A formal election complaint against a Multnomah County political action committee has created a new test of Oregon's 2024 law requiring disclosure of AI-altered campaign images.

Portland political consultant Bobbie Regan filed the complaint with the Oregon Secretary of State's office over a photo of Multnomah County Commissioner Julia Brim-Edwards posted by the "Don't Rank Julia" PAC, OPB first reported on Oct. 21. The PAC opposes Brim-Edwards' bid for Multnomah County chair.

The story carries a direct Washington County thread. The Secretary of State's office has also received at least three complaints alleging that Washington County Commissioner Nafisa Fai's campaign broke state law by manipulating a photo, OPB reported. The state has not decided whether to investigate those complaints.

OPB reviewed the Brim-Edwards photo's metadata and found it was "made with Google AI." Two online AI-detection services also flagged the image as AI-generated. The photo appeared on the PAC's website and Instagram account without the disclosure Oregon's 2024 law may require for AI-assisted campaign materials that create "a materially different understanding or impression" than the original.

The image resembles a still from a 2023 KGW interview with Brim-Edwards, OPB reported, but her complexion appears more ashen and her expression more solemn than in the original footage. Background trees changed from green to brown.

Regan, who has endorsed Brim-Edwards and donated to her campaign, wrote in her complaint that the photo appeared to age the commissioner by 15 to 20 years. Regan is a former Portland Public Schools board member.

Diane Goodwin, a top donor to the PAC who has helped place its media ads, told OPB that a campaign volunteer who designed the website said the photo was "edited in Photoshop, not AI." Goodwin said the designer wanted to remain anonymous. PAC director Jackie Yerby did not respond to OPB's request for comment.

After OPB contacted Goodwin on Oct. 20, the PAC removed the photo from its website. As of Oct. 21, the image remained on the PAC's Instagram page.

The state has investigated only two prior complaints under the 2024 AI disclosure law, both involving individual candidates. An investigation into former Republican congressional candidate Jonathan Lockwood's campaign is ongoing. A separate case involving Brooke West, a former Deschutes County commission candidate who used AI to smooth her hair and brighten her eyes in campaign photos, was resolved after the state determined those edits did not produce a "materially different" impression.

The Fai complaints stem from a separate controversy. A video circulated showing Fai speaking at a Minnesota event in front of what appeared to be an upside-down American flag. The Oregon Journalism Project initially reported the video was AI-edited, then retracted its story, citing concerns that a screenshot showing the flag right-side up might also be fake. The outlet later said the screenshot came from a "Fai campaign supporter," not the campaign itself, as we reported Oct. 21.

A Secretary of State spokesperson told OPB the office has not determined whether it will investigate the Don't Rank Julia complaint. No decision has been announced on the Fai complaints either.

Election Day is Nov. 3.