The complaint, filed Monday by Portland political consultant Bobbie Regan, alleges that the “Don’t Rank Julia” PAC used an image altered with artificial intelligence without the disclaimer required by a 2024 Oregon law. The Secretary of State’s office said it had not decided whether to investigate.

Oregon’s law requires a disclosure when AI-assisted campaign material creates “a materially different understanding or impression” from the unaltered image, audio or video. Whether the image meets that standard has not been determined.

Regan, who has endorsed Brim-Edwards and donated to her campaign, said the picture appeared to change the commissioner’s expression and make her look older. She called the use of Brim-Edwards’ likeness without her consent troubling and said the lack of a disclosure added to her concern.

The image appears similar to a still from a 2023 television interview with Brim-Edwards, but her complexion and expression differ, and the background foliage appears changed. An examination of the image’s metadata indicated it was “made with Google AI,” and two online detection services also identified it as AI-generated. Those indicators have not been confirmed by an official investigation.

Diane Goodwin, a major donor to the PAC who has helped it place media advertisements, said the volunteer who designed the group’s website told her the image had been edited in Photoshop, not with AI. Goodwin said the designer wished to remain anonymous because of concerns about retribution. The campaign’s director, Jackie Yerby, did not respond to a request for comment.

Brim-Edwards accused supporters of her opponent, Commissioner Shannon Singleton, of using AI to attack her. Singleton said her campaign had no involvement with the PAC and that she first saw the image when asked about it. She added that political groups should follow applicable laws and be held accountable if they do not.

The PAC’s website supports Singleton and another candidate for county chair, Sharon Meieran. Yerby and Goodwin are also closely involved with Portland For All, an advocacy group that has endorsed Singleton. Those connections have fueled questions about the PAC’s political alliances, but Singleton has denied her campaign’s involvement in the disputed image.

The complaint could test how Oregon applies its relatively new rules on AI in political campaigns. The state has investigated two previous complaints under the law. An inquiry into former Republican congressional candidate Jonathan Lockwood’s campaign remains open. In a separate case, election officials concluded that image edits by former Deschutes County commissioner candidate Brooke West did not violate the law because they did not create a materially different impression.

The dispute comes amid other recent concerns about AI and political imagery in Oregon. The Secretary of State’s office has also received at least three complaints alleging that Washington County Commissioner Nafisa Fai’s campaign violated the law by manipulating a video image involving an upside-down American flag. The office had not said whether it would investigate those complaints.