Letter Sent to Members of the Baltimore County Republican Central Committee and the MD State GOP
Subject: Formal Objection to Procedural and Substantive Deficiencies in the November 7, 2024 “Ethics Committee” Letter
Dear BCRCC and MDGOP Chair and Members of the Committee,
I write to formally object to the procedural irregularities and bylaw violations contained in the Baltimore County Republican Central Committee (“BCRCC”) Ethics Committee letter dated November 7, 2024, which purports to render a final determination regarding a complaint filed against Ms. Deb Sullivan. Given to me by Glen Geelhaar was the response to him from Linda Preece, then Chair of the Ethics Subcommittee, is attached.
reader: click here for letter
For those unaware, here is a link to the original complaint from Mr. Geelhaar. The complaint made headlines as well, as in this Fox45 News Story.
Upon review of the BCRCC Bylaws, it is evident that the Ethics Committee’s actions and conclusions in that correspondence do not comply with the governing rules and authority of the organization.
1. Defects of Authority by the Ethics Committee
The letter asserts that the “Ethics Committee met to review your complaint… and unanimously concluded…” This language indicates that the subcommittee rendered a final decision.
However, Article I, Section 7(C)(6) of the BCRCC Bylaws clearly limits the Ethics Subcommittee’s role to reviewing complaints and recommending appropriate action to the full Central Committee.
Only the full Central Committee, under Article I, Section 2(B), possesses “sole jurisdiction to hear and determine charges” of misconduct and to impose any disciplinary action.
Accordingly, any “decision” or “conclusion” issued directly by the Ethics Subcommittee exceeds its authority and is ultra vires (beyond its lawful power).
2. Chair of a Subcommittee Unauthorized to Issue Decisions to Complainants
The letter was sent directly from Linda Preece, Chair of the Ethics Subcommittee (at that time) to the complainant, conveying a final determination.
• Article I, Section 7(C)(6) specifies that subcommittees are responsible only for review and recommendation of complaints.
• No provision authorizes a subcommittee chair to communicate a final decision to a complainant.
By issuing a purported decision directly, the Chair may have committed misfeasance, defined under Article I, Section 2(B) as the improper performance of duties by a member of the Committee. This action improperly circumvents the procedural safeguards and the authority of the full Central Committee.
3. Failure to Follow Required Procedure for Misconduct Charges
The Bylaws require that misconduct charges be heard and determined by the full Central Committee, not by any subcommittee. There is no indication that a properly noticed meeting was convened or that a quorumed vote occurred. Therefore, the Ethics Committee’s letter cannot constitute a valid disposition under Article I, Section 2(B).
4. Lack of Due Notice and Recorded Vote
Pursuant to Article I, Section 3(B)(1), at least five days written notice must be given to the full Committee before any meeting or vote on disciplinary matters.
The November 7 correspondence does not reference any such notice, meeting, or vote—further invalidating any action taken.
5. Introduction of a Nonexistent “Official Candidate” Standard
The letter’s determination rests on the claim that “since you are not an official candidate for 2026, Ms. Sullivan did not violate” applicable sections.
No such limitation appears anywhere in Article I, Section 15, which defines misconduct as slander, libel, or false dissemination against “Republican Candidates, Republican Nominees, Elected Office Holders, and Committee Members.”
The Committee’s creation of an “official candidate” threshold is unsupported by the Bylaws and therefore impermissible.
6. Bypassing the Full Committee
Even assuming a proper review occurred, the Ethics Subcommittee was required to submit a written recommendation to the full Committee for discussion and vote.
No such referral or vote occurred, violating the chain of authority defined in Article I, Section 7(C)(6).
7. Non-Compliant Affirmation of Prior Matters
The letter asserts that:
“The Committee will not be revisiting the contribution to Delegate Carl Jackson as the full committee addressed it appropriately in 2022.”
This statement is false. The matter was never brought before the Ethics Committee. An email from Al Mendelsohn does not constitute an “investigation,” nor does Acting Chair Boccelli’s “forgiveness.”
Witnesses confirm that Ms. Sullivan received a binder containing the Bylaws at that time. By swearing an oath to abide by them, she affirmed her full awareness of their requirements and her obligation to uphold them. Her subsequent actions, therefore, constitute ongoing violations of those Bylaws. The assertion made in the November 7 letter is both misleading and incorrect.
8. Improper Promise of Future Political Support
The letter’s statement that “should you win the primary, the Committee will provide you with the same level of support as all other 2026 Republican General Election candidates” constitutes an unauthorized political assurance.
Under Article I, Section 2(F), the Committee may not support or commit to support any candidate prior to the general election. The statement violates this restriction and gives the appearance of partiality.
9. Failure to Timely Submit Amended Bylaws to the State GOP
Article III(B) of the BCRCC Bylaws requires that any amendments be filed with the State Administrative Board of Election Laws and State Central Committee within thirty (30) days of adoption.
• The current Bylaws are noted as amended November 13, 2023, but the version on the MDGOP website remains October 2022.
• Confirmation from the MDGOP verifies that the November 2023 version was either not submitted or not provided to the State in the required 30-day period.
This failure to comply with Article III(B) renders the purported authority in the November 2023 Bylaws procedurally questionable and calls into question any action taken therefore.
Hierarchy of Governing Documents
There appears to be a longstanding practice of treating Robert’s Rules of Order (RRO) as a primary source of binding rulings by the Parliamentarian. This is a misapplication of the role. By design, the Parliamentarian is advisory to the Chair only and does not issue rulings to the full Committee. Such actions are improper and inconsistent with the standards established in RRO.
As per RRO §2:14 (also MDGOP Bylaws Article II, Sec 2.3)
1. Law (if the organization is subject to statutory or regulatory law)
2. Charter or Articles of Incorporation
3. Bylaws
4. Special Rules of Order
5. Robert’s Rules of Order Newly Revised (if adopted)
Also note the Oath of Office taken by each member, which establishes the order as well;
The Maryland State Constitution Art 1, section 9, the Annotated Code of Maryland, Constitution and Bylaws of the Republican Party of Maryland Art. XII section 12.2 and the "Bylaws" of the BCRCC
I _______________(name) do solemnly swear or affirm that I will uphold and support the Constitution of the United States; be faithful and bear true allegiance to the state of Maryland and uphold the Maryland Constitution and laws thereof; abide by the Constitution and Bylaws of the Maryland Republican Party; and faithfully execute the office upon which I am about to enter with diligence to the best of my skill, abilities and judgment without partiality or prejudice.
Summary of Noncompliance
Conclusion and Requested Remedies
For the reasons above, the November 7, 2024 Ethics Committee letter is procedurally invalid and substantively noncompliant with the BCRCC Bylaws. The Ethics Subcommittee and its Chair acted beyond their defined scope and authority, introduced unauthorized standards, bypassed the full Central Committee, potentially engaged in misfeasance, and relied upon Bylaws not timely submitted to the State GOP.
Accordingly, I respectfully request that:
1. The November 7, 2024 letter be withdrawn from the Committee’s official record, and that Linda Preece, who served (at that time) as Chair of the Ethics Subcommittee, be publicly and formally reprimanded, censured or removed for improper exercise of her authority, including her false statement regarding the Delegate Carl Jackson matter;
And that ALL Ethics complaints, including Mr. Geelhaar’s complaint, be brought to the floor of the full Central Committee for a vote, in strict accordance with the Bylaws, as any prior actions are invalid otherwise.
2. When Mr. Geelhaar’s complaint comes to the floor, the Committee must address the remedies requested in the original complaint, including:
- A detailed explanation of the level of support expected from the BCRCC if a public apology is issued, as Ms. Sullivan’s comments suggested that support might be contingent upon compliance;
- A full refund of all contributions made by Mr. Geelhaar at the BCRCC event in question;
- A public apology from Ms. Sullivan, posted on the Baltimore County GOP website, issued via a formal press release, and read aloud at the next BCRCC meeting, with the apology included in the meeting minutes;
- The resignation or removal of Ms. Sullivan from the BCRCC, as the process dictates for such violations.
3. The Committee must return to proper governance procedures as directed by the superior governing documents and applicable authorities for all future ethics matters. This includes, but is not limited to, full compliance with state filing requirements for all legally mandated official documents. If compliance cannot be achieved, the Committee should initiate procedures to remove or replace any officers who have failed to uphold their sworn duties.
Thank you for your attention to this critical matter and for your ongoing commitment to transparent, bylaw-compliant operations within the BCRCC.
Although I am not a member, I am an active and published constituent, and I will ensure the public is made aware of the extent to which the BCRCC has strayed from proper procedures, leaving it ill-prepared for the 2026 midterms. I urge all members to remain vigilant in learning and understanding the Bylaws and to apply them correctly and consistently in all Committee proceedings.
Respectfully submitted,
Tom Henry
Former 2nd Vice Chair, BCRCC
Constituent, Councilmanic District 6
