PHOENIX — Attorney General Tom Horne used more than $300,000 worth of state employee time and office rent in his unsuccessful bid to get re-elected, the executive director of the Citizens Clean Elections Commission concluded Tuesday.

Thomas Collins said the evidence he has reviewed shows “volunteers” for Horne’s campaign were not really volunteers at all, but employees at the Attorney General’s Office. He said documents show Horne was aware of that fact.

Collins also cited an April campaign meeting where, with the exception of a paid out-of-state media consultant, all of those in attendance were employees of the office.

“This evidence further supports the inference that ‘volunteer’ work was performed in exchange for compensation, and that employees agreed to provide their services free of charge to the campaign because they were employees of the attorney general,” Collins wrote in his recommendation to the commission. “There were seamless operations between the Attorney General’s Office executive office and the Horne campaign at the highest levels including management, strategy, technology, communications, field work and fundraising.”

What all that means, Collins said, is Horne effectively took illegal donations from state taxpayers.

He said that is legally no different from a private corporation paying its employees to “volunteer” for a politician’s campaign, which would make the politician the beneficiary of illegal corporate donations.

Members of the commission are set to meet Thursday to decide whether to adopt his report as their own and assess a penalty or give Horne, who lost last month’s GOP primary to Mark Brnovich, an opportunity to refute the findings. Among the things the commission could do is order Horne to repay the money improperly taken and impose penalties equal to three times that amount.

But the findings could buttress a parallel investigation of Horne’s campaign by the Maricopa County Attorney’s Office. If that agency finds wrongdoing, it could charge Horne and others with improper use of public resources, which is a crime.

The inquiry began with a complaint by Sarah Beattie, a former AG’s office staffer, that she had worked on his re-election bid and saw other staffers do the same on state time.

Collins already has given Horne an opportunity to respond. But he told the commission there was “no evidence” refuting Beattie’s allegations.

Stephanie Grisham, who served as both spokeswoman for Horne’s office and his campaign, said the recommendation is flawed.

“It is crazy to me that Mr. Collins and the CCEC can make these findings without interviewing one person mentioned in the complaint,” Grisham said. And Grisham said the recommendation essentially amounts to Collins believing Beattie and dismissing statements from others in the office who say the charges are false.

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Collins said he did consider all of the statements.

Horne has said any work performed was during lunch breaks and other non-state time.

Collins, however, said there are problems with that explanation. “There is no evidence that any controls were in place to document the duration or location of breaks and personal time and no evidence that policies intended to safeguard employees and the state from the misuse of resources were relied upon,” he wrote.

Conversely, Collins said there were various documents obtained through subpoenas including “numerous emails sent during normal business hours” about the campaign by various employees in the office as well as to Horne himself.

Collins calculated the amount of state employee time spent on the campaign, based on each worker’s salary, at more than $287,000. But he said that’s only part of the issue.

He said evidence also indicates “the executive office of the Attorney General’s Office served as a de facto campaign headquarters for the campaign,” an unreported contribution he valued at more than $25,000.

Collins acknowledged Horne’s contention state employees can do political work “off duty and not at public expense.” But, he said, “When a state employee’s position with the state is expressly tied to campaign work that is done interchangeably during work and after work hours, there is no distinction to be drawn.”