

Rebuffed in its original request, the Oklahoma Ethics Commission voted Thursday to file a subpoena seeking campaign records related to Superintendent of Public Instruction Ryan Walters’ successful 2022 election.
In October, the Ethics Commission authorized a formal investigation of alleged campaign finance rule violations by Walters’ 2022 campaign. Walters, elected state superintendent of public instruction in November 2022 with nearly 60 percent of the vote, served as chairman and treasurer of his own campaign committee. The Ethics Commission’s attorney notified Walters in October that a subpoena would be issued seeking campaign reports and other financial records and information dealing with his campaign if he didn’t turn over the material.
Walters’ attorney responded last month by saying Walters and his committee objected to the subpoena’s requests and that they lack any responsive documents to produce to the Ethics Commission. Walters’ 2022 campaign was led by Matt Langston, a Texas political consultant whose subsequent employment with the State Department of Education has drawn criticism. Neither Langston nor Walters responded to requests for comment Friday morning prior to the publication of this article.
Ethics Commission executive director Lee Anne Bruce Boone said Thursday evening that Walters has not contacted her office about the case.
In October, the Ethics Commission notified Walters and his Walters for State Superintendent 2022 Committee that a subpoena would be issued if requested campaign reports and documents were not provided.
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The subpoena would seek “all documents, invoices, receipts, confirmations, credit card records, credit card statements and bank statements and bank records” concerning funds received for or in connection with every item listed on all required campaign reports for 2021, 2022, 2023 and 2024, according to an Oct. 14 letter sent to Walters by Margaret Kerr, the Ethics Commission’s general counsel. The correspondence was sent to Walters’ Edmond address via certified mail and also by email.
Other information sought includes all financial ledgers, check registers and “other similar financial or accounting documents,” including all QuickBooks records for Waters’ campaign committee, the letter states. It also would seek documents regarding the source, nature or value of funds received or accepted by the committee and records containing the name, address, occupation or employer of each individual or sovereign entity that gave, donated, gifted or otherwise provided funds, goods or services for the committee. Information is also being sought regarding political action committees, corporations, limited liability companies and partnerships that gave, donated, gifted or otherwise provided funds, goods or services to Walters’ campaign committee.
In a Dec. 2 letter responding to Kerr, Tim Davis, a Fort Worth attorney representing Walters and the Walters for State Superintendent 2022 Committee, wrote that his clients object to the subpoena’s requests and that they lack any responsive documents to produce.
Davis wrote that the subpoena’s request for “all documents” from the Walters 2022 committee spanning four years is too broad and vague.
“Because the subpoena fails to identify the specific conduct under investigation or articulate a clear nexus between the requests and the alleged violations, the subpoena fails to comply with constitutional and procedural requirements,” he wrote. “This lack of specificity also renders it impossible for Mr. Walters and the Walters for State Superintendent 2022 Committee to determine the relevance of the requested documents.”
Davis also wrote that it is Walters’ and his committee’s understanding that questions about his campaign were taken care of in a settlement agreement reached between Walters and the Ethics Commission in March 2024.
“The subpoena and any other attempt to reopen or revisit those settled issues with a new investigation or otherwise is improper and inconsistent with the terms and conditions of the settlement agreement,” he wrote.
‘Commission finds that release of that information be in the public’s interest’

But the March settlement dealt only with fines that were assessed to Walters for campaign reports that were filed late or not at all, Kerr responded to Davis in a Dec. 18 letter. The March settlement involved 12 different reports that were due from June 16, 2022, through Nov. 2, 2022. A total of $6,600 in fines were assessed, and Walters and the Ethics Commission settled the matter by the state superintendent paying $3,000 in fines, Kerr wrote.
The planned subpoena in the Oct. 14 letter relates to campaign finance rules and is not related to the March settlement, Kerr wrote.
Walters, as treasurer of his campaign committee, is obligated to maintain all financial records, and to tender those records to the Ethics Commission upon request, Kerr wrote.
“In your letter, you state that Mr. Walters does not possess or control the documents requested in the subpoena,” Kerr wrote to Davis. “The subpoena requests all the financial records of the committee, such as statements, invoices, receipts, etc. As the treasurer, it is Mr. Walters’ responsibility to maintain all financial records, and to make those records available to the commission upon request, pursuant to Rule 2.73. If he does not possessor control the documents requested, then he has failed to comply with Rule 2.73. Please confirm whether Mr. Walters has complied with Rule 2.73.”
Matters taken up by the Ethics Commission are usually confidential. Investigations and complaints are identified only through case numbers. Identity of those being investigated usually occurs only after a settlement agreement is reached or court action is taken, such as the filing of a subpoena.
Boone said the subpoena seeking campaign information from Walters and his committee likely will be filed next week in Oklahoma County District Court. When that occurs, it will be public information. She said it will be identical to the subpoena sent to Walters in October.
The Ethics Commission, after reviewing several cases in executive session Thursday, returned in open session to authorize Boone to proceed with Case No. 2024-03 alleging campaign finance law violations.
Commissioner Adam Weintraub then made a motion directing that certain information in the case could be released.
“Mr. Chairman, as the commission is aware,” Weintraub said to Chairman Eddie Fields, “Ethics Rule 6.9 requires all complaints, including discussions in executive session, remain confidential unless the commission finds a release of that information be in the public’s interest. Accordingly, I move to make certain limited information regarding case 24-03 be made public based on the determination of release of such information as in the public’s interest and as discussed in executive session.”
With the 2026 electoral landscape already taking shape, Walters has been viewed as a possible gubernatorial candidate. According to campaign records reported to the Ethics Commission, Walters raised more than $85,000 for his 2022 campaign committee over the first three quarters of 2024.
Read correspondence regarding the Ryan Walters investigation
- Ethics Commission’s Oct. 14 subpoena to Ryan Walters
- Dec. 2 response from Walters’ attorneys
- Ethics Commission’s Dec. 18 response
