Findings in the Post-Election Complaints of Joseph Rende against José Berra
/The Westchester County Fair Campaign Practices Committee met via Zoom on August 19, 2026 to hear the complaints of Joseph Rende (Democrat) against José Berra (Democrat), both of whom were candidates in a primary for North Castle Supervisor. Mr. Rende attended the Hearing with Michael Akavan. Mr. Berra attended the Hearing.
COMPLAINT #1: Mr. Rende complained that a mailer sent to North Castle voters containing his personal mobile telephone number and business email address was an invasion of his privacy.
FINDING: FAIR CAMPAIGN PRACTICE
The Committee found that including Mr. Rende’s personal mobile phone number and business email address in an image of Mr. Rende’s business card in a mailer was a fair campaign practice in this context. Mr. Rende included this information on his business card that he hands out to the public. Furthermore, the information is available in the public domain. The surrounding context did not encourage any abuse of the information. The Committee wants to make clear that this finding is context driven and does not mean that the Committee would find distribution of candidates’ personal information to be fair in all contexts.
COMPLAINT #2: Mr. Rende complained that in a mailer Mr. Berra sent to North Castle voters titled “What You Should Know About Joseph Rende’s Deceitful Mailing,” Mr. Berra misrepresents the documented findings of the 2021 Letter of Reprimand that had been issued to Mr. Berra, since there were five incidents cited in Mr. Berra’s 2021 Letter of Reprimand, not just the one incident Mr. Berra cites.
FINDING: FAIR CAMPAIGN PRACTICE
The Committee found that the mailer accurately cites an incident that occurred in 2021. Since the mailer does not reference the Letter of Reprimand, it is not distorting the facts by only citing the one incident as opposed to the five incidents in the Reprimand Letter.
COMPLAINT #3: Mr. Rende complained that mailers sent by Mr. Berra made unsupported assertions that Mr. Rende wanted to remain in office for personal financial gain. Specifically, in a mailer sent to North Castle voters titled “What You Should Know About Joseph Rende’s Deceitful Mailing,” Mr. Berra asserts as fact—without citing any source—that Mr. Rende seeks to remain in office “so he can continue benefiting financially by favoring the interests of developers and their lawyers…” In another mailer sent to North Castle voters, Mr. Berra claims, without citing any instances, that Mr. Rende “has a huge conflict of interest due to his being “Director of Business Development” at a major title insurance company.”
FINDING: UNFAIR CAMPAIGN PRACTICE
The Committee found that the text in the mailers was an unfair campaign practice. There was no evidence provided that supported Mr. Berra's claim that Mr. Rende seeks to remain in office “so he can continue benefiting financially by favoring the interests of developers and their lawyers" and no evidence was provided that any Town Board decision has affected Mr. Rende's compensation.
The mailers violate the following FCPC Principles:
“The candidate will neither engage in nor be involved with false or misleading attacks upon the character of an opponent, nor in invasions of privacy unrelated to fitness for office.”
“The candidate will not use or condone any campaign material or advertisement that misstates, misrepresents or distorts material fact or any communication that misleads the public.”
Committee Members: Susan P. Guma, [Chair], Jennifer Mebes Flagg [Coordinator], LaRuth Gray, Cassandra Hyacinthe, Kyle-Beth Hilfer, Lee Kinnally, Robert C. Kirkwood, Carole Princer Levy, Don Marra, Paul Bennett Marrow, Joy Rosenzweig, Susan Schwarz, John Stern, Evelyn Stock, Lilian Wu
Party representatives (ex officio): Republican Party, Democratic Party, Working Families Party.
The purpose of the Westchester County Fair Campaign Practices Committee is to help set an acceptable standard for political discussion by offering a forum for identifying unfair campaign practices and promoting a climate in which candidates conduct honest and fair campaigns. The Committee encourages candidates to conduct campaigns openly and fairly, to focus on issues and qualifications, to refrain from dishonest and defamatory attacks, and to avoid the use of campaign materials that distort the facts.
The Committee accepts written complaints from candidates about alleged unfair campaign practices. The Committee may then hold hearings to determine whether the action complained about is indeed unfair or whether it falls within acceptable political discourse. Among other things that the Committee will consider to be an unfair campaign practice is a misstatement of a material fact or any communication that misleads the public.
The Committee has no power to compel anyone or any group to stop doing what it has found to be unfair, nor does it have the authority or power to enforce election or other laws.
If the Committee acts on a complaint, it will release its findings to inform the public. The Committee may choose not to consider a complaint; in that case, a hearing is not held and the parties to the complaint are notified.
Statement of Principles of the Committee, as stated in its Manual, is available at www.faircampaignpractices.org. The Westchester County Fair Campaign Practices Committee believes that candidates should conduct their campaigns in accordance with the following principles:
The Candidate will conduct a campaign for public office openly and fairly, focusing on issues and qualifications.
The Candidate will not use or condone any campaign material or advertisement that misstates, misrepresents or distorts material fact or any communication that misleads the public.
The Candidate will neither engage in nor be involved with false or misleading attacks upon the character of an opponent, nor in invasions of privacy unrelated to fitness for office.
The Candidate will not participate in nor condone any appeal to prejudice.
The Candidate will clearly identify by name the funding source of all advertisements and campaign literature published and distributed.
The Candidate will not abuse the Westchester County Fair Campaign Practices Committee process in order to obtain political advantage. This includes, but is not limited to, announcing that he/she has filed a complaint, or quoting the Committee’s Findings unless the individual Finding cited is quoted in its entirety. The Committee considers selective quotation or misrepresentation of its Findings to be an unfair campaign practice.
The Candidate will publicly repudiate materials or actions made on behalf of their candidacy that violate this Statement of Principles.
