By Jen Schumann | Rocky Mountain Voice
A building paid for with bingo money. A political party using it as their headquarters. And more than $5 million in unreported financial activity that, to date, no one has answered for.
That’s the core of Pueblo resident Jonathan Ambler’s ongoing legal challenge against the Pueblo County Democratic Party and its Central Committee. Ambler, a former Republican candidate, filed two complaints last fall alleging the party used a bingo-funded building for years without reporting it in TRACER.
After the Colorado Secretary of State dismissed both complaints in April, Ambler – without an attorney – petitioned the Denver District Court for judicial review.
“If political activities are occurring at the building – and the Party itself refers to it as their headquarters – that should be reported,” Ambler wrote in a press release announcing the court filing. “Dismissing these complaints without fully investigating the facts undermines the transparency our laws are meant to ensure.”
As Rocky Mountain Voice first reported in January, the complaints center on a property located at 602 W. 9th Street in Pueblo.
The building is repeatedly referred to by the party as its headquarters in social media posts and event flyers for campaign gatherings, volunteer phone banks and barbecue fundraisers.
But in legal filings, the party claims the building is operated by a separate nonprofit entity – the Pueblo County Democratic Central Committee – which they describe as a charitable educational organization.
Campaign HQ or charitable hall?
Ambler argues that the party can’t have it both ways.
In his court filing, he points to more than a dozen screenshots from the Pueblo Democrats’ website and social media pages that call the building “Dem HQ,” inviting the public to attend candidate events there.
A 2023 post promoting a campaign event reads: “C’mon down to Dem HQ this Friday to have a beer with CD-3 candidate Adam Frisch… at Dem HQ, 602 W. 9th St.”
Posts and flyers call on volunteers to canvass and phone bank there twice a week through the election.
“Even on their website… they still talk about the building being a headquarters. And if it is a headquarters, then its party use and every penny of it should be reported,” Ambler told RMV.
The party’s own website adds to the confusion. A now-archived page describing their Friday night bingo fundraiser reads: “We own our Headquarters building outright thanks to bingo (!)” – an exhibit Ambler included in his petition for judicial review.
Despite the public branding, the party’s formal response to the Secretary of State described the building as a space used for “educational purposes” and “community outreach” – not campaign operations.
They reported the property was bought by a separate nonprofit, the PDCC, not subject to campaign finance law.
The money trail: Bingo revenue vs. TRACER filings
Ambler points to a multimillion-dollar gap between what the PDCC reported in bingo revenue and what the party disclosed in campaign finance filings.
According to reports filed with the Secretary of State’s charitable gaming division, the PDCC collected over $3.3 million in gross bingo receipts between 2013 and mid-2024.
Ambler estimates that half of that amount was spent on operational expenses like rent, printing, and staffing – a conservative estimate that adds another $1.6 million in unreported expenditures.
“These contributions should have included contributors’ information as required by law… This makes provable reporting violations in excess of $5 million,” Ambler wrote in his December 2024 complaint.
In contrast, TRACER filings from the Pueblo County Democratic Party show just $2,878 in monetary contributions reported for all of 2024 – and $23.25 in expenditures, filed electronically on December 10.
“The whole point of campaign finance laws is that a political party is supposed to report their transactions so that we can tell whether they’re using them properly or not,” Ambler told RMV.
Ambler contends that the gap is not just a paperwork issue, but a breakdown in transparency.
The party’s explanation – submitted in response to the original complaint – did not deny the revenue or the building’s political use but asserted that the PDCC is a separate nonprofit and that none of the bingo income goes to candidates.
Yet Ambler’s evidence includes a 2018 TRACER report showing the PDCC contributed $200 to the Fremont County Democratic Party, contradicting that claim.
No cure filed, no explanation given
What’s missing is key: after receiving a formal notice from the Secretary of State in January allowing them to submit a Notice of Intent to Cure – a standard remedy in cases of possible reporting violations.
Despite a January 23, 2025 deadline to amend their filings or demonstrate substantial compliance with the law, no such notice was submitted. A review of the party’s TRACER records shows no notice, corrections or supplemental reports.
The Secretary of State’s office ultimately dismissed both complaints on April 4, stating there was insufficient evidence to justify a formal hearing.
Ambler is now asking the Denver District Court to reverse that decision and order a full investigation.
“Even under that circumstance, the Secretary of State can investigate on their own,” Ambler said. “They can throw my complaint out, but they should still do their job.”
Legal contradictions: Is this a 501(c)(3) loophole?
Ambler also questions the PDCC’s legal structure, noting it owns the building and holds the bingo license. In court filings, he includes its 1984 articles of incorporation, which describe it as an educational nonprofit seeking 501(c)(3) status.
“The activities of this organization shall be educational and designed to advance public education… as required by Section 501(c)(3),” the articles read. The same document states that the PDCC shall not engage in any activity that would disqualify it from 501(c)(3) status.
According to Ambler, the PDCC never amended those articles, despite its current role in directly supporting partisan campaign activities – owning and maintaining the party’s headquarters and funding operations through bingo proceeds.
“If the PDCC remains a 501(c)(3), it may be operating in violation of federal tax law,” Ambler wrote in his petition. “And if it has ceased being a 501(c)(3), that change should be reflected in updated public filings – which it’s not.”
He argues that if the PDCC is part of the party, its finances should be reported in TRACER. If it’s separate, rent-free support could count as an illegal contribution.
“Either it’s part of the party and subject to reporting, or it’s separate and not allowed to donate to the party. It can’t be both,” Ambler said.
What Ambler wants from the court
Ambler isn’t asking the court to impose penalties at this stage.
His petition asks the court to reverse the Secretary of State’s dismissal and order a full investigation, including a hearing on the building’s political use and possible finance violations.
He asserts that a hearing could force testimony, disclose internal records and determine if the PDCC’s decades-old nonprofit status remains valid.
It would give regulators another chance to decide if activity at 602 W. 9th violated the law – and whether the reporting failure was intentional.
The court is not expected to rule on the matter until later this year. Meanwhile, the Pueblo County Democratic Party has made no public statement and has not amended its filings.
The broader question: Who’s watching?
For Ambler, this case is about more than one building or one party.
He believes it exposes a larger weakness in Colorado’s campaign finance enforcement system – one where rules exist on paper, but rarely get enforced unless watchdogs like him take the initiative.
“There are tens of millions of dollars in outstanding fines… Nobody talks about it,” he said. “And if the Secretary of State isn’t going to enforce the law, who is?”
He said the data suggests a culture of noncompliance – and a lack of follow-through from the agency in charge of oversight.
“I don’t care if you’re Democrat or Republican,” Ambler said. “The rules are there so voters know who’s paying for what. If one side gets to hide millions of dollars, what’s the point of having laws at all?”