# Matt Scarfo / OGEC Case 25-708ECF: comparator methodology

Published with Valor Investigates' August 22, 2026 article, "The Settlement Was Ordinary. The Coverage Was Not Complete."

## Finding

The education-only disposition in Matt Scarfo's case falls within the ordinary historical range for final orders expressly stating violations of ORS 244.120. The comparison does not support a claim that the Oregon Government Ethics Commission imposed an unusually harsh sanction or singled Scarfo out.

## Corpus

- Database: `valor_consolidated`
- Schema: `corpus_oregon_ogec`
- Harvest: `harvest-full-20260821`
- Total harvested dispositions: 2,029
- Total source files: 6,734
- Total text chunks at ingestion verification: 80,004
- Years represented in the comparator: 2017 through 2026

The article's comparator universe consists of 109 final orders whose text explicitly states a violation of ORS 244.120. Counts are exact within that text-defined universe. The query did not infer violations from case titles or allegations alone.

## Outcome classification

Among the 109 final orders:

- Education only: 53
- Education plus civil penalty: 2
- Civil penalty without education: 51
- Other or not classified into those categories: 3

For orders dated in 2026:

- Total: 15
- Education only: 10

For the closest textual cohort, final orders expressly stating "two violations of ORS 244.120":

- Total: 11
- Education only: 5
- Civil penalty without education: 5
- Education plus civil penalty: 1

## Important limitations

This is a text-defined outcome comparison, not a claim that every case involved identical facts, litigation posture, aggravating circumstances or mitigating circumstances. It cannot determine why a complaint was or was not filed against someone else. It supports the narrower conclusion that an education-only resolution for two asserted ORS 244.120 violations is neither unprecedented nor outside the Commission's normal historical practice.

ORS 244.350(5) expressly permits the Commission to issue a reprimand, explanation or education in lieu of, or in addition to, a violation finding or civil penalty.

## Retrieval and quality checks

Qualitative sensitivity review used the local Qwen reranker with 500 candidates, 500 hydrated candidates and a final top 50. Model: `Qwen/Qwen3-Reranker-8B`; retrieval mode: `search-hybrid-canonical+rerank`.

The full working analysis is preserved at:

`/home/levi/Desktop/Scarfo/OGEC_25-708ECF_Comparator_Review_2026-08-22/ELKHORN_REPORTING_AND_EDUCATION_LETTER_BASELINE_2026-08-22.md`