As I posted yesterday, Washington State Attorney General Bob Ferguson has finally gotten around to suing the Grocery Manufacturers Association for concealing the source of contributions to the No on I-522 campaign—alleging the most massive such campaign finance disclosure violation in state history. And the most striking thing from reading through the AG's complaint (pdf) is how blatantly obvious the GMA's deception appears to be.

The complaint doesn't cite the sources of its factual allegations, but it is filled with dates and numbers and quotations from documents detailing the GMA's plans to raise money from its members to fight Initiative 522 (which would label products made from genetically engineered crops), while intentionally hiding the contributors' identities:

In December 2012, following meetings of the GMA Government Affairs Council and GMA Board, the GMA Board directed GMA staff to conduct baseline polling in Washington State "to determine the viability of a campaign to defeat I-522." The GMA Board also directed GMA staff to "scope out a funding mechanism to address the GMO issue" "while better shielding individual companies from attack for providing funding." At the same time, the GMA Board directed GMA staff to prepare to oppose "efforts to require mandatory GMO labels: a. Fight Washington State Ballot Measure" and "begin preparations for a campaign, ... to defeat I-522, the Washington State Ballot measure."

According to the complaint, the GMA funded its anti-522 efforts through voluntary assessments on its members (major food companies) separate from their normal association dues. Invoices were sent to GMA members in March and August of 2013, with the goal of raising $10 million to oppose I-522. As of the No on I-522's most recent disclosure report, the GMA had contributed $7,222,500.

Of course, the GMA and its members are free to spend as much as they want opposing I-522; the issue here is their failure to disclose the source of the money. GMA members—familiar brands like Pepsi, Kraft, Coca-Cola, General Mills, and Kellogg's—faced a ton of bad publicity for the millions they contributed to defeat the similar Prop 37 in California last year. The complaint outlines what appears to be a deliberate effort to shield these companies from similar publicity, in direct violation of Washington's voter-approved public disclosure laws. In addition to penalties and legal fees, the AG is seeking to force the GMA to register as a political action committee and reveal its donors.

But as compelling as the evidence of the GMA's actions outlined in the complaint may be, equally damning is what the GMA has not done. The GMA will surely argue that this special assessment was to broadly fight GMO-labeling nationwide, not specifically to oppose I-522. Yet since first invoicing their members in March, they have spent this assessment almost entirely in Washington State. This is the very definition of an anti-522 PAC.

As for which companies have funded the bulk of the GMA's anti-522 efforts, one can probably assume that it's similar to the list that funded the No on Prop 37 campaign last year. A former GMA official tells me that special assessments are proportional to the size of the company, so it is most likely that America's largest food manufacturers are the largest contributors. But that's something that will have to wait for a court order to confirm.