Implementing SB 1439 – A Discussion of the New FPPC Guidance, and Recommended Best Practices

August 10, 2023 @ 12:00 pm 1:00 pm

1 Hour MCLE; 1 Legal Ethics

The Fair Political Practices Commission has adopted new and amended regulations to implement SB 1439 – the bill adopted last year that extended the Levine Act’s (Gov. Code § 84308) requirements to local elected officials. SB 1439 provides that local elected officials – including city council members, special district board members and school district board members – are now required to “conflict out” of certain proceedings involving persons that made contributions to their respective political campaigns. The statute also prohibits officials from receiving contributions exceeding $250 from a party to or participant in the proceeding, or their agents, while such a proceeding is pending and for 12 months after the final decision in the proceeding.  Prior to the passage of SB 1439, the Levine Act only applied to officials serving on appointed boards. 

The new FPPC guidance provides some clarification as to how the bill should be implemented, including by defining who is consider an “officer” and when a proceeding is considered “pending.” In addition to discussing the new FPPC guidance, this webinar will also consider recommended best practices for implementation.  

Non-Member Price: $75.00
Member Price: $55.00

Victoria Hester

As Partner and Director of BB&K’s Government Policy and Public Integrity group, Victoria “Tori” Hester routinely advises public agency clients regarding their ethical duties, including how to address potential conflicts of interest under the Political Reform Act and Government Code Section 1090. Tori also provides trainings to public agency clients, including the firm’s biennial AB 1234 Ethics Training and Brown Act trainings, and assists city attorneys (both inside and outside the firm) in providing ethics and conflict of interest advice to their clients. Tori serves as assistant city attorney for the City of Santee, and handles the day-to-day advisory work, including the City Council agenda review and contract review. Additionally, as a member of BB&K’s Housing Group, Tori assists clients in ensuring compliance with state housing law, including navigating the rapidly changing requirements of affordable housing and density bonus law.

Tori serves on the Executive Committee of the San Diego County Bar Association’s Government Law Section. She was a summer associate at BB&K before joining the firm in 2014.

Tori graduated summa cum laude from Point Loma Nazarene University, where she earned her bachelor’s degree in history with a minor in Spanish. Tori received her law degree from University of California, Irvine School of Law, where she was lead article editor on the UC Irvine Law Review, and participated in the UC Irvine Immigrants’ Rights Clinic. As a clinical student, Tori co-authored a report on juvenile deportation titled “Second Chances for All.” Throughout her law school career, Tori engaged in pro bono work, including assisting on a guardianship case and conducting preliminary screenings for the California Innocence Project.

Tori grew up in San Diego, where she now lives with her husband, Jeff, an underwater cameraman, and her son Ashton. As a member of the Point Loma Nazarene University Track & Field Team, Tori earned eight All-American titles. She enjoys running, playing volleyball, scuba diving and traveling. 

We are committed to accessibility! Virtual events are equipped with closed captioning. To request an in-person accommodation, send us a note at or contact us at 916-516-1760 for assistance.


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