A letter from Great Falls Public Schools to the Cascade County Commissioners regarding election administration was recently brought to my attention.

The letter, dated September 7, 2023, is signed by Superintendent Tom Moore; Brian Patrick, Director of Business Operations; and Gordon Johnson, Chairman of the Board of Trustees (GFPS school board).

The letter states “We are writing on behalf of Great Falls Public Schools to formally request the duties of Cascade County Elections Office be transferred to the jurisdiction of the Cascade County Commissioners.” (Emphasis added)

What does this mean exactly? I am awaiting a response from Superintendent Moore. The specific questions I asked him:

1. On what date did GFPS Board of Trustees vote to approve and send this letter?

I asked this because I could find no record in a search of GFPS school board minutes that this letter was approved by the full school board. There’s also no disclaimer on the letter that these three district officials were acting on their own volition to send this letter. In fact, the letter claims to be written on behalf of the school district.

It’s particularly troubling that Johnson signed this letter as board chair, because it implies school board approval when apparently that did not happen.

2. What is the legal justification for GFPS officials and the GFPS Board of Trustees to make such a request?

In other words, where is the authority through the Montana Code Annotated for public school officials to request that a duly elected county official be stripped of part of her duties?

I could find no such authority. Instead, I’d like to know whether the three district officials authoring and sending this letter violated any part of Montana Code Annotated §2-2 Standards of Conduct, specifically §2-2-121. Rules of Conduct for Public Officers and Public Employees, which provides restrictions on public officers and employees political activities on public’s time and dollar. Might this letter be considered a political activity?

3. County commissioners supervise the official conduct of all county officials, but they aren’t election administrators. What does GFPS specifically hope to accomplish through this letter?

It seems possible that Moore, Patrick and Johnson wish to subvert the will of the voters of Cascade County, who elected merchant as Clerk, Recorder AND ELECTION ADMINISTRATOR and are asking the commissioners to appoint another person to serve as election administrator separate from the county clerk and recorder’s office.

Yes, Montana Code Annotated makes this a possibly, in MCA § 13-1-301.Election administrator.

(1) The county clerk and recorder of each county is the election administrator UNLESS THE GOVERNING BODY OF THE COUNTY DESIGNATES ANOTHER OFFICIAL OR APPOINTS AN ELECTION ADMINISTRATOR. (EMPHASIS ADDED)

So though it appears legal for county commissioners to do what GFPS is requesting — is it just? We all know that when Merchant was elected, election administration was part of the job. How can these GFPS officials think their request is more valid than the will of Cascade County voters?

There is an opportunity for the public to express their opinions on this action by school officials. The next GFPS school board meeting is 5:30 pm, September 25 in the Aspen Meeting Room at the District Office Building. The District Office Building is located at 1100 4th Street South.

The county commissioners haven’t yet taken action on this request and comments can be shared with them through email or by phone:

Commissioner Briggs: jbriggs@cascadecountymt.gov
(406) 454-6815

Commissioner Larson: jlarson@cascadecountymt.gov
(406) 454-6816

Commissioner Grulkowski: rgrulkowski@cascadecountymt.gov
(406) 454-681