Audit Finds the Human Rights Commission Under Former Executive Director Violated City Rules and Misused Over $4 Million of Public Funds

San Francisco, CA — Following public reports of alleged corruption in 2024 about former Executive Director of San Francisco’s Human Rights Commission (HRC) Sheryl Davis, the Controller’s Office and City Attorney’ Office launched a joint audit and investigation into HRC’s noncontract spending during the last four years of her tenure. The audit report released today details the ways Sheryl Davis knowingly violated city purchasing rules and fostered an unethical tone at the top at HRC. Under her leadership, HRC routinely and pervasively disregarded City policies and controls, and ultimately misused and abused millions of taxpayer dollars.

The audit period covers July 1, 2020 through Sheryl Davis’s resignation on September 13, 2024, and specifically looks at all the payments from this period that did not go through the City’s contracting process — which this report refers to as noncontract payments. Noncontract payments allow departments to more expeditiously procure goods and services needed to perform work and deliver essential services, but they are intended for one-time or very specific purposes and should be used sparingly.

The audit found that $4.6 million of the $6.3 million HRC spent on noncontract payments were ineligible or likely ineligible payments. Ineligible payments are explicitly prohibited purchases (such as gala tickets or sponsoring a nonprofit’s weekend wellness retreat). Likely ineligible payments instead appeared excessive or improper, or failed to demonstrate necessity or reasonableness (such as airfare and weeks-long hotel charges for program speakers). HRC also repeatedly split invoices to circumvent expense caps of $10,000.

The report also discusses how the former Executive Director blurred the lines between her city duties and personal businesses by directing at least $75,000 of HRC funds to promote her personal branding, ventures, and non-City programs that she was still affiliated with. She concealed her personal relationship with James Spingola — the head of nonprofit Collective Impact — while participating in governmental decisions benefitting the nonprofit, which is currently the subject of debarment proceedings. Davis abused her position of power to override controls intended to prevent misuse of public funds, which led to widespread noncompliance as shown in the report. Even as the department worked to improve oversight, rules were bypassed, leading to a workplace where misconduct went unchallenged and ethical norms were ignored.

While the overall goals of HRC as a department are laudable, necessary processes were not followed and public dollars were ultimately spent with the discretion of personal dollars, which undermined well-intentioned programs.

"Our community and residents have benefitted from HRC’s important programs and services," said Controller Greg Wagner. "But what our audit decisively found is that on too many occasions HRC’s spending under the former Executive Director was clearly not for the benefit of community — it was frivolous, unethical, and unjustifiable. It unfairly tainted the broader work of the department and requires that trust and confidence now be rebuilt."

"Public money needs to be spent as intended," said City Attorney Chiu. "It is upsetting to see how much public money was misused because of Sheryl Davis’s self-dealing and creation of an unethical culture at HRC intended to avoid oversight. By taking these resources away from the community and spending them on herself and her friends, Sheryl Davis harmed the community that was counting on her."

Summary of Key Noncontract Purchase Types

Prop Q Purchases

Proposition Q allows city departments to bypass a competitive bidding process and removes the need for a city contract for purchases of goods that cost less than $10,000 (this amount has doubled to $20,000 beginning fiscal year 2024-25). HRC’s Prop Q purchases increased by over 600% over four years, almost doubling each year since fiscal year 2020-21. HRC spent significantly more in Prop Q purchases compared to other departments that also received an influx of Dream Keeper Initiative (DKI) funding in 2021. The majority was spent on events, professional services, and food, and invoices were intentionally split into multiple payments to circumvent the allowable expense cap. Professional services are strictly prohibited under Prop Q and generally require a contract because they can pose more risk and liability to the City than the purchase of simple commodities and general services. 93% of Prop Q purchases were ineligible or likely ineligible.

Direct Payments

Direct payments allow departments to make a payment as an exception to the standard procurement process and should be used sparingly and for a specific and authorized purpose. Of the $3.4 million HRC spent via direct payments, $3.1 million was in the form of single payments. The majority of single payments were for events (including services, merchandise, supplies, and food), sponsorships, alcoholic beverages, and financial support for individuals — none of which are allowed expenses. Using single payments for unintended purposes could lead to inaccurate information that is later used for the City’s tax compliance, reporting, and/or management.

Upcoming Related Reports from the Controller

• In November 2025, the Controller’s City Performance Division is expected to publish an assessment of DKI services, funding, and performance metrics on DKI-funded programs across city departments since inception in 2021.
• A separate audit of City grant agreements with Collective Impact is planned for release at the end of calendar year 2025 and will include a review of solicitation processes and grant compliance/oversight.

City Whistleblower Program

This audit highlights the need for City staff at all levels to be empowered to ask questions, trust their instincts, and raise flags. That can be hard to do when questionable directions come from higher-ups, which is partly why the City’s Whistleblower Program exists. Waste and abuse of public dollars are serious issues, and a critical part of government accountability is fostering a culture of "see something, say something." Any City employee or member of the public may report allegations of improper or illegal public activity to the City’s Whistleblower Program at sf.gov/whistleblower.