Superior Court Judge H. Shaina Colover has issued a Proposed Statement of Decision finding that Orange County Board of Education Trustee Marilyn “Mari” Barke "recklessly failed" to comply with the income-disclosure requirements of California’s Political Reform Act. This Act is “designed to reveal potential conflicts of interest” for elected officials. The ruling came yesterday, July 14, 2026, in an action brought by Hon. Lynne Riddle (Ret.), a retired United States Bankruptcy Judge, seeking compliance with the law.
The court found Barke failed to disclose approximately $14 million in required income and other assets over five years, from her election in 2018 to the filing of the lawsuit in 2023. During this period, Barke reportedly disclosed only $99 of income, investments, business positions, and gifts. Judge Colover imposed a total penalty of $81,800, which includes $5,000 for each of sixteen previously admitted Form 700 violations, an additional $5,000 for failing to amend her assuming-office statement, and credit for $3,200 she had already paid to the FPPC. In addition to these penalties, Barke is liable for plaintiff Lynne Riddle’s attorney fees and costs, which a press release noted “could run in the hundreds of thousands of dollars.”
Judge Colover's decision underscored the importance of financial transparency, conflict-of-interest disclosure, and accountability for elected education officials. The Court specifically stated that “substantial civil penalties are warranted for each violation to effectuate the purposes” of the Act and “deter future violations.” Judge Colover found Barke “reported nominal income figures while substantial reportable financial interests and community-property-related assets of over a million dollars per year existed.” The Court also determined that “the undisclosed interest and income were of a magnitude that would have been plainly material to members of the public evaluating potential conflicts of interest and transparency obligations of an elected official.”
At trial, Barke claimed she relied on the advice of her now-ex-husband, Dr. Jeffrey Barke. However, the Court deemed this “purported reliance” to be “objectively unreasonable,” stating it was “incomprehensible that anyone with defendant’s sophistication would rely on such a statement.”
Plaintiff Judge Riddle issued a statement regarding the decision, emphasizing that “financial interest disclosures are critical to the public. When elected officials flout their disclosure obligations like this, it undermines public’s right to honest and ethical government.” She added that the ruling “should send a clear message to every elected official in the County that they cannot shirk their responsibilities to disclose their economic interests.” The press release also noted Barke is an executive with the California Policy Center and stated she “holds herself out as someone who ‘advises and educates local elected officials on government transparency.’”
Under the California Rules of Court, the parties have 15 days to file any objections to the Proposed Statement of Decision, after which the Court may enter final judgment.
