An independent expenditure committee backing former Mayor Sam Adams in the May 19 primary appears to have violated the city's new election rules.

"It's most likely we made a mistake," Jenn Baker, director of the "Sam Works for Portland" political action committee, told WW on Sunday.

Voters across Portland this week got a big glossy mailer titled "Sam Works," extolling the virtues of Adams, who served as mayor from 2009 to 2013 and is seeking to make a political comeback.

Adams is challenging incumbent City Commissioner Chloe Eudaly. Both candidates, as well as two other challengers, Mingus Mapps and Seth Woolley, decided to take advantage of the city's new Open and Accountable Elections program, which provides matching funds of up to 6 to 1 for contributions up to $50 per donor and allows City Council candidates to raise up to $250,000 for the primary. (WW endorsed Adams in the race.)

But the new public financing mechanism still allows independent expenditures. In that case, outside funders form a committee to support or oppose a candidate, with the proviso that the independent committee cannot coordinate with the candidate it supports—in this case, Adams.

State filings show that on April 17, a new committee, Sam Works for Portland, was established. The director of the committee is Baker, state council director for Service Employees International Union.

The committee has not yet disclosed raising or spending any money—but the mailer it sent out on Adams' behalf came to the attention of Dan Meek and Jason Kafoury, two lawyers who are part of the group Honest Elections Portland.

A little after 6 pm on Friday May 8—i.e., after the City Elections Office closed for the weekend—Meek and Kafoury filed a complaint with that office, alleging the "Sam Works" mailer failed to comply with city rules requiring disclosure of who paid for it. The lawyers noted in their complaint that new city rules require communications with voters on a candidate's behalf to include the names of the individuals or group who paid for the communication.

Baker tells WW it appears the complainants are correct.

"While we haven't heard back from the city," Baker writes in an email, "after reviewing and conferring with counsel, I think it's most likely that we made a mistake."

Baker passed along a copy of the response her group sent to the City Elections Office. Here's what it says:

"When we prepared our mailer, we carefully reviewed the Open and Accountable Election section of your website, including the applicable rules for independent expenditures," the response says. "We did not see any notice of additional 'disclaimer' rules in those materials, so we followed the standard practices."

"We now understand that we may have missed the separate disclaimer provisions," the response continues. "Any omission was inadvertent; our political committee understands the importance of transparency."

In their complaint, Meek and Kafoury note that city election rules allow for a civil fine "which is not less than two nor more than 20 times the amount of the unlawful contribution or expenditure or independent expenditure at issue."

The elections office was closed for the weekend, so officials could not be reached for comment.