Included here are cases from October 2015 to the present. You can search across all fields by using the search box below. Click "Advanced search" to reveal a menu for more detailed filtering. You can download the results of your search by using the "csv" and "copy" buttons at the bottom of the list. To see case documents, click the case number. Or search across all case documents using the compliance case document search

For information about resolved campaign finance lawsuits brought under RCW 42.17A by the Attorney General, see the AGO’s website.  

For more information about how the PDC handles complaints alleging violations of RCW 42.17A and what the different case statuses mean, see our enforcement guide. For a glimpse at how long it is taking to close cases, see the case resolution chart


Case # Opened Complainant Respondent Subject Areas of Law Status Description Url
72787 07/02/2020 Glen Morgan Omari Tahir-Garrett Tahir-Garrett, Omari: Alleged violations of Chapter 42.17A RCW for failure to timely file a Candidate Registration and Personal Financial Affairs Statement within two weeks of becoming a candidate (EY 19/20; July 20) RCW 42.17A.700, RCW 42.17A.710, RCW 42.17A.235, RCW 42.17A.215, RCW 42.17A.205, RCW 42.17A.210 Assessment of Facts
  • Allegation One: Violations of RCW 42.17A.205, .210, .215, and .235 for failure to file a Candidate Registration designating a Treasurer, Depository, and contact information for inspection of books of account, due within two weeks of becoming a candidate in 2019 and 2020.
  • Allegation Two: Violations of RCW 42.17A.700 and .710 for failure to file a Personal Financial Affairs Statement disclosing financial details for twelve calendar months prior to becoming a candidate, due within two weeks of becoming a candidate in 2019 and 2020.
https://www.pdc.wa.gov/browse/cases/72787
72754 07/01/2020 Norman Smith Paul Mahre Mahre, Paul (2): Alleged Violation of RCW 42.17A.240 for failure to collect and maintain full contributor information (EY20, July20) WAC 390-16-105, RCW 42.17A.240 Assessment of Facts
  • Allegation One: Violation of RCW 42.17A.240 for failure to collect and maintain full contributor information
  • Allegation Two: Violation of WAC 390-16-105(5) mini reporting campaigns must adhere to chapter 42.17A RCW
https://www.pdc.wa.gov/browse/cases/72754
72721 07/01/2020 Glen Morgan Krystal Marx Marx, Krystal (6): Alleged Violation of RCW 42.17A.235 & .240 for failure to timely and completely disclose contributions and expenditures (C-3 & C-4 reports) (EY21, July20) RCW 42.17A.235, RCW 42.17A.240 Assessment of Facts
  • Allegation: Violation of RCW 42.17A.235 & .240 for failure to timely and completely disclose contributions and expenditures on C-3 and C-4 reports
https://www.pdc.wa.gov/browse/cases/72721
72472 06/25/2020 Debra Blodgett John Lovick Lovick, John: Alleged violation of RCW 42.17A.555 by using public office or agency facilities to assist an election campaign. (EY '20; Jun '20) RCW 42.17A.555 Assessment of Facts
  • Allegation: Alleged violation of RCW 42.17A.555 by using public office or agency facilities to assist an election campaign
https://www.pdc.wa.gov/browse/cases/72472
72467 06/25/2020 Debra Blodgett Everett Public Schools Everett Public Schools: Alleged violation of RCW 42.17A.555 by authorizing the use of public office or agency facilities to assist an election campaign. (EY '20; Jun '20) RCW 42.17A.555 Assessment of Facts
  • Allegation: Alleged violation of RCW 42.17A.555 by authorizing the use of public office or agency facilities to assist an election campaign (John Lovick)
https://www.pdc.wa.gov/browse/cases/72467
72446 06/24/2020 Lillian "Randy" Slovic Michael Alvarez Alvarez, Michael: Alleged Violation of RCW 42.17A.555 for misuse of public facilities (EY20, June 20) RCW 42.17A.555 Assessment of Facts
  • Allegation: Violation of RCW 42.17A.555 for misuse of public facilities; wearing city council pin in political advertising signage photo. 
https://www.pdc.wa.gov/browse/cases/72446
72431 06/24/2020 Norman Smith Donna Lands Lands, Donna: Alleged Violation of RCW 42.17A.235 for failure to accurately, completely and timely disclose expenditures (EY20, June 20) RCW 42.17A.235 Closed Administratively

The Public Disclosure Commission (PDC) has completed its review of the complaint Norm Smith filed on June 11, 2020. The complaint alleged that Donna Lands, a Candidate for County Commissioner for Pend Oreille County may have violated RCW 42.17A.235 for failure to timely, completely and accurately file Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing expenditures undertaken by the Campaign.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the applicable PDC reports filed by the Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to timely, completely and accurately disclose Expenditures on their C-4 report does not amount to a violation that warrants further investigation.

PDC staff is reminding Donna Lands about the importance of the timely, complete and accurate disclosure of all contribution and expenditure activities and the timely, complete and accurate filing of all future PDC reports in accordance with the statutes and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/72431
72364 06/23/2020 Norman Smith Devin Beach Beach, Devin: Alleged violation of RCW 42.17A.240 and WAC 390-16-115 for failure to maintain contributor address records (EY 20; June 20) WAC 390-16-115, RCW 42.17A.240 Assessment of Facts
  • Allegation: Violation of RCW 42.17A.240 and WAC 390-16-115 for failure to maintain contributor address records for a $25.01 contribution from Norm Smith.
https://www.pdc.wa.gov/browse/cases/72364
72310 06/22/2020 Lisa Neal Sarah Blossom Blossom, Sarah: Alleged violation of RCW 42.17A.235, .240 & .555 for failure to timely & accurately report contributions & expenditures, and by using public facilities to assist an election campaign. (EY '19; Jun '20) RCW 42.17A.240, RCW 42.17A.235, RCW 42.17A.555 Assessment of Facts
  • Allegation One: Alleged violation of RCW 42.17A.235 & .240 for failure to timely & accurately report contributions & expenditures for election year 2019
  • Allegation Two: Alleged violation of RCW 42.17A.555 by using public facilities (city photograph & and COBI-Connects newsletter) to assist an election campaign
https://www.pdc.wa.gov/browse/cases/72310
72298 06/22/2020 Dave Kimble Eric Gattenby Gattenby, Eric: Alleged violation of RCW 42.17A.205 for for failure to timely register as a candidate (June 20) RCW 42.17A.205 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on June 11, 2020. The complaint alleged that Eric Gattenby, a current School Director with South Kitsap School District 402, Position 1 may have violated RCW 42.17A.205 for failure to timely file a Candidate Registration report (C-1 report) within two weeks of becoming a candidate while using language that appeared to identify him as a candidate in online political advertisements.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the response provided by Mr. Gattenby, to determine whether the record supports a finding of one or more violations.

It appears that the language originally found on Mr. Gattenby’s Facebook page was left over from his candidacy for South Kitsap School District 402 School Director in the 2019 election and was not intended to be used as a new declaration of candidacy for a future election. Mr. Gattenby does not have any prior violations with the PDC, he responded promptly to the complaint and made appropriate changes to his Facebook page immediately.

Based on our findings staff has determined that, in this instance, Mr. Gattenby is not a current candidate for election to public office and was not required to submit a C-1 report within two weeks of making a public announcement and that no evidence supports a finding of a violation that warrants further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/72298
71928 06/15/2020 Carolyn Crain John Ley Ley, John: Alleged violation of RCW 42.17A.235 & .240 for failure to timely and accurately report contributions and expenditures. (Jun 20) RCW 42.17A.240, RCW 42.17A.235 Assessment of Facts
  • Allegation One: Alleged violation of RCW 42.17A.235 & .240 for failure to timely and accurately report contributions
  • Allegation Two: Alleged violation of RCW 42.17A.235 & .240 for failure to timely and accurately report expenditures
https://www.pdc.wa.gov/browse/cases/71928
71862 06/12/2020 Austin Taylor Daniel P. Evans Evans, Daniel P.: Alleged violation of RCW 42.17A.320 for failure to identify party preference on yard signs. (Jun 20) RCW 42.17A.320 Assessment of Facts
  • Allegation: Alleged violation of RCW 42.17A.320 for failure to identify party preference on yard signs
https://www.pdc.wa.gov/browse/cases/71862
71547 06/08/2020 Daniel Barnes Bryan White White, Bryan: Alleged Violation of RCW 42.17A.205 & .700 for failure to timely file campaign registration and personal financial affairs statements; & RCW 42.17A.235 for failure to timely report contributions and expenditures (EY 20, June 20) RCW 42.17A.205, RCW 42.17A.700, RCW 42.17A.235 Closed Administratively

The Public Disclosure Commission (PDC) has completed its review of the complaint Daniel Barnes filed on June 7, 2020. The complaint alleged that Bryan White (Respondent), a Candidate for State Representative Position 2 for Legislative District 17 may have violated RCW 42.17A.205 & .700 for failure to timely file campaign registration (C-1) and personal financial affairs statement (F-1); and RCW 42.17A.235 for failure to timely report contributions and expenditures (C-3 & C-4).

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the response provided by the Respondent to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to timely file the C-1 and F-1 does not amount to a violation that warrants further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/71547
71438 06/05/2020 Norman Smith Paul Mahre Mahre, Paul: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement within two weeks of becoming a candidate (EY 20; June 20) RCW 42.17A.700 Case Closed with Reminder

.The Public Disclosure Commission (PDC) has completed its review of the complaint filed on June 3, 2020. The complaint alleged that Paul Mahre, a candidate for Pend Oreille County Commissioner in the August 4, 2020 primary election, may have violated RCW 42.17A.700 for failure to timely a Personal Financial Affairs Statement (F-1 report) within two weeks of becoming a candidate or no later than June 1, 2020.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Paul Mahre; and the applicable PDC reports filed by the Respondent, to determine whether the record supports a finding of one or more violations.

Although the F-1 report was received five days late, it was submitted immediately upon receipt of the complaint and well before any information regarding candidates appearing on the primary election was distributed to voters.

Based on our findings, staff has determined that, in this instance, failure to timely file a F-1 report does not amount to a violation that warrants further investigation.

PDC staff reminded Mr. Mahre about the importance of timely filing a Personal Financial Affairs Statement with the PDC within two weeks of declaring candidacy, and the timely filing of all future PDC reports in accordance with the statutes and rules. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/71438
71435 06/05/2020 Lillian Slovic Robert Thompson Thompson, Bob (2): Alleged violations of RCW 42.17A.710 for failure to accurately disclose personal financial affairs (June 20) RCW 42.17A.710 Assessment of Facts
  • Allegation: Violation of RCW 42.17A.710 for failure to disclose income and payments to law firm from the City of Kennewick
https://www.pdc.wa.gov/browse/cases/71435
71239 06/01/2020 Norman Smith Luke Smith Smith, Luke: Alleged Violation of RCW 42.17A.205 for failure to timely and accurately file Campaign Registration; RCW 42.17A.700 for failure to timely and accurately file Personal Financial Affairs Statement (EY 20, June 20) RCW 42.17A.700, RCW 42.17A.205 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint Norm Smith filed on June 1, 2020. The complaint alleged that Luke Smith (Respondent), a Candidate for Public Utility Commissioner for Pend Oreille Pud may have violated RCW 42.17A.205 for failure to timely and accurately file Campaign Registration (C-1); RCW 42.17A.700 for failure to timely and accurately file Personal Financial Affairs Statement (F-1).

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent and the applicable PDC reports filed by the Respondent to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to timely file the C-1 and F-1 does not amount to a violation that warrants further investigation.

PDC staff is reminding Luke Smith about the importance of the timely filing of required registration and financial statements and the timely filings of all future PDC reports in accordance with the statutes and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/71239
71003 05/28/2020 Lillian Slovic Terry Christensen Christensen, Terry: Alleged violation of RCW 42.17A.710 for failure to disclose all sources of income in 2019 on the statement of financial affairs. (May 20) RCW 42.17A.710 Assessment of Facts
  • Allegation One: Alleged violation of RCW 42.17A.710 for failure to disclose 2019 social security income; 
  • Allegation Two: Alleged violation of RCW 42.17A.710 for failure to disclose 2019 pension income;
  • Allegation Three: Alleged violation of RCW 42.17A.710 for failure to disclose 2019 income from rental property
https://www.pdc.wa.gov/browse/cases/71003
71001 05/28/2020 Lillian Slovic Philip Lemley Lemley Philip (2): Alleged Violation of RCW 42.17A.710 for failure to disclose all sources of income or assets (May 20) RCW 42.17A.710 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint Lillian Slovic filed 
on May 27, 2020. The complaint alleged that Philip Lemley (Respondent), a City Council 
Member for the City of Richland may have violated RCW 42.17A.710 for failure to disclose all 
sources of income or assets. 


PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the 
response provided by the Respondent and the applicable PDC reports filed by the Respondent to 
determine whether the record supports a finding of one or more violations. 


Based on staff’s review, we found the following: 
* Pursuant to RCW 42.17A.710 the Respondent is required to disclose all sources of 
income and assets on the Personal Financial Affairs Statement. 
* The Respondent filed their F-1 on April 15, 2020 for the reporting period January 1, 2019 
through December 31, 2019. 
* The F-1 report filed on April 15, 2020 did not include any sources of income. 
* The complaint was filed on May 27, 2020 and was sent to the Respondent on May 28, 
2020. 
* The Respondent completed the amendment to include all sources of income on the F-1 on 
May 28, 2020. 
* The Respondent does not have any violations with the PDC within the last five years. 


Based on our findings staff has determined that, in this instance, failure to timely and accurately 
disclose all sources of income and assets on the F-1 report covering 2019 does not amount to a 
violation that warrants further investigation. 


PDC staff is reminding Philip Lemley about the importance of the timely and accurate disclosure 
of all sources of income and assets on Personal Financial Affairs Statements, and the timely and 
accurate filing of all future PDC reports in accordance with the statutes and rules. 


Based on this information, the PDC finds that no further action is warranted and has dismissed 
this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/71001
70864 05/26/2020 Byron Powell Tom McGarry McGarry, Thomas: Alleged Violation of RCW 42.17A.320 and WAC 390-18-020 for failure to disclose party preference on political advertising (EY 20, May 20) RCW 42.17A.320, WAC 390-18-020 Case Closed with Reminder

Allegation: Violation of RCW 42.17A.320 and WAC 390-18-020 for failure to disclose party preference on political advertising

https://www.pdc.wa.gov/browse/cases/70864
70561 05/19/2020 Leonard Christian Matt Shea Shea, Matthew (5): Alleged violation of RCW 42.17A.445 for personal use of campaign contributions (EY 20; May 20) RCW 42.17A.445 Assessment of Facts
  • Allegation: Violation of RCW 42.17A.445 for personal use of campaign contributions to purchase security curtains.
https://www.pdc.wa.gov/browse/cases/70561
69913 05/07/2020 Gregory Allen Pratt; and Lori Shavlik Fortney Recall Legal Defense Fund Fortney Recall Legal Defense Fund: Alleged violations of RCW 42.17A.205, .235, .240 & .405 for failure to register as a political committee, report contributions & expenditures, and by accepting over-limit contribution. (May 2020) RCW 42.17A.405, RCW 42.17A.235, RCW 24.17A.205, RCW 42.17A.240 Assessment of Facts
  • Allegation One: Alleged violation of RCW 42.17A.205 for failure to register as a political committee
  • Allegation Two: Alleged violation of RCW 42.17A.235 & .240 for failure to report contributions & expenditures
  • Allegation Three: Alleged violation of RCW 42.17A.405 by accepting over-limit contribution via GoFundMe account
https://www.pdc.wa.gov/browse/cases/69913
69908 05/07/2020 Charles L Eakins Recall Adam Fortney Committee Recall Adam Fortney Committee: Alleged violations of RCW 42.17A.205, .235 & .240 for failure to register as a political committee and file reports of contributions & expenditures. (May 2020) RCW 42.17A.235, RCW 42.17A.205, RCW 42.17A.240 Assessment of Facts
  • Allegation One: Alleged violation of RCW 42.17A.205 for failure to register recall committee as a political committee 
  • Allegation Two: Alleged violation of RCW 42.17A.235 & .240 for failure to report contributions & expenditures
https://www.pdc.wa.gov/browse/cases/69908
69871 05/06/2020 PDC Staff Amalgamated Transit Union Legislative Council of Washington (ATULC) Amalgamated Transit Union Legislative Council of Washington (ATULC) (3): Alleged Violation of RCW 42.17A.630 for failure to timely file Monthly Lobbyist Employer Contribution Reports (EY 16, May 20) RCW 42.17A.630 Resolved through Statement of Understanding

A PDC staff generated complaint was filed against the Amalgamated Transit Union Legislative Council of Washington (ATULC), alleging a violation of RCW 42.17A.630 for failure to timely file the Monthly Lobbyist Employer Contribution Reports (L-3c report) disclosing contributions made to candidates and political committees during calendar year 2016.  (EY 16, May 20) 

On June 24, 2020, the PDC received a completed a Statement of Understanding (SOU) from ATULC and paid a $300 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), acknowledging two violations of RCW 42.17A.630 for failing to timely file two Monthly Lobbyist Employers Contributions reports (L-3c reports) disclosing the late filed contributions made in 2016.  The $300 penalty assessed in this matter resolves the issue of the two late filed L-3c reports for 2016.

Based on the information, the PDC dismissed the staff generated complaint against the Amalgamated Transit Union Legislative Council of Washington State in accordance with RCW 42.17A.755(1).  

https://www.pdc.wa.gov/browse/cases/69871
69558 04/30/2020 Jeremy Wood Alisha Beeler Beeler, Alisha: Alleged violations of RCW 42.17A.235 and .240 for failure to report in-kind contributions or expenditures for political advertising (EY 20; Apr 20) RCW 42.17A.240, RCW 42.17A.235 Request for Technical Correction

The Public Disclosure Commission (PDC) has completed its review of the complaint Jeremy Wood filed on April 29, 2020. The complaint alleged that Alisha Beeler (Respondent), a candidate for State Representative for the 26th Legislative District may have violated RCW 42.17A.235 and .240 for failure to timely and accurately report expenditures or in-kind contributions for political advertising.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the responses provided by the Respondent; the applicable PDC reports filed by the Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to itemize an expenditure does not amount to a violation that warrants further investigation.

Alisha Beeler made minor or ministerial errors on required reports, which did not materially impact the public interest. Upon notification of these errors, Alisha Beeler timely amended their reports, making the necessary technical corrections as requested by staff.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/69558
69071 04/21/2020 Helen Clarice Surprenant Retired Firefighters of Washington Retired Firefighters of Washington: Alleged violations of RCW 42.17A.205, .235 & .240 for failure to timely & accurately register as a political committee, and report contributions & expenditures for election years 2016 -2020. (Apr ’20) RCW 42.17A.205, RCW 42.17A.235, RCW 42.17A.240 Case Closed with No Evidence of Violations
  • Allegation One: Alleged violation of RCW 42.17A.205 for failure to timely & accurately register as a political committee for election years 2016 -2020
  • Allegation Two: Alleged violation of RCW 42.17A.235 & .240 for failure to timely & accurately report contributions & expenditures for election years 2016 - 2020
https://www.pdc.wa.gov/browse/cases/69071
69008 04/20/2020 Martin Wheeler Jay Inslee Inslee, Jay (4): Alleged Violation of RCW 42.17A.240 for not disclosing contributor information on reports (EY 20, April 20) RCW 42.17A.240 Request for Technical Correction
  • Allegation: Violation of RCW 42.17A.240 for not disclosing contributor information on reports
https://www.pdc.wa.gov/browse/cases/69008
67383 03/25/2020 PDC Staff PDC Staff Board of Registration for Professional Engineers & Land Surveyors (BORPELS): Alleged violation of RCW 42.17A.635 by failing to disclose 2019 lobbying activities of employees & board members on L-5 report. (Mar '20) RCW 42.17A.635 Resolved through Statement of Understanding

PDC staff is alleging that BORPELS violated RCW 42.17A.635 by failing to timely file an Agency Lobbying Expense Report (L-5 report) disclosing lobbying activities of  employees and board members of BORPELS, a separate board that at the time was affiliated with the Department of Licensing for providing certain administrative purposes, undertaken during the first two quarters of the calendar year 2019.   

On December 20, 2019, BORPELS electronically late filed two L-5 reports for the first and second quarters of 2019, disclosing $1,447.65 in agency public funds were expended between January 1 through June 30, 2019 for public agency lobbying activities in support of House Bill 1176, Senate Bill 5443, and meeting with the Governor’s Office for the HB 1176 bill signing.

The L-5 report for the first quarter of 2019 was required to have been filed by BORPELS no later than April 30, 2019 and the information was filed 234 days late.  The L-5 report for the second quarter of 2019 was required to have been filed by BORPELS no later than July 31, 2019 and the information was filed 142 days late.

On April 24, 2020, the PDC received a completed Statement of Understanding (SOU) and a $150 civil penalty payment from BORPELS.  The $150 civil penalty assessed against BORPELS in this matter was done in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule).  By completing the SOU, BORPELS  acknowledged a violation of RCW 42.17A.635 by failing to timely file two L-5 reports as required for a state agency engaged in public agency lobbying activities.

Based on this information and the facts, the PDC have dismissed the complaint in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/67383
67094 03/18/2020 Norman Smith Phyllis Kardos Kardos, Phyllis: Alleged Violation of RCW 42.17A.320 for failure to disclose sponsor identification on political advertisements (EY20, Mar 20) RCW 42.17A.320 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint Norman Smith filed on March 17, 2020. The complaint alleged that Phyllis Kardos (Respondent), a candidate for County Commissioner for Pend Oreille County may have violated RCW 42.17A.320 for failure to disclose sponsor identification on political advertisement.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent and the applicable PDC reports filed by the Respondent to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to disclose sponsor information on political advertisement does not amount to a violation that warrants further investigation.

PDC staff is reminding Phyllis Kardos about the importance of the proper and full disclosure of sponsor identification on political advertisements in accordance with the statutes and rules in the future.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/67094
66926 03/16/2020 CHRISTEN L ELLIS Will Finn Finn, William: Alleged Violation of RCW 42.17A.205 for failure to timely file Candidate Registration (C-1) (EY 20, Mar 20) RCW 24.17A.205 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint Christen Ellis filed on March 11, 2020. The complaint alleged that Will Finn (Respondent), a candidate for County Commissioner for Cowlitz County may have violated RCW 42.17A.205 for failure to timely and accurately file Candidate Registration.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent and the applicable PDC reports filed by the Respondent to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to timely file the Candidate Registration does not amount to a violation that warrants further investigation.

PDC staff is reminding Will Finn about the importance of the timely filing of all required reports for future PDC reports in accordance with the statutes and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/66926
66555 03/10/2020 Martin L. "Iceman" Wheeler Joshua Freed Freed, Joshua (2): Alleged violations of RCW 42.17A.145, .235, and .240 for failure to properly certify reports and disclose accurate and complete contribution information (EY 20; Mar 20) RCW 42.17A.145, RCW 42.17A.240, RCW 42.17A.235, WAC 390-16-034 Investigation of Possible Violation

PDC staff opened a formal investigation and held an initial hearing (also referred to as a case status review), on April 27, 2020 pursuant to RCW 42.17A.755, and WACs 390-37-060 and 390-37-071.

The complaint alleged violations of RCW 42.17A.145, .235, and .240 by failing to properly certify reports and disclose accurate and complete contribution information. 

https://www.pdc.wa.gov/browse/cases/66555
66161 03/03/2020 William Joseph Casey, IV; and Lorie Walker Joshua Freed Freed Joshua: Alleged violations of RCW 42.17A.445 for making loan repayments to the candidate in excess of $6,000 limit (EY 20, Mar 20) RCW 42.17A.445 Investigation of Possible Violation

PDC staff opened a formal investigation and held an initial hearing, (also referred to as a case status review) on April 27, 2020, pursuant to RCW 42.17A.755, and WACs 390-37-060 and 390-37-071.

The complaint alleged violations of RCW 42.17A.445 for making loan repayments to the candidate in excess of $6,000 limit.

https://www.pdc.wa.gov/browse/cases/66161
66039 03/02/2020 Dan Sullivan Centralia School District Officials and Centralia School District Centralia School District Officials: Alleged Violation of RCW 42.17A.555 for using public facilities to support a ballot proposition; Centralia School District: Alleged violation of RCW 42.17A.495 for failing to have proper payroll deduction authorizations prior to allowing deductions for political contributions (EY 20, Mar 20) RCW 42.17A.495, RCW 42.17A.555 Investigation of Possible Violation
  • Allegation One: Violation of RCW 42.17A.555 for using public facilities to support a ballot proposition
  • Allegation Two: Violation of RCW 42.17A.495 for failing to have proper payroll deduction authorizations prior to allowing payroll deductions for political contributions
https://www.pdc.wa.gov/browse/cases/66039
65831 02/27/2020 PDC Staff ReviverMX Inc ReviverMX Inc: Alleged violation of RCW 42.17A.630 for failure to timely disclose Lobbyist Employer’s expenses for calendar year 2018 (Group Enforcement 2020) RCW 42.17A.630 Resolved through Statement of Understanding

On February 13, 2020 the Public Disclosure Commission (PDC) notified ReviverMx Inc. of an alleged violation of RCW 42.17A.630 for failure to timely file the annual Lobbyist Employer’s Expense report (L-3 report) disclosing lobbying activities for calendar year 2018.

ReviverMx, Inc. completed a Statement of Understanding (SOU) and paid a $100 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), acknowledging violations of RCW 42.17A.630 for failure to timely file the L-3 report, due no later than February 28, 2019. The L-3 report was received on February 27, 2020, 364 days beyond the statutory deadline. The $100 penalty assessed resolves the allegations.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1)(a). The PDC will not conduct a more formal investigation into these allegations or take further enforcement action in this matter.  

https://www.pdc.wa.gov/browse/cases/65831
65459 02/21/2020 Glen Morgan Mike Kreidler Kreidler, Mike (2): Alleged violations of RCW 42.17A.430 for unauthorized uses of campaign surplus funds (Feb 20) RCW 42.17A.430 Resolved through Statement of Understanding

A complaint was filed against Mike Kreidler, the incumbent Washington State Insurance Commissioner, alleging violations of RCW 42.17A.430 by making prohibited expenditures from the Mike Kreidler Surplus Funds Account.

A $500 contribution was made from the Mike Kreidler Surplus funds account to the Denny Heck for Congress Campaign in August of 2017.  The contribution had been made in error, and after being made aware of the error once the complaint had been filed, the Mike Kreidler Surplus funds account requested the Denny Heck Campaign refund the contribution.  The $500 contribution was refunded and received by the Mike Kreidler Surplus funds account on March 9, 2020.  

On April 9, 2020, the Mike Kreidler Surplus funds account filed the March 2020 reports disclosing the deposit date of the $500 refunded contribution from the Denny Heck Campaign as being March 10, 2020.  

On April 16, 2020, Commissioner Kreidler completed a Statement of Understanding (SOU) and paid a $150 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), acknowledging a violation of RCW 42.17A.430 by using surplus funds to make a prohibited $500 monetary contribution to the 2018 Denny Heck for Congress Campaign.  The $150 penalty assessed in this matter resolves the issue of making a prohibited surplus expenditure. 

PDC staff found no evidence of a material violation concerning the remaining allegations that would require conducting a more formal investigation into the complaint or pursuing enforcement action in this instance. Staff found that the surplus fund expenditures identified in the complaint, with the exception of the $500 contribution to the Denny Heck Campaign, were for official office related and/or team building activities, and for official office related travel, and thus permissible expenditures. 

Those permissible expenditures included: (1) office parties, annual holiday events, retirement parties for Insurance Commissioner Office staff; (2) entry fees and other costs associated with joining the State Agency Softball League, and other activities that boost Insurance Commissioner Officer morale and promote team building; and (3) expenditures made to Commissioner Kreidler reimbursing him for out-of-pocket expenses he incurred while attending the annual  National Association of Insurance Commissioner’s (NAIC), and other insurance industry-related meetings, roundtables, etc. while serving in his official capacity.

The PDC has dismissed the complaint in accordance with RCW 42.17A.755(1). 

 

https://www.pdc.wa.gov/browse/cases/65459
65458 02/21/2020 PDC Staff Lifelong AIDS Alliance Lifelong AIDS Alliance: Alleged violation of RCW 42.17A.630 for failure to timely disclose Lobbyist Employer’s expenses for calendar year 2018 (Group Enforcement 2020) RCW 42.17A.630 Resolved through Statement of Understanding

On February 13, 2020, the Public Disclosure Commission (PDC) notified Lifelong AIDS Alliance of an alleged violation of RCW 42.17A.630 for failure to timely file the annual Lobbyist Employer’s Expense report (L-3 report) disclosing lobbying activities for calendar year 2018.

Lifelong AIDS Alliance completed a Statement of Understanding (SOU) and paid a $100 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), acknowledging a violation of RCW 42.17A.630 for failing to timely file the annual Employer’s Lobbying Expenses report (L-3 report), disclosing lobbying activity in calendar year 2018, due no later than February 28, 2019. The $100 penalty assessed resolves the allegation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1)(a). The PDC will not conduct a more formal investigation into this allegation or take further enforcement action in this matter.  

https://www.pdc.wa.gov/browse/cases/65458
65295 02/19/2020 Donald Williams City of Ocean Shores Officials City of Ocean Shores Officials: Alleged Violation of RCW 42.17A.555 for misuse of public facilities (EY 20, Feb 20) RCW 42.17A.555 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint Donald Williams filed on February 14, 2020. The complaint alleged that City of Ocean Shores Officials, public agency officials, may have violated RCW 42.17A.555 for misuse of public facilities to either appose or support a candidate or ballot measure.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements and the response provided by the Respondent to determine whether the record supports a finding of one or more violations. Based on our findings staff has determined that, in this instance, the misuse of facilities by a volunteer DJ does not appear to be a violation that warrants further investigation.

PDC staff is reminding City of Ocean Shores Officials about the importance of monitoring and informing staff and volunteers of the policies regarding restrictions on use of facilities to support or oppose candidates or ballot measures, including school levies and bonds; the review and enforcement of these policies is as important as the initial handbook and guideline notifications.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/65295
65103 02/14/2020 PDC Staff Jacqueline True True, Jacqueline: Alleged Violation of RCW 42.17A.615 for failure to timely file monthly Lobbyist Reports (L-2 reports) in calendar year 2019 (Group Enforcement 2020) RCW 42.17A.615 Resolved through Statement of Understanding

On February 14, 2020, the Public Disclosure Commission (PDC) notified Jacqueline True of an alleged violation of RCW 42.17A.615 for failure to timely file one or more monthly Lobbying Expense reports (L-2 reports) for 2019.

PDC staff have reviewed this matter and found the following:

The PDC received your 2019 L-2 reports on February 26, 2020, as required by RCW 42.17A.615. As a Lobbyist registered to lobby in 2019, the monthly reports were due by the 15th day of each following month, making these reports 42 to 254 days late. 

Jacqueline True completed a Statement of Understanding (SOU) and paid a $100 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), acknowledging violation of RCW 42.17A.615 for failure to timely file one or more monthly Lobbying Expense reports (L-2 reports) for 2019. The $100 penalty assessed resolves the allegations listed in your complaint.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1)(a). The PDC will not conduct a more formal investigation into these allegations or take further enforcement action in this matter.  

https://www.pdc.wa.gov/browse/cases/65103
65101 02/14/2020 PDC Staff Colleen Laing Laing, Colleen: Alleged Violation of RCW 42.17A.615 for failure to timely file monthly Lobbyist Reports (L-2 reports) in calendar year 2019 (Group Enforcement 2020) RCW 42.17A.615 Resolved through Statement of Understanding

On February 14, 2020, the Public Disclosure Commission (PDC) notified Colleen Laing of an alleged violation of RCW 42.17A.615 for failure to timely file one or more monthly Lobbying Expense reports (L-2 reports) for 2019.

PDC staff have reviewed this matter and found the following:

The PDC received your 2019 L-2 reports on February 26, 2020, as required by RCW 42.17A.615. As a Lobbyist registered to lobby in 2019, the monthly reports were due by the 15th day of each following month, making the reports 42 to 376 days late. 

Colleen Laing completed a Statement of Understanding (SOU) and paid a $100 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), acknowledging violations of RCW 42.17A.615 for failure to timely file one or more monthly Lobbying Expense reports (L-2 reports) for 2019. The $100 penalty assessed resolves the allegations listed in this complaint.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1)(a). The PDC will not conduct a more formal investigation into these allegations or take further enforcement action in this matter.  

https://www.pdc.wa.gov/browse/cases/65101
65099 02/14/2020 PDC Staff Andrea Piper-Wentland Piper-Wentland, Andrea: Alleged Violation of RCW 42.17A.615 for failure to timely file monthly Lobbyist Reports (L-2 reports) in calendar year 2019 (Group Enforcement 2020) RCW 42.17A.615 Closed Administratively

On February 14, 2020, the Public Disclosure Commission (PDC) notified Andrea Piper-Wentland of an alleged failure to timely file Lobbying Expense (L-2) Report disclosing monthly income and expense information for December 2019.

PDC staff have reviewed this matter and found the following: 

The PDC received your 2019 L-2 report on February 14, 2020, as required by RCW 42.17A.615. As a Lobbyist registered to lobby in 2019, the monthly reports were due by the 15th day of each following month, making your report 30 days late. 

PDC staff will now close PDC Case 65099 administratively and remove your name from our hearing list. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1)(a). The PDC will not conduct a more formal investigation into these allegations or take further enforcement action in this matter.  

https://www.pdc.wa.gov/browse/cases/65099
65098 02/14/2020 PDC Staff Alma Gottlieb-McHale Gottlieb-McHale, Alma: Alleged Violation of RCW 42.17A.615 for failure to timely file monthly Lobbyist Reports (L-2 reports) in calendar year 2019 (Group Enforcement 2020) RCW 42.17A.615 Violation Found by Commission

BEFORE THE PUBLIC DISCLOSURE COMMISSION 
OF THE STATE OF WASHINGTON 

In Re: Compliance with RCW 42.17A 

ALMA GOTTLIEB-MCHALE, 
                            Respondent.  
PDC Case 65098 

Findings of Fact, 
Conclusions of Law, and 
Order Imposing Fine 

Pursuant to the brief enforcement hearing (brief adjudicative proceeding) notice sent to Alma Gottlieb-McHale on February 14, 2020, a brief adjudicative proceeding was held on February 28, 2020, in Room 206, Evergreen Plaza Building, 711 Capitol Way, Olympia, Washington, to consider whether the Respondent violated RCW 42.17A.615 by failing to file Monthly Lobbyist Expense Reports (L-2 reports) as a lobbyist for the 2019 calendar year. The L-2 reports were due to be filed by the 15th of each month, disclosing lobbying activities in the previous calendar month. 

The hearing was held in accordance with Chapters 34.05 RCW and 42.17A RCW and Chapter 390-37 WAC.  Commission Chair Dave Ammons was the Presiding Officer.  The Commission staff was represented by Tabitha Townsend, Compliance Coordinator.  The Respondent participated in the hearing telephonically and by written statement. 

Having considered the evidence, the Presiding Officer finds as follows: 

FINDINGS OF FACT 

1. The Respondent was a registered lobbyist in the State of Washington during calendar year 2019.   
2. As a registered lobbyist, the Respondent was required to file the L-2 reports by the 15th of each month, disclosing compensation and lobbying expenses in the prior calendar month, such as travel, entertainment, contributions, advertising, and other lobbying expenses. 
3. The Respondent filed the missing L-2 reports for August through November of 2019 prior to the date of the hearing. 
4. The Respondent did not lobby during December 2019.    
5. The Respondent has no prior violations. 
CONCLUSIONS OF LAW 

Based on the above facts, as a matter of law, the Presiding Officer concludes as follows: 

1. This matter was duly and properly convened and all jurisdictional, substantive, and procedural requirements have been satisfied. 

2. The Respondent violated RCW 42.17A.615 by failing to file the L-2 reports by the 15th of the month as required. 
ORDER 

On the basis of the foregoing Findings of Fact and Conclusions of Law, 

IT IS HEREBY ORDERED that the Respondent is assessed a civil penalty of $150, with $150 suspended, in accordance with the L-2 penalty schedule set forth in WAC 390-37-143. The suspended portion of the penalty is upon condition that the Respondent: 
1. Commits no further violations of Chapter 42.17A RCW or Title 390 WAC for a period of four years following the date of this Order. 
This is an Initial Order of the Public Disclosure Commission.   

Entered this 9th day of March. 

Public Disclosure Commission 
 

https://www.pdc.wa.gov/browse/cases/65098
65097 02/14/2020 PDC Staff Armstrong & Assoc Armstrong & Assoc: Alleged Violation of RCW 42.17A.615 for failure to timely file monthly Lobbyist Reports (L-2 reports) in calendar year 2019 (Group Enforcement 2020) RCW 42.17A.615 Violation Found by Commission

BEFORE THE PUBLIC DISCLOSURE COMMISSION 
OF THE STATE OF WASHINGTON 

In Re: Compliance with RCW 42.17A 

ARMSTRONG & ASSOC., 
                            Respondent.  
PDC Case 65097 

Findings of Fact, 
Conclusions of Law, and 
Order Imposing Fine 

Pursuant to the brief enforcement hearing (brief adjudicative proceeding) notice sent to Armstrong & Assoc. on February 14, 2020, a brief adjudicative proceeding was held on February 28, 2020, in Room 206, Evergreen Plaza Building, 711 Capitol Way, Olympia, Washington, to consider whether the Respondent violated RCW 42.17A.615 by failing to file Monthly Lobbyist Expense Reports (L-2 Reports) as a lobbyist for the 2019 calendar year. The L-2 reports were due to be filed by the 15th of each month, disclosing lobbying activities in the previous calendar month. 

The hearing was held in accordance with Chapters 34.05 RCW and 42.17A RCW and Chapter 390-37 WAC.  Commission Chair Dave Ammons was the Presiding Officer.  The Commission staff was represented by Tabatha Blacksmith, Compliance Coordinator.  The Respondent did not participate in the hearing or submit any written materials. 

Having considered the evidence, the Presiding Officer finds as follows: 

FINDINGS OF FACT 

1. The Respondent was a registered lobbyist in the State of Washington during calendar year 2019.   
2. As a registered lobbyist, the Respondent was required to file the L-2 reports by the 15th of each month, disclosing compensation and lobbying expenses in the prior calendar month, such as travel, entertainment, contributions, advertising, and other lobbying expenses. 
3. The Respondent did not file the missing L-2 reports for January through December of 2019 prior to the date of the hearing.    
4. The Respondent has no prior violations. 

CONCLUSIONS OF LAW 

Based on the above facts, as a matter of law, the Presiding Officer concludes as follows: 

1. This matter was duly and properly convened and all jurisdictional, substantive, and procedural requirements have been satisfied. 

2. The Respondent violated RCW 42.17A.615 by failing to file the L-2 reports by the 15th of the month as required. 
ORDER 

On the basis of the foregoing Findings of Fact and Conclusions of Law, 

IT IS HEREBY ORDERED that the Respondent is assessed a civil penalty of $250 in accordance with the L-2 penalty schedule set forth in WAC 390-37-143. The $250 penalty is due within 30 days from the date of this Order.  
In the event the Respondent fails to pay the assessed civil penalty within 90 days of the date of the Order, PDC staff is directed to refer the matter to outside collections for the amount owed.  
This is an Initial Order of the Public Disclosure Commission.   

Entered this 9th Day of March 

Public Disclosure Commission 
 

https://www.pdc.wa.gov/browse/cases/65097
65096 02/14/2020 PDC Staff JEFF BISSONNETTE JEFF BISSONNETTE: Alleged Violation of RCW 42.17A.615 for failure to timely file monthly Lobbyist Reports (L-2 reports) in calendar year 2019 (Group Enforcement 2020) RCW 42.17A.615 Resolved through Statement of Understanding

On February 14, 2020, the Public Disclosure Commission (PDC) notified Jeff Bissonnette of an alleged violation of RCW 42.17A.615 for failure to timely file one or more monthly Lobbying Expense reports (L-2 reports) for 2019.

Jeff Bissonnette completed a Statement of Understanding (SOU) and paid a $100 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), acknowledging violations of RCW 42.17A.615 for failure to timely file the L-2 report covering January 2019. The L-2 report was received on February 28, 2020, 365 days beyond the statutory deadline. The $100 penalty assessed resolves the allegations.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1)(a). The PDC will not conduct a more formal investigation into these allegations or take further enforcement action in this matter.  

https://www.pdc.wa.gov/browse/cases/65096
65095 02/14/2020 PDC Staff Jessica Hauffe Jessica Hauffe: Alleged Violation of RCW 42.17A.615 for failure to timely file monthly Lobbyist Reports (L-2 reports) in calendar year 2019 (Group Enforcement 2020) RCW 42.17A.615 Closed Administratively

The Public Disclosure Commission (PDC) received Jessica Hauffe's December 2019 L-2 report on 2/14/20, as required by RCW 42.17A.615. As a registered Lobbyist to lobby in 2019, the reports were due by the 15th of each month following, making the report 30 days late. PDC staff will now close PDC Case 65095 administratively and remove Jessica Hauffe's name from our hearing list. PDC staff reminds Jessica Hauffe about the importance of timely, accurate, and complete reporting requirements in the future.

https://www.pdc.wa.gov/browse/cases/65095
65093 02/14/2020 PDC Staff MARIO BROWN MARIO BROWN: Alleged Violation of RCW 42.17A.615 for failure to timely file monthly Lobbyist Reports (L-2 reports) in calendar year 2019 (Group Enforcement 2020) RCW 42.17A.615 Closed Administratively

On February 14, 2020, the Public Disclosure Commission (PDC) notified Mario Brown of an alleged violation of RCW 42.17A.615 for failure to timely file an Lobbyist Expense report (L-2 report) disclosing lobbying activities for September 2019.

PDC staff will now close PDC Case 65093 administratively and remove Mario Brown's from our hearing list. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance 

https://www.pdc.wa.gov/browse/cases/65093
65092 02/14/2020 PDC Staff Mark Dunn Mark Dunn: Alleged Violation of RCW 42.17A.615 for failure to timely file monthly Lobbyist Reports (L-2 reports) in calendar year 2019 (Group Enforcement 2020) RCW 42.17A.615 Violation Found by Commission

Pursuant to the brief enforcement hearing (brief adjudicative proceeding) notice sent to Mark Dunn on February 14, 2020, a brief adjudicative proceeding was held on February 28, 2020, in Room 206, Evergreen Plaza Building, 711 Capitol Way, Olympia, Washington, to consider whether the Respondent violated RCW 42.17A.615 by failing to file Monthly Lobbyist Expense Reports (L-2 Reports) as a lobbyist for the 2019 calendar year. The L-2 reports were due to be filed by the 15th of each month, disclosing lobbying activities in the previous calendar month. 

The hearing was held in accordance with Chapters 34.05 RCW and 42.17A RCW and Chapter 390-37 WAC.  Commission Chair Dave Ammons was the Presiding Officer.  The Commission staff was represented by Tabatha Blacksmith, Compliance Coordinator.  The Respondent did not participate in the hearing or submit any written materials. 

Having considered the evidence, the Presiding Officer finds as follows: 

FINDINGS OF FACT 

1. The Respondent was a registered lobbyist in the State of Washington during calendar year 2019.   
2. As a registered lobbyist, the Respondent was required to file the L-2 reports by the 15th of each month, disclosing compensation and lobbying expenses in the prior calendar month, such as travel, entertainment, contributions, advertising, and other lobbying expenses. 
3. The Respondent did not file the missing L-2 report for September of 2019 prior to the date of the hearing.    
4. The Respondent has no prior violations. 

CONCLUSIONS OF LAW 

Based on the above facts, as a matter of law, the Presiding Officer concludes as follows: 

1. This matter was duly and properly convened and all jurisdictional, substantive, and procedural requirements have been satisfied. 

2. The Respondent violated RCW 42.17A.615 by failing to file the L-2 report by the 15th of the month as required. 
 

ORDER 

On the basis of the foregoing Findings of Fact and Conclusions of Law, 

IT IS HEREBY ORDERED that the Respondent is assessed a civil penalty of $250 in accordance with the L-2 penalty schedule set forth in WAC 390-37-143. The $250 penalty is due within 30 days from the date of this Order.  
In the event the Respondent fails to pay the assessed civil penalty within 90 days of the date of the Order, PDC staff is directed to refer the matter to outside collections for the amount owed.  
 

https://www.pdc.wa.gov/browse/cases/65092
65091 02/14/2020 PDC Staff MARK OKAZAKI MARK OKAZAKI: Alleged Violation of RCW 42.17A.615 for failure to timely file monthly Lobbyist Reports (L-2 reports) in calendar year 2019 (Group Enforcement 2020) RCW 42.17A.615 Closed Administratively

On February 14, 2020, the Public Disclosure Commission (PDC) notified Mark Okazaki of an alleged violation of RCW 42.17A.615 for failure to timely file a Lobbyist Expense report (L-2 report) disclosing lobbying activities in September 2019.

The PDC received the 2019 L-2 report on February 14, 2020, as required by RCW 42.17A.615. As a Lobbyist registered to lobby in 2019, the September 2019 report was due by the 15th day of October 2019, making the report 122 days late. 

The PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1)(a) and WAC 390-37-060(1)(a). The PDC will not conduct a more formal investigation into these allegations or take further enforcement action in this matter.  

https://www.pdc.wa.gov/browse/cases/65091
65090 02/14/2020 PDC Staff PRINCIPLED SOLUTIONS* PRINCIPLED SOLUTIONS*: Alleged Violation of RCW 42.17A.615 for failure to timely file monthly Lobbyist Reports (L-2 reports) in calendar year 2019 (Group Enforcement 2020) RCW 42.17A.615 Resolved through Statement of Understanding

On February 14, 2020, the Public Disclosure Commission (PDC) notified Principled Solutions* of an alleged violation of RCW 42.17A.615 for failure to timely file one or more monthly Lobbying Expense reports (L-2 reports), disclosing lobbying activities in calendar year 2019.

Principled Solutions* completed a Statement of Understanding (SOU) and paid a $100 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), acknowledging a violation of RCW 42.17A.615 for failing to timely file the one or more monthly Lobbying Expense reports (L-2 reports), due by the 15th day of each calendar month, disclosing activity in the previous calendar month. The $100 penalty assessed resolves the allegation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1)(a). The PDC will not conduct a more formal investigation into these allegations or take further enforcement action in this matter. 

https://www.pdc.wa.gov/browse/cases/65090
65089 02/14/2020 PDC Staff Robert Knoll Robert Knoll: Alleged Violation of RCW 42.17A.615 for failure to timely file monthly Lobbyist Reports (L-2 reports) in calendar year 2019 (Group Enforcement 2020) RCW 42.17A.615 Closed Administratively

Allegation:  Violation of RCW 42.17A.615 for failure to timely file monthly Lobbyist Reports (L-2 reports) in calendar year 2019 (Group Enforcement 2020)

https://www.pdc.wa.gov/browse/cases/65089
65088 02/14/2020 PDC Staff Alison Holcomb Holcomb, Alison: Alleged Violation of RCW 42.17A.615 for failure to timely file monthly Lobbyist Reports (L-2 reports) in calendar year 2019 (Group Enforcement 2020) RCW 42.17A.615 Closed Administratively

On February 14, 2020, the Public Disclosure Commission (PDC) notified Alison Holcomb of an alleged failure to timely file Monthly Lobbyist (L-2) Reports disclosing lobbying income and expenses for November and December of 2019.

PDC staff have reviewed this matter and found the following: 

PDC records indicate that you are no longer registered to lobby for the months that previously triggered monthly L-2 reports in 2019 pursuant to RCW 42.17A.615. 

PDC staff will now close PDC Case 65088 administratively and remove your name from our hearing list. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1)(a) and WAC 390-37-060(1)(a). The PDC will not conduct a more formal investigation into these allegations or take further enforcement action in this matter.  

https://www.pdc.wa.gov/browse/cases/65088
65087 02/14/2020 PDC Staff ROBERT MITCHELL ROBERT MITCHELL: Alleged Violation of RCW 42.17A.615 for failure to timely file monthly Lobbyist Reports (L-2 reports) in calendar year 2019 (Group Enforcement 2020) RCW 42.17A.615 Violation Found by Commission

Pursuant to the brief enforcement hearing (brief adjudicative proceeding) notice sent to Robert Mitchell on February 14, 2020, a brief adjudicative proceeding was held on February 28, 2020, in Room 206, Evergreen Plaza Building, 711 Capitol Way, Olympia, Washington, to consider whether the Respondent violated RCW 42.17A.615 by failing to file Monthly Lobbyist Expense Reports (L-2 Reports) as a lobbyist for the 2019 calendar year. The L-2 reports were due to be filed by the 15th of each month, disclosing lobbying activities in the previous calendar month. 

The hearing was held in accordance with Chapters 34.05 RCW and 42.17A RCW and Chapter 390-37 WAC.  Commission Chair Dave Ammons was the Presiding Officer.  The Commission staff was represented by Tabatha Blacksmith, Compliance Coordinator.  The Respondent did not participate in the hearing or submit any written materials. 

Having considered the evidence, the Presiding Officer finds as follows: 

FINDINGS OF FACT 

1. The Respondent was a registered lobbyist in the State of Washington during calendar year 2019.   
2. As a registered lobbyist, the Respondent was required to file the L-2 reports by the 15th of each month, disclosing compensation and lobbying expenses in the prior calendar month, such as travel, entertainment, contributions, advertising, and other lobbying expenses. 
3. The Respondent did not file the missing L-2 reports for May and June of 2019 prior to the date of the hearing.    
4. The Respondent has no prior violations. 

CONCLUSIONS OF LAW 

Based on the above facts, as a matter of law, the Presiding Officer concludes as follows: 

1. This matter was duly and properly convened and all jurisdictional, substantive, and procedural requirements have been satisfied. 

2. The Respondent violated RCW 42.17A.615 by failing to file the L-2 reports by the 15th of the month as required. 
 

ORDER 

On the basis of the foregoing Findings of Fact and Conclusions of Law, 

IT IS HEREBY ORDERED that the Respondent is assessed a civil penalty of $250 in accordance with the L-2 penalty schedule set forth in WAC 390-37-143. The $250 penalty is due within 30 days from the date of this Order.  
In the event the Respondent fails to pay the assessed civil penalty within 90 days of the date of the Order, PDC staff is directed to refer the matter to outside collections for the amount owed.  
 

https://www.pdc.wa.gov/browse/cases/65087
65085 02/14/2020 PDC Staff Rosie Cullen Rosie Cullen: Alleged Violation of RCW 42.17A.615 for failure to timely file monthly Lobbyist Reports (L-2 reports) in calendar year 2019 (Group Enforcement 2020) RCW 42.17A.615 Violation Found by Commission

Pursuant to the brief enforcement hearing (brief adjudicative proceeding) notice sent to Rosie Cullen on February 14, 2020, A brief adjudicative proceeding was held on February 28, 2020, in Room 206, Evergreen Plaza Building, 711 Capitol Way, Olympia, Washington, to consider whether the Respondent violated RCW 42.17A.615 by failing to file Monthly Lobbyist Expense Reports (L-2 Reports) as a lobbyist for the 2019 calendar year. The L-2 reports were due to be filed by the 15th of each month, disclosing lobbying activities in the previous calendar month. 

The hearing was held in accordance with Chapters 34.05 RCW and 42.17A RCW and Chapter 390-37 WAC.  Commission Chair Dave Ammons was the Presiding Officer.  The Commission staff was represented by Tabatha Blacksmith, Compliance Coordinator.  The Respondent participated in the hearing telephonically and by written statement. 

Having considered the evidence, the Presiding Officer finds as follows: 

FINDINGS OF FACT 

1. The Respondent was a registered lobbyist in the State of Washington during calendar year 2019.   
2. As a registered lobbyist, the Respondent was required to file the L-2 reports by the 15th of each month, disclosing compensation and lobbying expenses in the prior calendar month, such as travel, entertainment, contributions, advertising, and other lobbying expenses. 
3. The Respondent filed the missing L-2 report for February 2019 prior to the date of the hearing.    
4. The Respondent has no prior violations. 

CONCLUSIONS OF LAW 

Based on the above facts, as a matter of law, the Presiding Officer concludes as follows: 

1. This matter was duly and properly convened and all jurisdictional, substantive, and procedural requirements have been satisfied. 

2. The Respondent violated RCW 42.17A.615 by failing to file the L-2 reports by the 15th of the month as required. 
 

ORDER 

On the basis of the foregoing Findings of Fact and Conclusions of Law, 

IT IS HEREBY ORDERED that the Respondent is assessed a civil penalty of $150, with $150 suspended, in accordance with the L-2 penalty schedule set forth in WAC 390-37-143. The suspended portion of the penalty is upon condition that the Respondent: 
1. Commits no further violations of Chapter 42.17A RCW or Title 390 WAC for a period of four years following the date of this Order. 
 

https://www.pdc.wa.gov/browse/cases/65085
65084 02/14/2020 PDC Staff Sarah Jaynes Sarah Jaynes: Alleged Violation of RCW 42.17A.615 for failure to timely file monthly Lobbyist Reports (L-2 reports) in calendar year 2019 (Group Enforcement 2020) RCW 42.17A.615 Closed Administratively

After the Public Disclosure Commission (PDC) reached out to Sarah Jaynes regarding her failure to timely file a monthly Lobbyist Report (L-2 report) for May of 2019, she updated her lobbyist registration account to reflect that no lobbying occurred during this time period. Subsequent to this change, PDC staff administratively closed PDC Case 65084.

Based on the information provided by Sarah Jaynes, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1)(a) and WAC 390-37-060(1)(a). The PDC will not conduct a more formal investigation into these allegations or take further enforcement action in this matter. 

https://www.pdc.wa.gov/browse/cases/65084
65083 02/14/2020 PDC Staff SCOTT BLONIEN SCOTT BLONIEN: Alleged Violation of RCW 42.17A.615 for failure to timely file monthly Lobbyist Reports (L-2 reports) in calendar year 2019 (Group Enforcement 2020) RCW 42.17A.615 Resolved through Statement of Understanding

On February 14, 2020, the Public Disclosure Commission (PDC) notified Scott Blonien of an alleged violation of RCW 42.17A.615 for failure to timely file one or more monthly Lobbying Expense reports (L-2 reports), disclosing lobbying activities in calendar year 2019.

John Scott Blonien completed a Statement of Understanding (SOU) and paid a $100 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), acknowledging a violation of RCW 42.17A.615 for failing to timely file the one or more monthly Lobbying Expense reports (L-2 reports), due by the 15th day of each calendar month, disclosing activity in the previous calendar month. The $100 penalty assessed resolves the allegation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1)(a). The PDC will not conduct a more formal investigation into these allegations or take further enforcement action in this matter.  

https://www.pdc.wa.gov/browse/cases/65083
65082 02/14/2020 PDC Staff Alice Dietz Dietz, Alice: Alleged Violation of RCW 42.17A.615 for failure to timely file monthly Lobbyist Reports (L-2 reports) in calendar year 2019 (Group Enforcement 2020) RCW 42.17A.615 Resolved through Statement of Understanding

On February 14, 2020, the Public Disclosure Commission (PDC) notified Alice Dietz of an alleged Violation of RCW 42.17A.615 failure to timely file your Monthly Lobbyist (L-2) Report disclosing Lobbying Income and Expenses for April 2019.

PDC staff have reviewed this matter and found the following:

The PDC received your 2019 L-2 report on February 18, 2020, as required by RCW 42.17A.615. As a Lobbyist registered to lobby in 2019, the monthly reports were due by the 15th day of each following month, making the report 279 days late.

Alice Dietz completed a Statement of Understanding (SOU) and paid a $100 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), acknowledging violations of RCW 42.17A.615 by failing to file one or more monthly Lobbying Expense reports (L-2 reports), due by the 15th day of each calendar month, disclosing lobbying activity in the previous calendar month. The $100 penalty assessed resolves the allegations listed in your complaint.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1)(a). The PDC will not conduct a more formal investigation into these allegations or take further enforcement action in this matter.

https://www.pdc.wa.gov/browse/cases/65082
65080 02/14/2020 PDC Staff TODD W MIELKE TODD W MIELKE: Alleged Violation of RCW 42.17A.615 for failure to timely file monthly Lobbyist Reports (L-2 reports) in calendar year 2019 (Group Enforcement 2020) RCW 42.17A.615 Resolved through Statement of Understanding

On February 14, 2020, the Public Disclosure Commission (PDC) notified Todd Mielke of an alleged violation of RCW 42.17A.615 for failure to timely file one or more monthly Lobbyist Reports (L-2 reports) in calendar year 2019.

Todd Mielke completed a Statement of Understanding (SOU) and paid a $100 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), acknowledging a violation of RCW 42.17A.615 for failing to timely file one or more monthly Lobbyist Reports (L-2 reports), due the 15th day of each month, disclosing lobbying activity in the prior calendar month. The $100 penalty assessed resolves the allegation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1)(a). The PDC will not conduct a more formal investigation into this allegation or take further enforcement action in this matter.  

https://www.pdc.wa.gov/browse/cases/65080
65026 02/13/2020 Kevin Schofield and Glen Morgan Kshama Sawant Sawant, Kshama (3): Alleged violations of RCW 42.17A.555 for misuse of public facilities to support election campaigns, or RCW 42.17A.635 for indirectly lobbying the legislature (EY 20; Feb 20) RCW 42.17A.555, RCW 42.17A.635 Investigation of Possible Violation
  • Allegation One: Violations of RCW 42.17A.555 for misuse of public facilities to support a ballot proposition.
  • Allegation Two: Violations of RCW 42.17A.635 for indirectly lobbying the legislature outside of authorized channels for public agency lobbying.
https://www.pdc.wa.gov/browse/cases/65026
65022 02/13/2020 Kevin Schofield and Glen Morgan Tax Amazon Movement Tax Amazon Movement: Alleged violations of RCW 42.17A.205, .235, and .240 for failure to register and report as a political committee, or RCW 42.17A.640 for failure to report grassroots lobbying (EY 20; Feb 20) RCW 42.17A.235, RCW 42.17A.205, RCW 42.17A.640, RCW 42.17A.240 Investigation of Possible Violation
  • Allegation One: Violation of RCW 42.17A.205 for failure to register as a political committee.
  • Allegation Two: Violations of RCW 42.17A.235 and .240 for failure to report contributions and expenditures as a political committee.
  • Allegation Three: Violations of RCW 42.17A.640 for failure to report grassroots lobbying activity.
https://www.pdc.wa.gov/browse/cases/65022
64934 02/12/2020 PDC Staff ABBOTT LABORATORIES ABBOTT LABORATORIES: Alleged violation of RCW 42.17A.630 for failure to timely disclose Lobbyist Employer’s expenses for calendar year 2018 (Group Enforcement 2020) RCW 42.17A.630 Resolved through Statement of Understanding

On February 13, 2020, the Public Disclosure Commission (PDC) notified Abbott Laboratories of an alleged violation of RCW 42.17A.630 for failure to timely file the annual Lobbyist Employer’s Expense report (L-3 report) disclosing lobbying activities for calendar year 2018.

The PDC received the annual L-3 report for 2018 on February 19, 2020, as required by RCW 42.17A.630. As a Lobbyist employer, the yearly report is due by the last day of February of each following year, making the report 356 days late

Abbott Laboratories completed a Statement of Understanding (SOU) and paid a $100 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), acknowledging a violation of RCW 42.17A.630 for failing to timely file the annual Employer’s Lobbying Expenses report (L-3 report), disclosing lobbying activity in calendar year 2018, due no later than February 28, 2019. The $100 penalty assessed resolves the allegation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1)(a). The PDC will not conduct a more formal investigation into this allegation or take further enforcement action in this matter.  

https://www.pdc.wa.gov/browse/cases/64934
64930 02/12/2020 PDC Staff Spectrum Health Systems Spectrum Health Systems: Alleged violation of RCW 42.17A.630 for failure to timely disclose Lobbyist Employer’s expenses for calendar year 2018 (Group Enforcement 2020) RCW 42.17A.630 Violation Found by Commission

BEFORE THE PUBLIC DISCLOSURE COMMISSION 
OF THE STATE OF WASHINGTON 

In Re: Compliance with RCW 42.17A 

SPECTRUM HEALTH SYSTEMS, 
                            Respondent.  
PDC Case 64930 

Findings of Fact, 
Conclusions of Law, and 
Order Imposing Fine 

Pursuant to the brief enforcement hearing (brief adjudicative proceeding) notice sent to  
Spectrum Health Systems on February 13, 2020, a brief adjudicative proceeding was held on February 28, 2020, in Room 206, Evergreen Plaza Building, 711 Capitol Way, Olympia, Washington, to consider whether the Respondent violated RCW 42.17A.630 by failing to file Annual Lobbyist Employer Reports (L-3 Reports) as a lobbyist employer for the 2018 calendar year. The L-3 report was due to be filed no later than February 28, 2019. 

The hearing was held in accordance with Chapters 34.05 RCW and 42.17A RCW and Chapter 390-37 WAC.  Commission Chair Dave Ammons was the Presiding Officer.  The Commission staff was represented by Tabitha Townsend, Compliance Coordinator.  The Respondent did not participate in the hearing or submit any written materials. 

Having considered the evidence, the Presiding Officer finds as follows: 

FINDINGS OF FACT 

1. The Respondent was a lobbyist employer of a registered lobbyist in the State of Washington during calendar year 2018.   
2. As a lobbyist employer, the Respondent was required to file the L-3 report by the last day of February in 2019 disclosing the annual amount of lobbying expenses in the prior calendar year, such as lobbyist compensation, contributions and independent expenditures made, lobbying expenditures made, and compensation for professional services to entities held by state officials, successful state candidates, or their immediate families. 
3. The Respondent filed the missing L-3 report for 2018 prior to the date of the hearing.    
4. The Respondent has no prior violations. 

CONCLUSIONS OF LAW 

Based on the above facts, as a matter of law, the Presiding Officer concludes as follows: 

1. This matter was duly and properly convened and all jurisdictional, substantive, and procedural requirements have been satisfied. 

2. The Respondent violated RCW 42.17A.630 by failing to file the L-3 reports by the last day of February, February 28, 2019, as required. 
ORDER 

On the basis of the foregoing Findings of Fact and Conclusions of Law, 

IT IS HEREBY ORDERED that the Respondent is assessed a civil penalty of $150 in accordance with the L-2 penalty schedule set forth in WAC 390-37-143. The $150 penalty is due within 30 days from the date of this Order.  
In the event the Respondent fails to pay the assessed civil penalty within 90 days of the date of the Order, PDC staff is directed to refer the matter to outside collections for the amount owed.  
This is an Initial Order of the Public Disclosure Commission.   

Entered this 9th day of March. 

Public Disclosure Commission 
 

https://www.pdc.wa.gov/browse/cases/64930
64927 02/12/2020 PDC Staff CADMAN INC CADMAN INC: Alleged violation of RCW 42.17A.630 for failure to timely disclose Lobbyist Employer’s expenses for calendar year 2018 (Group Enforcement 2020) RCW 42.17A.630 Closed Administratively
  • Allegation: Violation of RCW 42.17A.630 for failure to timely file the annual Lobbyist Employer’s Expense Report (L-3 report) for calendar year 2018, due no later than February 28, 2019.
https://www.pdc.wa.gov/browse/cases/64927
64921 02/12/2020 PDC Staff EQUAL RIGHTS WA EQUAL RIGHTS WA: Alleged violation of RCW 42.17A.630 for failure to timely disclose Lobbyist Employer’s expenses for calendar year 2018 (Group Enforcement 2020) RCW 42.17A.630 Resolved through Statement of Understanding

On February 13, 2020, the Public Disclosure Commission (PDC) notified Equal Rights WA of an alleged violation of RCW 42.17A.630 for failure to timely file the annual Lobbyist Employer’s Expense report (L-3 report) disclosing lobbying activities for calendar year 2018.

Equal Rights WA completed a Statement of Understanding (SOU) and paid a $100 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), acknowledging a violation of RCW 42.17A.630 for failing to timely file the annual Employer’s Lobbying Expenses report (L-3 report), disclosing lobbying activity in calendar year 2018, due no later than February 28, 2019. The $100 penalty assessed resolves the allegation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1)(a). The PDC will not conduct a more formal investigation into this allegation or take further enforcement action in this matter.  

https://www.pdc.wa.gov/browse/cases/64921
64920 02/12/2020 PDC Staff Emerald Enterprises, LLC Emerald Enterprises, LLC: Alleged violation of RCW 42.17A.630 for failure to timely disclose Lobbyist Employer’s expenses for calendar year 2018 (Group Enforcement 2020) RCW 42.17A.630 Resolved through Statement of Understanding

On February 13, 2020, the Public Disclosure Commission (PDC) notified Emerald Enterprises, LLC of an alleged violation of RCW 42.17A.630 for failure to timely file the annual Lobbyist Employer’s Expense report (L-3 report) disclosing lobbying activities for calendar year 2018.

The PDC received your annual L-3 report for 2018 on February 18, 2020, as required by RCW 42.17A.630. As a Lobbyist employer, the yearly report is due by the last day of February of each following year, making your report 355 days late

Emerald Enterprises, LLC completed a Statement of Understanding (SOU) and paid a $100 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), acknowledging a violation of RCW 42.17A.630 for failing to timely file the annual Employer’s Lobbying Expenses report (L-3 report), disclosing lobbying activity in calendar year 2018, due no later than February 28, 2019. The $100 penalty assessed resolves the allegation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1)(a). The PDC will not conduct a more formal investigation into this allegation or take further enforcement action in this matter.  

https://www.pdc.wa.gov/browse/cases/64920
64918 02/12/2020 PDC Staff EDUCATION MANAGEMENT CORP EDUCATION MANAGEMENT CORP: Alleged violation of RCW 42.17A.630 for failure to timely disclose Lobbyist Employer’s expenses for calendar year 2018 (Group Enforcement 2020) RCW 42.17A.630 Closed Administratively

This case has been closed due to lack of identifying an active business. Upon research it was discovered that EDMC and the Dream Center had both closed due to legal proceedings and overwhelming financial burden. We are closing administratively. 

https://www.pdc.wa.gov/browse/cases/64918
64914 02/12/2020 PDC Staff Zenefits Zenefits: Alleged violation of RCW 42.17A.630 for failure to timely disclose Lobbyist Employer’s expenses for calendar year 2018 (Group Enforcement 2020) RCW 42.17A.630 Violation Found by Commission

BEFORE THE PUBLIC DISCLOSURE COMMISSION 
OF THE STATE OF WASHINGTON 

In Re: Compliance with RCW 42.17A 

ZENEFITS, 
                            Respondent.  
PDC Case 64914 

Findings of Fact, 
Conclusions of Law, and 
Order Imposing Fine 

Pursuant to the brief enforcement hearing (brief adjudicative proceeding) notice sent to  
Zenefits on February 13, 2020, a brief adjudicative proceeding was held on February 28, 2020, in Room 206, Evergreen Plaza Building, 711 Capitol Way, Olympia, Washington, to consider whether the Respondent violated RCW 42.17A.630 by failing to file Annual Lobbyist Employer Reports (L-3 Reports) as a lobbyist employer for the 2018 calendar year. The L-3 report was due to be filed no later than February 28, 2019. 

The hearing was held in accordance with Chapters 34.05 RCW and 42.17A RCW and Chapter 390-37 WAC.  Commission Chair Dave Ammons was the Presiding Officer.  The Commission staff was represented by Tabitha Townsend, Compliance Coordinator.  The Respondent did not participate in the hearing or submit any written materials. 

Having considered the evidence, the Presiding Officer finds as follows: 

FINDINGS OF FACT 

1. The Respondent was a lobbyist employer of a registered lobbyist in the State of Washington during calendar year 2018.   
2. As a lobbyist employer, the Respondent was required to file the L-3 report by the last day of February in 2019 disclosing the annual amount of lobbying expenses in the prior calendar year, such as lobbyist compensation, contributions and independent expenditures made, lobbying expenditures made, and compensation for professional services to entities held by state officials, successful state candidates, or their immediate families. 
3. The Respondent did not file the missing L-3 report for 2018 prior to the date of the hearing.    
4. The Respondent has no prior violations. 

CONCLUSIONS OF LAW 

Based on the above facts, as a matter of law, the Presiding Officer concludes as follows: 

1. This matter was duly and properly convened and all jurisdictional, substantive, and procedural requirements have been satisfied. 

2. The Respondent violated RCW 42.17A.630 by failing to file the L-3 reports by the last day of February, February 28, 2019, as required. 
ORDER 

On the basis of the foregoing Findings of Fact and Conclusions of Law, 

IT IS HEREBY ORDERED that the Respondent is assessed a civil penalty of $250 in accordance with the L-2 penalty schedule set forth in WAC 390-37-143. The $250 penalty is due within 30 days from the date of this Order.  
In the event the Respondent fails to pay the assessed civil penalty within 90 days of the date of the Order, PDC staff is directed to refer the matter to outside collections for the amount owed.  
This is an Initial Order of the Public Disclosure Commission.   

Entered this 9th day of March. 

Public Disclosure Commission 
 

https://www.pdc.wa.gov/browse/cases/64914
64912 02/12/2020 PDC Staff DB3 DB3: Alleged violation of RCW 42.17A.630 for failure to timely disclose Lobbyist Employer’s expenses for calendar year 2018 (Group Enforcement 2020) RCW 42.17A.630 Resolved through Statement of Understanding

On March 13, 2020, the Public Disclosure Commission (PDC) notified DB3 of an alleged violation of RCW 42.17A.630 for failure to timely file the annual Lobbyist Employer’s Expense report (L-3 report) disclosing lobbying activities for calendar year 2018.

DB3 completed a Statement of Understanding (SOU) and paid a $100 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), acknowledging violations of RCW 42.17A.630 for failure to timely file the annual L-3 report no later than February 28, 2019. The L-3 report was received on February 17, 2020, 354 days beyond the statutory deadline. The $100 penalty assessed resolves the allegations.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1)(a). The PDC will not conduct a more formal investigation into these allegations or take further enforcement action in this matter.  

https://www.pdc.wa.gov/browse/cases/64912
64911 02/12/2020 PDC Staff Washington for Good Policing Washington for Good Policing: Alleged violation of RCW 42.17A.630 for failure to timely disclose Lobbyist Employer’s expenses for calendar year 2018 (Group Enforcement 2020) RCW 42.17A.630 Violation Found by Commission

BEFORE THE PUBLIC DISCLOSURE COMMISSION 
OF THE STATE OF WASHINGTON 

In Re: Compliance with RCW 42.17A 

WA FOR GOOD POLICING, 
                            Respondent.  
PDC Case 64911 

Findings of Fact, 
Conclusions of Law, and 
Order Imposing Fine 

Pursuant to the brief enforcement hearing (brief adjudicative proceeding) notice sent to  
WA for Good Policing on February 13, 2020, a brief adjudicative proceeding was held on February 28, 2020, in Room 206, Evergreen Plaza Building, 711 Capitol Way, Olympia, Washington, to consider whether the Respondent violated RCW 42.17A.630 by failing to file Annual Lobbyist Employer Reports (L-3 Reports) as a lobbyist employer for the 2018 calendar year. The L-3 report was due to be filed no later than February 28, 2019. 

The hearing was held in accordance with Chapters 34.05 RCW and 42.17A RCW and Chapter 390-37 WAC.  Commission Chair Dave Ammons was the Presiding Officer.  The Commission staff was represented by Tabitha Townsend, Compliance Coordinator.  The Respondent did not participate in the hearing or submit any written materials. 

Having considered the evidence, the Presiding Officer finds as follows: 

FINDINGS OF FACT 

1. The Respondent was a lobbyist employer of a registered lobbyist in the State of Washington during calendar year 2018.   
2. As a lobbyist employer, the Respondent was required to file the L-3 report by the last day of February in 2019 disclosing the annual amount of lobbying expenses in the prior calendar year, such as lobbyist compensation, contributions and independent expenditures made, lobbying expenditures made, and compensation for professional services to entities held by state officials, successful state candidates, or their immediate families. 
3. The Respondent did not file the missing L-3 report for 2018 prior to the date of the hearing.    
4. The Respondent has no prior violations. 

CONCLUSIONS OF LAW 

Based on the above facts, as a matter of law, the Presiding Officer concludes as follows: 

1. This matter was duly and properly convened and all jurisdictional, substantive, and procedural requirements have been satisfied. 

2. The Respondent violated RCW 42.17A.630 by failing to file the L-3 reports by the last day of February, February 28, 2019, as required. 
ORDER 

On the basis of the foregoing Findings of Fact and Conclusions of Law, 

IT IS HEREBY ORDERED that the Respondent is assessed a civil penalty of $250 in accordance with the L-2 penalty schedule set forth in WAC 390-37-143. The $250 penalty is due within 30 days from the date of this Order.  
In the event the Respondent fails to pay the assessed civil penalty within 90 days of the date of the Order, PDC staff is directed to refer the matter to outside collections for the amount owed.  
This is an Initial Order of the Public Disclosure Commission.   

Entered this 9th day of March. 

Public Disclosure Commission 
 

https://www.pdc.wa.gov/browse/cases/64911
64910 02/12/2020 PDC Staff WA Landlord Assn WA Landlord Assn: Alleged violation of RCW 42.17A.630 for failure to timely disclose Lobbyist Employer’s expenses for calendar year 2018 (Group Enforcement 2020) RCW 42.17A.630 Closed Administratively

On February 13, 2020, the Public Disclosure Commission (PDC) notified you of an alleged failure to timely file Annual Employer (L-3) Reports disclosing Lobbying Expenses for 2018.

PDC staff have reviewed this matter and found the following: 

PDC records indicate that you are no longer have a registered lobbyist for the months that previously triggered monthly L-3 reports covering 2018 pursuant to RCW 42.17A.630. 

PDC staff will now close PDC Case 64910 administratively and remove your name from our hearing list. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1)(a). The PDC will not conduct a more formal investigation into these allegations or take further enforcement action in this matter

https://www.pdc.wa.gov/browse/cases/64910
64908 02/12/2020 PDC Staff CONSTRUCTION MATERIAL RECYCLING ASSN - NW CHAPTER CONSTRUCTION MATERIAL RECYCLING ASSN - NW CHAPTER: Alleged violation of RCW 42.17A.630 for failure to timely disclose Lobbyist Employer’s expenses for calendar year 2018 (Group Enforcement 2020) RCW 42.17A.630 Resolved through Statement of Understanding

On February 13, 2020, the Public Disclosure Commission (PDC) notified Construction Material Recycling Assn - NW Chapter of an alleged violation of RCW 42.17A.630 for failure to timely file the annual Lobbyist Employer’s Expense report (L-3 report) disclosing lobbying activities for calendar year 2018.

The PDC received your annual L-3 report for 2018 on February 19, 2020, as required by RCW 42.17A.630. As a Lobbyist employer, the yearly report is due by the last day of February of each following year, making your report 356 days late

Construction Material Recycling Assn – NW Chapter completed a Statement of Understanding (SOU) and paid a $100 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), acknowledging a violation of RCW 42.17A.630 for failing to timely file the annual Employer’s Lobbying Expenses report (L-3 report), disclosing lobbying activity in calendar year 2018, due no later than February 28, 2019. The $100 penalty assessed resolves the allegation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1)(a). The PDC will not conduct a more formal investigation into this allegation or take further enforcement action in this matter.  

https://www.pdc.wa.gov/browse/cases/64908
64907 02/12/2020 PDC Staff WA Asparagus Commission WA Asparagus Commission: Alleged violation of RCW 42.17A.630 for failure to timely disclose Lobbyist Employer’s expenses for calendar year 2018 (Group Enforcement 2020) RCW 42.17A.630 Resolved through Statement of Understanding

On February 13, 2020, the Public Disclosure Commission (PDC) notified WA Asparagus Commission of an alleged Violation of RCW 42.17A.630 for failure to timely file Lobbyist Employer (L-3) Report disclosing lobbying expenses for 2018.

PDC staff have reviewed this matter and found the following: 

The PDC received the annual L-3 report for 2018 on February 18, 2020, as required by RCW 42.17A.630. As a Lobbyist employer, the yearly report is due by the last day of February of each following year, making this report 357 days late. 

WA Asparagus Commission completed a Statement of Understanding (SOU) and paid a $100 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), acknowledging violations of RCW 42.17A.630 by failing to file or timely file an annual Employer’s Lobbying Expenses report (L-3 report) disclosing lobbying activity in calendar year 2018 that was due February 28, 2019. The $100 penalty assessed resolves the allegations listed in this complaint.

PDC staff will now close PDC Case 64907 and remove their name from our hearing list.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1)(a). The PDC will not conduct a more formal investigation into these allegations or take further enforcement action in this matter.  

https://www.pdc.wa.gov/browse/cases/64907
64906 02/12/2020 PDC Staff US Anesthesia Partners Inc US Anesthesia Partners Inc: Alleged violation of RCW 42.17A.630 for failure to timely disclose Lobbyist Employer’s expenses for calendar year 2018 (Group Enforcement 2020) RCW 42.17A.630 Resolved through Statement of Understanding

On February 13, 2020, the Public Disclosure Commission (PDC) notified US Anesthesia Partners Inc of an alleged Violation of RCW 42.17A.630 for failure to timely file Lobbyist Employer (L-3) Report disclosing lobbying expenses for 2018.

PDC staff have reviewed this matter and found the following: 

The PDC received your annual L-3 report for 2018 on February 20, 2020, as required by RCW 42.17A.630. As a Lobbyist Employer, the yearly report is due by the last day of February of each following year, making your report 359 days late. 

US Anesthesia Partners Inc completed a Statement of Understanding (SOU) and paid a $100 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), acknowledging violations of RCW 42.17A.630 by failing to file or timely file an annual Employer’s Lobbying Expenses report (L-3 report) disclosing lobbying activity in calendar year 2018 that was due February 28, 2019. The $100 penalty assessed resolves the allegations listed in your complaint.

PDC staff will now close PDC Case 64906 and remove your name from our hearing list.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1)(a). The PDC will not conduct a more formal investigation into these allegations or take further enforcement action in this matter.  

https://www.pdc.wa.gov/browse/cases/64906
64904 02/12/2020 PDC Staff Community Education Centers Community Education Centers: Alleged violation of RCW 42.17A.630 for failure to timely disclose Lobbyist Employer’s expenses for calendar year 2018 (Group Enforcement 2020) RCW 42.17A.630 Closed Administratively

On February 13, 2020, the Public Disclosure Commission (PDC) notified Community Education Center/GEO Group of an alleged violation of RCW 42.17A.630, for failure to timely file the annual Lobbyist Employer’s Expense report (L-3 report) disclosing lobbying activities for calendar year 2018.

PDC staff have reviewed this matter and found the following:

PDC records indicate that the contracted Lobbyist, Bill Clarke, is no longer registered to lobby for the reporting period that previously triggered monthly L-3 report due by February 28, 2019 to cover 2018 pursuant to RCW 42.17A.630.

PDC staff will now close PDC Case 64904 administratively and remove their name from our hearing list.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1)(a) and WAC 390-37-060(1)(a). The PDC will not conduct a more formal investigation into these allegations or take further enforcement action in this matter.

https://www.pdc.wa.gov/browse/cases/64904
64903 02/12/2020 PDC Staff Talgo Inc Talgo Inc: Alleged violation of RCW 42.17A.630 for failure to timely disclose Lobbyist Employer’s expenses for calendar year 2018 (Group Enforcement 2020) RCW 42.17A.630 Resolved through Statement of Understanding

On February 13, 2020, the Public Disclosure Commission (PDC) notified Talgo Inc of an alleged Violation of RCW 42.17A.630 for failure to timely file Annual Lobbyist Employer (L-3) Reports disclosing lobbying expenses for 2018.

PDC staff have reviewed this matter and found the following: 

The PDC received Talgo Inc's annual L-3 report for 2018 on February 18, 2020, as required by RCW 42.17A.630. As a Lobbyist Employer, the yearly report is due by the last day of February of each following year, making their report 355 days late. 

Talgo Inc completed a Statement of Understanding (SOU) and paid a $100 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), acknowledging violations of RCW 42.17A.630 by failing to file or timely file an annual Employer’s Lobbying Expenses report (L-3 report) disclosing lobbying activity in calendar year 2018 that was due February 28, 2019. The $100 penalty assessed resolves the allegations listed in your complaint.

PDC staff will now close PDC Case 64903 and remove their name from our hearing list.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1)(a). The PDC will not conduct a more formal investigation into these allegations or take further enforcement action in this matter.

https://www.pdc.wa.gov/browse/cases/64903
64901 02/12/2020 PDC Staff Tabor 100 Tabor 100: Alleged violation of RCW 42.17A.630 for failure to timely disclose Lobbyist Employer’s expenses for calendar year 2018 (Group Enforcement 2020) RCW 42.17A.630 Closed Administratively

On February 13, 2020, the Public Disclosure Commission (PDC) notified you of an alleged 
failure to timely file Lobbyist Employer (L-3) Report disclosing Lobbyist Expenses for 2018. 

PDC staff have reviewed this matter and found the following: 
The PDC received your annual L-3 report for 2018 on February 13, 2020, as required by RCW 
42.17A.630. As a Lobbyist employer, the yearly report is due by the last day of February of each 
following year, making your report 350 days late. 


PDC staff will now close PDC Case 64901 administratively and remove your name from our 
hearing list. 


Based on this information, the PDC finds that no further action is warranted and has dismissed 
this matter in accordance with RCW 42.17A.755(1)(a). The PDC will not conduct a more formal 
investigation into these allegations or take further enforcement action in this matter.

https://www.pdc.wa.gov/browse/cases/64901
64899 02/12/2020 PDC Staff CATTLE PRODUCERS OF WA CATTLE PRODUCERS OF WA: Alleged violation of RCW 42.17A.630 for failure to timely disclose Lobbyist Employer’s expenses for calendar year 2018 (Group Enforcement 2020) RCW 42.17A.630 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.630 for failure to timely file the annual Lobbyist Employer’s Expense Report (L-3 report) for calendar year 2018, due no later than February 28, 2019.
https://www.pdc.wa.gov/browse/cases/64899
64898 02/12/2020 PDC Staff Snap! Mobile LLC Snap! Mobile LLC: Alleged violation of RCW 42.17A.630 for failure to timely disclose Lobbyist Employer’s expenses for calendar year 2018 (Group Enforcement 2020) RCW 42.17A.630 Closed Administratively

On February 13, 2020, the Public Disclosure Commission (PDC) notified Snap! Mobile LLC of an alleged violation of RCW 42.17A.630 for failure to timely file the annual Lobbyist Employer’s Expense report (L-3 report) disclosing lobbying activities for calendar year 2018.

PDC staff have reviewed this matter and found the following:

As a Lobbyist employer, your yearly L-3 report is due by the last day of February of each following year. Our records show your Lobbyist has updated their contract, thereby relieving you of the L-3 reporting requirements for the year of 2018.

PDC staff will now close PDC Case 64898 administratively and remove your name from our hearing list. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1)(a) and WAC 390-37-060(1)(a). The PDC will not conduct a more formal investigation into these allegations or take further enforcement action in this matter.  

https://www.pdc.wa.gov/browse/cases/64898
64895 02/12/2020 PDC Staff BLACK ALLIANCE OF THURSTON CO BLACK ALLIANCE OF THURSTON CO: Alleged violation of RCW 42.17A.630 for failure to timely disclose Lobbyist Employer’s expenses for calendar year 2018 (Group Enforcement 2020) RCW 42.17A.630 Violation Found by Commission

BEFORE THE PUBLIC DISCLOSURE COMMISSION 
OF THE STATE OF WASHINGTON 

In Re: Compliance with RCW 42.17A 

BLACK ALLIANCE OF THURSTON COUNTY, 
                            Respondent.  
PDC Case 64895 

Findings of Fact, 
Conclusions of Law, and 
Order Imposing Fine 

Pursuant to the brief enforcement hearing (brief adjudicative proceeding) notice sent to  
the Black Alliance of Thurston County on February 13, 2020, a brief adjudicative proceeding was held on February 28, 2020, in Room 206, Evergreen Plaza Building, 711 Capitol Way, Olympia, Washington, to consider whether the Respondent violated RCW 42.17A.630 by failing to file Annual Lobbyist Employer Reports (L-3 Reports) as a lobbyist employer for the 2018 calendar year. The L-3 report was due to be filed no later than February 28, 2019. 

The hearing was held in accordance with Chapters 34.05 RCW and 42.17A RCW and Chapter 390-37 WAC.  Commission Chair Dave Ammons was the Presiding Officer.  The Commission staff was represented by Tabitha Townsend, Compliance Coordinator.  The Respondent did not participate in the hearing or submit any written materials. 

Having considered the evidence, the Presiding Officer finds as follows: 

FINDINGS OF FACT 

1. The Respondent was a lobbyist employer of a registered lobbyist in the State of Washington during calendar year 2018.   
2. As a lobbyist employer, the Respondent was required to file the L-3 report by the last day of February in 2019 disclosing the annual amount of lobbying expenses in the prior calendar year, such as lobbyist compensation, contributions and independent expenditures made, lobbying expenditures made, and compensation for professional services to entities held by state officials, successful state candidates, or their immediate families. 
3. The Respondent did not file the missing L-3 report for 2018 prior to the date of the hearing.    
4. The Respondent has no prior violations. 
CONCLUSIONS OF LAW 

Based on the above facts, as a matter of law, the Presiding Officer concludes as follows: 

1. This matter was duly and properly convened and all jurisdictional, substantive, and procedural requirements have been satisfied. 

2. The Respondent violated RCW 42.17A.630 by failing to file the L-3 reports by the last day of February, February 28, 2019, as required. 
ORDER 

On the basis of the foregoing Findings of Fact and Conclusions of Law, 

IT IS HEREBY ORDERED that the Respondent is assessed a civil penalty of $250 in accordance with the L-2 penalty schedule set forth in WAC 390-37-143. The $250 penalty is due within 30 days from the date of this Order.  
In the event the Respondent fails to pay the assessed civil penalty within 90 days of the date of the Order, PDC staff is directed to refer the matter to outside collections for the amount owed.  
This is an Initial Order of the Public Disclosure Commission.   

Entered this 9th day of March. 

Public Disclosure Commission 
 

https://www.pdc.wa.gov/browse/cases/64895
64894 02/12/2020 PDC Staff American Multi-Cinema Inc American Multi-Cinema Inc: Alleged violation of RCW 42.17A.630 for failure to timely disclose Lobbyist Employer’s expenses for calendar year 2018 (Group Enforcement 2020) RCW 42.17A.630 Resolved through Statement of Understanding

On February 13, 2020, the Public Disclosure Commission (PDC) notified American Multi-Cinema of an alleged violation of RCW 42.17A.630 for failure to timely file the annual Lobbyist Employer’s Expense report (L-3 report) disclosing lobbying activities for calendar year 2018.

The PDC received your annual L-3 report for 2018 on February 14, 2020, as required by RCW 42.17A.630. As a Lobbyist employer, the yearly report is due by the last day of February of each following year, making your report 351 days late

American Multi-Cinema completed a Statement of Understanding (SOU) and paid a $100 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), acknowledging a violation of RCW 42.17A.630 for failing to timely file the annual Employer’s Lobbying Expenses report (L-3 report), disclosing lobbying activity in calendar year 2018, due no later than February 28, 2019. The $100 penalty assessed resolves the allegation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1)(a). The PDC will not conduct a more formal investigation into this allegation or take further enforcement action in this matter.  

https://www.pdc.wa.gov/browse/cases/64894
64888 02/12/2020 PDC Staff AMERICAN INSURANCE ASSN AMERICAN INSURANCE ASSN: Alleged violation of RCW 42.17A.630 for failure to timely disclose Lobbyist Employer’s expenses for calendar year 2018 (Group Enforcement 2020) RCW 42.17A.630 Closed Administratively

On February 13, 2020, the Public Disclosure Commission (PDC) notified American Insurance Assn of an alleged violation of RCW 42.17A.630 for failure to timely file the annual Lobbyist Employer’s Expense report (L-3 report) disclosing lobbying activities for calendar year 2018.

PDC staff have reviewed this matter and found the following:

The PDC received your annual L-3 report for 2018 on March 11, 2020, as required by RCW 42.17A.630. As a Lobbyist employer, the yearly report is due by the last day of February of each following year, making your report 377 days late. 

PDC staff will now close PDC Case 64888 administratively and remove your name from their hearing list. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1)(a) and WAC 390-37-060(1)(a). The PDC will not conduct a more formal investigation into these allegations or take further enforcement action in this matter.  

https://www.pdc.wa.gov/browse/cases/64888
64882 02/12/2020 PDC Staff Alan Stromberger Alan Stromberger: Alleged violation of RCW 42.17A.630 for failure to timely disclose Lobbyist Employer’s expenses for calendar year 2018 (Group Enforcement 2020) RCW 42.17A.630 Resolved through Statement of Understanding

On February 13, 2020, the Public Disclosure Commission (PDC) notified Alan Stromberger of an alleged violation of RCW 42.17A.630 for failure to timely file the annual Lobbyist Employer’s Expense report (L-3 report) disclosing lobbying activities for calendar year 2018.

The PDC received your annual L-3 report for 2018 on February 19, 2020, as required by RCW 42.17A.630. As a Lobbyist employer, the yearly report is due by the last day of February of each following year, making your report 356 days late

Alan Stromberger completed a Statement of Understanding (SOU) and paid a $100 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), acknowledging a violation of RCW 42.17A.630 for failing to timely file the annual Employer’s Lobbying Expenses report (L-3 report), disclosing lobbying activity in calendar year 2018, due no later than February 28, 2019. The $100 penalty assessed resolves the allegation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1)(a). The PDC will not conduct a more formal investigation into this allegation or take further enforcement action in this matter.  

https://www.pdc.wa.gov/browse/cases/64882
64875 02/12/2020 PDC Staff 7-ELEVEN INC 7-ELEVEN INC: Alleged violation of RCW 42.17A.630 for failure to timely disclose Lobbyist Employer’s expenses for calendar year 2018 (Group Enforcement 2020) RCW 42.17A.630 Violation Found by Commission

BEFORE THE PUBLIC DISCLOSURE COMMISSION 
OF THE STATE OF WASHINGTON 

In Re: Compliance with RCW 42.17A 

7-ELEVEN, INC., 
                            Respondent.  
PDC Case 64875 

Findings of Fact, 
Conclusions of Law, and 
Order Imposing Fine 

Pursuant to the brief enforcement hearing (brief adjudicative proceeding) notice sent to  
7-Eleven, Inc. on February 13, 2020, a brief adjudicative proceeding was held on February 28, 2020, in Room 206, Evergreen Plaza Building, 711 Capitol Way, Olympia, Washington, to consider whether the Respondent violated RCW 42.17A.630 by failing to file Annual Lobbyist Employer Reports (L-3 Reports) as a lobbyist employer for the 2018 calendar year. The L-3 report was due to be filed no later than February 28, 2019. 

The hearing was held in accordance with Chapters 34.05 RCW and 42.17A RCW and Chapter 390-37 WAC.  Commission Chair Dave Ammons was the Presiding Officer.  The Commission staff was represented by Tabitha Townsend, Compliance Coordinator.  The Respondent did not participate in the hearing or submit any written materials. 

Having considered the evidence, the Presiding Officer finds as follows: 

FINDINGS OF FACT 

1. The Respondent was a lobbyist employer of a registered lobbyist in the State of Washington during calendar year 2018.   
2. As a lobbyist employer, the Respondent was required to file the L-3 report by the last day of February in 2019 disclosing the annual amount of lobbying expenses in the prior calendar year, such as lobbyist compensation, contributions and independent expenditures made, lobbying expenditures made, and compensation for professional services to entities held by state officials, successful state candidates, or their immediate families. 
3. The Respondent filed the missing L-3 report for 2018 prior to the date of the hearing.    
4. The Respondent has no prior violations. 

CONCLUSIONS OF LAW 

Based on the above facts, as a matter of law, the Presiding Officer concludes as follows: 

1. This matter was duly and properly convened and all jurisdictional, substantive, and procedural requirements have been satisfied. 

2. The Respondent violated RCW 42.17A.630 by failing to file the L-3 reports by the last day of February, February 28, 2019, as required. 
ORDER 

On the basis of the foregoing Findings of Fact and Conclusions of Law, 

IT IS HEREBY ORDERED that the Respondent is assessed a civil penalty of $150 in accordance with the L-2 penalty schedule set forth in WAC 390-37-143. The $150 penalty is due within 30 days from the date of this Order.  
In the event the Respondent fails to pay the assessed civil penalty within 90 days of the date of the Order, PDC staff is directed to refer the matter to outside collections for the amount owed.  
This is an Initial Order of the Public Disclosure Commission.   

Entered this 9th day of March. 

Public Disclosure Commission 
 

https://www.pdc.wa.gov/browse/cases/64875
64873 02/12/2020 PDC Staff San Juan Sun Grown LLC San Juan Sun Grown LLC: Alleged violation of RCW 42.17A.630 for failure to timely disclose Lobbyist Employer’s expenses for calendar year 2018 (Group Enforcement 2020) RCW 42.17A.630 Violation Found by Commission

BEFORE THE PUBLIC DISCLOSURE COMMISSION 
OF THE STATE OF WASHINGTON 

In Re: Compliance with RCW 42.17A 

SAN JUAN SUN GROWN, LLC, 
                            Respondent.  
PDC Case 64873 

Findings of Fact, 
Conclusions of Law, and 
Order Imposing Fine 

Pursuant to the brief enforcement hearing (brief adjudicative proceeding) notice sent to  
San Juan Sun Grown, LLC on February 13, 2020, a brief adjudicative proceeding was held on February 28, 2020, in Room 206, Evergreen Plaza Building, 711 Capitol Way, Olympia, Washington, to consider whether the Respondent violated RCW 42.17A.630 by failing to file Annual Lobbyist Employer Reports (L-3 Reports) as a lobbyist employer for the 2018 calendar year. The L-3 report was due to be filed no later than February 28, 2019. 

The hearing was held in accordance with Chapters 34.05 RCW and 42.17A RCW and Chapter 390-37 WAC.  Commission Chair Dave Ammons was the Presiding Officer.  The Commission staff was represented by Tabitha Townsend, Compliance Coordinator.  The Respondent did not participate in the hearing or submit any written materials. 

Having considered the evidence, the Presiding Officer finds as follows: 

FINDINGS OF FACT 

1. The Respondent was a lobbyist employer of a registered lobbyist in the State of Washington during calendar year 2018.   
2. As a lobbyist employer, the Respondent was required to file the L-3 report by the last day of February in 2019 disclosing the annual amount of lobbying expenses in the prior calendar year, such as lobbyist compensation, contributions and independent expenditures made, lobbying expenditures made, and compensation for professional services to entities held by state officials, successful state candidates, or their immediate families. 
3. The Respondent filed the missing L-3 report for 2018 prior to the date of the hearing.    
4. The Respondent has no prior violations. 

CONCLUSIONS OF LAW 

Based on the above facts, as a matter of law, the Presiding Officer concludes as follows: 

1. This matter was duly and properly convened and all jurisdictional, substantive, and procedural requirements have been satisfied. 

2. The Respondent violated RCW 42.17A.630 by failing to file the L-3 reports by the last day of February, February 28, 2019, as required. 
ORDER 

On the basis of the foregoing Findings of Fact and Conclusions of Law, 

IT IS HEREBY ORDERED that the Respondent is assessed a civil penalty of $150 in accordance with the L-2 penalty schedule set forth in WAC 390-37-143. The $150 penalty is due within 30 days from the date of this Order.  
In the event the Respondent fails to pay the assessed civil penalty within 90 days of the date of the Order, PDC staff is directed to refer the matter to outside collections for the amount owed.  
This is an Initial Order of the Public Disclosure Commission.   

Entered this 9th day of March. 

Public Disclosure Commission 
 

https://www.pdc.wa.gov/browse/cases/64873
64869 02/12/2020 PDC Staff Recreation Vehicle Industry Association Recreation Vehicle Industry Association: Alleged violation of RCW 42.17A.630 for failure to timely disclose Lobbyist Employer’s expenses for calendar year 2018 (Group Enforcement 2020) RCW 42.17A.630 Closed Administratively

On February 13, 2020, the Public Disclosure Commission (PDC) notified the Recreational Vehicle Industry Association of an alleged violation of RCW 42.17A.630 for failure to timely file an annual Lobbyist Employer’s Expense report (L-3 report) disclosing lobbying activities for 2018.

PDC staff will now close PDC Case 64869 administratively and remove your name from our hearing list. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1)(a) and WAC 390-37-060(1)(a). The PDC will not conduct a more formal investigation into these allegations or take further enforcement action in this matter.  

https://www.pdc.wa.gov/browse/cases/64869
64867 02/12/2020 PDC Staff POSaBit, Inc POSaBit, Inc: Alleged violation of RCW 42.17A.630 for failure to timely disclose Lobbyist Employer’s expenses for calendar year 2018 (Group Enforcement 2020) RCW 42.17A.630 Violation Found by Commission

BEFORE THE PUBLIC DISCLOSURE COMMISSION 
OF THE STATE OF WASHINGTON 

In Re: Compliance with RCW 42.17A 

POSABIT, Inc., 
                            Respondent.  
PDC Case 64867 

Findings of Fact, 
Conclusions of Law, and 
Order Imposing Fine 

Pursuant to the brief enforcement hearing (brief adjudicative proceeding) notice sent to  
POSaBit, Inc. on February 13, 2020, a brief adjudicative proceeding was held on February 28, 2020, in Room 206, Evergreen Plaza Building, 711 Capitol Way, Olympia, Washington, to consider whether the Respondent violated RCW 42.17A.630 by failing to file Annual Lobbyist Employer Reports (L-3 Reports) as a lobbyist employer for the 2018 calendar year. The L-3 report was due to be filed no later than February 28, 2019. 

The hearing was held in accordance with Chapters 34.05 RCW and 42.17A RCW and Chapter 390-37 WAC.  Commission Chair Dave Ammons was the Presiding Officer.  The Commission staff was represented by Tabitha Townsend, Compliance Coordinator.  The Respondent did not participate in the hearing or submit any written materials. 

Having considered the evidence, the Presiding Officer finds as follows: 

FINDINGS OF FACT 

1. The Respondent was a lobbyist employer of a registered lobbyist in the State of Washington during calendar year 2018.   
2. As a lobbyist employer, the Respondent was required to file the L-3 report by the last day of February in 2019 disclosing the annual amount of lobbying expenses in the prior calendar year, such as lobbyist compensation, contributions and independent expenditures made, lobbying expenditures made, and compensation for professional services to entities held by state officials, successful state candidates, or their immediate families. 
3. The Respondent did not file the missing L-3 report for 2018 prior to the date of the hearing.    
4. The Respondent has no prior violations. 

CONCLUSIONS OF LAW 

Based on the above facts, as a matter of law, the Presiding Officer concludes as follows: 

1. This matter was duly and properly convened and all jurisdictional, substantive, and procedural requirements have been satisfied. 

2. The Respondent violated RCW 42.17A.630 by failing to file the L-3 reports by the last day of February, February 28, 2019, as required. 
ORDER 

On the basis of the foregoing Findings of Fact and Conclusions of Law, 

IT IS HEREBY ORDERED that the Respondent is assessed a civil penalty of $250 in accordance with the L-2 penalty schedule set forth in WAC 390-37-143. The $250 penalty is due within 30 days from the date of this Order.  
In the event the Respondent fails to pay the assessed civil penalty within 90 days of the date of the Order, PDC staff is directed to refer the matter to outside collections for the amount owed.  
This is an Initial Order of the Public Disclosure Commission.   

Entered this 9th day of March. 

Public Disclosure Commission 
 

https://www.pdc.wa.gov/browse/cases/64867
64863 02/12/2020 PDC Staff PAYQWICK PAYQWICK: Alleged violation of RCW 42.17A.630 for failure to timely disclose Lobbyist Employer’s expenses for calendar year 2018 (Group Enforcement 2020) RCW 42.17A.630 Violation Found by Commission

BEFORE THE PUBLIC DISCLOSURE COMMISSION 
OF THE STATE OF WASHINGTON 

In Re: Compliance with RCW 42.17A 

PAYQWICK, 
                            Respondent.  
PDC Case 64863 

Findings of Fact, 
Conclusions of Law, and 
Order Imposing Fine 

Pursuant to the brief enforcement hearing (brief adjudicative proceeding) notice sent to  
PayQwick on February 13, 2020, a brief adjudicative proceeding was held on February 28, 2020, in Room 206, Evergreen Plaza Building, 711 Capitol Way, Olympia, Washington, to consider whether the Respondent violated RCW 42.17A.630 by failing to file Annual Lobbyist Employer Reports (L-3 Reports) as a lobbyist employer for the 2018 calendar year. The L-3 report was due to be filed no later than February 28, 2019. 

The hearing was held in accordance with Chapters 34.05 RCW and 42.17A RCW and Chapter 390-37 WAC.  Commission Chair Dave Ammons was the Presiding Officer.  The Commission staff was represented by Tabitha Townsend, Compliance Coordinator.  The Respondent did not participate in the hearing or submit any written materials. 

Having considered the evidence, the Presiding Officer finds as follows: 

FINDINGS OF FACT 

1. The Respondent was a lobbyist employer of a registered lobbyist in the State of Washington during calendar year 2018.   
2. As a lobbyist employer, the Respondent was required to file the L-3 report by the last day of February in 2019 disclosing the annual amount of lobbying expenses in the prior calendar year, such as lobbyist compensation, contributions and independent expenditures made, lobbying expenditures made, and compensation for professional services to entities held by state officials, successful state candidates, or their immediate families. 
3. The Respondent did not file the missing L-3 report for 2018 prior to the date of the hearing.    
4. The Respondent has no prior violations. 

CONCLUSIONS OF LAW 

Based on the above facts, as a matter of law, the Presiding Officer concludes as follows: 

1. This matter was duly and properly convened and all jurisdictional, substantive, and procedural requirements have been satisfied. 

2. The Respondent violated RCW 42.17A.630 by failing to file the L-3 reports by the last day of February, February 28, 2019, as required. 
ORDER 

On the basis of the foregoing Findings of Fact and Conclusions of Law, 

IT IS HEREBY ORDERED that the Respondent is assessed a civil penalty of $250 in accordance with the L-2 penalty schedule set forth in WAC 390-37-143. The $250 penalty is due within 30 days from the date of this Order.  
In the event the Respondent fails to pay the assessed civil penalty within 90 days of the date of the Order, PDC staff is directed to refer the matter to outside collections for the amount owed.  
This is an Initial Order of the Public Disclosure Commission.   

Entered this 9th day of March. 

Public Disclosure Commission 
 

https://www.pdc.wa.gov/browse/cases/64863
64859 02/12/2020 PDC Staff NINTENDO OF AMERICA NINTENDO OF AMERICA: Alleged violation of RCW 42.17A.630 for failure to timely disclose Lobbyist Employer’s expenses for calendar year 2018 (Group Enforcement 2020) RCW 42.17A.630 Resolved through Statement of Understanding

On February 13, 2020, the Public Disclosure Commission (PDC) notified Nintendo of America of an alleged violation of RCW 42.17A.630 for failure to timely file the annual Lobbyist Employer’s Expense report (L-3 report) disclosing lobbying activities for calendar year 2018.

Nintendo of America completed a Statement of Understanding (SOU) and paid a $100 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), acknowledging violations of RCW 42.17A.630 for failure to timely file the annual L-3 report, due no later than February 28, 2019. The L-3 report was received on February 19, 2020, 356 days beyond the statutory deadline. The $100 penalty assessed resolves the allegations listed in your complaint.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1)(a). The PDC will not conduct a more formal investigation into these allegations or take further enforcement action in this matter.  

https://www.pdc.wa.gov/browse/cases/64859
64858 02/12/2020 PDC Staff NATURAL EXTRACTIONS INC NATURAL EXTRACTIONS INC: Alleged violation of RCW 42.17A.630 for failure to timely disclose Lobbyist Employer’s expenses for calendar year 2018 (Group Enforcement 2020) RCW 42.17A.630 Resolved through Statement of Understanding

On February 13,2020, the Public Disclosure Commission (PDC) notified Natural Extractions, Inc. of an alleged violation of RCW 42.17A.630 for failure to timely file an annual Lobbying Employer’s Expense report (L-3 report) disclosing lobbying activities for calendar year 2018.

Natural Extractions, Inc. completed a Statement of Understanding (SOU) and paid a $100 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), acknowledging a violation of RCW 42.17A.630 for failure to timely file the annual L-3 report disclosing lobbying activity in calendar year 2018, due no later than February 28, 2019. The L-3 report was received February 20, 2020, 357 days beyond the statutory deadline. The $100 penalty assessed resolves the allegations.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1)(a). The PDC will not conduct a more formal investigation into these allegations or take further enforcement action in this matter.  

https://www.pdc.wa.gov/browse/cases/64858
64857 02/12/2020 PDC Staff NATL UTILITY CONTRACTORS ASSN WA CHAPTER NATL UTILITY CONTRACTORS ASSN WA CHAPTER: Alleged violation of RCW 42.17A.630 for failure to timely disclose Lobbyist Employer’s expenses for calendar year 2018 (Group Enforcement 2020) RCW 42.17A.630 Dismissed by Commission

This matter was heard remotely by the Washington State Public Disclosure Commission (Commission) on May 28, 2020, by telephonic and online streaming access. The National Utility Contractors Association, Washington Chapter (Respondent, NUCA), requested reconsideration of the Presiding Officer's Order issued on February 28, 2020, following a Brief Enforcement Hearing (Brief Adjudicative Proceeding in this matter. The hearing was held in accordance with Chapters 34.05 and 42.17A RCW, and Chapter 390-37 WAC.

Commissioners present both telephonically and online were David Ammons, Commission Chair (presiding); Russell Lehman, Commission Vice-Chair; and Commissioners William Downing, Fred Jarrett, and Nancy Isserlis. Also present both telephonically and online were Assistant Attorney General John S. Meader representing the Commission, Assistant Attorney General Chad Standifer representing PDC Staff, and Fox Blackhorn, PDC Compliance Coordinator 2, and Liz Truong on behalf of Respondent. The proceeding was open to the public as limited by Governor's Proclamation 20-28 et seq. and recorded.

I. Findings of Fact

The matter involved Respondent's request that the Commission reconsider a Final Order issued on March 9, 2020, resulting from an Initial Hearing on February 28, 2020, regarding NUCA, a lobbyist employer of a registered lobbyist during the 2018 calendar year. The Presiding Officer at the Brief Adjudicative Proceeding found NUCA in violation of RCW 42.17A.630 for failure to timely file a report of lobbying expenses (L-3 report) by February 28, 2019, as required, and imposed a civil penalty of $250. The basis of Respondent's Request for Reconsideration was that the PDC had seven-year-old contact information, the Respondent had a lack of knowledge of non-compliance, and when informed Respondent complied immediately.

  1. PDC contact information for the NUCA was over seven-years-old and Respondent did not receive notice of the Initial Hearing. Respondent has updated its contact information and immediately complied with the 2018 reporting requirements.

II. Conclusions of Law

  1. The Commission has jurisdiction over this proceeding pursuant to Chapter 42.17A RCW, the State campaign finance and disclosure law; Chapter 34.05 RCW, the Administrative procedure Act; and Title 390 WAC.

III. Order

As a result of Respondent's outdated contact information and its immediate compliance with reporting requirements when notified of the missing report, the Request for Reconsideration is GRANTED. This Amended Order will be the Final Order. The Findings of Fact, Conclusions of Law, and the civil penalty assessed at the February 28, 2020, hearing are VACATED.

SO ORDERED this 8th day of May, 2020.

 

https://www.pdc.wa.gov/browse/cases/64857
64852 02/12/2020 PDC Staff Liberty Health Partners Liberty Health Partners: Alleged violation of RCW 42.17A.630 for failure to timely disclose Lobbyist Employer’s expenses for calendar year 2018 (Group Enforcement 2020) RCW 42.17A.630 Closed Administratively

On February 13, 2020, the Public Disclosure Commission (PDC) notified Liberty Health Partners of an alleged violation of RCW 42.17A.630 for failure to timely file a Lobbyist Employer’s Expense Report disclosing lobbying activities for calendar year 2018, due no later than February 28, 2019.

The PDC received your annual L-3 report for 2018 on February 13, 2020, as required by RCW 42.17A.630. As a Lobbyist employer, the yearly report is due by the last day of February of each following year, making their report 350 days late. 

PDC staff will now close PDC Case 64852 administratively and remove Liberty Health Partners from our hearing list. On February 21, 2020, the PDC received a signed Statement of Understanding and check #1364 for $100. As this case will be closed administratively, the PDC returned check #1364 via certified mail on February 24, 2020.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1)(a) and WAC 390-37-060(1)(a). The PDC will not conduct a more formal investigation into these allegations or take further enforcement action in this matter.  

https://www.pdc.wa.gov/browse/cases/64852
64847 02/12/2020 PDC Staff Innocence Project Northwest Innocence Project Northwest: Alleged violation of RCW 42.17A.630 for failure to timely disclose Lobbyist Employer’s expenses for calendar year 2018 (Group Enforcement 2020) RCW 42.17A.630 Resolved through Statement of Understanding

On February 13, 2020, the Public Disclosure Commission (PDC) notified Innocence Project Northwest of an alleged violation of RCW 42.17A.630 for failure to timely file the annual Lobbyist Employer’s Expense report (L-3 report) disclosing lobbying activities for calendar year 2018.

Innocence Project Northwest completed a Statement of Understanding (SOU) and paid a $100 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), acknowledging violations of RCW 42.17A.630 for failure to timely file the annual L-3 report no later than February 28, 2019. The L-3 report was received February 18, 2020, 355 days beyond the statutory deadline. The $100 penalty assessed resolves the allegations.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1)(a). The PDC will not conduct a more formal investigation into these allegations or take further enforcement action in this matter.  

https://www.pdc.wa.gov/browse/cases/64847
64845 02/12/2020 PDC Staff Handy Technologies Inc Handy Technologies Inc: Alleged violation of RCW 42.17A.630 for failure to timely disclose Lobbyist Employer’s expenses for calendar year 2018 (Group Enforcement 2020) RCW 42.17A.630 Closed Administratively

On February 13, 2020, the Public Disclosure Commission (PDC) notified Handy Technologies, Inc. of an alleged violation of RCW 42.17A.630 for failure to timely file an annual Lobbyist Employer’s Expense report (L-3 report) disclosing lobbying activities for calendar year 2018.

PDC records indicate that Handy Technologies, Inc. has updated their lobbyist contract to indicate that they did not lobby in Washington State during calendar year 2018, and were not required to file an L-3 report covering activity in that year. 

On February 24, 2020, PDC staff received a signed Statement of Understanding acknowledging violations of RCW 42.17A.630 for failure to timely file the L-3 report covering calendar year 2018, along with check #2060 for a $100 civil penalty, and a late filed L-3 report covering calendar year 2017.

While the L-3 report covering calendar year 2017 was due no later than February 28, 2017, and was received on February 18, 2020, 1085 days beyond the statutory deadline of RCW 42.17A.630, the hearing notice sent on February 13, 2020, concerned their reporting obligations for calendar year 2018.

PDC staff will now close PDC Case 64845 administratively, return check #2060, and remove Handy Technologies, Inc. from our hearing list. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1)(a) and WAC 390-37-060(1)(a). The PDC will not conduct a more formal investigation into these allegations or take further enforcement action in this matter.  

https://www.pdc.wa.gov/browse/cases/64845
64843 02/12/2020 PDC Staff FareStart FareStart: Alleged violation of RCW 42.17A.630 for failure to timely disclose Lobbyist Employer’s expenses for calendar year 2018 (Group Enforcement 2020) RCW 42.17A.630 Resolved through Statement of Understanding

On February 13, 2020, the Public Disclosure Commission (PDC) notified FareStart of an alleged violation of RCW 42.17A.630 for failure to timely file the annual Lobbyist Employer’s Expense report (L-3 report) disclosing lobbying activities for calendar year 2018.

FareStart completed a Statement of Understanding (SOU) and paid a $100 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), acknowledging violations of RCW 42.17A.630 for failure to timely file the annual L-3 report, due no later than February 28, 2019. The L-3 report was received February 14, 2020, 351 days beyond the statutory deadline. The $100 penalty assessed resolves the allegations listed in your complaint.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1)(a) and WAC 390-37-060(1)(a). The PDC will not conduct a more formal investigation into these allegations or take further enforcement action in this matter.  

https://www.pdc.wa.gov/browse/cases/64843
64841 02/12/2020 PDC Staff FAMILY WINERIES OF WA ST FAMILY WINERIES OF WA ST: Alleged violation of RCW 42.17A.630 for failure to timely disclose Lobbyist Employer’s expenses for calendar year 2018 (Group Enforcement 2020) RCW 42.17A.630 Violation Found by Commission

BEFORE THE PUBLIC DISCLOSURE COMMISSION 
OF THE STATE OF WASHINGTON 

In Re: Compliance with RCW 42.17A 

FAMILY WINERIES OF WA STATE, 
                            Respondent.  
PDC Case 64841 

Findings of Fact, 
Conclusions of Law, and 
Order Imposing Fine 

Pursuant to the brief enforcement hearing (brief adjudicative proceeding) notice sent to  
Family Wineries of WA State on February 13, 2020, a brief adjudicative proceeding was held on February 28, 2020, in Room 206, Evergreen Plaza Building, 711 Capitol Way, Olympia, Washington, to consider whether the Respondent violated RCW 42.17A.630 by failing to file Annual Lobbyist Employer Reports (L-3 Reports) as a lobbyist employer for the 2018 calendar year. The L-3 report was due to be filed no later than February 28, 2019. 

The hearing was held in accordance with Chapters 34.05 RCW and 42.17A RCW and Chapter 390-37 WAC.  Commission Chair Dave Ammons was the Presiding Officer.  The Commission staff was represented by Tabitha Townsend, Compliance Coordinator.  The Respondent did not participate in the hearing or submit any written materials. 

Having considered the evidence, the Presiding Officer finds as follows: 

FINDINGS OF FACT 

1. The Respondent was a lobbyist employer of a registered lobbyist in the State of Washington during calendar year 2018.   
2. As a lobbyist employer, the Respondent was required to file the L-3 report by the last day of February in 2019 disclosing the annual amount of lobbying expenses in the prior calendar year, such as lobbyist compensation, contributions and independent expenditures made, lobbying expenditures made, and compensation for professional services to entities held by state officials, successful state candidates, or their immediate families. 
3. The Respondent filed the missing L-3 report for 2018 prior to the date of the hearing.    
4. The Respondent has no prior violations. 

CONCLUSIONS OF LAW 

Based on the above facts, as a matter of law, the Presiding Officer concludes as follows: 

1. This matter was duly and properly convened and all jurisdictional, substantive, and procedural requirements have been satisfied. 

2. The Respondent violated RCW 42.17A.630 by failing to file the L-3 reports by the last day of February, February 28, 2019, as required. 
ORDER 

On the basis of the foregoing Findings of Fact and Conclusions of Law, 

IT IS HEREBY ORDERED that the Respondent is assessed a civil penalty of $150 in accordance with the L-2 penalty schedule set forth in WAC 390-37-143. The $150 penalty is due within 30 days from the date of this Order.  
In the event the Respondent fails to pay the assessed civil penalty within 90 days of the date of the Order, PDC staff is directed to refer the matter to outside collections for the amount owed.  
This is an Initial Order of the Public Disclosure Commission.   

Entered this 9th day of March. 

Public Disclosure Commission 
 

https://www.pdc.wa.gov/browse/cases/64841
64840 02/12/2020 PDC Staff EVgo Services LLC EVgo Services LLC: Alleged violation of RCW 42.17A.630 for failure to timely disclose Lobbyist Employer’s expenses for calendar year 2018 (Group Enforcement 2020) RCW 42.17A.630 Resolved through Statement of Understanding

On February 13, 2020, the Public Disclosure Commission (PDC) notified EVgo Services LLC of an alleged violation of RCW 42.17A.630 for failure to timely file an annual Lobbyist Employer’s Expense report (L-3 report) disclosing lobbying activities for calendar year 2018.

EVgo Services LLC completed a Statement of Understanding (SOU) and paid a $100 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), acknowledging violations of RCW 42.17A.630 for failure to timely file the annual L-3 report for calendar year 2018, due no later than February 28, 2019. The L-3 report was received on February 24, 2020, 361 days after the statutory deadline. The $100 penalty assessed resolves the allegations.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1)(a). The PDC will not conduct a more formal investigation into these allegations or take further enforcement action in this matter.  

https://www.pdc.wa.gov/browse/cases/64840
64834 02/12/2020 PDC Staff Evergreen State Taxi Association Evergreen State Taxi Association: Alleged violation of RCW 42.17A.630 for failure to timely disclose Lobbyist Employer’s expenses for calendar year 2018 (Group Enforcement 2020) RCW 42.17A.630 Closed Administratively

The Public Disclosure Commission (PDC) issued the Evergreen State Taxi Association a hearing notice on 2/13/20, for a Brief Adjudicative Proceeding (Brief Enforcement Hearing) to be held on February 28, 2020, concerning theirfailure to file the required annual Lobbying Employer's Expense Report (L-3 report), as required by RCW 42.17A.630. Their L-3 report was due no later than 2/28/19, but was received 2/13/20, 350 days late.

​As we have received their L-3 report however, the PDC closed this case administratively without pursuing further enforcement or fines.

https://www.pdc.wa.gov/browse/cases/64834
64331 02/06/2020 MADISON EVANS LOREN CULP Culp, Loren: Alleged Violation of RCW 42.17A.445 for personal use of campaign contributions RCW 42.17A.445 Case Closed with Written Warning

A complaint was filed against Loren Culp, the incumbent Police Chief of Republic, and a candidate seeking election to the office of Governor of Washington State in 2020, alleging violations of RCW 42.17A.445 by making expenditures from his 2020 Gubernatorial Campaign that constituted a personal use of contributions.

On April 29, 2020,  PDC staff held an Initial Hearing (Case status review) pursuant to RCW 42.17A.755, and WACs 390-37-060 and 390-37-071, and opened a formal investigation concerning this matter.  PDC staff's investigation found that the Campaign purchased 732 copies of American Cop and used the books as a fundraiser. That resulted in the Campaign receiving a total of $10,230 in net contributions from the proceeds of the sale.  

The sale of the book American Cop was directly related to Loren Culp’s campaign for Governor of Washington State, and was part of the campaign fundraising strategy.  While the sales price of the books sold to the Campaign were based on the fair market value, due to his ownership interest in American Cop, Mr. Culp nonetheless personally benefitted from the sale of the books purchased directly from the publisher at the wholesale price. 

Staff found that a potential conflict of interest exists where, as here, a candidate or his/her business provides goods or services to his/her campaign, and may profit from that sale, in this case of the book American Cop

However, there are a number of mitigating factors in this specific instance that renders the allegation as a minor violation of RCW 42.17A, including that: (1) Mr. Culp is a first-time candidate for public office; (2) a demand for the book American Cop existed prior to Mr. Culp declaring his candidacy for Governor; and (3) the Culp for Governor Campaign disclosed receiving $278,991 in total contributions received through April 30, 2020, so the $10,230 paid by the Campaign for the books, and the $10,230 netted for the Campaign, each represents a small percentage of total Campaign funds. 

To resolve this violation, pursuant to WAC 390-37-060(1)(d), Mr. Culp will receive a formal written warning concerning the payments made to him through his business, American Cop, based on the sale of books to the Campaign using Campaign funds. Mr. Culp will be informed that the Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

The PDC dismissed the complaint in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/64331
64102 02/03/2020 Sean Boutz James Alexander Alexander, James: Alleged Violation of RCW 42.17A.320 for failure to disclose sponsor identification on political advertising; RCW 42.17A.255 and .260 for failure to report expenditure for political advertisement (EY 19, Feb20) RCW 42.17A.260, RCW 42.17A.255, RCW 42.17A.320 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint Sean Boutz filed on January 30, 2020. The complaint alleged that James Alexander (Respondent) may have violated RCW 42.17A.320 for failure to disclose sponsor identification on political advertisement; RCW 42.17A.255 & .260 for failure to report independent expenditure for political advertisement.

PDC staff reviewed the allegations; the applicable statutes, rules, reporting requirements and response from the Respondent to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation that warrants further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/64102
63549 01/23/2020 Andrew Saturn People for Thurston County Jobs People for Thurston County Jobs (3): Alleged Violation of RCW 42.17A.235 and .240 for failure to timely and accurately disclose expenditures on C-4 reports (EY19, Jan20) RCW 42.17A.240, RCW 42.17A.235 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint Andrew Saturn filed on January 17, 2020. The complaint alleged that People for Thurston County Jobs (Respondent) a political committee may have violated RCW 42.17A.235 and .240 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; the applicable PDC reports filed by the Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance there is no evidence that supports the finding of a violation that warrants further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/63549
63412 01/21/2020 Stefan Sharkansky Bellevue School District Officials Bellevue School District Officials: Alleged Violation of RCW 42.17A.555 for misuse of public facilities (EY20, Jan20) RCW 42.17A.555 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint Stefan Sharkansky filed on January 17, 2020. The complaint alleged that Bellevue School District Officials (Respondent), a Public Agency in the State of Washington may have violated RCW 42.17A.555 for misuse of public facilities by producing and distributing political advertising that supports or opposes a candidate or ballot proposition, levy or bond. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the responses provided by the Respondent to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance there is no evidence supporting a finding of a violation that warrants further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/63412
63408 01/21/2020 Joe Kunzler Puget Sound Regional Council Staff and Board Members Puget Sound Regional Council Staff and Board Members: Alleged Violation of RCW 42.17A.555 for misuse of public facilities (EY 20, Jan20) RCW 42.17A.555 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint Joe Kunzler filed on January 13, 2020. The complaint alleged that Puget Sound Regional Council (PSRC) Staff and Board Members (Respondent), a regional council for transportation, growth management and economic development in the Puget Sound Region, may have violated RCW 42.17A.555 for misuse of public facilities, by allowing an individual to promote or oppose a campaign or ballot proposition during open public comments during a public meeting.

PDC staff reviewed the allegations; the applicable statutes and rules, as well as the response provided by the Respondent to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance there is no evidence that supports the finding of a violation that warrants further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/63408
63091 01/15/2020 Jason chu North Thurston Public School District Officials North Thurston Public School District Officials: Alleged Violation of RCW 42.17A.555 for misuse of public facilities (EY20, Jan20) RCW 42.17A.555 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint Jason Chu filed on January 12, 2020. The complaint alleged that North Thurston Public School District Officials (Respondent), a Public Agency in the State of Washington may have violated RCW 42.17A.555 for misuse of public facilities by producing and distributing political advertising that supports or opposes a candidate or ballot proposition, levy or bond. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the responses provided by the Respondent to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance there is no evidence supporting a finding of a violation that warrants further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/63091
62893 01/13/2020 PDC Staff Michael Lindsay Lindsay, Michael: Alleged violation of RCW 42.17A.603 for failure to attest to completing mandatory training by December 31, 2019. (Group Enforcement 2020) RCW 42.17A.603 Closed Administratively

The Public Disclosure Commission’s (PDC) records indicate that Michael Lindsay is no longer registered to lobby in 2020. All lobbyists are required by RCW 42.17A.603 to attest that they have completed the new Legislative Code of Conduct Training. Michael may have received warning letters or hearing notices for PDC Case 62893 concerning failure to attest, sent out prior to the updated registration being submitted. PDC staff will now close PDC Case 62893 administratively, and remove Micahel's name from our hearing list. PDC staff reminds Michael Lindsay about the importance of timely, accurately, and completely attending to your registration and reporting requirements in the future. 

https://www.pdc.wa.gov/browse/cases/62893
62717 01/09/2020 PDC Staff Mark Dunn Dunn, Mark: Alleged violation of RCW 42.17A.603 for failure to attest to completing mandatory training by December 31, 2019. (Group Enforcement 2020) RCW 42.17A.603 Closed Administratively

This case alleged a violation of RCW 42.17A.603 for failure to attest, by December 31, 2019, to completing Legislative Code of Conduct training as required by the WA State Legislature. 

Mark Dunn does not have a current lobbyist contract and is not planning to be a registered lobbyist in 2020.Subsequently, the Public Disclosure Commission (PDC) administratively closed this case and no hearing will be held.

https://www.pdc.wa.gov/browse/cases/62717
62716 01/09/2020 PDC Staff Alma Gottlieb-McHale Gottlieb-McHale, Alma M: Alleged violation of RCW 42.17A.603 for failure to attest to completing mandatory training by December 31, 2019. (Group Enforcement 2020) RCW 42.17A.603 Violation Found by Commission

This case alleged a violation of RCW 42.17A.603 for failure to attest, by December 31, 2019, to completing Legislative Code of Conduct training as required by the WA State Legislature. 

A brief adjudicative proceeding was held on January 23, 2020, at which time Alma Gottlieb-McHale's lobbying registration was revoked by the Public Disclosure Commission.

https://www.pdc.wa.gov/browse/cases/62716
62712 01/09/2020 PDC Staff Thomas Schaaf Schaaf, Thomas: Alleged violation of RCW 42.17A.603 for failure to attest to completing mandatory training by December 31, 2019. (Group Enforcement 2020) RCW 42.17A.603 Closed Administratively

This case alleged a violation of RCW 42.17A.603 for failure to attest, by December 31, 2019, to completing Legislative Code of Conduct training as required by the WA State Legislature. 

Thomas Schaaf does not have a current lobbyist contract and is not planning to be a registered lobbyist in 2020.Subsequently, the Public Disclosure Commission (PDC) administratively closed this case and no hearing will be held.

https://www.pdc.wa.gov/browse/cases/62712
62710 01/09/2020 PDC Staff Dave T Sumner IV Sumner, Dave IV: Alleged violation of RCW 42.17A.603 for failure to attest to completing mandatory training by December 31, 2019. (Group Enforcement 2020) RCW 42.17A.603 Violation Found by Commission

This case alleged a violation of RCW 42.17A.603 for failure to attest, by December 31, 2019, to completing Legislative Code of Conduct training as required by the WA State Legislature. 

A brief adjudicative proceeding was held on January 23, 2020, at which time Dave Sumner IV’s lobbying registration was revoked by the Public Disclosure Commission.

https://www.pdc.wa.gov/browse/cases/62710
62708 01/09/2020 PDC Staff Christopher Plante Plante, Christopher: Alleged violation of RCW 42.17A.603 for failure to attest to completing mandatory training by December 31, 2019. (Group Enforcement 2020) RCW 42.17A.603 Violation Found by Commission

This case alleged a violation of RCW 42.17A.603 for failure to attest, by December 31, 2019, to completing Legislative Code of Conduct training as required by the WA State Legislature. 

A brief adjudicative proceeding was held on January 23, 2020, at which time Christopher Plante’s lobbying registration was revoked by the Public Disclosure Commission.

https://www.pdc.wa.gov/browse/cases/62708
62707 01/09/2020 PDC Staff Liba Meatchi Meatchi, Liba: Alleged violation of RCW 42.17A.603 for failure to attest to completing mandatory training by December 31, 2019. (Group Enforcement 2020) RCW 42.17A.603 Closed Administratively

​On January 14, 2020,the Public Disclosure Commission (PDC) received your attestation of completion of the Legislative Code of Conduct Training, as required by RCW 42.17A.603. As a lobbyist registered to lobby in 2020, this attestation was due on December 31, 2019, making your attestation 14 days late. PDC staff will now close PDC Case 62707 administratively, and remove your name from our hearing list. PDC staff reminds you about the importance of timely, accurately, and completely attending to your registration and reporting requirements in the future.

https://www.pdc.wa.gov/browse/cases/62707
62705 01/09/2020 PDC Staff Mary Van Cleve Van Cleve, Mary: Alleged violation of RCW 42.17A.603 for failure to attest to completing mandatory training by December 31, 2019. (Group Enforcement 2020) RCW 42.17A.603 Closed Administratively

The Public Disclosure Commission’s (PDC) records indicate that Mary Van Cleve is no longer registered to lobby in 2020. All lobbyists are required by RCW 42.17A.603 to attest that they have completed the new Legislative Code of Conduct Training. Mary Van Cleve may have received warning letters or hearing notices for PDC Case 62705 concerning failure to attest, sent out prior to an updated registration being submitted. PDC staff will now close PDC Case 62705 administratively, and remove Mary Van Cleve's name from our hearing list. PDC staff reminds Mary Van Cleve about the importance of timely, accurately, and completely attending to your registration and reporting requirements in the future. 

https://www.pdc.wa.gov/browse/cases/62705
62702 01/09/2020 PDC Staff Luis Moscoso Moscoso, Luis: Alleged violation of RCW 42.17A.603 for failure to attest to completing mandatory training by December 31, 2019. (Group Enforcement 2020) RCW 42.17A.603 Closed Administratively
  • Allegation: Alleged violation of RCW 42.17A.603 for failure to attest, by December 31, 2019, to completing Legislative Code of Conduct training as required by the WA State Legislature
https://www.pdc.wa.gov/browse/cases/62702
62701 01/09/2020 PDC Staff Christopher Connolly Connolly, Christopher: Alleged violation of RCW 42.17A.603 for failure to attest to completing mandatory training by December 31, 2019. (Group Enforcement 2020) RCW 42.17A.603 Closed Administratively

The Public Disclosure Commission’s (PDC) records indicate that Christopher Connolly is no longer registered to lobby in 2020. All lobbyists are required by RCW 42.17A.603 to attest that they have completed the new Legislative Code of Conduct Training. Christopher may have received warning letters or hearing notices for PDC Case 62701 concerning failure to attest, sent out prior to your updated registration being submitted. PDC staff will now close PDC Case 62701 administratively, and remove their name from our hearing list. PDC staff reminds you about the importance of timely, accurately, and completely attending to the registration and reporting requirements in the future.

https://www.pdc.wa.gov/browse/cases/62701
62699 01/09/2020 PDC Staff Melanie Smith Smith, Melanie: Alleged violation of RCW 42.17A.603 for failure to attest to completing mandatory training by December 31, 2019. (Group Enforcement 2020) RCW 42.17A.603 Closed Administratively

This case alleged a violation of RCW 42.17A.603 for failure to attest, by December 31, 2019, to completing Legislative Code of Conduct training as required by the WA State Legislature. 

Melanie Smith attested to having completing the required training on January 13, 2020. Subsequently, the Public Disclosure Commission (PDC) administratively closed this case and no hearing will be held.

https://www.pdc.wa.gov/browse/cases/62699
62698 01/09/2020 PDC Staff Tonia Sorrell-Neal Sorrell-Neal, Tonia: Alleged violation of RCW 42.17A.603 for failure to attest to completing mandatory training by December 31, 2019. (Group Enforcement 2020) RCW 42.17A.603 Violation Found by Commission

This case alleged a violation of RCW 42.17A.603 for failure to attest, by December 31, 2019, to completing Legislative Code of Conduct training as required by the WA State Legislature. 

A brief adjudicative proceeding was held on January 23, 2020, at which time Tonia Sorrell-Neal’s lobbying registration was revoked by the Public Disclosure Commission.

https://www.pdc.wa.gov/browse/cases/62698
62694 01/09/2020 PDC Staff Todd Mielke Mielke, Todd: Alleged violation of RCW 42.17A.603 for failure to attest to completing mandatory training by December 31, 2019. (Group Enforcement 2020) RCW 42.17A.603 Violation Found by Commission

This case alleged a violation of RCW 42.17A.603 for failure to attest, by December 31, 2019, to completing Legislative Code of Conduct training as required by the WA State Legislature. 

A brief adjudicative proceeding was held on January 23, 2020, at which time Todd Mielke’s lobbying registration was revoked by the Public Disclosure Commission.

https://www.pdc.wa.gov/browse/cases/62694
62693 01/09/2020 PDC Staff William Hirota Hirota, William: Alleged Violation of RCW 42.17A.603 for failure to attest to completing mandatory training by December 31, 2019. (Group Enforcement 2020) RCW 42.17A.603 Closed Administratively

The Public Disclosure Commission’s (PDC) records indicate that William Hirota is no longer registered to lobby in 2020. All lobbyists are required by RCW 42.17A.603 to attest that they have completed the new Legislative Code of Conduct Training. You may have received warning letters or hearing notices for PDC Case 62693 concerning failure to attest, sent out prior to your updated registration being submitted. PDC staff will now close PDC Case 62693 administratively, and remove your name from our hearing list. PDC staff reminds you about the importance of timely, accurately, and completely attending to your registration and reporting requirements in the future.

https://www.pdc.wa.gov/browse/cases/62693
62692 01/09/2020 PDC Staff Mary McHale McHale, Mary: Alleged violation of RCW 42.17A.603 for failure to attest to completing mandatory training by December 31, 2019. (Group Enforcement 2020) RCW 42.17A.603 Violation Found by Commission

This case alleged a violation of RCW 42.17A.603 for failure to attest, by December 31, 2019, to completing Legislative Code of Conduct training as required by the WA State Legislature. 

A brief adjudicative proceeding was held on January 23, 2020, at which time Mary McHale’s lobbying registration was revoked by the Public Disclosure Commission.

https://www.pdc.wa.gov/browse/cases/62692
62690 01/09/2020 PDC Staff Benita Hyder Hyder, Benita: Alleged violation of RCW 42.17A.603 for failure to attest to completing mandatory training by December 31, 2019. (Group Enforcement 2020) RCW 42.17A.603 Closed Administratively

The Public Disclosure Commission’s (PDC) records indicate that Benita Hyder is no longer registered to lobby in 2020. All lobbyists are required by RCW 42.17A.603 to attest that they have completed the new Legislative Code of Conduct Training. Benita Hyder may have received warning letters or hearing notices for PDC Case 62690 concerning failure to attest, sent out prior to an updated registration being submitted. PDC staff will now close PDC Case 62690 administratively, and remove Benita Hyder's name from our hearing list. PDC staff reminds Benita Hyder about the importance of timely, accurately, and completely attending to your registration and reporting requirements in the future. 

https://www.pdc.wa.gov/browse/cases/62690
62686 01/09/2020 PDC Staff Bob Guenther Guenther, Bob: Alleged violation of RCW 42.17A.603 for failure to attest to completing mandatory training by December 31, 2019. (Group Enforcement 2020) RCW 42.17A.603 Closed Administratively

On January 14, 2020, the Public Disclosure Commission (PDC) received Bob Guenther's attestation of completion of the Legislative Code of Conduct Training, as required by RCW 42.17A.603. As a lobbyist registered to lobby in 2020, this attestation was due on December 31, 2019, making Bob's attestation 14 days late. PDC staff will now close PDC Case 62686 administratively, and remove Bob's name from our hearing list. PDC staff reminds Bob Guenther about the importance of timely, accurately, and completely attending to your registration and reporting requirements in the future. 

https://www.pdc.wa.gov/browse/cases/62686
62685 01/09/2020 PDC Staff Shawn Bunney Bunney, Shawn: Alleged violation of RCW 42.17A.603 for failure to attest to completing mandatory training by December 31, 2019. (Group Enforcement 2020) RCW 42.17A.603 Closed Administratively

On January 14, 2020, the Public Disclosure Commission (PDC) received Shawn Bunney's attestation of completion of the Legislative Code of Conduct Training, as required by RCW 42.17A.603. As a lobbyist registered to lobby in 2020, this attestation was due on December 31, 2019, making Shawn's attestation 14 days late. PDC staff will now close PDC Case 62685 administratively, and remove Shawn's name from our hearing list. PDC staff reminds Shawn Bunney about the importance of timely, accurately, and completely attending to your registration and reporting requirements in the future. 

https://www.pdc.wa.gov/browse/cases/62685
62683 01/09/2020 PDC Staff Mike Armstrong Armstrong, Mike: Alleged violation of RCW 42.17A.603 for failure to attest to completing mandatory training by December 31, 2019. (Group Enforcement 2020) RCW 42.17A.603 Violation Found by Commission

This case alleged a violation of RCW 42.17A.603 for failure to attest, by December 31, 2019, to completing Legislative Code of Conduct training as required by the WA State Legislature. 

A brief adjudicative proceeding was held on January 23, 2020, at which time Mike Armstrong’s lobbying registration was revoked by the Public Disclosure Commission.

https://www.pdc.wa.gov/browse/cases/62683
62659 01/09/2020 Joseph Colombo Kelly Chambers Chambers, Kelly: Alleged Violation of RCW 42.17A.560 for accepting contributions during the Legislative Session Freeze (EY 20, Jan 20) RCW 42.17A.560 Closed Administratively

The Public Disclosure Commission (PDC) has completed its review of the complaint Joseph Colombo filed on January 8, 2020. The complaint alleged that Kelly Chambers, a 2020 Candidate for State Representative for Legislative District 25 may have violated RCW 42.17A.560 for accepting contributions during the Legislative Session Freeze, the period beginning on the thirtieth day before the date a regular legislative session convenes and continuing through the date of final adjournment.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; the applicable PDC reports filed by the Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance there is no evidence that supports the finding of a violation that warrants further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/62659
62411 01/06/2020 Maxford Nelsen Washington Federation of State Employees (AFSCME Council 28) Separate Segregated Fund Washington Federation of State Employees (AFSCME Council 28) Separate Segregated Fund: Alleged violations of Chapter 42.17A RCW for failure to register and report as a political committee (EY 16; Jan 20) RCW 42.17A.205, RCW 42.17A.240, RCW 42.17A.235, RCW 42.17A.225, RCW 42.17A.215, RCW 42.17A.210 Case Closed with No Evidence of Violations

A complaint was filed alleging that the  Washington Federation of State Employees - AFSCME Council 28 Separate Segregated Fund (WSFE) may have violated: (1) RCW 42.17A.205 by failing to register as a political committee with a designated depository and treasurer; and (2) RCW 42.17A.235 and .240 for failing to timely and accurately report contributions and expenditures as required for a political committee.

On April 1, 2020,  PDC staff opened a formal investigation and held an Initial Hearing (Case Status Review Hearing) pursuant to RCW 42.17A.755, and WACs 390-37-060 and 390-37-071 concerning the WSFE.

In the response, WFSE stated that the Freedom Foundation has provided no evidence indicating that the $200,000 in question was deposited into WFSE’s Separate Segregated Fund (SSF).  WSFE's legal counsel confirmed the $200,000 from American Federation of State, County and Municipal Employees Special Account (AFSCME), was deposited into WFSE’s member dues account, which is the primary account used by WFSE to pay for all of its representational and operational expenses.   

Based on the information, PDC staff found no evidence requiring further inquiry into whether WFSE's SSF was acting as a political committee. In addition, there is no evidence that the $200,000 in AFSCME funds received by WFSE was deposited into the SSF, such that further inquiry is necessary as to whether the SSF was a political committee as a receiver of contributions. 

PDC staff dismissed this matter in accordance with RCW 42.17A.755(1). 

 

https://www.pdc.wa.gov/browse/cases/62411
62221 01/02/2020 Peg Leland David Lugliani Lugliani, David: Alleged violations of RCW 42.17A.255 & .320 for failure to timely & accurately report independent expenditures, and identify sponsor on political advertising. (EY '19; Dec '19) RCW 42.17A.320, RCW 42.17A.255 Case Closed with Written Warning
  • Allegation One: Alleged violation of RCW 42.17A.255 for failure to timely & accurately report independent expenditures (signs & flyers supporting Prop 2)
  • Allegation Two: Alleged violation of RCW 42.17A.320 for failure to identify sponsor on political advertising (flyers supporting Prop 2)
https://www.pdc.wa.gov/browse/cases/62221
62130 12/30/2019 Glen Morgan 34th District Democratic Organization 34th District Democrats (2): Alleged violations of RCW 42.17A.235 and .240 for failure to timely and accurately report contributions and expenditures (EY 19; Dec 19) RCW 42.17A.235, RCW 42.17A.240 Investigation of Possible Violation
  • Allegation: Violations of RCW 42.17A.235 and .240 for failure to timely and accurately report contributions and expenditures.
https://www.pdc.wa.gov/browse/cases/62130
61764 12/24/2019 Peter Starzynski Jami Lund Lund, Jami (2): Alleged Violation of 42.17A.240 for failure to accurately disclose contributions and expenditures on C-3 and C-4 reports (EY 19, Dec 19) RCW 42.17A.240, WAC 390-16-034, WAC 390-16-037 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint Peter Starzynski filed on December 23, 2019. The complaint alleged that Jami Lund, a 2019 candidate for School Director for Centralia School District 401 may have violated RCW 42.17A.240 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures, including details, undertaken by the Campaign.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; the applicable PDC reports filed by the Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to timely accurately disclosure of contribution and expenditure details on C-3 and C-4 reports does not amount to a violation that warrants further investigation.

PDC staff is reminding Jami Lund about the importance of the timely and accurate disclosure of all contribution and expenditure activities, and the timely and accurate filings of all future PDC reports in accordance with the statutes and rules. 

The PDC encourages you to review the Candidate Instructions and the many other guides and videos available in the Learn, Guides and training videos section of the www.pdc.wa.gov website to further understand the rules for candidates. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/61764
61738 12/23/2019 Chris Leyba Martin Wheeler Wheeler, Martin: Alleged Violation of RCW 42.17A.320(1) for failure to identify party preference on political advertising; WAC 390-18-010 for failure to disclose complete sponsor identification on political advertising (EY 20, Dec 19) WAC 390-18-010, RCW 42.17A.320 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint Chris Leyba filed on December 21, 2019. The complaint alleged that Martin Wheeler (Respondent), a candidate for Governor of the State of Washington may have violated RCW 42.17A.320(1) for failure to identify party preference on political advertising and WAC 390-18-010 for failure to disclose complete sponsor identification on political advertising. 


PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the responses provided by the Respondent to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, failure to disclose party preference and full sponsor identification on political advertising does not amount to a violation that warrants further investigation. 

However, PDC staff is reminding Martin Wheeler about the importance of disclosing party preference and full sponsor identification on political advertising and disclosing all required party preference and sponsor identification on all future political advertising in accordance with the statutes and rules. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/61738
61735 12/23/2019 Helen Wheatley People for Thurston County Jobs, Dean Nielsen People for Thurston County Jobs & Dean Nielsen: Alleged Violation of RCW 42.17A.205 for failure to completely and accurately disclose officers of committee (EY 19, Dec 19) RCW 42.17A.205 Case Closed with No Evidence of Violations

On December 21, 2019 the Public Disclosure Commission (PDC) received a complaint alleging that the People for Thurston County and Dean Nielsen, may have violated RCW 42.17A.205 by failing to completely and accurately disclose officers of the committee, as defined under RCW 42.17A.205 and WAC 390-05-245. 

PDC staff reviewed the allegations; the applicable statutes, rules and reporting requirements; the applicable PDC reports filed by the People for Thurston County Jobs and Dean Nielsen (Committee); and the response from Jason Bennett on behalf of Dean Nielsen. 

RCW 42.17A.205(c)(j) states, (c) "The Statement of Organization shall include but not limited to: The names, addresses, and titles of its officers; or if it has no officers, the names, addresses, and titles of it responsible leaders; and (j) The name, address, and title of any person who authorizes expenditures or makes decisions on behalf of the candidate or committee." 

WAC 390-05-245 broadly defines a committee officer as, "Any person designated by the committee as an officer on the C-1 or C-1pc registration statement and any person who alone or in conjunction with other persons, makes, directs, or authorizes contribution, expenditure, strategic or policy decisions on behalf of the Committee."

The Committee listed Dean Nielsen and Jason Bennett as committee officers on the initial Committee Registration that was filed on October 11, 2019 and on two subsequent Committee Registrations that were amended to reflect the inclusion and removal of "Weyerhaeuser Company" as sponsor of the Committee on October 21, 2019 and October 25, 2019, respectively. All three Committee Registrations were filed with the PDC prior to this complaint being filed. 

Except for Dean Nielsen and Jason Bennett, staff found no other unnamed individuals affiliated with the Committee who meet the statutory/rule definition of a committee officer that were not included on the committee registration. 

Based on these findings, staff determined that no evidence supports a finding of a violation warranting further investigation. 

Based on this information, staff dismissed this matter in accordance with RCW 42.17A.755(1). 

 

https://www.pdc.wa.gov/browse/cases/61735
61437 12/19/2019 PDC Staff Chad Searls Searls, Chad: Alleged violation of RCW 42.17A.205 for failure to timely register as a candidate with two weeks of declaring candidacy. (EY '19; Dec '19) RCW 24.17A.205 Case Closed with Written Warning

This case alleges a violation of RCW 42.17A.205 for failure to timely register as a candidate with two weeks of declaring candidacy.

After conducting a preliminary review and assessment of a staff-generated complaint, dated 12/19/19 concerning Chad Searls, PDC staff opened a formal investigation and held a case status review, referred to an an initial hearing, on 2/20/20, pursuant to RCW 42.17.755 and WACs 390-37-060 and  390-37-071.

https://www.pdc.wa.gov/browse/cases/61437
61260 12/16/2019 Ed Husmann Dan Chaplik Chaplik, Dan: Alleged violation of RCW 42.17A.555 by using public agency facilities to assist an election campaign. (EY '19; Dec '19) RCW 42.17A.555 Case Closed with No Evidence of Violations
  • Alleged violation of RCW 42.17A.555 by using public agency facilities (e.g. school district Facebook page) to assist an election campaign for write-in candidate Heidi Dawson.
https://www.pdc.wa.gov/browse/cases/61260
61052 12/10/2019 Kitty Thomas Roy Keck Keck, Roy: Alleged Violation of RCW 42.17A.495 for discrimination based on failure to support or oppose a candidate for elected office; RCW 42.17A.555 for misuse of public facilities (EY 19, Dec 19) RCW 42.17A.495, RCW 42.17A.555 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on December 9, 2019. The complaint alleged that Roy Keck, a Port Commissioner for the Port of Benton may have violated RCW 42.17A.495 for discrimination based on failure to support or oppose a candidate for elected office and (2) RCW 42.17A.555 for misuse of public facilities.

PDC staff reviewed the allegations; the applicable statutes, and rules; and the response provided by the Respondent, to determine whether the record supports a finding of one or more violations.

  • During its investigation, PDC staff found no evidence that Port of Benton staff were demoted or terminated due to their support or opposition of Commissioner Keck or his re-election campaign. In addition, PDC staff found no other evidence to prove discrimination as described in RCW 42.17A.495.
  • Staff found no evidence showing that Commissioner Keck used the facilities, staff or other resources of the Port of Benton to support his 2019 re-election campaign in violation of RCW 42.17A.555.

By all accounts given in the Summary of Investigative Findings and review of commission meetings from May 2019 to December 2019, it is apparent that there were numerous changes within the Port of Benton, including staffing changes, policy and procedure updates, and training at all levels of personnel. Although these changes appear to have created a difficult and stressful work environment, most of the evidence of possible violations fell outside of PDC laws or rules.

 

Based on our findings staff has determined that no evidence supports a finding of a violation that warrants further investigation.

 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with WAC 390-37-070.

https://www.pdc.wa.gov/browse/cases/61052
60977 12/09/2019 Glen Morgan Amalgamated Transit Union Legislative Council of Washington Amalgamated Transit Union Legislative Council of Washington (2): Alleged violations of RCW 42.17A.255 for failure to report independent expenditures in opposition to a ballot proposition (EY 19; Dec 19) RCW 42.17A.255 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint Glen Morgan filed on December 7, 2019. The complaint alleged that Amalgamated Transit Union Legislative Council of Washington (Respondent), a political committee, may have violated RCW 42.17A.255 for failure to report the value of legal services in opposition to Initiative 976.

PDC staff reviewed the allegations; and the applicable statutes, rules, and reporting requirements to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation that warrants further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/60977
60975 12/09/2019 Glen Morgan Association of Washington Cities Association of Washington Cities: Alleged violations of RCW 42.17A.255 for failure to report independent expenditures in opposition to a ballot proposition (EY 19; Dec 19) RCW 42.17A.255 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint Glen Morgan filed on December 6, 2019. The complaint alleged that Association of Washington Cities (Respondent), a nonprofit organization, may have violated RCW 42.17A.255 for failure to report the value of legal services in opposition to Initiative 976.

PDC staff reviewed the allegations; and the applicable statutes, rules, and reporting requirements to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation that warrants further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/60975
60974 12/09/2019 Glen Morgan Intercity Transit Officials Intercity Transit Officials: Alleged violations of RCW 42.17A.555 for misuse of public facilities to oppose a ballot proposition (EY 19; Dec 19) RCW 42.17A.555 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint Glen Morgan filed on December 7, 2019. The complaint alleged that Intercity Transit Officials (Respondent), public employees, may have violated RCW 42.17A.555 for misuse of public facilities to oppose Initiative 976.

PDC staff reviewed the allegations; and the applicable statutes, rules, and reporting requirements to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation that warrants further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/60974
60972 12/09/2019 Glen Morgan Washington State Transit Association and Officials Washington State Transit Association and Officials: Alleged violations of RCW 42.17A.255 for failure to report independent expenditures and RCW 42.17A.555 for misuse of public facilities to oppose a ballot proposition (EY 19; Dec 19) RCW 42.17A.555, RCW 42.17A.255 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint Glen Morgan filed on December 6, 2019. The complaint alleged that Washington State Transit Association and Officials (Respondents), a nonprofit organization and its employees, may have violated RCW 42.17A.255 for failure to report the value of legal services in opposition to Initiative 976; and RCW 42.17A.555 for misuse of public facilities to oppose Initiative 976.

PDC staff reviewed the allegations; and the applicable statutes, rules, and reporting requirements to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation that warrants further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/60972
60970 12/09/2019 Glen Morgan Port of Seattle Officials Port of Seattle Officials: Alleged violations of RCW 42.17A.555 for misuse of public facilities to oppose a ballot proposition (EY 19; Dec 19) RCW 42.17A.555 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint Glen Morgan filed on December 6, 2019. The complaint alleged that Port of Seattle Officials (Respondent), public employees, may have violated RCW 42.17A.555 for misuse of public facilities to oppose Initiative 976.

PDC staff reviewed the allegations; and the applicable statutes, rules, and reporting requirements to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation that warrants further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/60970
60964 12/09/2019 Glen Morgan City of Seattle Officials City of Seattle Officials: Alleged violations of RCW 42.17A.555 for misuse of public facilities to oppose a ballot proposition (EY 19; Dec 19) RCW 42.17A.555 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint Glen Morgan filed on December 6, 2019. The complaint alleged that City of Seattle Officials (Respondent), public employees, may have violated RCW 42.17A.555 for misuse of public facilities to oppose Initiative 976.

PDC staff reviewed the allegations; and the applicable statutes, rules, and reporting requirements to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation that warrants further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/60964
60963 12/09/2019 Glen Morgan King County Officials King County Officials: Alleged violations of RCW 42.17A.555 for misuse of public facilities to oppose a ballot proposition (EY 19; Dec 19) RCW 42.17A.555 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint Glen Morgan filed on December 6, 2019. The complaint alleged that King County Officials (Respondent), public employees, may have violated RCW 42.17A.555 for misuse of public facilities to oppose Initiative 976.

PDC staff reviewed the allegations; and the applicable statutes, rules, and reporting requirements to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation that warrants further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/60963
60811 12/05/2019 Stephen Finley FedEx FedEx: Alleged violations of RCW 42.17A.345 and WAC 390-18-050 for failure to promptly provide documents and books of account concerning political advertising, upon request from any person (EY 19; Dec 19) RCW 42.17A.345, WAC 390-18-050 Investigation of Possible Violation
  • Allegation: Violation of RCW 42.17A.345 and WAC 390-18-050 for failure to provide documents and books of account detailing the exact nature and extent of political advertising services rendered, within 24 hours of request from any person.
https://www.pdc.wa.gov/browse/cases/60811
60723 12/03/2019 Kenton Gartrell Liz Hallock Hallock, Elizabeth (4): Alleged violations of RCW 42.17A.205 and .235 for failure to timely register as a candidate and report contributions and expenditures. RCW 42.17A.205, RCW 42.17A.235 Resolved through Statement of Understanding

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on December 9, 2019. The complaint alleged that Elizabeth Hallock, a candidate for Yakima City Council, Position 4 in 2019 may have violated: (1) RCW 42.17A.205 for failure to timely file a Candidate Registration report (C-1 report) within two weeks of becoming a candidate in the 2019 election; and (2) RCW 42.17A.235 for failure to timely and accurately file Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing in-kind contributions made by the candidate to her 2019 campaign. 
 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements;  the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations. 
 

Pursuant to WAC 390-37-060(1)(f), Elizabeth Hallock completed a Statement of Understanding (SOU) and paid a $300 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), acknowledging violations of RCW 42.17A.235 for failing to timely file the 21-Day Pre-Primary C-4 report; and (2) failing to timely file the 7-Day Pre-Primary Election C-4 report during the 2019 election. The $300 assessed penalty resolves these allegations. 

During its investigation, staff found that some of the descriptions for in-kind contributions made by the candidate, Elizabeth Hallock, to the 2019 Liz Hallock for Yakima City Council campaign were insufficient. Pursuant to WAC 390-37-060(1)(d), Ms. Hallock will receive a formal written warning concerning her failure to include adequate detail for expenditures made directly to vendors using personal funds and disclosed as in-kind contributions. The formal written warning will include staff’s expectation that Ms. Hallock will use RCW 42.17A.240 and WAC 390-16-037 as a guide for descriptions of expenditure activities disclosed as in-kind contributions, on future reports. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules. 

The complaint included evidence showing that Elizabeth Hallock publicly announced her candidacy for Yakima City Council, in the online version of the Yakima Herald on January 25, 2019 and alleged that she had violated RCW 42.17A.205 by failing to timely file the C-1 report registering her campaign with the PDC. Staff found that Ms. Hallock’s C-1 was timely submitted on January 31, 2019 and is dismissing this allegation in accordance with WAC 390-37-070. 
 

https://www.pdc.wa.gov/browse/cases/60723
60672 12/02/2019 Alana K. Bullis Mike Courts Courts, Mike: Alleged violations of Chapter 42.17A. and WAC 390-32, the Fair Campaign Practices Code ('EY 19; Nov '19) Resolved through Complaint Publication Process

On December 2, 2019, the Public Disclosure Commission (PDC) received a complaint from Alana Bullis, alleging a violation of one or more specific provisions of WAC 390-32-010, the Fair Campaign Practices Code (FCPC).  The complaint concerned Mike Courts, a candidate for Mayor of the City of DuPont.

The Campaign Fair Practices Code requires the PDC to forward the complaint to the party alleged to have violated the FCPC, request a response within five days, and then send the complaint and the response, if one is received, to news media.  WAC 390-32-030 prevents the Commission and staff from commenting on the complaint or the response. 

Attached with this memorandum are copies of the Complaint filed by Alana Bullis, and the Response provided by Mike Courts. Any questions should be directed to Alana Bullis or Mike Courts.

https://www.pdc.wa.gov/browse/cases/60672
60659 12/02/2019 Glen Morgan Peter Swant Swant, Peter: Alleged violations of RCW 42.17A.205, .235 & .240 for failure to timely register as a candidate, timely & accurately report expenditures, and provide sufficient expenditure & in-kind contribution descriptions on reports. ('EY 19; Nov '19) RCW 42.17A.205, RCW 42.17A.235, RCW 42.17A.240 Case Closed with Written Warning
  • Allegation One: Alleged violation of RCW 42.17A.205 for failure to timely register as a candidate within two weeks of candidacy 
  • Allegation Two: Alleged violations of RCW 42.17A..235 & .240 for failure to timely & accurately report expenditures 
  • Allegation Three: Alleged violations of RCW 42.17A.235 & .240 by not providing sufficient expenditure & in-kind contribution details on C-4 reports
https://www.pdc.wa.gov/browse/cases/60659
60520 11/26/2019 Robert Shirley City of Olympia Officials City of Olympia Officials (3): Alleged violations of RCW 42.17A.555 for misuse of public facilities, .255 for failure to report independent expenditures, and .320 for failure to disclose sponsor identification (EY 19; Nov 19) RCW 42.17A.555 Closed Administratively

This case has been consolidated into City of Olympia Officials (2), PDC Case 59039. For updates, please see https://www.pdc.wa.gov/browse/cases/59039.

https://www.pdc.wa.gov/browse/cases/60520
60511 11/26/2019 Nicolas Duchastel de Montrouge 45th Leg Dist Republicans 45th Leg Dist Republicans: Alleged Violation of RCW 42.17A.235, .255, .260, .305 for failure to timely and accurately report expenditures for political advertising (EY 19, Nov 19) RCW 24.17A.235, RCW 42.17A.305, RCW 42.17A.255, RCW 42.17A.260 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint Nicolas Duchastel de Montrouge filed on November 25, 2019. The complaint alleged that 45th Leg Dist. Republicans (Respondent), a bona fide party committee, may have violated RCW 42.17A.235, .255, .260 and .305 for failure to timely and accurately file Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign, and failure to timely and accurately file Independent Expenditure and Electioneering Communication reports (C-6 reports).

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; the applicable PDC reports filed by the Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to accurately file the C-6 report detailing independent or electioneering expenditures does not amount to a violation that warrants further investigation.

PDC staff is reminding 45th Leg Dist. Republicans about the importance of the timely and accurate disclosure of all expenditure activities, including independent expenditures and electioneering communications reports, and the timely and accurate filings of all future PDC reports in accordance with the statutes and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/60511
60509 11/26/2019 Glen Morgan Amanda "Mandi" McDougall McDougall, Amanda "Mandi": Alleged violations of RCW 42.17A.235, .240 & WAC 390-16-037 for failure to timely report contributions & expenditures, and provide expenditure details on reports. (EY '19; Nov '19) WAC 390-16-037, RCW 42.17A.240, RCW 42.17A.235 Case Closed with Reminder

This case alleged violations of RCW 42.17A.235 & .240 for failure to timely report contributions & expenditures, and RCW 42.17A.240 & WAC 390-16-037 for failure to provide expenditure details on reports.

PDC staff found that the Respondent filed five C-3 reports 6-76 days late and six C-4 reports 4-100 days late. Two of the late C-4 reports were for critical reporting periods prior to the General election, and three C-4 reports lacked expenditure details.

The Respondent, who is a first-time candidate, apologized for the unintentional oversight, indicated a willingness to amend reports to resolve noncompliance, and made technical corrections to reports per the PDC's request.  

https://www.pdc.wa.gov/browse/cases/60509
60458 11/25/2019 Craig Keller Washington Fairness Coalition Washington Fairness Coalition (2): Alleged Violation of RCW 42.17A.320 for failure to disclose sponsor identification on political advertising (pre-recorded calls) (EY 19, Nov 19) RCW 42.17A.320 Case Closed with Written Warning

The complaint alleged Washington Fairness Coalition, a 2019 Ballot Proposition Committee supporting Referendum 88, may have violated RCW 42.17A.320 by failing to provide sponsor identification in political advertising.

It appears the omission of sponsor identification, including the top five contributors was unintentional and not purposely omitted to mislead the public. The identity of the top five contributors was available to the public on the committee’s Monetary Contribution (C-3) reports submitted prior to the advertisements being presented to the public. In addition, the committee has included appropriate expenditure details on Receipts and Expenditures Summary (C-4) reports. Although Washington Fairness Coalition has no previous violations of RCW 42.17A, the committee employs a professional treasurer and is aware of the sponsor identification requirements for political advertisement it sponsors. 

Based on our findings staff has determined that, in this instance, failure to include the top five contributors on these advertisements does not amount to a finding of a violation that warrants further investigation. Pursuant to WAC 390-37-060(1)(d), however, Washington Fairness Coalition will receive a formal written warning concerning failure to include complete sponsor identification, specifically the top five contributors required by statute, on political advertisements it sponsored. The formal written warning will include staff’s expectation that the committee includes complete sponsor identification on all political advertisement it sponsors in the future. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules. Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/60458
60443 11/25/2019 Sean Bates and Eleanor Brodahl Othello School District Officials Othello School District Officials: Alleged violations of RCW 42.17A.555 for misuse of public facilities to support an election campaign (EY 19; Nov 19) RCW 42.17A.555 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint Sean Bates and Eleanor Brodahl filed on November 22, 2019. The complaint alleged that Othello School District Officials, public employees, may have violated RCW 42.17A.555 for authorizing the misuse of public facilities to support the election campaign of Tony Ashton.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the responses provided by the Respondent, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, insufficient evidence supports a finding of a violation that warrants further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/60443
60389 11/22/2019 Glen Morgan Siri Bliesner Bliesner, Siri: Alleged Violation of RCW 42.17A.205, .235 & .240 for failure to timely & accurately register as a candidate, report contributions & expenditures & RCW 42.17A.320 for failure to disclose sponsor identification (EY 19, Nov 19) RCW 42.17A.320, RCW 42.17A.240, RCW 42.17A.205, RCW 42.17A.235 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint Glen Morgan filed on November 21, 2019. The complaint alleged that Siri Bliesner, a Candidate for School Director in Lake Washington School District 414 may have violated RCW 42.17A.205, .210, .215 for failure to timely and accurately file Candidate Registration reports (C-1 reports), disclosing treasurer and depository information; RCW 42.17A.235, .240 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign; and RCW 42.17A.320 for failure to disclosure sponsor identification on political advertising. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; the applicable PDC reports filed by the Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to include accurate detail in the description of expenditures on C-4 reports and providing full sponsor identification on political advertising does not amount to a violation that warrants further investigation.

PDC staff is reminding Siri Bliesner about the importance including accurate and complete expenditure information on C-4 reports and disclosing full sponsor identification on political advertising. PDC staff expects in the future that Siri Bliesner will provide accurate and complete details on C-4 reports and disclose full sponsor identification on political advertising in accordance with the statutes and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/60389
60381 11/22/2019 Marcie Maxwell Renton Regional Fire Authority Officials Renton Regional Fire Authority Officials: Alleged Violation of 42.17A.555 for misuse of public facilities (EY 19, Nov 19) RCW 42.17A.555 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint Marcie Maxwell filed on November 21, 2019. The complaint alleged that Renton Regional Fire Authority Officials (RRFA) (Respondent), public officials in the Fire Districts comprising the RRFA may have violated RCW 42.17A.555 for misuse of public facilities by publishing political advertising in support or opposition of a candidate up for election or re-election in the 2019 election cycle.

PDC staff reviewed the allegations listed in the complaint to determine whether a formal investigation or enforcement action is warranted. Staff reviewed all attachments submitted with the complaint, the statute, rules, and PDC Interpretation 04-02 “Guidelines for Local Government Agencies in Election Campaigns,” and the December 9, 2019, response from Brian Snure, Attorney for the Renton Regional Fire Authority Officials. 

Based on our findings staff has determined that, in this instance, there is no evidence that supports finding of a violation that warrants further investigation.

However, the PDC staff is reminding the Renton Regional Fire Authority Officials about the prohibitions of using commissioners and facilities to support or oppose any candidate or ballot proposition, and encouraged the RRFA to not feature any elected officials in RRFA business related communications or publications concerning relevant RRFA issues when that official is up for election or re-election. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/60381
60336 11/21/2019 Chad E Searls Andrew "Drew" Hooper Hooper, Andrew "Drew": Alleged violations of RCW 42.17A.205, .235 & .240 for failure to timely register as a candidate and report contributions & expenditures. (EY '19; Nov '19) RCW 42.17A.240, RCW 42.17A.205, RCW 42.17A.235 Case Closed with Written Warning
  • Allegation One: Alleged violation of RCW 42.17A.205 for failure to timely register as a candidate with the PDC within two weeks of declaring candidacy 
  • Allegation Two: Alleged violation of RCW 42.17A.235 & .240 for failure to timely report contributions & expenditures
https://www.pdc.wa.gov/browse/cases/60336
60308 11/20/2019 Glen Morgan Ann Parks Parks, Ann (3): Alleged Violation of RCW 42.17A.205, .210, .215 for failure to timely file Candidate Registration report (C1 report) (EY 19, Nov 19) RCW 42.17A.205, RCW 42.17A.215, RCW 42.17A.210 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint Glen Morgan filed on November 18, 2019. The complaint alleged that Ann Parks, a Candidate for Pullman City Council Member may have violated RCW 42.17A.205, .210, .215 for failure to timely and accurately file Campaign Registration reports (C-1 reports), disclosing the treasurer and depositories.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent and the applicable PDC reports filed by the Respondent to determine whether the record supports a finding of one or more violations.

Technical problems with the electronic registration filing system were identified by the PDC from May 13, 2019 to June 27, 2019, which prevented or delayed filers’ ability to timely file registrations during this period. Due to such circumstances, the filing requirements for the filer were suspended during this period, pursuant to RCW 42.17A.055.

Based on our findings staff has determined that, in this instance, failure to timely file the C-1 report does not amount to a violation that warrants further investigation.

However, PDC staff is reminding the Respondent about the importance of timely filing the Candidate Registration report (C-1 report), including PDC staff’s expectations that the Respondent timely will file all reports of registration in accordance with PDC laws and rules going forward.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/60308
60299 11/20/2019 Glen Morgan Francis Benjamin Benjamin, Francis: Alleged Violation of RCW 42.17A.235, .240 for failure to timely and accurately file contribution and expenditure reports (C-3 and C-4 reports) (EY 19, Nov 19) RCW 42.17A.240, RCW 42.17A.235 Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the complaint Glen Morgan filed on November 18, 2019. The complaint alleged that Francis Benjamin (Respondent), a candidate, for City Council Member for the City of Pullman may have violated RCW 42.17A.235 and .240 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the responses provided by the Respondent; the applicable PDC reports filed by the Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to timely and accurately file the C-3 and C-4 reports does not amount to a violation that warrants further investigation.

However,Pursuant to WAC 390-37-060(1)(d), Francis Benjamin will receive a formal written warning concerning failure to timely and accurately disclose all contribution and expenditures. The formal written warning will include staff’s expectation that Francis Benjamin timely and accurately files all future required reports of contributions and expenditures. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/60299
60238 11/18/2019 Peg Leland Awna Underwood Underwood, Awna: Alleged Violation of RCW 42.17A.205, .210, .215 for failure to timely file Candidate Registration report (C-1 report); RCW 42.17A.700 for failure to timely file Personal Financial Affairs Statement report (F-1 report) (EY 19, Nov 19) RCW 42.17A.215, RCW 42.17A.700, RCW 42.17A.210, RCW 42.17A.205 Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the complaint Peg Leland filed on November 16, 2019. The complaint alleged that Awna Underwood (Respondent), a write-in candidate for Mayor for the City of Camas may have violated RCW 42.17A.205, .210, .215 for failure to timely file Candidate Registration, disclosing treasurer and depository information for the campaign; and RCW 42.17A.700 for failure to timely file your Personal Financial Affairs Statement (F-1 report).

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements, the response provided by the Respondent and the applicable PDC reports filed by the Respondent to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to timely file the C-1 and F-1 reports does not amount to a violation that warrants further investigation.

Pursuant to WAC 390-37-060(1)(d), however, Awna Underwood will receive a formal written warning concerning failure to timely file a Candidate Registration and Personal Financial Affairs Statement. The formal written warning will include staff’s expectation that Awna Underwood timely files all future required reports of registration and financial disclosure. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/60238
60235 11/18/2019 Sandra Robson Jay Rodne Rodne, Jay (2): Alleged violations of RCW 42.17A.430 for misuse of surplus funds to form a limited liability company (Nov 19) RCW 42.17A.430 Resolved through Statement of Understanding

The Public Disclosure Commission (PDC) has completed its review of the complaint Sandra Robson filed on November 15, 2019. The complaint alleged that Jay Rodne, a former State Representative for Legislative District 5 and a candidate seeking re-election to that office in 2016 and 2018,  made unauthorized expenditures from the Jay Rodne Surplus Funds Account as disclosed on the Summary Full Campaign Contributions and Expenditures Report (C-4 report), in violation of RCW 42.17A.430. 


PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the responses provided by the Respondent; the applicable PDC reports filed by the Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations. 


On February 3, 2020, Representative Rodne completed a signed Statement of Understanding (SOU) acknowledging a violation of RCW 42.17A.430 by making an unauthorized non-office related expenditure of surplus funds to pay the initial filing fee for Pac Rim Bridges LLC.  He paid a $150 civil penalty that was assessed against him in this matter in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), resolving the personal use of surplus funds violation.   

Based on our findings and the facts that Representative Rodne is no longer in office, has no prior PDC violations, and that the campaign-related expenditures only required to him to transfer surplus funds back into the respective campaign accounts to have been permitted, staff has determined that, in this instance, the remaining expenditures of surplus funds listed above do not amount to violations warranting further investigation. 

Pursuant to WAC 390-37-060(1)(d), Jay Rodne will receive a formal written warning concerning the permitted uses of surplus funds in the future, should he decide to again seek public office.  The formal written warning includes staff’s expectation that Jay Rodne will disclose and pay for all campaign-related expenses through campaign committees in the future and will not make any prohibited personal use expenditures. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1). 
 

https://www.pdc.wa.gov/browse/cases/60235
60162 11/15/2019 Robin Carl Johnson North Snohomish County Union Firefighters Local 4033 North Snohomish County Union Firefighters Local 4033: Alleged violations of RCW 42.17A.255, .260 & .305 for failure to timely & accurately report independent expenditures. (EY '19; Nov '19) RCW 42.17A.260, RCW 42.17A.305, RCW 42.17A.255 Case Closed with Reminder
  • Alleged violation of RCW 42.17A.255, .260 & .305 for failure to timely & accurately report an independent expenditure (Jeff Sinker campaign mailers) 
  • Alleged violation of RCW 42.17A.255, .260 & .305 for failure to accurately describe an independent expenditure on a C-6 report (postage for Jeff Sinker mailers)
https://www.pdc.wa.gov/browse/cases/60162
60143 11/15/2019 Dorothy L Luzzo Gilmour Bob Thompson Thompson, Bob: Alleged violations of RCW 42.17A.235 & 240 for failure to timely & accurately report deposits, contributions & expenditures. (EY '19; Nov '19) RCW 42.17A.240, RCW 42.17A.235 Case Closed with Written Warning
  • Allegation: Alleged violations of RCW 42.17A.235 & .240 for failure to timely & accurately report deposits, contributions & expenditures by filing C-3 & C-4 reports with the PDC
https://www.pdc.wa.gov/browse/cases/60143
60094 11/13/2019 Peg Leland Melissa Smith Smith, Melissa: Alleged violations of RCW 42.17A.205 & .235 by failing to timely register as a candidate w/the PDC and report contributions & expenditures. (EY '19) (Nov '19) RCW 24.17A.235, RCW 24.17A.205 Case Closed with Written Warning
  • Allegation One: Alleged violation of RCW 42.17A.205 for failure to register as a candidate with PDC within two weeks of declaring candidacy.  
  • Allegation Two:  Alleged violation of RCW 42.17A.235 for failure to timely report contributions & expenditures.
https://www.pdc.wa.gov/browse/cases/60094
60068 11/13/2019 Kelly Anderson Tim Larson Larson, Tim: Alleged violations of RCW 42.17A.205, .235 & .700 by failing to timely register as a candidate w/the PDC, file statement of financial affairs and report contributions & expenditures. (EY '19) (Nov '19) RCW 42.17A.700, RCW 24.17A.235, RCW 24.17A.205 Case Closed with Reminder
  • Allegation One: Alleged violation of RCW 42.17A.205 for failure to register as a candidate with PDC within two weeks of declaring candidacy.
  • Allegation Two: Alleged violation of RCW 42.17A.700 for failure to file a statement of financial affairs with PDC within two weeks of declaring candidacy.
  • Allegation Three: Alleged violation of RCW 42.17A.235 for failure to timely report contributions & expenditures.
https://www.pdc.wa.gov/browse/cases/60068
60036 11/12/2019 Timothy Schmitt North County EMS Officials North County EMS Officials: Alleged violation of RCW 42.17A.555 for misuse of public facilities to support a ballot proposition (EY 19; Nov 19) RCW 42.17A.555 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint Timothy Schmitt filed on November 12, 2019. The complaint alleged that North County EMS Officials, public employees, may have violated RCW 42.17A.555 for misuse of public facilities to support a ballot proposition.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the responses provided by the Respondent, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, insufficient evidence supports a finding of a violation that warrants further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/60036
60032 11/12/2019 David Bryan Holloway Mary "Peggy" Shepard Shepard, Mary "Peggy": Alleged violation of RCW 42.17A.555 by using public agency/office facilities to assist an election campaign. (EY '19; Nov '19) RCW 42.17A.555 Case Closed with No Evidence of Violations

The complaint alleged Mary “Peggy” Shepard, a City of Snoqualmie City Council Member, may have violated RCW 42.17A.555 by using city facilities to assist another candidate’s campaign. You provided photos of a sweatshirt that listed three 2019 candidates for Snoqualmie City County Shepard wore at a public meeting.  
PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements, and the response provided by Shepard, to determine whether the record supports a finding of one or more violations. 

The meeting referenced in the complaint was advertised on the city website; however, it was not administered as a regular city council meeting or by Shepard. As such, Shepard’s actions were not governed by RCW 42.17A.555. Based on these findings staff has determined, in this instance, the alleged use of public facilities by Shepard to campaign for another candidate, does not amount to a violation warranting further investigation. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1). 
 

https://www.pdc.wa.gov/browse/cases/60032
60018 11/12/2019 Carl Schoenleber Liz Vogeli Vogeli, Liz: Alleged Violation of RCW 42.17A.235, .240 for failure to timely and accurately file C-4 reports disclosing expenditures and in-kind contributions (EY 19, Nov 19) RCW 42.17A.240, RCW 42.17A.235 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint Carl Schoenleber filed on November 7, 2019. The complaint alleged that Elizabeth Vogeli (Respondent), a Candidate for City of Everett City Council Member may have violated RCW 42.17A.235 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent and the applicable PDC reports filed by the Respondent to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to disclose the detailed description as demonstrated in WAC 390-16-205 does not amount to a violation that warrants further investigation.

Elizabeth Vogeli made minor or ministerial errors on required reports, which did not materially impact the public interest. Upon notification of these errors, Elizabeth Vogeli timely amended their reports, making the necessary technical corrections as requested by staff.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/60018
59877 11/08/2019 Andrew Saturn People for Thurston County Jobs & Jason Bennett People for Thurston County Jobs & Jason Bennett: Alleged violation of RCW 42.17A.205 for failure to disclose a committee officer, as defined under WAC 390-05-245, on Committee Registration. (EY '19; Oct '19) RCW 42.17A.205 Case Closed with No Evidence of Violations

On November 1, 2019, the Public Disclosure Commission (PDC) received a complaint alleging that the People for Thurston County Jobs and Jason Bennett, may have violated RCW 42.17A.205 by failing to disclose a committee officer on the Committee Registration, as defined under RCW 42.17A.205 and WAC 390-05-245. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the applicable PDC reports filed by the People for Thurston County Jobs and Jason Bennett (Committee); and reviewed their data in the PDC database, to determine whether the record supports a finding of one or more violations. 

Staff determined that the Committee identified/listed Dean Nielsen and Jason Bennett as Committee officers on the initial Committee Registration that was filed on October 11, 2019, and on the two subsequent Committee Registrations that were amended to reflect the inclusion and removal of "Weyerhaeuser Company" as sponsor of the Committee on October 21, 2019 and October 25, 2019, respectively. All three Committee registrations were filed with the PDC prior to this complaint being filed. 

Based on these findings, staff determined that no evidence supports a finding of a violation warranting further investigation. 

Based on this information, the PDC staff dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/59877
59839 11/07/2019 Peg Leland Yes for Camas Community and Kerry Ticknor Yes for Camas Community: Alleged violations of RCW 42.17A.235, .320 & WAC 390-16-125 by failing to keep timely & accurate books of account, allow for timely public inspection, exceeding mini-reporting limit & identify political advertising sponsor. (Oct '19) RCW 42.17A.320, RCW 42.17A.235, WAC 390-16-125 Case Closed with Reminder

On November 5, 2019, the Public Disclosure Commission (PDC) received a complaint alleging that the Yes for Camas Community (Committee), may have violated RCW 42.17A.235 by failing to keep timely and accurate books of account and allow for their timely public inspection, and WAC 390-16-125 by exceeding mini-reporting contribution limit.  

PDC staff reviewed the allegations; the applicable statutes, rules and reporting requirements; and the response provided by the treasurer on behalf of the Committee.

Staff determined that the Committee failed to timely produce books of accounts for public inspection during the 10 days preceding  the 2019 general election. Staff also found that the Committee's books of account was deficient in details. However, the Committee's officials were inexperienced and unfamiliar with the PDC requirements pertaining to books of accounts. Additionally, the Committee has no prior PDC violations. 

Based on the above, staff issued a reminder letter to the Committee officials about the importance  of keeping accurate books of account, including allowing public inspection of books of account in a timely fashion in future years. 

Based on this information, the PDC staff dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/59839
59783 11/06/2019 Philip Johnson Rhiannon Parks Parks, Rhiannon: Alleged Violation of RCW 42.17A.205, .210, .215 for failure to timely file Candidate Registration report (C-1 report); RCW 42.17A.700 for failure to timely file Personal Financial Affairs Statement report (F-1 report) (EY19, Nov 19) RCW 42.17A.215, RCW 42.17A.700, RCW 42.17A.210, RCW 42.17A.205 Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the complaint Philip Johnson filed on November 5, 2019. The complaint alleged that Rhiannon Parks (Respondent), a candidate for Battle Ground City Council Member may have violated RCW 42.17A.205, .210 and .215 for failure to file Candidate Registration report, disclosing treasurer and depository information, within two weeks of becoming a candidate; and RCW 42.17A.700 for failure to file Personal Financial Affairs Statement within two weeks of becoming a candidate. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements, and the Respondent’s filing history to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to timely file the Candidate Registration and Personal Financial Affairs Statement reports does not amount to a violation that warrants further investigation.

However, Pursuant to WAC 390-37-060(1)(d), Rhiannon Parks will receive a formal written warning concerning failure to timely file Candidate Registration and Personal Financial Affairs Statement reports. The formal written warning will include staff’s expectation that Rhiannon Parks timely files all future required reports of registration and personal financial affairs. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/59783
59780 11/06/2019 Craig Keller Approve I-1000 Approve I - 1000: Alleged Violation of RCW 42.17A.320 for failure to provide sponsor identification on political advertising (pre-recorded calls) (EY 19, Nov 19) RCW 42.17A.320 Case Closed with No Evidence of Violations

Case originally sent to incorrect Committee. Please see PDC case 60458

https://www.pdc.wa.gov/browse/cases/59780
59777 11/06/2019 Glen Morgan Common Purpose PAC Common Purpose PAC: Alleged violations of RCW 42.17A.235 & .240 for failure to timely & accurately report contributions & expenditures. (EY '19; Oct '19) RCW 42.17A.240, RCW 42.17A.235 Case Closed with Reminder

A complaint was filed against the Common Purpose PAC, a single-year local political committee registered with the PDC to support 2019 candidates seeking office in the City of Sea-Tac, alleging that Common Purpose PAC may have violated RCW 42.17A.235 and .240 by failing to file Monetary Contributions reports (C-3 reports) and Summary Full Campaign Contributions and Expenditures reports (C-4 reports) disclosing contribution and expenditure details, including orders place for activities undertaken by the Committee.

The Response stated that Common Purpose PAC has been registered with the Federal Election Commission (FEC) as a “federal hybrid PAC …organized and operated out of Seattle, Washington,” and “unlike other federal PAC’s engaging in state or local election activity in Washington, the Committee does not qualify as an “out-of-state committee” 

Since Common Purpose PAC (Committee) registered as a committee within 21 days of the November 5, 2019 general election, the reporting requirements included filing a 7-Day Pre-General Election C-4 report due on October 28, 2019 covering the period October 14 through 28, 2019, and a Post-General Election C-4 report on December 10, 2019.  In addition, Common Purpose PAC was required to file weekly C-3 reports for the 2019 general election from October 23 through November 4, 2019. 

On October 28, 2019, the Committee timely filed the 7-Day Pre-General Election C-4 report disclosing no contribution or expenditure activities had been undertaken, including no orders placed.  On November 4, 2019, the Committee timely filed a C-3 report disclosing that a $3,811.51 contribution had been received from Common Purpose PAC on November 1, 2019 and deposited on the same day. 

On November 5, 2019, the Committee also timely filed a C-5 report disclosing that it is a federal PAC domiciled in Washington State submitting the first report in 2019, and that the PAC has “not been registered to work in any state election before now.”   The C-5 report disclosed that on November 1, 2019 the PAC made in-kind contributions to four candidates for Sea-Tac City Council of $952.97, totaling $3,811.51 for an expenditure made to Progressive Strategies NW and included Ali Egal, Takele Gobena, Damiana Merryweather, and Senayet Negusse. 

The candidates disclosed receiving a $952.88 in-kind contribution from the Committee on their 7-Day Pre-General Election C-4 reports filed on October 28, 2019 for a joint mailer that was mailed on October 29, 2019.   In addition , after receiving the complaint, the Committee filed an amended 7-Day Pre-General Election C-4 report on November 20, 2019, disclosing four orders were placed on October 24, 2019 with Progressive Strategies to print the mailer.

Staff’s review of the facts found that Common Purpose PAC: (1) was a federal committee registered with the FEC and domiciled in Washington State for all of calendar year 2019; (2) made contributions to local candidates in Washington state for the first time and late in the 2019 election cycle, and fully cooperated with PDC staff; (3) based on the Commissions rule, was a first-time committee that was required to register and report with PDC based solely on being domiciled in Washington State; (4) the federal committee file a voluntary C-5 report five days early; and (5) the candidates that received in-kind contributions for the mailer timely disclosed that activity on the C-4 reports.  

Based on these findings, staff has determined in this instance, the late filed reports do not warrant further investigation.  PDC staff has reminded Common Purpose PAC to timely and accurately register and report as an in-state committee, including filing C-3 and C-4 reports disclosing contribution, expenditure and orders placed, should it undertake activities involving candidates or ballot propositions in Washington State in the future as required for a political committee.  The PDC has dismissed the complaint in accordance with RCW 42.17A.755(1). 

 

https://www.pdc.wa.gov/browse/cases/59777
59773 11/06/2019 Glen Morgan Yes for Homes Coalition of San Juan County Yes for Homes Coalition of San Juan County: Alleged violations of RCW 42.17A.240 & WAC 390-16-037 for failure to provide sufficient expenditure details on C-4 reports for election year 2018. (Oct '19) RCW 42.17A.240, WAC 390-16-037 Case Closed with Reminder
  • Allegation: Alleged violation of RCW 42.17A.240 & WAC 390-16-037 for failure to provide sufficient expenditure details on C-4 reports for election year 2018.
https://www.pdc.wa.gov/browse/cases/59773
59769 11/06/2019 Bret Uhrich LET PEOPLE VOTE / Reject R-88 Let People Vote / Reject R-88 (2): Alleged Violation of RCW 42.17A.320 for failure to provide complete and accurate sponsor identification in political advertising (pre-recorded calls) (EY 19, Nov 19) RCW 42.17A.320 Case Closed with No Evidence of Violations

The complaint alleged a violation of RCW 42.17A.320 for failing to provide complete and accurate sponsor identification in political advertising, specifically a pre-recorded call/robocall. 

On the PDC website outlining requirements for political advertising, it states a sponsor’s address is not required for broadcast, video, and online audio ads. While a robocall is not specifically mentioned in this section as not requiring a sponsor’s address, a robocall has similar participant interaction to a broadcast or online audio advertisement. 

Based on these findings staff has determined, in this instance, the alleged failure to provide complete and accurate sponsor identification in political advertising does not amount to a violation warranting further investigation. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/59769
59761 11/06/2019 Michell Thyng Toni Overmyer Overmyer, Toni (2): Alleged Violation of RCW 42.17A.205, .210, .215 for failure to timely file Candidate Registration report (C-1 report) (EY 19, Nov 19) RCW 42.17A.215, RCW 42.17A.210, RCW 42.17A.205 Violation Found by Commission

Pursuant to the brief enforcement hearing (brief adjudicative proceeding) notice sent to Toni Overmyer on January 13, 2020, a brief adjudicative proceeding was held on January 23, 2020, in Room 206, Evergreen Plaza Building, 711 Capitol Way, Olympia, Washington, to consider whether the Respondent violated RCW 42.17A.205, .210, and .215 by failing to file a Candidate Registration (C-1) as a 2019 Candidate for Park & Recreation Commissioner of Des Moines Pool Metro Park District, which was due to be filed within two weeks of becoming a candidate or no later than June 3, 2019. 

The hearing was held in accordance with Chapters 34.05 RCW and 42.17A RCW and Chapter 390-37 WAC. Commission Chair David Ammons was the Presiding Officer.  The Commission staff was represented by Tabitha Townsend, Compliance Coordinator.  The Respondent did not participate. 

Having considered the evidence, the Presiding Officer finds as follows: 


                                        CONCLUSIONS OF LAW 

Based on the above facts, as a matter of law, the Presiding Officer concludes as follows: 

1. This matter was duly and properly convened and all jurisdictional, substantive, and procedural requirements have been satisfied. 

2. The Respondent violated RCW 42.17A.205, .210 and .215 by failing to file the Candidate Registration report by June 3, 2019. 

                                                 ORDER 

ON the basis of the foregoing Findings of Fact and Conclusions of Law, 

IT IS HEREBY ORDERED that the Respondent is assessed a civil penalty of $500, in accordance with the C-1 penalty schedule set forth in WAC 390-37-143, payable within 30 days of the date of the Order.  
It is further ordered that the Respondent: 


1. Pay the $500 civil penalty within 30 days of the date of this Order. 
2. Commit no further violations of Chapter 42.17A RCW or Title 390 WAC, for a period of 5 years from the date of this Order. 


In the event the Respondent fails to pay the $500 civil penalty within 30 days of the date of the Order, PDC staff will refer the matter for collections. 
 

https://www.pdc.wa.gov/browse/cases/59761
59740 11/05/2019 Sean Bates Scootney Springs Elementary School Officials Scootney Springs Elementary School Officials: Alleged violations of RCW 42.17A.555 for authorizing the misuse of public facilities to support an election campaign. (EY 19; Nov 19) RCW 42.17A.555 Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the complaint Sean Bates filed on October 30, 2019. The complaint alleged that Scootney Springs Elementary School Officials (Respondents), public employees, may have violated RCW 42.17A.555 for authorizing the misuse of public facilities to support the election campaign of candidate Lindsy Prows.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the responses provided by the Respondents; and PDC Interpretation 01-03, Guidelines for School Districts in Election Campaigns, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, authorizing the misuse of public facilities to store and distribute yard signs in support of a candidate does not amount to a violation that warrants further investigation.

Pursuant to WAC 390-37-060(1)(d), however, Cynthia Tovar, Jessica Suarez, Janet Axtman, Jacee Martinez, Tammy Foley, and Sandra Garza will receive a formal written warning concerning their actions regarding the use of public facilities to support an election campaign. The formal written warning will include staff’s expectation that Cynthia Tovar, Jessica Suarez, Janet Axtman, Jacee Martinez, Tammy Foley, and Sandra Garza review PDC Interpretation 01-03, Guidelines for School Districts in Election Campaigns and that they will prevent the misuse of public facilities in the future. The Commission will consider the formal written warning in deciding on further Commission action, if there are future violations of PDC laws or rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/59740
59732 11/05/2019 Wilma Edmonds City of Medina Officials City of Medina Officials: Alleged Violation of RCW 42.17A.555 for misuse of public facilities (EY 19, Nov 19) RCW 42.17A.555 Case Closed with Reminder

The complaint alleged City of Medina officials may have violated RCW 42.17A.555 by using or authorizing the use of City of Medina facilities for the promotion of Proposition 1, a 2019 ballot proposition. PDC staff reviewed the allegations, the applicable statutes and rules, the mailer, and the response provided by Scott M. Missal, Medina City Attorney, to determine whether the record supports a finding of one or more violations. 

Based on these findings staff has determined, in this instance, the alleged use of public facilities to produce and distribute a mailer regarding Proposition 1 does not amount to a violation warranting further investigation. 

Staff’s review of the publication found that the majority of the content was a fair and objective presentation of facts, however there was some statements or phrases included such as “unstainable financial future,” and that “threatening the delivery of essential City services – police, fire, medical aid…” that were more inflammatory in nature rather than factual statements.  In addition, staff believes the statement “Medina’s property tax rate is the 4th lowest in King County” is not an objective statement or comparison, and the graphic using a dollar bill to indicate the amount received by the City of Medina, minimizes the amount of the proposed taxation level. 

PDC staff is reminding City of Medina officials that in the future when publishing election related information about a ballot proposition, that information be an objective and fair presentation of the facts in accordance with the statutes, rules and PDC Interpretation No. 04-02. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/59732
59707 11/05/2019 Hillary Moralez Anna Rohrbough Rorhbough, Anna: Alleged Violation of RCW 42.17A.555 for misuse of public facilities; RCW 42.17A.320 for failure to disclose full sponsor identification on political advertising (EY 19, Nov 19) RCW 42.17A.320, RCW 42.17A.555 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on October 30, 2019. The complaint alleged that Anna Rohrbough, a candidate for Snohomish County Council, Position 2 in 2019, may have violated: (1) RCW 42.17A.555 for misuse of public facilities by using a county sheriff’s ride-along event to benefit her 2019 election campaign; and (2) RCW 42.17A.320 for failure to include complete sponsor identification in online political advertisement paid for by the 2019 campaign.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; PDC Interpretation 04-02; and the response provided by Anna Rohrbough, to determine whether the record supports a finding of one or more violations.

The complaint included an additional allegation regarding a possible breech of the signed contract Ms. Rohrbough agreed to when participating in the ride-along related to the use of what she observed during the event. Apart from the portion of the ride-along event resulting in a possible violation of RCW 42.17A.555, staff found this allegation to be outside of the PDC’s jurisdiction and did not address this part of the complaint.

Anna Rohrbough is a current elected official and was a candidate for a separate county-wide office in 2019. It appears that her failure to disclose a complete sponsor identification for online poltical advertisement sponsored by her campaign, was due to a misunderstanding the applicable statute. Sponsor identification is used to inform the public who has paid for or sponsored a political advertisement. Although the half dozen online advertisements referenced above did not contain the mailing address of the sponsor required in RCW 42.17A.320, the sponsor was still clearly identified as the 2019 Campaign to Elect Anna Rohrbough.

Staff found no evidence to prove that Ms. Rohrbough used the ride-along event to support her campaign. Ms. Rohrbough responded promptly to the complaint and has not previously been found in violation of PDC laws or rules. 

Based on these findings staff has determined that, in this instance, failure to include complete sponsor identification in online advertisements paid for by the candidate’s campaign, does not amount to a finding of a violation warranting further investigation.

PDC staff reminded Anna Rohrbough about the importance of including sponsor identification, including the name and address of the sponsor, as required on written political advertisements in accordance with the statutes and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/59707
59685 11/04/2019 Melissa O'Neill Albert Schreiber Schreiber, Albert: Alleged violations of RCW 42.17A.555 for misuse of public facilities to support election campaigns (EY 19; Nov 19) RCW 42.17A.555 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint Melissa O'Neill filed on November 2, 2019. The complaint alleged that Albert Schreiber (Respondent), a School Board Director for Stanwood-Camano School District may have violated RCW 42.17A.555 for misuse of public facilities. 

PDC staff reviewed the allegations; the applicable statutes and rules; the response provided by the Respondent to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance no evidence supports a finding of a violation that warrants further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/59685
59678 11/04/2019 Freedom Foundation (Maxford Nelsen) American Federation of State, County and Municipal Employees/Special Account American Federation of State, County and Municipal Employees Special Account (2): Alleged violations of RCW 42.17A.250 for failure to timely and accurately report as an out-of-state political committee (Oct 19) RCW 42.17A.250 Case Closed with No Evidence of Violations

A complaint was filed against American Federation of State, County and Municipal Employees, AFL-CIO Special Account (AFSCME Special Account).  The complaint alleged that AFSCME Special Account, a separate segregated fund registered with the Internal Revenue Service as a 527 political organization, may have violated RCW 42.17A.250 by failing to timely and accurately file Out-of-State Political Committee Campaign Finance Reports (C-5 reports) disclosing contributions made to Washington State Candidates and Political Committees during calendar years 2014 to 2018.

An earlier complaint was filed on July 3, 2019 against AFSMCE Special Account (PDC Case 54145) that provided copies of AFSCME’s 8872 forms filed with the IRS as a 527 segregated fund, alleging that the C-5 reports filed by AFSCME Special Account for calendar years 2014 through 2018, failed to disclose all contribution and expenditure activities undertaken by the committee on the C-5 reports. 

AFSCME Special Account legal counsel stated that on October 4, 2019, the PDC and AFSMCE executed a stipulated agreement in Case No. 54145, acknowledging violations of RCW 42.17A.250 were committed by AFSCME Special Account for failing to timely and accurately file C-5 Reports that included a $5,250 civil penalty being assessed, of which $2,000 was suspended on several conditions, and “AFSCME tendered payment of the other $3,250 on October 7.”  

Counsel stated the Freedom Foundation “filed a new complaint, alleging that AFSCME failed to timely file the same C-5 reports disclosing additional transfers made from AFSCME International to AFSMCE Special Account in calendar years 2014 and 2016.  While none of the additional transfers included funds spent in Washington State, she noted that all of the new allegations “were either indirectly contemplated by, or were addressed directly in, the final order in Case No. 54145.”  

Staff’s review of the facts found that: (1) the late reported contributions received and disclosed on the December 3, 2019 amended C-5 reports were transfers from AFSCME International to AFSCME’s Special (segregated) Account made in calendar years 2014 and 2016; (2) the 2014 late reported transfers were beyond the five-year statute of limitations for PDC action; (3) of the  total funds transferred from AFSCME International AFSCME to Special Account for calendar years 2014 through 2018, $790,000 was disclosed as being spent to make contributions to Washington State candidates and political committees, which represented less than one percent of all funds transferred ; and (4) AFSCME took prompt corrective action by filing the amended reports when their noncompliance was brought to their attention by your complaint, and after conducting an internal audit.

Based on these findings, staff has determined that the issues raised in the complaint were previously resolved by the Commission pursuant to Case No. 54145, and this complaint does not raise new issues warranting further investigation.  The PDC has dismissed the complaint in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/59678
59671 11/04/2019 Bruce Thomson Citzens for Liberty and Labor Citzens for Liberty and Labor (2): Alleged violations of Chapter 42.17A RCW for making over-limit coordinated expenditures (EY 19; Nov 19) RCW 42.17A.240, RCW 42.17A.305, WAC 390-05-210, RCW 42.17A.260, RCW 42.17A.255, RCW 42.17A.405, RCW 42.17A.235 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint Bruce Thomson filed on November 1, 2019. The complaint alleged that Citizens for Liberty and Labor (Respondent), a political committee may have violated RCW 42.17A.405 and WAC 390-05-210 for making over-limit coordinated expenditures in support of Candidate Stuckart, RCW 42.17A.235 and .240 for failure to timely and accurately report coordinated expenditures in support of Candidate Stuckart on Summary Contribution and Expenditure reports (C-4 reports), and RCW 42.17A.255, .260, and .305 for certifying independent expenditures or electioneering communications as independent, when they may have been coordinated.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; the applicable PDC reports filed by the Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation that warrants further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/59671
59665 11/04/2019 Glen Morgan NARAL Pro-Choice Washington PAC NARAL Pro-Choice Washington PAC: Alleged violations of RCW 42.17A.235 & .240 for failure to timely & accurately report contributions made in election year 2019. (Oct '19) RCW 42.17A.235, RCW 42.17A.240 Case Closed with Written Warning
  • Allegation: Alleged violations of RCW 42.17A.235 & .240 for failure to timely & accurately report contributions made in election year 2019
https://www.pdc.wa.gov/browse/cases/59665
59657 11/04/2019 Glen Morgan Washington Conservation Voters Action Fund Washington Conservation Voters Action Fund (4): Alleged violations of RCW 42.17A.260, .235 & .240 for failure to timely & accurately report independent expenditures, and provide expenditure details on reports (EY '19; Oct '19) RCW 42.17A.240, RCW 42.17A.235, RCW 42.17A.260 Resolved through Statement of Understanding

After conducting a preliminary review and assessment of complaints filed October 26, 2019 and November 18, 2019 concerning Washington Conservation Voters Action Fund, PDC Staff opened a formal investigation and held a Case Status Review, referred to as an initial hearing, on January 21, 2020 pursuant to RCW 42.17A.755 and WACs 390-37-060 and 390-37-071. 

These complaints alleged violations of RCW 42.17A.260 for failure to timely & accurately report independent expenditures made within 21 days of an election, RCW 42.17A.235 & .240 for failure to timely & accurately report independent expenditures on C-4 reports; and RCW 42.17A.240 for failure to provide sufficient expenditure details on reports.

https://www.pdc.wa.gov/browse/cases/59657
59652 11/04/2019 Kendra Cook Phyllis "Joy" Gilfilen Phyllis Joy Gilfilen (2): Alleged violations of RCW 42.17A.445(2), .265 & .235 by using campaign funds for personal use, failing to timely report a $1,000 last-minute contribution, and not timely reporting contributions & expenditures. (EY '19; Oct '19) RCW 42.17A.235, RCW 42.17A.265, RCW 42.17A.445 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on October 28, 2019. The complaint alleged that Phyllis Joy Gilfilen, a candidate for  Whatcom County Sheriff in 2019, may have violated: (1) RCW 42.17A.445(2) & WAC 390-16-238 for personal use of campaign funds; and (2) RCW 42.17A.265 for failure to timely report a contribution of $1,000 or more within forty-eight hours of receipt during the 21-days before the November 5, 2019 general election.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Ms. Gilfilen; the applicable PDC reports filed by Respondent; PDC Case 58089; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

The complaint included an additional allegation regarding “carelessness” and “negligence” for general reporting issues. Apart from the portion of reporting discrepancies or tardiness resulting in a possible violation of RCW 42.17A, staff found this allegation to be outside of the PDC’s jurisdiction and did not address this part of the complaint.

Phyllis Joy Gilfilen was an unsuccessful candidate in the 2019 Whatcom County Sheriff campaign. It appears that her failure to timely report an in-kind contribution of $1,000 or more within forty-eight hours of receipt during the 21-days before the November 5, 2019 general election, or by no later than October 28, 2019, was due to inexperience and general lack of knowledge. 

Based on these findings staff has determined that, in this instance, failure to timely report one contribution of $1,000 or more within forty-eight hours of receipt during the 21-days before the November 5, 2019 general election, does not amount to a finding of a violation warranting further investigation.

PDC staff reminded Ms. Gilfilen about the importance of the timely reporting of all campaign expenditures and contributions, specifically including the forty-eight hour disclosure of any contributions that are received during the accelerated reporting periods of $1,000 or more in the aggregate from one source within the 21-days of a general election or 7-days before a primary election, in any future PDC reports in accordance with the statutes and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/59652
59642 11/04/2019 Glen Morgan Cydney Moore Moore, Cydney (2): Alleged Violation of RCW 42.17A.235, .240 for failure to timely and accurately report expenditures on C-4 reports (EY19, Nov 19) RCW 42.17A.240, RCW 42.17A.235 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on October 31, 2019. The complaint alleged that Cydney Moore, a candidate for Burien City Council in 2019, may have violated RCW 42.17A.235 & .240 for failure to timely and accurately file Summary Full Campaign Contribution and Expenditure reports (C-4 reports) disclosing expenditures political advertising, a campaign video and candidate photos.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Cydney Moore; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Ms. Moore was a first-time candidate for public office and was the subject of a previous complaint filed during the 2019 campaign cycle. She was elected to the Burien City Council in the November 5, 2019 general election.

The response from Ms. Moore and staff’s general review of the Elect Cydney campaign website, Facebook page and political advertisement, show that the campaign used volunteer services and free online options as well as paid or professional services. Ms. Moore’s response and subsequent amendments show that the expenditure for costs related to a mailer were disclosed late.

Based on our findings staff has determined that, in this instance, failure to timely file a C-4 report disclosing one expenditure for political advertisement ten days after the general election does not amount to a finding of a violation that warrants further investigation.

PDC staff reminded Cydney Moore about the importance of the timely disclosure of all expenditure activities prior to an election in which her name appears on the ballot in order to ensure transparency for the public, and the timely filing of all future PDC reports in accordance with the statutes and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/59642
59579 11/01/2019 Glen Morgan SeaTac Progress SeaTac Progress (3): Alleged violations of RCW 42.17A.320 and .350 for failure to accurately and completely disclose top contributors on political advertising, and RCW 42.17A.240 for failure to accurately disclose contributor names (EY 19; Nov 19) RCW 42.17A.350, RCW 42.17A.240, RCW 42.17A.320 Case Closed with Reminder

On November 1, 2019, the Public Disclosure Commission (PDC) received a complaint alleging that SeaTac Progress, may have violated RCW 42.17A.320 and .350 for failure to accurately and completely disclose top contributors on political advertising, and RCW 42.17A.240 for failure to accurately disclose contributors names. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the applicable PDC filed by SeaTac Progress (Committee); and reviewed their data in the PDC database, to determine whether the record supports a finding of one or more violations. 

Staff determined that three other contributors gave more that $250 to the Committee before the mailer at issue in this complaint was mailed to the voters but were not included in the Top Five Contributors list. Staff also found that the names of two of the contributors depicted on the mailer were not listed correctly. 

Based on the above, staff issued a reminder letter to the Committee regarding the importance of making sure that mailers depict accurate Top Five Contributors and Top Three Donors to the Committee when applicable in future years in accordance with the PDC laws and rules. 

Based on this information, the PDC staff dismissed this matter in accordance with RCW 42.17A.755(1). 

 

https://www.pdc.wa.gov/browse/cases/59579
59572 11/01/2019 Bradley J. Williamson Amy Falcone Falcone, Amy: Alleged violation of RCW 42.17A.555 by using public office or agency facilities to assist an election campaign. (EY '19; Oct '19) RCW 42.17A 555 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on October 25, 2019. The complaint alleged that Amy Falcone, a candidate for Kirkland City Council, Position 6 in 2019, may have violated RCW 42.17A.555 for misuse of public facilities by using a City of Kirkland police department ride-along event to benefit her 2019 election campaign.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; PDC Interpretation 04-02; and the response provided by Amy Falcone, to determine whether the record supports a finding of one or more violations.

The complaint included an additional allegation regarding a possible ethics violation. Apart from the portion of the ride-along event resulting in a possible violation of RCW 42.17A.555, staff found this allegation to be outside of the PDC’s jurisdiction and did not address this part of the complaint.

Amy Falcone is a first-time candidate for public office in 2019. It appears that Ms. Falcone did not intend to imply that the Kirkland Police Department endorsed or otherwise supported her 2019 Kirkland City Council campaign by including her campaign logo in close proximity to photos bearing the name of the department. In addition, City of Kirkland staff requested that Ms. 
Falcone remove the October 18, 2019 Facebook post. The post was removed two days later on October 20, 2019.

Staff found no evidence to prove that Ms. Falcone used the ride-along event to support her campaign. Ms. Falcone responded promptly to the complaint and has not previously been found in violation of PDC laws or rules. 

Based on these findings staff has determined that, in this instance, no evidence supports a finding of a violation that warrants further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/59572
59569 11/01/2019 Glen Morgan Mia Gregerson Gregerson, Mia (4): Alleged violations of RCW 42.17A.235 and .240 for failure to timely and accurately report transfers of funds and expenditures from surplus funds (EY 19; Oct 19) RCW 42.17A.240, RCW 42.17A.235 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review two complaints filed by Glen Morgan, PDC Case #59019 filed October 21, 2019 & Case #59569 filed on October 31, 2019. The complaints alleged that Mia Gregerson, a Representative in Legislative District 33 may have violated: (1)RCW 42.17A.240 for failure to timely and accurately file Summary Full Campaign Contribution and Expenditure reports (C-4 reports) disclosing expenditures made to political consultant, John Wyble, or WinPower Strategies; (2) RCW 42.17A.430 for misuse of surplus funds; (3) RCW 42.17A.490 for improper transfer of funds received for a 2011 City of SeaTac campaign to a 2014 State Representative campaign; (4) RCW 42.17A.235, .240 & WAC 390-16-037 for failure to timely and accurately describe expenditures on C-4 reports; and (5) RCW 42.17A.240 for failure to timely and accurately file C-4 reports disclosing surplus funds.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Rep. Gregerson; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

The two complaints included six separate allegations in total with some overlapping evidence provided between them. During staff’s review, evidence was found to substantiate two of the allegations in whole and one in part. Rep. Gregerson’s response confirmed that she believed she had improperly used surplus funds in one instance in March 2017 as described in Allegation 2 and she suggested an appropriate remedy. The three expenditure descriptions included in Allegation 4 required edits after the complaint was received, and the receipt of the $10,000 transfer to the Gregerson Surplus Funds Account was disclosed late as described in Allegation 5.

Rep. Gregerson has been a candidate and elected or appointed official since 2007. She promptly responded to the complaints, submitted amendments and provided details regarding missing or otherwise deficient information.  It appears that the errors made related to her Surplus Funds Account and the insufficient descriptions provided in her 2016 campaign, were not done to mislead the public or prevent transparency. Rep. Gregerson has not been found in violation of RCW 42.17A within the past five years.

Based on our findings staff has determined that, in this instance, failure to include accurate descriptions for three expenditures in a 2016 campaign, failure to timely file receipt of a transfer into the Gregerson Surplus Funds Account, and a misuse of surplus funds that required reimbursement to correct, does not amount to a finding of a violation that warrants further investigation.

PDC staff is reminding Rep. Gregerson about the importance of including detailed descriptions for all expenditures disclosed on C-4 reports, the timely disclosure of all contribution and expenditure activities related to the Surplus Funds Account, and to review all expenditures of surplus funds to ensure they are permissible in accordance with the statutes and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1)

https://www.pdc.wa.gov/browse/cases/59569
59568 11/01/2019 Alvin H McNeil Chief Ben Andrews Clallam Fire Protection District 3 Officials: Alleged Violation of RCW 42.17A.555 for misuse of public facilities (EY 19, Nov 19) RCW 42.17A.555 Case Closed with Written Warning

The complaint alleged Clallam County Fire Protection District No. 3 officials or staff (the District) may have violated RCW 42.17A.555 by using, or authorizing the use of, fire district facilities to produce and distribute a newsletter in November 2019 that provided citizens with information in support of Emergency Medical Services Property Tax Levy (Proposition No. 1) in the November 2019 election.

PDC staff has determined that in this instance, the wording used in the 2019 mailer does not amount to a violation warranting further investigation. 

Pursuant to WAC 390-37-060(1)(d), District officials and staff will receive a formal written warning concerning the requirement for election-related information, distributed by a public agency using public funds, to be a fair and objective presentation of the facts, and to not include language or photographs provoking an emotional reaction in support of or in opposition to a ballot proposition. 

The formal written warning will include staff's expectation that Clallam County Fire Protection District No. 3 and its staff will review and follow PDC guidance in PDC Interpretation #04-02. 

The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/59568
59566 11/01/2019 Jeanne Crevier Rosamaria Graziani Graziani, Rosamaria: Alleged Violation of RCW 42.17A.335 for false or defamatory statements in political advertising (EY 19, Oct 19) RCW 42.17A.335 Case Closed with No Evidence of Violations

The complaint alleged Rosamaria Graziani may have violated RCW 42.17A.335 for political advertising that contains false statements constituting libel or defamation.

RCW 42.17A.335 prohibits a person from sponsoring, with actual malice, a false statement of material fact about a candidate for public office that constitutes libel or defamation per se. The violation must be proven by clear and convincing evidence. There was no clear and convincing evidence of defamatory or libelous statements made with actual malice. 

Based on these findings staff has determined, in this instance, the alleged violation of political advertising that contains false statements about a candidate constituting libel or defamation, does not amount to a violation warranting further investigation. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/59566
59563 11/01/2019 Roger Lenk and Jerry Martin Chuck Torelli Torelli, Chuck: Alleged violations of RCW 42.17A.205 for failure to accurately disclose committee officers, and RCW 42.17A.235 for failure to maintain books of account open for public inspection (EY 19; Oct 19) RCW 42.17A.235, RCW 42.17A.205 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint Roger Lenk and Jerry Martin filed on October 31, 2019. The complaint alleged that Chuck Torelli (Respondent), a 2019 candidate for City Council Member for the City of Kennewick may have violated RCW 42.17A.205 for failure to accurately disclose Treasurer performing more than ministerial duties on the Candidate Registration; and RCW 42.17A.235 for failure to maintain books of account and make them available for public inspection.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the responses provided by the Respondent; the applicable PDC reports filed by the Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to maintain books of account, current within one business day, does not amount to a violation that warrants further investigation.

PDC staff is reminding Chuck Torelli about the importance of complete and accurate record-keeping within one business day in the period ten days before an election. PDC staff expects Chuck Torelli to completely document all contribution and expenditure activity in the campaign books of account, and make that information available for public inspection in the future.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/59563
59543 10/31/2019 Maria Pierce DuPont Citizens for Paramedics DuPont Citizens for Paramedics: Alleged violation of WAC 390-16-125 for exceeding Mini Reporting limitations by accepting contributions from one source over $500 (EY 19; Oct 19) WAC 390-16-125 Resolved through Statement of Understanding

The Public Disclosure Commission (PDC) has completed its review of the complaint Maria Pierce filed on October 31, 2019. The complaint alleged that DuPont Citizens for Paramedics (Committee), a local ballot committee registered with the PDC in support of Proposition 1, a City of DuPont Levy Lid Lift for Fire and Medic One, appearing on the November 6, 2019 general election ballot may have violated WAC 390-16-125 by exceeding the contribution limitations of the Mini Reporting Option by accepting contributions from one source that exceeded $500.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements for a local ballot committee; the responses provided by the Committee Officers; the applicable PDC reports filed by the Committee; and queried the Committee’s data in the PDC contribution and expenditure database.

The $150 civil penalty assessed against the Dupont Citizens for Paramedics in this matter was done in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule).  By completing the SOU, Dupont Citizens for Paramedics acknowledged a violation of WAC 390-16-125 for exceeding the contribution limits of the Mini Reporting Option by receiving and depositing the $2,500 monetary contribution from the DuPont Professional Fire Fighter Local 3829.  The $150 penalty paid by the DuPont Citizens for Paramedics resolves the allegation listed in your complaint.

Based on this information, and that the DuPont Citizens for Paramedics: (1) was a first-time ballot committee; (2) was unfamiliar with the committee reporting requirements; and (3) completed an SOU, paid a $150 civil penalty, and acknowledged a violation of WAC 390-16-125, staff has determined in this instance, the exceeding the limitations of the Mini Reporting Option do not warrant further investigation.

PDC staff has reminded the DuPont Citizens for Paramedics to adhere to the PDC reporting requirements in the future should the committee register and report as a Ballot Committee or political committee in accordance with PDC statues and rules. 

Based on these facts, PDC staff is dismissing the complaint in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/59543
59542 10/31/2019 Glen Morgan Partnering for Spokane's Future PAC Partnering for Spokane's Future PAC: Alleged violation of RCW 42.17A.240 for failure to provide sufficient expenditure details on C-4 reports for election year 2018. (Oct '19) RCW 42.17A.240 Investigation of Possible Violation

After conducting a preliminary review and assessment of a complaint filed October 23 , 2019 concerning Partnering for Spokane's Future PAC, PDC staff opened a formal investigation and held a case status review, referred to as an initial hearing, on January 15, 2020 pursuant to RCW 42.17A.755, and WACs 390-37-060 and 390-37-071.

The complaint alleges Partnering for Spokane's Future PAC may have violated RCW 42.17A.240 by failing to provide sufficient expenditure details on C-4 reports for election year 2018. 

https://www.pdc.wa.gov/browse/cases/59542
59539 10/31/2019 Glen Morgan Washington Conservation Voters Action Fund Washington Conservation Voters Action Fund (3): Alleged violations of RCW 42.17A.240 and WAC 390-16-037 for failure to completely and accurately disclose expenditure details (EY 19; Oct 19) WAC 390-16-037, RCW 42.17A.240 Resolved through Statement of Understanding

After conducting a preliminary review and assessment of a complaint filed October 30, 2019 concerning Washington Conservation Voters Action Fund, PDC Staff opened a formal investigation and held a Case Status Review, referred to as an initial hearing, on January 21, 2020 pursuant to RCW 42.17A.755 and WACs 390-37-060 and 390-37-071. 

This complaint alleged violations of RCW 42.17A.240 and WAC 390-16-037 for failure to completely and accurately disclose expenditure details, including the number of items printed for political advertising.

https://www.pdc.wa.gov/browse/cases/59539
59523 10/31/2019 Tallman Trask Choozle, Inc. Choozle, Inc.: Alleged violations of RCW 42.17A.345 and WAC 390-18-050 for failure to promptly provide documents and books of account concerning political advertising, upon request from any person (EY 19; Oct 19) RCW 42.17A.345, WAC 390-18-050 Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the complaint Tallman Trask filed on October 30, 2019. The complaint alleged that Choozle, Inc. (Respondent), a commercial advertiser, may have violated RCW 42.17A.345 and WAC 390-18-050 for failure to provide documents and books of account detailing the exact nature and extent of political advertising services rendered, within 24 hours of request from any person.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the responses provided by the Respondent; to determine whether the record supports a finding of one or more violations.

Based on our findings, staff has determined that, in this instance, failure to provide access to documents and books of account for commercial advertising within 24 hours of request does not amount to a violation that warrants further investigation.

Pursuant to WAC 390-37-060(1)(d), Choozle, Inc. will receive a formal written warning concerning failure to timely facilitate public inspection of documents and books of account for political advertising and electioneering communications targeting elections in Washington State. The formal written warning will include staff’s expectation that Choozle, Inc. facilitates timely and complete access to books of account in the future. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/59523
59521 10/31/2019 Tallman Trask Twitter, Inc. Twitter, Inc.: Alleged violations of RCW 42.17A.345 and WAC 390-18-050 for failure to promptly provide documents and books of account concerning political advertising, upon request from any person (EY 19; Oct 19) RCW 42.17A.345, WAC 390-18-050 Referred to Attorney General by Commission

On June 15, 2020, pursuant to RCW 42.17A.755 and WAC 390-37-042, the Public Disclosure Commission (PDC) referred of the above-cited matter, PDC Case 59521, from the PDC to the Washington State Attorney General's Office (AGO) for appropriate action under Chapter 42.17A RCW. The Executive Director's referral, in which Commission Chair David Ammons concurs, is based on PDC staff’s assessment, including information received from the Respondent, of a complaint received by the PDC on October 30, 2019, filed by Tallman Trask IV against Twitter, Inc., as discussed in the letter attached below. 

Mr. Trask lodged a formal complaint with the PDC alleging that Twitter did not honor his requests to inspect the company’s books of account for certain political advertisements that were reported as placed through Twitter on reports of expenditures filed with the PDC (see complaint for specific sponsor and report information).


The PDC’s review to date of this matter has led PDC staff to the conclusion that the additional authority, resources and penalty discretion of the AGO under the Fair Campaign Practices Act (RCW 42.17A) are implicated and could be warranted.


The PDC received correspondence from counsel for Twitter, Inc., on June 9, 2020, in which counsel states, in part, that due to an “engineering issue”:

[A]fter Twitter decided to ban political advertisements on its platform, Twitter de-certified political advertising accounts, and these accounts no longer have funding instruments associated with them. An unintended and unanticipated consequence of this de-certification process was that data previously stored within the database was lost or irretrievably corrupted. So even if Twitter once collected billing names associated with these political advertisements as a part of the billing process, Twitter no longer possesses this information.

Twitter cites similar “engineering issues” for the unavailability of other information commercial advertisers are required to maintain and make available for inspection, including complete sponsor addresses, payment dates, and demographics of audiences targeted and reached. See WAC 390-18-050.


Twitter further states that these engineering issues are “related to Twitter’s decision to stop accepting political advertisements starting November 22, 2019,” weeks after Mr. Trask’s complaint was filed with the PDC and nearly two months after Mr. Trask alleges he initially requested to inspect Twitter’s books of account.


Based on PDC staff’s assessment of the complaint, it appears that Twitter may have committed violations of RCW 42.17A. Further, Twitter appears to have—inadvertently, the company asserts—destroyed records relevant to the inquiry and required to be maintained for no less than five years after the date of the applicable election, RCW 42.17A.345.


Because these circumstances may warrant additional authority to ensure compliance and reach an appropriate resolution, the PDC referred this matter to the AGO, pursuant to RCW 42.17A.755(4).

https://www.pdc.wa.gov/browse/cases/59521
59520 10/31/2019 Glen Morgan Anthony Oddo Oddo, Anthony: Alleged Violation of RCW 42.17A.240 for failure to accurately and completely report expenditures on expenditure reports (C-4 reports) (EY 19, Oct 19) RCW 42.17A.240 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint Glen Morgan filed on October 30, 2019. The complaint alleged that Anthony Oddo (Respondent), a Candidate for City Council Member for City of Bainbridge Island may have violated RCW 42.17A.240 for failure to accurately and completely file Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing details of expenditures undertaken by the Campaign.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to file complete and accurate expenditure details on C-4 reports does not amount to a violation that warrants further investigation.

PDC staff is reminding Anthony Oddo about the importance of the complete and accurate disclosure of all expenditure activities, and the complete and accurate filings of all future PDC reports in accordance with the statutes and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/59520
59504 10/31/2019 Jill gregerson Scott Whelpley Whelpley, Scott: Alleged Violation of RCW 42.17A.235, .240 for failure to timely file contribution and expenditure reports (C-3 & C-4 reports) (EY 19, Oct 19) RCW 42.17A.240, RCW 42.17A.235 Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the complaint Jill Gregerson filed on October 29, 2019. The complaint alleged that Scott Whelpley, a candidate for City Council Member for City of Mukilteo may have violated RCW 42.17A.235, .240 for failure to timely and accurately file Monetary Contribution reports and Summary Full Campaign Contribution and Expenditure reports, disclosing contributions and expenditures undertaken by the Campaign.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the responses provided by the Respondent; the applicable PDC reports filed by the Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to timely and accurately file the contribution and expenditure reports for the 2015 and 2019 elections does not amount to a violation that warrants further investigation.

Pursuant to WAC 390-37-060(1)(d), Scott Whelpley will receive a formal written warning concerning failure to timely disclosure of all contribution and expenditures. The formal written warning will include staff’s expectation that Scott Whelpley timely files all future required reports of contributions and expenditures. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/59504
59475 10/30/2019 Tallman Trask Google, LLC Google, LLC (3): Alleged violations of RCW 42.17A.345 and WAC 390-18-050 for failure to promptly provide documents and books of account concerning political advertising, upon request from any person (EY 19; Oct 19) RCW 42.17A.345 Investigation of Possible Violation
  • Allegation: Violation of RCW 42.17A.345 and WAC 390-18-050 for failure to provide documents and books of account detailing the exact nature and extent of political advertising services rendered, within 24 hours of request from any person.
https://www.pdc.wa.gov/browse/cases/59475
59437 10/30/2019 Glen Morgan Washington Fairness Coalition Washington Fairness Coalition: Alleged violation of RCW 42.17A.320 for failure to disclose, in sponsor identification, the top 3 donors to the political committees listed as top 5 contributors. (EY '19; Oct '19) RCW 42.17A.320 Case Closed with No Evidence of Violations

The complaint alleged Washington Fairness Coalition, a 2019 Ballot Proposition Committee supporting Referendum 88, may have violated RCW 42.17A.320 by failing to disclose the “Top Three Donors to PAC Contributors” in political advertising.

Because incidental committees are not political committees, they may be listed as a Top 5 Contributor without further disclosure concerning the incidental committee. You also alleged WFC needed to disclose the Top 3 Donors to the Seattle Foundation. However, the Seattle Foundation is not listed as one of WFC’s Top 5 Contributors, and even if it was listed as a Top 5 Contributor, it is not a political committee. None of the Top 5 Contributors to WFC are political committees, and as such, the requirement to list the Top 3 non-PAC donors to the Top 5 Contributors is not applicable. 

Based on these findings, staff has determined that, in this instance, the alleged failure to disclose the Top 3 Donors to a PAC’s Top 5 Contributors is not a violation that warrants further investigation. The PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/59437
59412 10/29/2019 Glen Morgan Elizabeth Hallock Hallock, Elizabeth (3): Alleged violations of RCW 42.17A.240 and WAC 390-16-037 for failure to accurately and completely disclose expenditure details (EY 19; Oct 19) WAC 390-16-037, RCW 42.17A.240 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on October 29, 2020. The complaint alleged that Elizabeth Hallock, a candidate for Yakima City Council, Position 4 in 2019, may have violated RCW 42.17A.235, .240 & WAC 390-16-037 for failure to timely and accurately describe expenditures on Summary Full Campaign Contribution and Expenditure reports (C-4 reports) expenditures undertaken by the Campaign.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Elizabeth Hallock; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on activity disclosed on C-4 reports, the 2019 Liz Hallock for Yakima City Council campaign reported more than $30,000 in total campaign activity and was entirely funded by the candidate via in-kind contributions. Ms. Hallock promptly responded to the complaint and submitted amendments to provide details regarding missing or otherwise deficient information. Although Ms. Hallock has previous experience as a candidate, it appears that the lack of detail provided for her out-of-pocket expenditures were not done to mislead the public or prevent transparency.

Based on our findings staff has determined that, in this instance, failure to include complete descriptions for in-kind contributions from the candidate, does not amount to a finding of a violation that warrants further investigation.

PDC staff reminded Elizabeth Hallock about the importance of including detailed descriptions for all in-kind contributions disclosed on C-4 reports, in accordance with the statutes and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/59412
59410 10/29/2019 Glen Morgan Kevin Schilling Schilling, Kevin: Alleged violations of RCW 42.17A.235 and .240 for failure to timely and accurately report expenditures for political advertising (EY 19; Oct 19) RCW 42.17A.235, RCW 42.17A.240 Case Closed with Written Warning

On October 29, 2019, the Public Disclosure Commission (PDC) received a complaint alleging that Kevin Schilling, a first-time candidate for City Council Member position  for the City of Burien in 2019, may have violated RCW 42.17A.235 and .240 for failure to timely and accurately report expenditures for political advertising.  

Staff review found that Mr. Schilling should have reported all the orders placed for political advertising in June 2019, on the original 21-Day Pre-Primary C-4 report as required by law.  Based on this determination, pursuant to WAC 390-37-060(1)(d), staff issued a formal written warning to Mr. Schillings concerning his failure to timely and accurately report expenditures for political advertising. The Commission will consider this formal written warning in deciding on further Commission action if there are future violations of PDC laws and rules. 

Based on this information, Staff dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/59410
59408 10/29/2019 Glen Morgan Fair and Equal Whatcom PAC Fair & Equal Whatcom PAC: Alleged Violation of RCW 42.17A.240 for failure to accurately and completely report expenditures on C-4 reports (EY 15, Oct 19) RCW.42.17A.240 Request for Technical Correction

The Public Disclosure Commission (PDC) has completed its review of the complaint Glen Morgan filed on October 26, 2019. The complaint alleged that Fair & Equal Whatcom (Respondent), a single election political committee, may have violated RCW 42.17A.240 for failure to provide accurate and complete descriptions and details on Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; the applicable PDC reports filed by the Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to accurately and completely report expenditures on reports filed does not amount to a violation that warrants further investigation.

Fair & Equal Whatcom made minor or ministerial errors on required reports, which did not materially impact the public interest. Upon notification of these errors, Fair & Equal Whatcom timely amended their reports, making the necessary technical corrections as requested by staff.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/59408
59380 10/29/2019 Nicholas Gullickson David Chan Chan, David (4): Alleged Violation of RCW 42.17A.555 for misuse of public office or public facilities for political campaigning (EY 19, Oct 19) RCW 42.17A.555 Case Closed with No Evidence of Violations

The complaint alleged David Chan, a 2019 Candidate for South Snohomish Fire and Rescue Regional Fire Authority Fire Commissioner Position 4, may have violated RCW 42.17A.555 by using fire district facilities to assist his and another candidate’s campaign, by campaigning in his official uniform supplied with taxpayer funds. You provided photos of Chan waving campaign signs in a shirt with the South Snohomish Fire and Rescue Regional Fire Authority Fire logo. 

In the response, Chan provided the purchase order and check he used to pay for the shirt worn in the photographs provided in the complaint. PDC guidance (PDC Interpretation 04-02) for local government agencies in election campaigns states the use of self-purchased uniforms is permitted to support a campaign.  

Based on these findings staff has determined, in this instance, the alleged use of public facilities of South Snohomish Fire and Rescue to assist David Chan’s re-election campaign and the campaign of another candidate, does not amount to a violation warranting further investigation. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/59380
59376 10/29/2019 Jeffrey Brittig, Joseph Cooper Michael Sheetz Sheetz, Michael: Alleged violations of RCW 42.17A.555 by using public office or agency facilities to assist an election campaign. (EY '19; Oct '19) RCW 42.17A.555 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint Jeffrey Brittig filed on October 25, 2019 and the complaint filed by Joseph D. Cooper on November 10, 2019. Staff reviewed the complaint filed by Mr. Cooper and, finding the allegations similar to those already being investigated under the original complaint filed by Mr. Brittig, merged the two complaints and notified Mr. Cooper of this action on November 15, 2019. The complaints alleged that Michael Sheetz, incumbent Fire Commissioner for Mason County Fire Protection District 6, Position 2 and candidate in the 2019 election, may have violated RCW 42.17A.555 by using public facilities to support his 2019 re-election campaign.

PDC staff reviewed the allegations; the applicable statutes and rules; PDC Interpretation 04-02; and the response provided by Commissioner Sheetz, to determine whether the record supports a finding of one or more violations.

During staff’s review of the allegations and materials provided in the complaints, no evidence was found to confirm that MCFD 6 maintained a Facebook page or was the creator of the page for The Mighty Mason 6. In addition, no evidence was found to connect Michael Sheetz to the mailed political advertisement sponsored by Friends of the Union Fire Department.

Based on these findings staff has determined that no evidence supports a finding of a violation warranting further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/59376
59370 10/29/2019 Phillip Tavel Lisa Herbold Herbold, Lisa: Alleged violation of RCW 42.17A.335 for sponsoring false statements of material fact about Candidate Tavel in political advertising (EY 19; Oct 19) RCW 42.17A.335 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint Phillip Tavel filed on October 28, 2019. The complaint alleged that Lisa Herbold (Respondent), a 2019 candidate for Seattle City Council, may have violated RCW 42.17A.335 for sponsoring with actual malice, false statements of material fact in political advertising, constituting libel per se, about Candidate Phil Tavel.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the response provided by the Respondent to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, insufficient evidence supports a finding of a violation that warrants further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/59370
59361 10/29/2019 Amy Hughes Rebeca Muñiz Muñiz, Rebeca: Alleged violations of RCW 42.17A.235 for failure to timely report contributions and expenditures (EY 19; Oct 19) RCW 42.17A.235 Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the complaint Amy Hughes filed on October 28, 2019. The complaint alleged that Rebeca Muñiz, a 2019 candidate for School Director for the Seattle School District, may have violated RCW 42.17A.235 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Muñiz campaign.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; the applicable PDC reports filed by the Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to timely file reports of contributions and expenditures does not amount to a violation that warrants further investigation.

Pursuant to WAC 390-37-060(1)(d), Rebeca Muñiz will receive a formal written warning concerning failure to timely file reports of contributions and expenditures. The formal written warning will include staff’s expectation that Rebeca Muñiz timely files all future required reports of contributions and expenditures. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/59361
59360 10/29/2019 Bradley Mertens Patrick Burch Burch, Patrick: Alleged violations of Chapter 42.17A RCW for unauthorized transfer of candidate funds to another candidate, failure to report independent expenditures, and failure to disclose complete sponsor identification (EY 19; Oct 19) RCW 42.17A.255, RCW 42.17A.430, RCW 42.17A.320 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint Bradley Mertens filed on October 29, 2019. The complaint alleged that Patrick Burch, a 2019 candidate for Fire Commissioner for Spokane Fire Protection District 01, may have violated RCW 42.17A.430 for unauthorized contributions from active candidate funds to support other candidate campaigns; RCW 42.17A.255 for failure to disclose independent expenditures in support of other candidate campaigns; RCW 42.17A.320 for failure to disclose proper sponsor identification on political advertising.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the responses provided by the Respondent; the applicable PDC reports filed by the Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to timely receive reimbursement for a joint expenditure within two business days, and failure to disclose sponsor identification on a candidate campaign Facebook page, do not amount to violations that warrant further investigation.

PDC staff is reminding Patrick Burch about the importance of timely receiving reimbursement for joint expenditures and completely and accurately disclosing sponsor identification on political advertising. PDC staff expects Patrick Burch to timely, completely, and accurately comply with PDC laws and rules in the future.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/59360
59334 10/28/2019 Glen Morgan Susan Boundy-Sanders Boundy-Sanders, Susan: Alleged violations of RCW 42.17A.240 and WAC 390-16-037 for failure to accurately and completely disclose expenditure details (EY 17; Oct 19) RCW 42.17A.240, WAC 390-16-037 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint Glen Morgan filed on October 28, 2019. The complaint alleged that Susan Boundy-Sanders (Respondent), a 2017 candidate for City Council Member for the City of Woodinville, may have violated RCW 42.17A.240 and WAC 390-16-037 for failure to accurately and completely disclose expenditure details.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; and the applicable PDC reports filed by the Respondent, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to accurately and completely disclose expenditure details does not amount to a violation that warrants further investigation.

PDC staff is reminding Susan Boundy-Sanders about the importance of accurately and completely disclosing expenditure details. PDC staff expects the timely, complete, and accurate disclosure of all contribution and expenditure details on required reports in the future.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/59334
59326 10/28/2019 Robin Carl Johnson Jeff Sinker Sinker, Jeff: Alleged violation of RCW 42.17A.235 & .240 for failure to timely & accurately report contributions & expenditures. (EY '19; Oct '19) RCW 42.17A.235, RCW 42.17A.240 Case Closed with Reminder
  • Alleged violation of RCW 42.17A.235 & .240 for failure to timely & accurately report deposits, contributions & expenditures by filing C-3 & C-4 reports with the PDC
https://www.pdc.wa.gov/browse/cases/59326
59315 10/28/2019 Glen Morgan Citizens for Lopez Solid Waste Levy Citizens for Lopez Solid Waste Levy: Alleged violations of RCW 42.17A.205(5) & .240(11) & WAC 390-16-011A by failing to include sponsor name in registered committee name on reports during election years 2016 & 2019. (Oct '19) RCW 42.17A.240, wac 390-16-011a, RCW 42.17A.205 Case Closed with Reminder
  • Allegation One: Alleged violation of RCW 42.17A.205(5) & WAC 390-16-011A for failure to include sponsor name (Solid Waste Alternative Program) in registered committee name on C-1PC report during election years 2016 & 2019
  • Allegation Two: Alleged violation of RCW 42.17A.240(11) by failing to include sponsor name in registered committee name on C-3 report
https://www.pdc.wa.gov/browse/cases/59315
59313 10/28/2019 Glen Morgan Megan Dunn Dunn, Megan: Alleged Violation of RCW 42.17A.240 for failure to accurately and completely file reports of expenditures (C-4 reports) (EY 19, Oct 19) RCW.42.17A.240 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint Glen Morgan filed on October 26, 2019. The complaint alleged that Megan Dunn (Respondent), a Candidate for County Council Member for Snohomish County Council may have violated RCW 42.17A.240 for failure to completely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; the applicable PDC reports filed by the Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign does not amount to a violation that warrants further investigation.

PDC staff is reminding Megan Dunn about the importance of the timely, complete and accurate disclosure of all contribution and expenditure activities, including the filing fee, and the timely, complete and accurate filings of all future PDC reports in accordance with the statutes and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/59313
59312 10/28/2019 Glen Morgan SeaTac Progress PAC (sponsored by John Wyble) SeaTac Progress PAC (sponsored by John Wyble) (2): Alleged violations of RCW 42.17A.320 for failure to accurately disclose Top 5 Contributors on political advertising and .240 for failure to accurately disclose contributor address (EY 19; Oct 19) RCW 42.17A.320, RCW 42.17A.240 Case Closed with Reminder

On October 25, 2019, the Public Disclosure Commission (PDC) received a complaint alleging that SeaTac Progress, may have violated RCW 42.17A.240 by failing to accurately disclose contributor address and RCW 42.17A.320 for failure to accurately disclose the Top 5 Contributors on political advertising. 

PDC staff reviewed the allegations; the applicable statutes, rules and reporting requirement; the applicable PDC reports filed by SeaTac Progress (Committee); and reviewed their data in the PDC database, to determine whether the record supports a finding of one or more violations. 

Staff determined that on October 11, 2019, the same day that the Top Five Contributors' donations/contributions were received, the Committee also received over $1000 in contributions each from two separate contributors that were not included in the Top Five Contributors on the mailer. 

Staff reminded the Committee about the importance of making sure that mailers depict the accurate Top Five Contributors in future years in accordance with the PDC laws and rules. 

Based on this information, the PDC staff dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/59312
59303 10/28/2019 Erik Larson Pete Schave Schave, Pete: Alleged Violation of RCW 42.17A.020 and WAC 390-16-043 for failure to provide access to campaign records and books of account for public inspection(EY 19, Oct 19) WAC 390-16-043 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint Erik Larson filed on October 25, 2019. The complaint alleged that Pete Schave (Respondent), a Candidate for Mayor for City of Aberdeen may have violated RCW 42.17A.020, .235 and WAC 390-16-043 for failure to provide access to campaign records and books of account for public inspection.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements and the response provided by the Respondent to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance there is no evidence to support a finding of a violation and does not warrant further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/59303
59299 10/28/2019 Douglas Speas Camas Taxpayers Alliance (No to Camas Pool Bond) Camas Taxpayers Alliance (No to Camas Pool Bond): Alleged violations of RCW 42.17A.205, .235, .240 & .220(4) for failure to register as a political committee, timely & accurately report contributions & expenditures; and by accumulating more than $300 in unidentified contributions. (EY '19; Oct '19) RCW 42.17A.205, RCW 42.17A.220, RCW 42.17A.240, RCW 42.17A.235 Case Closed with Reminder
  • Allegation One: Alleged violation of RCW 42.17A.205 for failure to register as a political committee
  • Allegation Two: Alleged violation of RCW 42.17A.235 & .240 for failure to timely & accurately report contributions & expenditures
  • Allegation Three: Alleged violation of RCW 42.17A.220(4) by accumulating more than $300 in unidentified contributions
https://www.pdc.wa.gov/browse/cases/59299
59238 10/25/2019 Glen Morgan Seattle Firefighters Union, Local 27 Voluntary PAC Seattle Fire Fighters Union Local 27: Alleged Violation of RCW 42.17A.420 for for exceeding contribution limitations within 21 days of an election (EY 17, Oct 19) RCW 42.17A.420 Case Closed with Reminder

On October 24, 2019, the Public Disclosure Commission (PDC) received a complaint alleging that the Seattle Firefighters Union Local 27 Voluntary PAC, a committee registered with the PDC in 2016 as an Other Political Committee, may have violated RCW 42.17A.420 by accepting contributions exceeding $5,000 from a single source within twenty-one days of the November 7, 2017 general election. 

PDC staff reviewed the allegation, including the applicable statutes, rules and the reporting requirement and found that prior to receiving the $25,000 contribution from IAFF PAC, the Committee had received $101,295 in total contributions received and made $85,365 in total expenditures as of October 26, 2017. The Committee's 2017 expenditures totaled $87,370, so according to staff's calculations, none of the IAFF PAC's $25,000 contribution was used to support or oppose candidates for the 2017 general election. In addition, the January 2018 C-4 report filed by the Committee disclosed $49,627 in surplus 2017 Committee funds were carried forward into calendar year 2018, which further confirmed that those had not been spent in 2017. 

Based on this finding staff determined that, in this instance, accepting a contribution exceeding $5,000 from a single source within twenty-one days of a general election, does not amount to a violation that warrants further investigation. 

However, staff reminded the Committee about the importance of the statutory restriction on accepting contributions exceeding  $5,000 from a single source within twenty-one days of a general election, including all other  applicable statutes and rules. 

Based on this information, staff dismissed this matter in accordance with RCW 42.17A.755(1).  

https://www.pdc.wa.gov/browse/cases/59238
59237 10/25/2019 Glen Morgan Fuse Votes PAC Fuse Votes (2): Alleged Violation of RCW 42.17A.420 for for exceeding contribution limitations within 21 days of an election (EY 16, Oct 19) RCW 42.17A.420 Case Closed with No Evidence of Violations

On October 24, 2019, the Public Disclosure Commission (PDC) received a complaint alleging that Fuse Votes, a committee registered with the PDC in 2016 as an “Other Political Committee,” may have violated RCW 42.17A.420 by exceeding contribution limitations within 21 days of an election in 2016. 

PDC staff reviewed the allegation; the applicable statutes, rules, and reporting requirements; and the response filed by Fuse Votes (Committee); and the applicable PDC reports filed by Committee to determine whether the record supports a finding of one or more violations. 

Staff found the Committee filed a C-3 report listing $8,000 contribution from SEIU 925 Local Services PAC (SEIU) as having been received on November 8, 2016. However, upon review of its response to this complaint together with the scanned copies of a deposit slip and the check from SEIU, it appears this was a typographical oversight by the Committee’s treasurer. Based on the deposit slip and the copy of the check, the check was received on November 28, 2016, as opposed to November 8, 2016 as alleged in the complaint, and deposited on the same day (November 28, 2016). 

Based on these findings staff determined that no evidence supports a finding of a violation warranting further investigation. 

Based on this information, PDC dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/59237
59233 10/25/2019 Glen Morgan Smart Reforms for a Better Spokane Smart Reforms for a Better Spokane: Alleged violations of RCW 42.17A.240 for failure to accurately disclose contributor address and expenditure details (EY 19; Oct 19) wac 390-16-205, RCW 42.17A.240, WAC 390-16-037 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint Glen Morgan filed on October 25, 2019. The complaint alleged that Smart Reforms for a Better Spokane (Sponsored by Standard Trust), a political committee, may have violated RCW 42.17A.240 for failure to accurately and completely disclose contributor addresses on Monetary Contribution reports (C-3 reports); RCW 42.17A.240, WAC 390-16-037, and WAC 390-16-205 for failure to accurately and completely disclose expenditure details, including the number of items printed for political advertising, and sub-vendors utilized by the campaign, on Summary Full Campaign Contribution and Expenditure reports (C-4 reports); and RCW 42.17A.205, RCW 42.17A.320, and WAC 390-16-011A for failure to disclose the name of Standard Trust as the sponsoring person in the committee’s name on the Political Committee Registration (Registration) and on political advertising.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; the applicable PDC reports filed by the Respondent; queried the Respondent’s data in the PDC contribution and expenditure database; and contacted the Central Business Park in Spokane Valley, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to accurately and completely disclose contribution and expenditure details, and to disclose the name of the committee’s sponsor, do not amount to violations that warrant further investigation.

PDC staff is reminding Smart Reforms for a Better Spokane (Sponsored by Standard Trust) about the importance of completely and accurately disclosing contribution and expenditure details, and timely disclosing sponsorship on committee registrations and political advertising. PDC staff expects Smart Reforms for a Better Spokane (Sponsored by Standard Trust) to review their filings and timely make required disclosures on reports and political advertising in the future.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/59233
59232 10/25/2019 Glen Morgan A Better Spokane A Better Spokane: Alleged violations of RCW 42.17A.240 and .205 for failure to accurately disclose contributor addresses and name of committee sponsor (EY 19; Oct 19) wac 390-16-011a, RCW 42.17A.320, RCW 42.17A.240, RCW 42.17A.205 Request for Technical Correction

The Public Disclosure Commission (PDC) has completed its review of the complaint Glen Morgan filed on October 25, 2019. The complaint alleged that A Better Spokane (Sponsored by Standard Trust), a political committee, may have violated RCW 42.17A.240 for failure to accurately and completely disclose contributor addresses on Monetary Contribution reports (C-3 reports); and RCW 42.17A.205, RCW 42.17A.320, and WAC 390-16-011A for failure to disclose the name of Standard Trust as the sponsoring person in the committee’s name on the Political Committee Registration (Registration) and on political advertising.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; the applicable PDC reports filed by the Respondent; queried the Respondent’s data in the PDC contribution and expenditure database; and contacted the Central Business Park in Spokane Valley, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to accurately and completely disclose contribution and expenditure details, and to disclose the name of the committee’s sponsor, do not amount to violations that warrant further investigation.

A Better Spokane (Sponsored by The Standard Trust)” made minor or ministerial errors on required reports, which did not materially impact the public interest. Upon notification of these errors, A Better Spokane (Sponsored by The Standard Trust)” timely amended their reports, making the necessary technical corrections as requested by staff.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/59232
59229 10/25/2019 Glen Morgan Better Spokane PAC Better Spokane PAC: Alleged violations of RCW 42.17A.240 and .205 for failure to accurately disclose contributor addresses, name of committee sponsor, and expenditure details (EY 19; Oct 19) wac 390-16-011a, wac 390-16-205, WAC 390-16-037, RCW 42.17A.320, RCW 42.17A.205, RCW 42.17A.240 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint Glen Morgan filed on October 25, 2019. The complaint alleged that Better Spokane PAC (Sponsored by Standard Trust), a political committee, may have violated RCW 42.17A.240 for failure to accurately and completely disclose contributor addresses on Monetary Contribution reports (C-3 reports); RCW 42.17A.240, WAC 390-16-037, and WAC 390-16-205 for failure to accurately and completely disclose expenditure details, including the number of items printed for political advertising, and sub-vendors utilized by the campaign, on Summary Full Campaign Contribution and Expenditure reports (C-4 reports); and RCW 42.17A.205, RCW 42.17A.320, and WAC 390-16-011A for failure to disclose the name of Standard Trust as the sponsoring person in the committee’s name on the Political Committee Registration (Registration) and on political advertising.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; the applicable PDC reports filed by the Respondent; queried the Respondent’s data in the PDC contribution and expenditure database; and contacted the Central Business Park in Spokane Valley, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to accurately and completely disclose contribution and expenditure details, and to disclose the name of the committee’s sponsor, do not amount to violations that warrant further investigation.

PDC staff is reminding Better Spokane PAC (Sponsored by Standard Trust) about the importance of completely and accurately disclosing contribution and expenditure details, and timely disclosing sponsorship on committee registrations and political advertising. PDC staff expects Better Spokane PAC (Sponsored by Standard Trust) to review their filings and timely make required disclosures on reports and political advertising in the future.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/59229
59228 10/25/2019 Glen Morgan NICOLAS DUCHASTEL Duchastel Nicolas: Alleged Violation of RCW 42.17A.320 for failure to disclose accurate and complete sponsor identification on political advertising (EY 19, Oct 19) RCW 42.17A.320 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint Glen Morgan filed on October 25, 2019. The complaint alleged that Nicolas Duchastel (Respondent), a Candidate for City Council Member for City of Woodinville may have violated RCW 42.17A.320 for failure to provide sponsor identification, including the name and address of the sponsor, on political advertising.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements and the response provided by the Respondent to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to provide sponsor identification on political advertising does not amount to a violation that warrants further investigation.

PDC staff is reminding Nicolas Duchastel about the importance of including sponsor identification, including name and address of the sponsor, on political advertising in accordance with the statutes and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/59228
59226 10/25/2019 Richard Gustafson Luis Berbesi Berbesi, Luis: Alleged Violation of RCW 42.17A.320 for failure to disclose accurate and complete sponsor identification on political advertising (EY 19, Oct 19) RCW 42.17A.320 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint Richard Gustafson filed on October 24, 2019. The complaint alleged that Luis Berbesi (Respondent), a Candidate for City Council Member for the City of Shoreline may have violated RCW 42.17A.320 for failure to disclose accurate and complete sponsor identification on political advertising.

PDC staff reviewed the allegations; the applicable statutes, rules, reporting requirements and the responses provided by the Respondent to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to provide complete and accurate sponsor identification on political advertising does not amount to a violation that warrants further investigation.

PDC staff is reminding Luis Berbesi about the importance of disclosing complete and accurate sponsor identification on political advertising, including name and address of sponsor, in accordance with the statutes and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/59226
59225 10/25/2019 Glen Morgan Citizens for Liberty and Labor Citizens for Liberty and Labor: Alleged violations of RCW 42.17A.320 for failure to disclose Top Three Donors to PAC Contributors in political advertising (EY 19; Oct 19) RCW 42.17A.320 Case Closed with Reminder

The complaints alleged Citizens for Liberty and Labor PAC, a Continuing Political Committee, may have violated RCW 42.17A.320 by failing to disclose the “Top Three Donors to PAC Contributors” in political advertising.

PDC staff has determined that, in this instance, the alleged failure to disclose the Top Three donors to a PAC’s contributors when the sponsor identification for political advertising includes the Top Five contributors and one or more of those contributors are PACs, does not amount to a violation warranting further investigation.

PDC staff is reminding Citizens for Liberty and Labor about the importance of listing the Top Three donors to PAC contributors in accordance with PDC laws and rules. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/59225
59218 10/25/2019 Glen Morgan Washington Health Care Association PAC Washington Health Care Association PAC: Alleged Violation of RCW 42.17A.420 for exceeding contribution limitations within 21 days of an election (EY 18, Oct 19) RCW 42.17A.420 Case Closed with Reminder

The complaint alleged the Washington Health Care Association PAC (PAC), a Continuing Political Committee associated with the Washington Health Care Association (Association), may have violated RCW 42.17A.420 for accepting contributions exceeding $5,000 from a single source within twenty-one days of the November 6, 2018 general election.

The three contributions were received by the Association between October 4 and 11, 2018, but not deposited or transferred into the PAC bank account until November 1, 2018. The PAC is affiliated with the Association, as well as being administered and controlled by the Association, so the contributions were technically received prior to the $5,000 contribution limitation period that is within 21 days of a general election, and for the 2018 general election began on October 16, 2018.   

Based on these findings, staff has determined that, in this instance, failing to make deposits within five business days of receipt does not amount to a violation that warrants further investigation.  

PDC staff is reminding the Washington Health Care Association PAC any political contributions received, even if combined with Association fees, must be reported and deposited into the PAC as required in 42.17A.220. Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/59218
59212 10/25/2019 Glen Morgan UA Local 32 Pipe PAC UA Local 32 Pipe PAC: Alleged Violation of RCW 42.17A.420 for exceeding contribution limitations within 21 days of an election (EY 18, Oct 19) RCW 42.17A.420 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on October 24, 2019. The complaint alleged that UA Local 32 Pipe PAC, a political committee registered during the 2018 primary and general elections, may have violated RCW 42.17A.420 for accepting contributions exceeding $5,000 from a single source within twenty-one days of the November 6, 2018 general election.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Dmitri Iglitzin, on behalf of his client UA Local 32 Pipe PAC; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

During its review, staff found that of the reported $24,750 dollars in total campaign contributions made by UA Local 32 Pipe PAC during the 2018 election, more than sixty-seven percent went to candidates during the primary election. A total of $8,000 dollars in additional contributions was made on September 17, 2018 and October 17, 2018, to candidates participating in the November 6, 2018 general election. It appears that UA Local 32 Pipe PAC did not use any of the funds received from United Association Local 32 Plumbers, Pipefitters & HVAC/Refrigeration Mechanics Union on October 18, 2018 to make contributions to 2018 candidate campaigns.

Based on our findings staff has determined that, in this instance, accepting a contribution exceeding $5,000 from a single source within twenty-one days of the November 6, 2018 general election, does not amount to a violation that warrants further investigation.

PDC staff reminded UA Local 32 Pipe PAC about the importance of the restriction on accepting contributions exceeding $5,000 from a single source within twenty-one days of a general election and all other applicable statutes and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/59212
59175 10/24/2019 Glen Morgan Woodinville Citizens First Woodinville Citizens First: Alleged Violation of RCW 42.17A.205, .210 and .215 for failure to timely and accurately file Committee Registration; RCW 42.17A.320 for failure to disclose complete sponsor identification on political advertising (EY 19 Oct 19) RCW 42.17A.320, RCW 42.17A.205 Case Closed with Reminder

On October 23, 2019, the Public Disclosure Commission (PDC) received a complaint alleging that the Woodinville Citizens First (Committee), may have violated RCW 42.17A.205, .210 and .215 by failing to timely and accurately file Committee Registration and RCW 42.17A.320 for failure to disclose complete sponsor identification on a political advertising. 

Staff reviewed the allegations; applicable statutes, rules and reporting requirements and the PDC reports filed by the Committee. Staff determined that the Committee failed to file a Candidate Registration in a timely manner, and to include Ms. Boundy-Sanders as the only sponsor in the name of the Committee. 

However, the Committee made a good faith effort by responding quickly and working with the PDC filer assistance personnel to file the missing Candidate Registration. The Committee also amended its Last Minute Contribution (LMC) report and the Independent Expenditure report (C-6) to reflect Susan Boundy-Sanders as the sole sponsor of the Committee. 

Based on the above, staff issued a reminder in this case and dismissed it in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/59175
59162 10/24/2019 Glen Morgan Citizens for Community Driven Prosperity PAC Citizens for Community Driven Prosperity PAC: Alleged violation of RCW 42.17A.205(5) & .240(11) and WAC 390-16-011A by failing to include sponsor name in registered committee name on reports during election years 2017 & 2019. (Oct '19) RCW 42.17A.240, wac 390-16-011a, RCW 42.17A.205 Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on October 23, 2019. The complaint alleged that Citizens for Community Driven Prosperity (C4CDPPAC), a political committee registered with the PDC since 2017, may have violated: (1) RCW 42.17A.205(5) & WAC 390-16-011A for failure to include the name of the committee’s sponsor on the Committee Registration (C-1pc report) for election year 2017 and 2019; and (2) RCW 42.17A.240(11) for failure to include the same sponsor on Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), filed by C4CDPPAC.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by James E. Barton II, on behalf of his client C4CDPPAC; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

RCW 42.17A.205(5), RCW 42.17A.005(b)(i) and WAC 390-16-011A include filing requirements, definitions and methods for determining a sponsor or sponsored committee name. The laws and rules do not identify or suggest a specific naming convention for a sponsored committee. According to Mr. Barton’s response, it appears that C4CDPPAC believed that it had complied with PDC laws and rules.

Although C4CDPPAC has no previous violations of RCW 42.17A and a closer examination of the C-1pc filed by the committee identified Community Driven Prosperity PAC as an affiliated committee, staff believes that the sponsor would have been more evident to the general public through an amendment of the registration and that this is the intent of the law.

Staff did not request C4CDPPAC to amend previously submitted C-3 and C-4 reports to include the sponsor in the committee name.

Based on our findings staff has determined that, in this instance, failure to include the sponsor of the committee in the name of the committee on the C-1pc does not amount to a finding of a violation that warrants further investigation. 

Pursuant to WAC 390-37-060(1)(d), however, C4CDPPAC received a formal written warning concerning failure to accurately disclosure the name of the entity sponsoring the committee in the name of the committee on the C-1pc report. The formal written warning included staff’s expectation that C4CDPPAC accurately files all future required reports including the C-1pc and any C-3 and C-4 reports with the sponsor clearly identified in a manner easily recognizable to the general public. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/59162
59160 10/24/2019 Fennelle Miller Lisa Young Young, Lisa: Alleged violation of RCW 42.17A.555 for misuse of public facilities to support the election campaign of Candidate Cory Wright (EY 19; Oct 19) RCW 42.17A.555 Case Closed with Reminder

The complaint alleged Kittitas County Human Resources Director and Risk Manager Lisa Young may have violated RCW 42.17A.555 by using county facilities to support the campaign of Cory Wright for Kittitas County Commissioner. PDC staff reviewed the allegations, the applicable statutes and rules, the e-mails you provided, and the response provided by Lisa Young, to determine whether the record supports a finding of one or more violations. 

PDC Staff has determined, in this instance, the alleged use of public facilities to support the campaign of Cory Wright for Kittitas County Commissioner does not amount to a violation warranting further investigation. PDC staff is reminding Lisa Young to refrain from distributing materials posted on a campaign website as these are inherently campaign-related and, in the future, public officials should access campaign-related materials without using public resources. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/59160
59159 10/24/2019 Fennelle Miller Cory Wright Wright, Cory: Alleged violation of RCW 42.17A.555 for misuse of public facilities to support the candidate's own election campaign (EY 19; Oct 19) RCW 42.17A.555 Case Closed with No Evidence of Violations

The complaint alleged Kittitas County Commissioner Cory Wright may have violated RCW 42.17A.555 by using county facilities to support the 2019 campaign of Cory Wright for Kittitas County Commissioner.  
PDC staff reviewed the allegations, the applicable statutes and rules, the mailer, and the response provided by Drew Stokesbary of Stokesbary PLLC, counsel for Cory Wright, to determine whether the record supports a finding of one or more violations.

RCW 42.17A.555 states “No elective official nor any employee of his or her office nor any person appointed to or employed by any public office or agency may use or authorize the use of any of the facilities of a public office or agency, directly or indirectly, for the purpose of assisting a campaign for election of any person to any office or for the promotion of or opposition to any ballot proposition.”  RCW 42.17A.555 does not restrict the right of any individual to express his or her own personal views concerning, supporting, or opposing any candidate or ballot proposition, if such expression does not involve a use of the facilities of a public office or agency.

Cory Wright is not found to have used public facilities to promote his 2019 campaign for Kittitas Board of County Commissioners. 

Based on these findings staff has determined, in this instance, the alleged use of public facilities to support the campaign of Cory Wright for Kittitas County Commissioner does not amount to a violation warranting further investigation. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/59159
59158 10/24/2019 Ken Maurice Lee Nadine Woodward Woodward, Nadine (2): Alleged Violation of RCW 42.17A.710 for failure to accurately and completely disclose personal financial information on Personal Financial Affairs Statement (F-1) (EY 19, Oct 19) RCW 42.17A.710 Case Closed with No Evidence of Violations

The complaint alleged Nadine Woodward, a 2019 Candidate for City of Spokane Mayor, may have violated RCW 42.17A.710 by failing to accurately and completely disclose personal financial information on a Personal Financial Affairs Statement (F-1) report.

PDC staff has determined, in this instance, the alleged violation of failing to accurately and completely disclose personal financial information on a Personal Financial Affairs Statement (F-1) report does not amount to a violation warranting further investigation. Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/59158
59154 10/24/2019 Steven Fox Kelly Geiger Geiger, Kelly: Alleged violation of RCW 42.17A.240 for failure to provide sufficient expenditure details on C-4 reports for election year 2017. (Oct '19) RCW 42.17A.240 Case Closed with Reminder
  • Allegation: Alleged violation of RCW 42.17A.240 for failure to provide sufficient expenditure details on C-4 reports for election year 2017 (e.g. signs, handouts & flyers)
https://www.pdc.wa.gov/browse/cases/59154
59150 10/24/2019 Glen Morgan Keep Washington Rolling Keep Washington Rolling: Alleged violations of RCW 42.17A.320 for failure to disclose top contributors in sponsor identification, and RCW 42.17A.240 for failure to accurately and completely disclose expenditure details (EY 19; Oct 19) wac 390-16-205, RCW 42.17A.320, WAC 390-16-037, RCW 42.17A.240 Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on October 24, 2019 and the four supplemental complaints received shortly after. The complaints alleged that Keep Washington Rolling, a political committee opposing a statewide ballot measure in the November 5, 2019 general election, may have violated: (1) RCW 42.17A.320 for failure to disclose top five donors on political advertisement sponsored by the Committee; and (2) RCW 42.17A.235, RCW 42.17A.240 & WAC 390-16-037 for failure to timely and accurately describe expenditures on Summary Full Campaign Contribution and Expenditure reports (C-4 reports) for election year 2019.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Philip Lloyd, Treasurer for Keep Washington Rolling; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

It appears that the omission of sponsor identification, including the top five contributors, on at least five separate pieces of political advertisement sponsored by Keep Washington Rolling, was unintentional and not purposely omitted to mislead the public. The identity of the top five contributors was available to the public on the committee’s Monetary Contribution reports (C-3 reports) submitted prior to the advertisements being presented to the public. In addition, the committee has included appropriate expenditure details on C-4 reports.

Although Keep Washington Rolling has no previous violations of RCW 42.17A, the committee has been in existence for several campaign cycles, currently employs a professional treasurer and is aware of the sponsor identification requirements for political advertisement it sponsors.

Based on our findings staff has determined that, in this instance, failure to include the top five contributors on these advertisements does not amount to a finding of a violation that warrants further investigation.

Pursuant to WAC 390-37-060(1)(d), however, Keep Washington Rolling received a formal written warning concerning failure to include complete sponsor identification, specifically the top five contributors required by statute, on political advertisement it sponsored. The formal written warning will included staff’s expectation that the committee includes complete sponsor identification on all political advertisement it sponsors in the future. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/59150
59148 10/24/2019 James Young Mike Wallin Wallin, Mike: Alleged violations of RCW 42.17A.235 and .240 for failure to timely and accurately report contributions and expenditures (EY 19; Oct 19) RCW 42.17A.240, RCW 42.17A.235 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint Jim Young filed on October 23, 2019. The complaint alleged that Mike Wallin (Respondent), a 2019 candidate for City Council Member for the City of Longview, may have violated RCW 42.17A.235 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign; and RCW 42.17A.240 for failure to accurately disclose contributions and expenditures undertaken by the Campaign.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the responses provided by the Respondent; the applicable PDC reports filed by the Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to timely file the 21-day pre-general C-4 report does not amount to a violation that warrants further investigation.

PDC staff is reminding Mike Wallin about the importance of the timely disclosure of all contribution and expenditure activities. PDC staff expects the timely filings of all future PDC reports in accordance with the statutes and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/59148
59146 10/24/2019 Glen Morgan Safer Spokane Safer Spokane (2): Alleged violations of RCW 42.17A.220 for accepting over-limit anonymous contributions, and .240 for failure to accurately and completely disclose expenditure details (EY 17; Oct 19) WAC 390-16-037, RCW 42.17A.240, RCW 42.17A.220 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint Glen Morgan filed on October 23, 2019. The complaint alleged that Safer Spokane (Respondent), a 2017 single-year political committee, may have violated RCW 42.17A.220 for accepting over-limit anonymous contributions; and RCW 42.17A.240 and WAC 390-16-037 for failure to disclose the number of items printed for expenditures for political advertising. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; the applicable PDC reports filed by the Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to disclose the number of items printed for political advertising does not amount to a violation that warrants further investigation.

PDC staff is reminding Safer Spokane about the importance of the timely, complete, and accurate disclosure of all expenditure details. PDC staff expects full disclosure of expenditure details in accordance with PDC laws and rules in the future.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/59146
59100 10/23/2019 Glen Morgan Mark Ozias Ozias, Mark: Alleged violations of RCW 42.17A.235 & 240 for failure to timely & accurately report 2015 filing fee, carry forward cash from 2015 to 2019, and expenditure details for election years 2015 & 2019. (Oct '19) RCW 42.17A.240, RCW 42.17A.235 Case Closed with Reminder

The complaint alleged Mark Ozias may have violated RCW 42.17A.235 and 240 by failing to (1) timely and accurately report the 2015 filing fee, (2) accurately report carry forward cash from 2015 to 2019 and (3) timely and accurately provide expenditure details for election years 2015 and 2019.

Staff has determined that in this instance, the failure to timely and accurately file reports of contributions and expenditures does not amount to an actual violation warranting further investigation.  

PDC staff is reminding Mark Ozias and the Committee about the importance to timely disclose all contribution and expenditure activities with expenditure detail, including the filing fee, and the timely filings of all future PDC reports in accordance with the statutes and rules. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).  

https://www.pdc.wa.gov/browse/cases/59100
59068 10/23/2019 Orla Poole No Federal Way Pot Retailers No Federal Way Pot Retailers: Alleged violations of RCW 42.17A.205, .235, .240 & .320 for failure to timely & accurately register political committeee, report contributions & expenditures, and identify sponsor on political advertising RCW 42.17A.320, RCW 42.17A.235, RCW 42.17A.205, RCW 42.17A.240 Case Closed with Written Warning

On November 10, 2019, the Public Disclosure Commission (PDC) received a complaint alleging that the No Federal Way Pot Retailers, a Political Action Committee opposing the City of Federal Way Initiative to Allow Retail Marijuana Sales in 2019, may have violated RCW 42.17A.205, .235, .240 and .320 for failure to timely and accurately register political committee, report contributions (C-3 reports) and expenditures (C-4 reports), and identify sponsor on political advertising. 

PDC staff reviewed the allegation, including the applicable statutes, rules and the reporting requirements and found that the Committee failed to timely file the 21-Day Pre-General Election and the 7-Day Pre-General C4 reports.  However, the Committee did file both reports on November 10, 2019. 

Based on the above review, staff issued a warning letter to the Committee with the expectation that the Committee will fully adhere to the statutory requirements regarding filing timely and accurate C-3 and C-4 reports in future years. The Commission will consider the formal written warning in deciding on further action if there are future violations of PDC laws or rules. 

Based on this information, staff dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/59068
59064 10/23/2019 Alexander Ramel Coalition for a Better Northwest Washington Coalition for a Better Northwest Washington: Alleged violations of Chapter 42.17A RCW for failure to timely deposit and report contributions and pledges, and for accepting over-limit contributions within 21 days of an election RCW 42.17A.235, RCW 42.17A.420, RCW 42.17A.220, RCW 42.17A.240 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on October 23, 2019. The complaint alleged that Coalition for a Better Northwest Washington (CBNWA), a political committee registered in 2019 making contributions to Whatcom County Council candidate, Ben Elenbaas, and independent expenditures opposing Whatcom County Executive candidate, Satpal Sidhu, may have violated: (1) RCW 42.17A.220 for failure to deposit monetary contributions within five business days of receipt; (2) RCW 42.17A.235 and .240 for failure to timely and accurately file Summary Full Campaign Contribution and Expenditure reports (C-4 reports) disclosing a monetary pledge; and (3) RCW 42.17A.420 for accepting contributions exceeding $5,000 from a single source within twenty-one days of an election.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Dan Brady on behalf of his client CBNWA; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database], to determine whether the record supports a finding of one or more violations.

During its review, staff found no evidence showing that the contributions from Phillips 66 and Marathon Petroleum Corp. were deposited late, reported on a C-3 or C-4 report late, or were received during a restricted time period for contributions exceeding $5,000 on the aggregate. It appears that CBNWA is aware that pledges are included in the statutory definition of a contribution and that it has a general understanding of filing deadlines, including “last minute contributions” (LMCs) disclosing contributions of $1,000 or more in the aggregate received before a general election.

Although the pledge from Marathon was timely reported October 22, 2019 on a C-3 report within 48 hours of being redeemed, staff found that the $5,000 pledge received by CBNWA on October 15, 2019, as described in Mr. Brady’s response, should have been disclosed within 48 hours of the pledge being made, or by no later than October 17, 2019. 

Based on our findings staff has determined that, in this instance, failure to timely file a report disclosing the receipt of a pledge of $1,000 or more within 48 hours does not amount to a violation that warrants further investigation.

PDC staff reminded CBNWA about the importance of the timely disclosure of all contributions, including pledges, received during the time period and dollar amount described in RCW 42.17A.265 and the timely filings of all future PDC reports in accordance with the statutes and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/59064
59039 10/22/2019 Charles Eakins; Glen Morgan; John Wissler; Edwin Pole, II; and Robert Shirley City of Olympia Officials City of Olympia Officials (2): Alleged violation of RCW 42.17A.555 for misuse of public facilities to oppose a ballot proposition (EY 19; Oct 19) RCW 42.17A.555, RCW 42.17A.320 Investigation of Possible Violation
  • Allegation One: Violation of RCW 42.17A.555 for misuse of public facilities to design, produce, and distribute a mailer in opposition to Initiative 976.
  • Allegation Two: Violation of RCW 42.17A.320 for failure to disclose sponsor identification on political advertising in opposition to Initiative 976.
  • Allegation Three: Violation of RCW 42.17A.255 for failure to disclose the value of independent expenditures in opposition to Initiative 976.
https://www.pdc.wa.gov/browse/cases/59039
59019 10/22/2019 Glen Morgan Mia Gregerson Gregerson, Mia (3): Alleged violations of Chapter 42.17A RCW for failure to timely and accurately report transfers of real property, debts, expenditures, and for unauthorized transfers of funds (Oct 19) RCW 42.17A.430, WAC 390-16-037, RCW 42.17A.235, RCW 42.17A.240, RCW 42.17A.490 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review two complaints filed by Glen Morgan, PDC Case #59019 filed October 21, 2019 & Case #59569 filed on October 31, 2019. The complaints alleged that Mia Gregerson, a Representative in Legislative District 33 may have violated: (1)RCW 42.17A.240 for failure to timely and accurately file Summary Full Campaign Contribution and Expenditure reports (C-4 reports) disclosing expenditures made to political consultant, John Wyble, or WinPower Strategies; (2) RCW 42.17A.430 for misuse of surplus funds; (3) RCW 42.17A.490 for improper transfer of funds received for a 2011 City of SeaTac campaign to a 2014 State Representative campaign; (4) RCW 42.17A.235, .240 & WAC 390-16-037 for failure to timely and accurately describe expenditures on C-4 reports; and (5) RCW 42.17A.240 for failure to timely and accurately file C-4 reports disclosing surplus funds.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Rep. Gregerson; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

The two complaints included six separate allegations in total with some overlapping evidence provided between them. During staff’s review, evidence was found to substantiate two of the allegations in whole and one in part. Rep. Gregerson’s response confirmed that she believed she had improperly used surplus funds in one instance in March 2017 as described in Allegation 2 and she suggested an appropriate remedy. The three expenditure descriptions included in Allegation 4 required edits after the complaint was received, and the receipt of the $10,000 transfer to the Gregerson Surplus Funds Account was disclosed late as described in Allegation 5.

Rep. Gregerson has been a candidate and elected or appointed official since 2007. She promptly responded to the complaints, submitted amendments and provided details regarding missing or otherwise deficient information.  It appears that the errors made related to her Surplus Funds Account and the insufficient descriptions provided in her 2016 campaign, were not done to mislead the public or prevent transparency. Rep. Gregerson has not been found in violation of RCW 42.17A within the past five years.

Based on our findings staff has determined that, in this instance, failure to include accurate descriptions for three expenditures in a 2016 campaign, failure to timely file receipt of a transfer into the Gregerson Surplus Funds Account, and a misuse of surplus funds that required reimbursement to correct, does not amount to a finding of a violation that warrants further investigation.

PDC staff is reminding Rep. Gregerson about the importance of including detailed descriptions for all expenditures disclosed on C-4 reports, the timely disclosure of all contribution and expenditure activities related to the Surplus Funds Account, and to review all expenditures of surplus funds to ensure they are permissible in accordance with the statutes and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/59019
59010 10/22/2019 Ignacio Resendez Mike Farmer Farmer, Mike: Alleged Violation of RCW 42.17A.205 for failure to timely file Campaign Registration report (C-1 report) (EY 19, Oct 19) RCW 42.17A.205 Unfounded or Frivolous

The Public Disclosure Commission (PDC) has completed its review of the complaint Ignacio Resendez filed on October 21, 2019. The complaint alleged that Mike Farmer, a City Council Member candidate for City of Sunnyside may have violated RCW 42.17A.205 for failure to timely file their Candidate Registration report (C-1 report).

Staff has determined that in this instance, no evidence supports a finding of a violation warranting further investigation.

The PDC has closed the matter and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1) and WAC 390-37-060(1)(a).

https://www.pdc.wa.gov/browse/cases/59010
59005 10/22/2019 Charles Schrag Egan Orion Orion, Egan (4): Alleged Violation of RCW 42.17A.235 for failure to timely and accurately report contributions and expenditures (EY 19, Oct 19) RCW 42.17A.235 Closed Administratively

The Public Disclosure Commission (PDC) has completed its review of the complaint Charles Schrag filed on October 21, 2019. The complaint alleged that Egan Orion, a Candidate for City Council Member for City of Seattle may have violated RCW 42.17A.235 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign. 

Based on these initial findings, staff has determined that, pursuant to WAC 390-37-061(3), to defer this complaint to the jurisdiction of the SEEC because the alleged violation was resolved under an analogous local ordinance. The PDC has dismissed this complaint in accordance with RCW 42.17A.755(1) and will not be pursing further investigation or enforcement action in this case. 

https://www.pdc.wa.gov/browse/cases/59005
58969 10/21/2019 Glen Morgan Brandi Peetz Peetz, Brandi (2): Alleged Violation of RCW 42.17A.240 for failure to timely and accurately report debts and obligations (EY 19, Oct 19) RCW 42.17A.240 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint Glen Morgan filed on October 21, 2019. The complaint alleged that Brandi Peetz, a Candidate for City Council Member for City of Spokane Valley may have violated RCW 42.17A.240 for failure to timely and accurately file Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing debts and obligations undertaken by the Campaign. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the responses provided by the Respondent; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to timely file the C-4 report reflecting debt and obligation undertaken by the campaign does not amount to a violation that warrants further investigation.

PDC staff is reminding Brandi Peetz about the importance of the timely disclosure of all debts and obligations undertaken by the campaign and the timely filings of all future PDC reports in accordance with the statutes and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/58969
58919 10/21/2019 Kelly Geiger Steven C Fox Fox, Steven C.: Alleged violation of RCW 42.17A.240 for failure to provide sufficient expenditure details on C-4 reports. (EY '19; Oct '19) RCW 42.17A.240 Request for Technical Correction
  • Allegation: Alleged violation of RCW 42.17A.240 for failure to provide sufficient expenditure details on C-4 reports (e.g. number of signs & mailers purchased, purpose/description of Visa card purchase, etc.)
https://www.pdc.wa.gov/browse/cases/58919
58914 10/21/2019 Glen Morgan SeaTac Progress PAC (sponsored by John Wyble) SeaTac Progress PAC (sponsored by John Wyble): Alleged violations of Chapter 42.17A RCW for failure to accurately register, report addresses, and disclose sub-vendors (EY 19; Oct 19) wac 390-16-011a, RCW 42.17A.305, RCW 42.17A.260, wac 390-16-205, RCW 42.17A.255, RCW 42.17A.240, RCW 42.17A.205 Case Closed with Reminder

On October 19, 2019, the Public Disclosure Commission (PDC) received a complaint alleging that the Sea-Tac Progress PAC, may have violated RCW 42.17A.205 by failing to timely and accurately file Committee Registration, to include the sponsor of the political action committee, and RCW 42.17A.235 and .240 for failure to properly report the purpose of expenditures, as required by WAC 390-16-205 and WAC 390-16-037. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the applicable PDC reports filed by SeaTac Progress (Committee); and reviewed their data in the PDC database, to determine whether the record supports a finding of one or more violations. 

Staff determined that the Committee failed to correctly identify the name of the city as "SeaTac" instead of "Searac."  The Committee made a typographical error in the name of the city on their C-6 reports but listed the name of the city correctly on all C-3 and C-4 reports, including the Last-Minute Contribution (LMC) report. Staff issued a reminder as a result. 

Based on this information, the PDC staff dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/58914
58825 10/18/2019 Glen Morgan Spokane Firefighters Union PAC Spokane Firefighters Union PAC: Alleged violations of RCW 42.17A.220, .235, and .240 for failure to timely and accurately deposit and report contributions (EY 19; Oct 19) RCW 42.17A.235, RCW 42.17A.240, RCW 42.17A.220 Request for Technical Correction

The complaint alleged the Spokane Firefighters Union PAC (Committee), a continuing political committee, may have violated RCW 42.17A.220 by failing to timely deposit contributions within five business days of receipt and RCW 42.17A.235 and .240 by failing to timely and accurately report deposits of contributions.

Staff has determined, in this instance, and due to Committee’s reporting the carry-forward balance in all 2018 reports, the alleged failure to accurately report the 2018 election year cash-on-hand balance on the initial 2019 election year C-4 reports does not amount to a violation warranting further investigation. 

The Spokane Firefighters Union PAC made minor or ministerial errors on required reports, which did not materially impact the public interest. Upon notification of these errors, the Spokane Firefighters Union PAC timely amended its reports, making the necessary technical corrections as requested by staff. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/58825
58807 10/17/2019 Darnell Hibbler Egan Orion Orion, Egan (3): Alleged Violation of RCW 42.17A.320 for failure to provide sponsor identification on political advertising; RCW 42.17A.335 for false and defamatory statements in political advertising (EY 19, Oct 19) RCW 42.17A.335, RCW 42.17A.320 Closed Administratively

The Public Disclosure Commission (PDC) has completed its review of the complaint Darnell Hibbler filed on October 16, 2019. Your complaint alleged that Egan Orion (Respondent) may have violated RCW 42.17A.320 for failure to provide sponsor identification on political advertising; RCW 42.17A.335 for false or defamatory statements in political advertising.

Based on these findings, staff has determined that, pursuant to WAC 390-37-061(3), to defer the complaint regarding sponsor identification to the jurisdiction of the SEEC because the alleged violation was resolved under an analogous local ordinance, and in the matter of the false or defamatory statements in political advertising staff has determined that, in this instance, insufficient evidence supports a finding of a violation that warrants further investigation. The PDC has dismissed this complaint in accordance with RCW 42.17A.755(1) and will not be pursing further investigation or enforcement action in this case. 

https://www.pdc.wa.gov/browse/cases/58807
58801 10/17/2019 Joan Halbert Pete Miller Miller, Peter: Alleged violation of RCW 42.17A.320 for failure to disclose sponsor identification on billboard political advertising (EY 19; Oct 19) RCW 42.17A.320 Closed Administratively
  • Allegation: Violation of RCW 42.17A.320 for failure to disclose sponsor identification on billboard political advertising.
https://www.pdc.wa.gov/browse/cases/58801
58800 10/17/2019 Joan Halbert Malia Hollowell Hollowell, Malia: Alleged violation of RCW 42.17A.320 for failure to disclose sponsor identification on billboard political advertising (EY 19; Oct 19) RCW 42.17A.320 Closed Administratively
  • Allegation: Violation of RCW 42.17A.320 for failure to disclose sponsor identification on billboard political advertising.
https://www.pdc.wa.gov/browse/cases/58800
58745 10/16/2019 Washington Fairness Campaign (James Williams) Let People Vote/ Reject R-88 Let People Vote/ Reject R-88: Alleged violations of RCW 42.17A.235 and .240 for failure to timely and accurately report expenditures or in-kind contributions for security (EY 19; Oct 19) RCW 42.17A.240, RCW 42.17A.235 Case Closed with Reminder

The complaint alleged Let People Vote, a ballot measure committee opposing Referendum 88, may have violated RCW 42.17A.235 and .240 by failing to timely and accurately report monetary expenditures or the receipt of in-kind contributions for security provided by the Proud Boys.

Volunteers (who are not paid by anyone in connection with the volunteer tasks they perform) may do certain campaign work without the Committee having to report the services as in-kind contributions. There is no indication the services provided by the Proud Boys are services the group typically provides for a fee.  

Based on these findings, staff has determined in this instance the alleged failure to timely and accurately report expenditures or in-kind contributions for security from the Proud Boys does not amount to a violation warranting further investigation.  

PDC staff is reminding Let People Vote about the importance of clarifying what services will be provided when making agreements with volunteers who provide services outside the common volunteer functions listed in WAC 390-17-405, in accordance with PDC laws and rules.  

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/58745
58722 10/16/2019 Amanda Zimmerman Clay Shaya Shaya, Clay: Alleged violations of RCW 42.17A.205, .700 & .235 for failure to register as a candidate & file financial affairs statement within 2 weeks of declaring candidacy & timely report contributions & expenditures. (EY '19) (Oct '19) RCW 42.17A.205, RCW 42.17A.235, RCW 42.17A.700 Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on October 14, 2019. The complaint alleged that Clay Shaya, a write-in candidate for Whatcom County Sheriff in the November 5, 2019 general election, may have violated: (1) RCW 42.17A.205 for failure to file a Candidate Registration (C-1 report) within two weeks of declaring candidacy; (2) RCW 42.17A.700 for failure to file a Personal Financial Affairs Statement (F-1 report) within two weeks of declaring candidacy; and (3) RCW 42.17A.235 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign.

PDC staff reviewed the allegations; and the applicable statutes, rules, and reporting requirements, to determine whether the record supports a finding of one or more violations.

Mr. Shaya has no filing history with the PDC as a candidate or appointed official and has not been found in violation of PDC laws or rules. He was not successful in the election for Whatcom County Sheriff and the small number of votes he may have received as a write-in candidate appears to have had little impact on the final outcome of the election as the total votes for all write-ins accounted for only 0.17%.

During its review, staff found evidence to suggest that Mr. Shaya was a candidate as defined in RCW 42.17A.005(8) and was required by RCW 42.17A.205 to file a C-1 report and by RCW 42.17A.700 to file an F-1 report, both by no later than September 27, 2019. Despite numerous attempts to illicit a response from Mr. Shaya regarding this evidence, staff has had no communication from him, and the C-1 report and F-1 report have not been received.

Based on our findings staff has determined that, in this instance, failure to timely file the C-1 report as a candidate and a candidate F-1 report covering the previous twelve months, does not amount to a finding of a violation that warrants further investigation.

Pursuant to WAC 390-37-060(1)(d), however, Mr. Shaya received a formal written warning concerning failure to timely file a C-1 report and F-1 report as a candidate for local office in 2019. The formal written warning will included staff’s expectation that Mr. Shaya timely files all required reports as a candidate for state or local office, beginning with the Candidate Registration (C-1 report) and the Personal Financial Affairs Statement (F-1 report) in future years. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/58722
58719 10/16/2019 Abraham Ritter, Joan Halbert Peter Miller Miller, Peter: Alleged violation of RCW 42.17A.320 for failure to identify sponsor on political advertising (billboard). (EY '19; Oct '19) RCW 42.17A.320 Case Closed with Reminder
  • Allegation: Alleged violation of RCW 42.17A.320 for failure to identify sponsor on political advertising (billboard)
https://www.pdc.wa.gov/browse/cases/58719
58718 10/16/2019 Abraham Ritter, Joan Halbert Malia Hollowell Hollowell, Malia: Alleged violation of RCW 42.17A.320 for failure to identify sponsor on political advertising (billboard). (EY '19; Oct '19) RCW 42.17A.320 Case Closed with Reminder
  • Allegation: Alleged violation of RCW 42.17A.320 for failure to identify sponsor on political advertising (billboard)
https://www.pdc.wa.gov/browse/cases/58718
58694 10/15/2019 David Asher Martin Morgan Morgan, Martin: Alleged violations of RCW 42.17A.205, .215, 235 & .240 for failure to timely register as a candidate & report depository in 2019; and report deposits, contributions & expenditures for election years 2015, 2017 & 2019. (Oct '19) RCW 42.17A.240, RCW 42.17A.235, RCW 42.17A.215, RCW 42.17A.205 Scheduled for Full Commission Hearing

Pursuant to the brief enforcement hearing (brief adjudicative proceeding) notice sent to Martin Morgan on January 13, 2020, a brief adjudicative proceeding was held on January 23, 2020, in Room 206, Evergreen Plaza Building, 711 Capitol Way, Olympia, Washington, to consider whether the Respondent violated RCW 42.17A.205 by failing to file a Candidate Registration (C-1 report) and RCW 42.17A.700 by failing to timely file Personal Financial Affairs Statement (F-1 report) as a candidate for the 2019 election cycle, disclosing campaign information and financial activities for the previous 12 calendar months. The C-1 and F-1 reports were due within two weeks of declaring candidacy, or no later than June 3, 2019. 

The hearing was held in accordance with Chapters 34.05 RCW and 42.17A RCW and Chapter 390-37 WAC.  Commission Chair David Ammons was the Presiding Officer.  The Commission staff was represented by Jennifer Hansen, Compliance Officer.  The Respondent did not participate in the hearing or submit any written materials. 
 

CONCLUSIONS OF LAW 

Based on the above facts, as a matter of law, the Presiding Officer concludes as follows: 

1. This matter was duly and properly convened and all jurisdictional, substantive, and procedural requirements have been satisfied. 

2. The Respondent violated RCW 42.17A.205 and RCW 42.17A.700 by failing to file the C-1 and F-1 reports within two weeks of declaring candidacy, or no later than June 3, 2019. 

3. The Respondent violated the conditions of the Order entered on August 21, 2015 in PDC Case No. 16-210 by failing to file the C-1 and F-1 reports due to be filed within two weeks of declaring candidacy, or no later than June 3, 2019. 

ORDER 

ON the basis of the foregoing Findings of Fact and Conclusions of Law, 

IT IS HEREBY ORDERED that: the Respondent is assessed a civil penalty of $300, in accordance with the C-1 and F-1 penalty schedule set forth in WAC 390-37-143;  the $100 suspended penalty for a violation found in PDC Case No. 16-210 is reinstated; and the full penalty amount of $400 is payable within 30 days of the date of the Order.  
 

In the event the Respondent fails to pay the $400 civil penalty within 30 days of the date of the Order, PDC staff will refer the matter for collections. 

https://www.pdc.wa.gov/browse/cases/58694
58674 10/15/2019 Andrew Saturn Egan Orion Orion, Egan (2): Alleged Violation of RCW 42.17A.335 for false and defamatory statements in political advertising (EY 19, Oct 19) RCW 42.17A.335 Closed Administratively

The Public Disclosure Commission (PDC) has completed its review of the complaint Andrew Saturn filed on October 15, 2019. The complaint alleged that Egan Orion (Respondent), a Candidate for City Council Member for City of Seattle may have violated RCW 42.17A.335 for false or defamatory statements in political advertisements. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, insufficient evidence supports a finding of a violation that warrants further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/58674
58473 10/10/2019 Glen Morgan City of Camas Officials City of Camas Officials: Alleged violations of RCW 42.17A.555 for misuse of public facilities to support a ballot proposition (EY 19; Oct 19) RCW 42.17A.555 Case Closed with No Evidence of Violations

On October 7, 2019, the Public Disclosure Commission (PDC) received a complaint alleging that the City of Camas officials may have violated RCW 42.17A.555 by using the City of Camas facilities to support a Bond Ballot Proposition for a proposed City Community Aquatics Center. 

PDC staff reviewed the allegation, including the applicable statutes, rules and reporting requirement and found that City of Camas officials did not violate the law when they retained a consultant, WSP USA Inc., to assist the City of Camas by soliciting public input concerning the Plan, and informing the public about the ballot proposition that would finance the Plan. 

Based on this finding, staff determined that the City of Camas officials did not violate the law by retaining a private consultant to assist in soliciting public input concerning the Plan for the Community Aquatics Center. 

Based on this information, staff dismissed this matter in accordance RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/58473
58457 10/10/2019 John Patrick Kelly Mark Michel Michel, Mark: Alleged violation of RCW 42.17A.335(1)(b) for misuse of the term "reelect" in political advertising (EY '19; Oct '19). RCW 42.17A.335 Case Closed with No Evidence of Violations
  • Allegation: Alleged violation of RCW 42.17A.335(1)(b) for misuse of the term "reelect" in political advertising. 
https://www.pdc.wa.gov/browse/cases/58457
58357 10/09/2019 Chase Broderick Egan Orion Orion, Egan: Alleged Violation of RCW 42.17A.320 for failure to provide sponsor identification on political advertising (EY 19, Oct 19) RCW 42.17A.320 Closed Administratively

The Public Disclosure Commission (PDC) has completed its initial review of the complaint Chase Burns and Allison Hopstad filed on October 9, 2019. Your complaint alleged that Egan Orion (Respondent) may have violated RCW 42.17A.320 for failure to provide sponsor identification on political advertising. 

Based on these initial findings, staff has determined that, pursuant to WAC 390-37-061(3), to defer this complaint to the jurisdiction of the SEEC because the alleged violation was resolved under an analogous local ordinance. The PDC has dismissed this complaint in accordance with RCW 42.17A.755(1) and will not be pursing further investigation or enforcement action in this case. 

https://www.pdc.wa.gov/browse/cases/58357
58353 10/09/2019 Chestine Edgar James Dow Constantine Constantine, James Dow (2): Alleged violation of RCW 42.17A.555 by using public office or agency facilities to assist an election campaign. (EY 2017; Oct '19) RCW 42.17A.555 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on October 2, 2019. The complaint alleged that James Dow Constantine, incumbent King County Executive, may have violated RCW 42.17A.555 by arranging and holding a press conference that included campaigning for four candidates for Burien City Council running in the 2017 election and by authorizing his staff members, Lauren Leigh Craig and Diana Carlson, to assist with the event in their official capacity, including the use of King County equipment and staff time.

PDC staff reviewed the allegations; the applicable statutes and rules; PDC Interpretation 04-02; and the response provided by Gregory Wong, Attorney with Pacifica Law Group on behalf of his client, Mr. Constantine, to determine whether the record supports a finding of one or more violations.

It appears that the October 30, 2017 press conference was arranged for the purpose of responding to flyers, that were seen by community members as a “threat to public safety” and were circulated to residents of Burien four days earlier. No evidence was found that Dow Constantine used King County equipment, staff or other resources to support the 2017 Burien City Council candidate campaigns of Jimmy Matta, Krystal Marx, Pedro Olguin or Nancy Tosta.

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation that warrants further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/58353
58350 10/09/2019 Nola Coston Linda Susan Moschetti-Newing Moschetti-Newing, Linda Susan: Alleged violation of RCW 42.17A.555 by using public office or agency facilities (library) to assist an election campaign. (EY '19; Oct '19) RCW 42.17A.555 Case Closed with No Evidence of Violations
  • Allegation: Alleged violation of RCW 42.17A.555 by using public office or agency facilities (Newcastle Library) to assist an election campaign
https://www.pdc.wa.gov/browse/cases/58350
58346 10/09/2019 Nola Coston Allen Dauterman Dauterman, Allen: Alleged violations of RCW 42.17A.555 by using public office or agency facilities (library, city park) to assist an election campaign. (EY '19; Oct '19) RCW 42.17A.555 Case Closed with No Evidence of Violations
  • Allegation One: Alleged violation of RCW 42.17A.555 by using public office or agency facilities (Newcastle Library) to assist an election campaign 
  • Allegation Two: Alleged violation of RCW 42.17A.555 by using public office or agency facilities (city park) to assist an election campaign
https://www.pdc.wa.gov/browse/cases/58346
58314 10/08/2019 Arthur David Churchman Charla Neuman Neuman, Charla: Alleged Violation of RCW 42.17A.700 for failure to timely file Personal Financial Affairs Statement reports (F-1 reports) (EY 19, Oct 19) RCW 42.17A.700 Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the complaint David Churchman filed on October 8, 2019. The complaint alleged that Charla Neuman (Respondent), a Candidate for City Council Member for City of Sumner may have violated RCW 42.17A.700 for failure to timely file Personal Financial Affairs Statement reports (F-1 reports). 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements and the applicable PDC reports filed by the Respondent to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to timely file the F-1 report does not amount to a violation that warrants further investigation.

Pursuant to WAC 390-37-060(1)(d), Charla Neuman will receive a formal written warning concerning failure to timely file their F-1 report. The formal written warning will include staff’s expectation that Charla Neuman timely files all future required Personal Financial Affairs Statements. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/58314
58311 10/08/2019 Miki Mullor Kathleen Huckabay Livable Sammamish: Alleged Violation of RCW 42.17A.240 for failure to accurately report contributor information on Receipts & Expenditure Summary reports (C-4 reports) (EY 19, Oct 19) RCW 42.17A.240 Request for Technical Correction

The complaint alleged Livable Sammamish Sponsored by Merrill Company (Committee), a continuing committee, may have violated RCW 42.17A.240 by failing to accurately report contributor information. 

PDC staff has determined, in this instance, the alleged failure to accurately report contributor information, does not amount to a violation warranting further investigation. The minor or ministerial error on required reports did not materially impact the public interest. Upon notification of this error, the Committee timely amended the report, making the necessary technical correction as requested by staff. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/58311
58201 10/04/2019 Glen Morgan Monica Mickhager Mickhager, Monica: Alleged Violation of RCW 42.17A.235, .240 for failure to timely and accurately file expenditure reports (C-4 reports) (EY 19, Oct 19) RCW 42.17A.240, RCW 42.17A.235 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint Glen Morgan filed on October 4, 2019. The complaint alleged that Monica Mickhager (Respondent), a Candidate for City Council Member for City of Port Townsend may have violated RCW 42.17A.235, .240 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the responses provided by the Respondent; the applicable PDC reports filed by the Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign does not amount to a violation that warrants further investigation.

PDC staff is reminding Monica Mickhager about the importance of the timely and accurate disclosure of all contribution and expenditure activities, including the filing fee, and the timely filings of all future PDC reports in accordance with the statutes and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/58201
58200 10/04/2019 Glen Morgan Sofia Aragon Aragon, Sofia (2): Alleged Violation of RCW 42.17A.430 for prohibited distribution of funds from one candidate or candidate committee to another candidate or candidate committee (EY 19, Oct 19) RCW 42..17A.430 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint Glen Morgan filed on October 3, 2019. The complaint alleged that Sofia Aragon (Respondent), a Candidate for City Council Member for City of Burien may have violated RCW 42.17A.430 for prohibited distribution of funds from one candidate or candidate committee to another candidate or candidate committee.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent and the applicable PDC reports filed by the Respondent to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance there does not appear to be evidence that supports a finding of a violation that warrants further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/58200
58195 10/04/2019 James Luce Dale Rice Rice, Dale: Alleged violations of RCW 42.17.235 and .240 for failure to timely and accurately report contributions and expenditures and RCW 42.17A.205 for failing to timely register as a candidate with the PDC within two weeks of candidacy. (EY 19; Oct 19) RCW 42.17A.240, RCW 42.17A.235, RCW 42.17A.205 Case Closed with Reminder

The complaint alleged Dale Rice, a candidate for Vancouver School Board, Position 1, may have violated RCW 42.17A.235 and .240 for failing to timely and accurately report contributions and expenditures. 

https://www.pdc.wa.gov/browse/cases/58195
58190 10/04/2019 Glen Morgan Krystal Marx Marx, Krystal (5): Alleged Violation of RCW 42.17A.700, .710 for failure to accurately & timely report Personal Financial Affairs Statement reports (F-1 reports); RCW 42.17A.235, .240 for failure to accurately & timely report contributions and expenditures reports (C-3 & C-4 reports) (Oct 19) RCW 42.17A.710, RCW 42.17A.700, RCW 42.17A.235, RCW 42.17A.240 Case Closed with Written Warning

The complaint alleged that Krystal Marx, a City of Burien council member, may have violated: (1) RCW 42.17A.710 by failing to accurately disclose personal financial information on a Personal Financial Affairs Statement (F-1) filed in 2019 for calendar year 2018 activities; and (2) RCW 42.17A.235 and .240 for failing to timely and accurately file reports of contribution and expenditure activities on Monetary Contributions (C-3) reports and Summary Full Campaign Contributions and Expenditures (C-4) reports concerning the establishment of a GoFundMe account.

Staff has determined in this instance, failure to accurately disclose personal financial information on the F-1 report filed in 2019 covering 2018 activity does not amount to a finding of a violation that warrants further investigation.

Pursuant to WAC 390-37-060(1)(d), however, Krystal Marx will receive a formal written warning concerning her failure toaccurately disclose personal financial information on the F-1 report filed for calendar year 2018. The formal written warning will include staff’s expectation Marx will disclose her City of Burien stipend earned in calendar year 2019 on the F-1 filed in 2020, and, in the future, she must comply with all applicable PDC statutes, rules and reporting requirements.

The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/58190
58175 10/04/2019 Glen Morgan Pedro Olguin Olguin, Pedro (7): Alleged Violation of RCW 42.17A.700, .710 for failure to timely and accurately file Personal Financial Affairs Statement reports (F-1 reports) (Oct 19) RCW 42.17A.710, RCW 42.17A.700 Case Closed with Written Warning

The complaint alleged Pedro Olguin, a City of Burien council member, may have violated RCW 42.17A.710 by failing to accurately disclose personal financial interests on a Personal Financial Affairs Statement (F-1) filed in 2019 covering 2018 activity. 

As an elected official, Olguin is required to file an F-1 and if needed, an F-1 Supplement report, by April 15 of each year. The report covers the prior year. As noted in the complaint, Olguin failed to report the $7,200 stipend paid to council members on the F-1. The stipend paid to city council members is public information and there is no indication Olguin attempted to conceal the income from the public. 

Based on our findings staff has determined that, in this instance, failure to list a city council stipend on an F-1 form does not amount to a finding of a violation that warrants further investigation. Pursuant to WAC 390-37-060(1)(d), however, Pedro Olguin will receive a formal written warning concerning the failure to list income as required on the F-1. The formal written warning will include staff’s expectation Olguin include the stipend on the F-1 in the future.  

The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules. Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/58175
58161 10/03/2019 PDC Staff Darold Brandenburg Brandenburg, Darold: Alleged violations of RCW 42.17A.205, .235, .240, and WAC 390-16-125 by failing to timely change from the Mini Reporting Option to the Full Reporting Option, and to timely file the accompanying reports (EY 19; Oct 19) RCW 42.17A.240, RCW 42.17A.235, RCW 42.17A.205, WAC 390-16-125 Resolved through Statement of Understanding

A Public Disclosure Commission (PDC) staff generated complaint was filed against Darold Brandenberg, a 2019 candidate for Fire Commissioner for Okanogan County Fire Protection District #6, alleging that he exceeded the $5,000 contribution limitations of the Mini Reporting Option.  

On September 6, 2019, PDC staff sent a letter informing to Mr. Brandenberg concerning his request to change from the Mini Reporting Option to the Full Reporting option, which was was approved despite the fact that his 2019 Campaign for Fire Commissioner exceeded the $5,000 contribution limitation to qualify for the Mini Reporting Option. 

On October 29, 2019, staff sent Mr. Brandenberg a letter informing him that an assessment of facts had been completed, and a staff generated complaint was opened concerning allegations that his 2019 Campaign exceeded the limitations of the Mini Reporting Option. 

On January 10, 2020, PDC staff received a signed Statement of Understanding (SOU) from Mr. Brandenberg dated January 7, 2020, along with a $150 penalty payment.  The SOU signed by him acknowledged a violation of WAC 390-16-125 by exceeding the contribution limitations of the Mini Reporting Option, and resolved the allegation listed in the staff generated complaint.   

Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1).  

https://www.pdc.wa.gov/browse/cases/58161
58157 10/03/2019 PDC Staff Thomas Moak Moak, Thomas: Alleged violations of RCW 42.17A.205, .235, .240, and WAC 390-16-125 by failing to timely change from the Mini Reporting Option to the Full Reporting Option, and to timely file the accompanying reports (EY 19; Oct 19) RCW 42.17A.240, RCW 42.17A.235, RCW 42.17A.205, WAC 390-16-125 Resolved through Statement of Understanding

The Public Disclosure Commission (PDC) has completed its review of the staff-generated complaint initiated on October 3, 2019, against Thomas Moak, a 2019 candidate for Port Commissioner for the Port of Kennewick, may have violated WAC 390-16-125 for exceeding the limitations of the Mini Reporting option without prior written authorization from the PDC. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the applicable PDC reports filed by the Respondent; the Respondent’s request to change reporting options; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, exceeding the limitations of the Mini Reporting option without prior written authorization from the PDC does not amount to a violation that warrants further investigation. 

Thomas Moak completed a Statement of Understanding (SOU) and paid a $150 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), acknowledging violations of WAC 390-16-125 for exceeding the limitations of the Mini Reporting option without prior written authorization from the PDC. The $150 penalty assessed resolved the allegations in this complaint. 

Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/58157
58155 10/03/2019 PDC Staff Tam Dinh Dinh, Tam: Alleged violations of RCW 42.17A.205, .235, .240, and WAC 390-16-125 by failing to timely change from the Mini Reporting Option to the Full Reporting Option, and to timely file the accompanying reports (EY 19; Oct 19) WAC 390-16-125, RCW 42.17A.240, RCW 42.17A.235, RCW 42.17A.205 Resolved through Statement of Understanding

A PDC staff generated complaint was filed against Tam Dinh, a 2019 candidate for School Director for Mercer Island School District 400, for exceeding the limitations of the Mini Reporting Option.   

On June 26, 2019, PDC staff Ms. Dinh a letter approving her Campaign to change from the Mini Reporting Option to the Full Reporting Option despite her 2019 Campaign receiving $6,152 in total contributions, which exceeded the contribution limits of the Mini Reporting Option by $1,152.

On November 7, 2019, PDC staff received a signed Statement of Understanding (SOU) from Tam Dinh aong with a $150 civil penalty payment, acknowledging violations of RCW 42.17A.205, .235, and .240 by exceeding the contribution limitations of the Mini Reporting Option, and resolving this matter.

https://www.pdc.wa.gov/browse/cases/58155
58134 10/03/2019 PDC Staff Jorge Chacón Chacón, Jorge: Alleged violation of WAC 390-16-125 for exceeding Mini Reporting limitations without prior authorization from the PDC (EY 19; Oct 19) WAC 390-16-125 Resolved through Statement of Understanding

The Public Disclosure Commission (PDC) has completed its review of the staff-generated complaint initiated on October 3, 2019. The complaint alleged that Jorge Chacón (Respondent), a 2019 candidate for City Council Member for the City of Wenatchee may have violated WAC 390-16-125 for exceeding the limitations of the Mini Reporting option without prior written authorization from the PDC. 
PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the applicable PDC reports filed by the Respondent; the Respondent’s request to change reporting options; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, exceeding the limitations of the Mini Reporting option without prior written authorization from the PDC does not amount to a violation that warrants further investigation. 

Jorge Chacón completed a Statement of Understanding (SOU) and paid a $150 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), acknowledging violations of WAC 390-16-125 for exceeding the limitations of the Mini Reporting option without prior written authorization from the PDC. The $150 penalty assessed resolves the allegations in this complaint. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/58134
58104 10/02/2019 Deborah Treen Karen Howe Howe, Karen: Alleged Violation RCW 42.17A.235 for failure to timely report monetary or in-kind contributions and expenditures reports (C-3 & C-4 reports) (EY19, Oct 19) RCW 42.17A.235 Case Closed with No Evidence of Violations

On September 30, 2019, the Public Disclosure Commission (PDC) received a complaint alleging that Karen Howe, a candidate for City Council Member for the City of Sammamish Position 4 in 2019, may have violated RCW 42.17A.235 for failure to timely and accurately file the Summary Full Campaign Contribution and Expenditure report (C-4 report) disclosing expenditures undertaken by the campaign. 

PDC staff reviewed the allegation, including the applicable statutes, rules and the reporting requirement and found that Ms. Howe reported the expenditure at issue in this complaint on September 17, 2019. 

Based on this finding staff determined that, in this instance, no evidence supports a finding of a violation warranting further investigation. 

Based on this information, staff dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/58104
58103 10/02/2019 Deborah Treen Rituja Indapure Indapure, Rituja: Alleged Violation RCW 42.17A.235 for failure to timely report monetary or in-kind contributions and expenditures reports (C-3 & C-4 reports) (EY19, Oct 19) RCW 42.17A.235 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint you filed on September 30, 2019. The complaint alleged that Rituja Indapure (Respondent), a Candidate for City County for City of Sammamish may have violated RCW 42.17A.235 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; and the applicable PDC reports filed by the Respondent to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, the timely filing of the C-4 report reflecting the expenditure leaves no evidence supporting a finding of a violation that warrants further investigation.

https://www.pdc.wa.gov/browse/cases/58103
58102 10/02/2019 Glen Morgan Daniel Hammill Hammill, Daniel: Alleged violations of RCW 42.17A.240 for failure to provide sufficient expenditure details & report candidate filing fee (EY '19; Sep '19) RCW 42.17A.240 Case Closed with Reminder
  • Allegation: Alleged violations of RCW 42.17A.240 for failure to provide sufficient expenditure details & report candidate filing fee
https://www.pdc.wa.gov/browse/cases/58102
58101 10/02/2019 Glen Morgan Elizabeth Hartsoch Hartsoch, Elizabeth "Beth": Alleged violations of RCW 42.17A.240 for failure to provide sufficient expenditure details & report candidate filing fee (EY '19; Sep '19) RCW 42.17A.240 Request for Technical Correction

On September 2019, the Public Disclosure Commission (PDC) received a complaint alleging that Elizabeth Hartsoch, a candidate for City Council Member for the City of Bellingham in 2019, may have violated RCW 42.17A.240 by failing to provide sufficient expenditure details and for failure to report the candidate registration/filing fee. 

PDC staff reviewed the allegation, and the May and July 2019 C-4 reports filed by Ms. Hartsoch and found that the Campaign, through its consultant, made a $1,302.21 expenditure towards "pieces of walk literature," but failed to include the number of literature materials purchased. Staff also found that the Campaign initially neglected to report the PDC filing fee as required by the law/rule, but later amended both C-4 reports and included the required details. 

Staff determined that the noncompliance was a result of a minor error, which the Campaign remedied  by filing amended C-4 reports as soon as it received a copy of the complaint. Staff also noted that Ms. Hartsoch is a first-time candidate who does not have any prior violations with the PDC. 

Based on these findings staff has determined that, in this instance, the Campaign's failure to properly and accurately describe an expenditure and report a contribution for registration fee, is a violation that does not warrant further investigation. 

Ms. Hartsoch made a minor or ministerial error(s) on a few expenditures already disclosed on her C-4 reports, which did not materially impact the public interest since the expenditures were timely disclosed on the initial reports, except for the filing fee, which was included after the May 2019 C-4 was amended. After being notified of the error(s) by the PDC, Ms. Hartsoch amended the C-4 reports after four days of receiving the complaint disclosing  the proper expenditure descriptions and making the necessary technical corrections. 

Based on this information, the PDC dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/58101
58100 10/02/2019 Chandler Bailey Mead Citizens Advisory Committee Mead Citizens Advisory Committee: Alleged Violations of RCW 42.17A.205, .210, .215 for failure to timely file a registration report; RCW 42.17A.235 for failure to timely report contributions and expenditures reports (EY 19, Oct 19) RCW 42.17A.205, RCW 42.17A.235, RCW 42.17A.215, RCW 42.17A.210 Resolved through Statement of Understanding

On December 20, 2019, pursuant to RCW 42.17A.755, WAC 390-37-060 and WAC 390-37-071, the PDC opened a formal investigation and held a Case Status Review (Initial Hearing) in this matter after conducting a preliminary review and assessment of this complaint. 

The complaint, which was filed with the PDC on October 2, 2019, alleges that the Mead School District Advisory Committee, may have violated RCW 42.17A.205, .210, and .215 by failing to timely file contribution and expenditure reports. 

https://www.pdc.wa.gov/browse/cases/58100
58099 10/02/2019 Glen Morgan Hollie Huthman Huthman, Hollie: Alleged violation of RCW 42.17A.240 for failure to provide sufficient expenditure details (EY '19; Sep '19) RCW 42.17A.240 Case Closed with Reminder

The complaint alleged Hollie Huthman, a 2019 candidate for Bellingham City Council, may have violated RCW 42.17A.240 and WAC 390-16-037 for failing to completely and accurately report expenditure details.

PDC staff has determined that, in this instance, the alleged failure to completely and accurately report expenditure details does not amount a violation warranting further investigation. 

PDC staff is reminding Huthman about the importance of completely and accurately reporting expenditure details. Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/58099
58094 10/02/2019 Glen Morgan April Barker Barker, April: Alleged violations of RCW 42.17A.445 & .240 for personal use of campaign contributions & failure to provide sufficient expenditure details (EY '19; Sep '19) RCW 42.17A.240, RCW 42.17A.445 Request for Technical Correction

On September 27, 2019, the Public Disclosure Commission (PDC) received a complaint from Glen Morgan alleging that April Barker, a candidate for Mayor for the City of Bellingham in 2019, may have violated RCW 42.17A.240 and .445 by failing to provide sufficient expenditure details and for personal us of campaign contributions. 

Staff reviewed the allegations; the applicable statutes, rules and reporting requirements; the C-3 and C-4 reports filed by the April Barker for Bellingham Committee and determined that the two expenditures mentioned in the complaint lacked proper or complete description as required by PDC law/rules. Regarding the allegation of alleged misuse of campaign funds for personal use, staff found that the two expenditures to Verizon Wireless for cellular phone service for the Campaign covering the months of June and July 2019, were not for Ms. Barker's personal use, but rather a specific/dedicated campaign line.

Staff determined that the noncompliance was a result of a minor error, which the Campaign remedied by filing amended C-4 reports as soon as they received a copy of the complaint. 

Based on this information, the PDC finds that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755 (1). 

https://www.pdc.wa.gov/browse/cases/58094
58089 10/02/2019 Glen Morgan Phyllis Joy Gilfilen Gilfilen, Phyllis Joy: Alleged violations of RCW 42.17A.445, .240 & .700 for personal use of campaign contributions, failure to provide sufficient expenditure details & disclose obligations/debt on financial affairs statement. (EY '19; Sep '19) RCW 42.17A.700, RCW 42.17A.445, RCW 42.17A.240 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on September 26, 2019. Your complaint alleged that Phyllis Joy Gilfilen, a candidate for  Whatcom County Sheriff in 2019, may have violated: (1) RCW 42.17A.445(2) & WAC 390-16-238 for personal use of campaign funds; (2) RCW 42.17A.240 & WAC 390-16-037 for failure to accurately describe expenditures on Summary Full Campaign Contribution and Expenditure reports (C-4 reports); and (3) RCW 42.17A.700 & .710 for failure to timely and accurately file Personal Financial Affairs Statement (F-1 report) as a candidate.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Phyllis Joy Gilfilen; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

The complaint included an additional allegation regarding a possible misuse of the Schedule A to the C-4 report’s un-itemized expenditures of $50 or less in the aggregate. No evidence was found that the JoyForSheriff campaign incorrectly disclosed expenditures reported in this section of the C-4 reports filed for the 2019 campaign.

Phyllis Joy Gilfilen was an unsuccessful candidate in 2015 and had a separate individual acting as her treasurer and filing campaign reports. During the 2019 Whatcom County Sheriff campaign, she served as her own treasurer and did not list any other officers or committee members. It appears that her failure to disclose adequate descriptions for campaign expenditures on C-4 reports and her failure to disclose a reportable debt on her candidate F-1, was due to inexperience and general misunderstanding. Ms. Gilfilen responded promptly to the complaint and has not previously been found in violation of PDC laws or rules. 

Based on these findings staff has determined that, in this instance, failure to timely and accurately file two C-4 reports and failure to include a reportable debt on the candidate F-1 report, does not amount to a finding of a violation warranting further investigation.

PDC staff reminded Ms. Gilfilen about the importance of the timely disclosure of all expenditure activities, specifically including any required detail and vendor breakdown as prescribed in WAC, and the timely and accurate disclosure of all reportable financial information on F-1 reports in any future PDC reports in accordance with the statutes and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/58089
58013 09/30/2019 Cody Hart Pat Beehler Beehler, Pat: Alleged violations of RCW 42.17A.635 for indirectly lobbying the legislature outside of authorized channels and .640 for failure to report a grass roots lobbying campaign (EY 19; Sep 19) RCW 42.17A.640, RCW 42.17A.635 Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the complaint Cody Hart filed on September 30, 2019. The complaint alleged that Pat Beehler (Respondent), a public employee for the Washington State Department of Natural Resources (DNR), may have violated RCW 42.17A.635 for indirectly lobbying the legislature outside of authorized channels and RCW 42.17A.640 for failure to report a grass roots lobbying campaign.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the responses provided by the Respondent; and the applicable PDC reports filed by the Respondent, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, indirectly lobbying the legislature outside of the proper official channels and in the proper performance of official duties does not amount to a violation that warrants further investigation.

Pursuant to WAC 390-37-060(1)(d), Pat Beehler will receive a formal written warning concerning indirectly lobbying the legislature outside of the proper official channels and in the proper performance of official duties. The formal written warning will include staff’s expectation that Pat Beehler will not authorize the expenditure of public funds, whether direct or indirect, to lobby the legislature outside of the proper official channels and in proper performance of his official duties as a public employee. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/58013
58011 09/30/2019 Cody Hart Derek Pohle Pohle, Derek: Alleged violations of RCW 42.17A.635 for indirectly lobbying the legislature outside of authorized channels and .640 for failure to report a grass roots lobbying campaign (EY 19; Sep 19) RCW 42.17A.640, RCW 42.17A.635 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint you filed on September 30, 2019. The complaint alleged that Derek Pohle (Respondent), a public employee with the Washington State County Road Administration Board (CRAB) may have violated RCW 42.17A.635 for indirectly lobbying the legislature outside of authorized channels and .640 for failure to report a grass roots lobbying campaign.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the response provided by the Respondent to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, no evidence support a finding of a violation that warrants further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/58011
58010 09/30/2019 Cody Hart Steve Collins Collins, Steve: Alleged violations of RCW 42.17A.635 for indirectly lobbying the legislature outside of authorized channels and .640 for failure to report a grass roots lobbying campaign (EY 19; Sep 19) RCW 42.17A.640, RCW 42.17A.635 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint Cody Hart filed on September 30, 2019. The complaint alleged that Steve Collins (Respondent), a public employee for the University of Washington Bothell (UWB) may have violated RCW 42.17A.635 for indirectly lobbying the legislature outside of authorized channels for public agency lobbying; and RCW 42.17A.640 for failure to report a grass roots lobbying campaign. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the response provided by the Respondent, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, insufficient evidence supports a finding of a violation that warrants further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/58010
58009 09/30/2019 Cody Hart Weston Dorszynski Dorszynski, Weston: Alleged violations of RCW 42.17A.635 for indirectly lobbying the legislature outside of authorized channels and .640 for failure to report a grass roots lobbying campaign (EY 19; Sep 19) RCW 42.17A.635, RCW 42.17A.640 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint Cody Hart filed on September 30, 2019. The complaint alleged that Weston Dorszynski (Respondent), a public employee for the City of Vancouver, may have violated RCW 42.17A.635 for indirectly lobbying the legislature outside of authorized channels for public agency lobbying; and RCW 42.17A.640 for failure to report a grass roots lobbying campaign.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the response provided by the Respondent, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, insufficient evidence supports a finding of a violation that warrants further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/58009
58008 09/30/2019 Cody Hart Jon Warren Warren, Jon: Alleged violations of RCW 42.17A.635 for indirectly lobbying the legislature outside of authorized channels and .640 for failure to report a grass roots lobbying campaign (EY 19; Sep 19) RCW 42.17A.635, RCW 42.17A.640 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint Cody Hart filed on September 30, 2019. The complaint alleged that Jon Warren (Respondent), a public employee for the City of Bellevue, may have violated RCW 42.17A.635 for indirectly lobbying the legislature outside of authorized channels for public agency lobbying; and RCW 42.17A.640 for failure to report a grass roots lobbying campaign. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the response provided by the Respondent, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, insufficient evidence supports a finding of a violation that warrants further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/58008
58007 09/30/2019 Cody Hart Thomas Barger Barger, Thomas: Alleged violations of RCW 42.17A.635 for indirectly lobbying the legislature outside of authorized channels and .640 for failure to report a grass roots lobbying campaign (EY 19; Sep 19) RCW 42.17A.640, RCW 42.17A.635 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint Cody Hart filed on September 30, 2019. The complaint alleged that Thomas Barger (Respondent), a public employee for the City of Seattle may have violated RCW 42.17A.635 for indirectly lobbying the legislature outside of authorized channels for public agency lobbying; and RCW 42.17A.640 for failure to report a grass roots lobbying campaign. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the response provided by the Respondent, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, insufficient evidence supports a finding of a violation that warrants further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/58007
58006 09/30/2019 Cody Hart James Wengler Wengler, James: Alleged violations of RCW 42.17A.635 for indirectly lobbying the legislature outside of authorized channels and .640 for failure to report a grass roots lobbying campaign (EY 19; Sep 19) RCW 42.17A.640, RCW 42.17A.635 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint Cody Hart filed on September 30, 2019. The complaint alleged that James Wengler (Respondent), a board member for the Board of Registration for Professional Engineers and Land Surveyors may have violated RCW 42.17A.635 for indirectly lobbying the legislature outside of authorized channels for public agency lobbying; and RCW 42.17A.640 for failure to report a grass roots lobbying campaign. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the response provided by the Respondent, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, soliciting public employees to lobby the legislature outside of the proper official channels and in the proper performance of their official duties does not amount to a finding of a violation that warrants further investigation.

PDC staff is reminding James Wengler about the importance of avoiding the expenditure of public funds, whether directly or indirectly, to lobby the legislature outside of the proper official channels and the proper performance of official duties. PDC staff expects that James Wengler will avoid using publicly funded email and telephone services to solicit personal support or opposition for legislation in the future.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/58006
58005 09/30/2019 Cody Hart Doug Hendrickson Hendrickson, Doug: Alleged violations of RCW 42.17A.635 for indirectly lobbying the legislature outside of authorized channels and .640 for failure to report a grass roots lobbying campaign (EY 19; Sep 19) RCW 42.17A.635, RCW 42.17A.640 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint Cody Hart filed on September 30, 2019. The complaint alleged that Doug Hendrickson (Respondent), a board member for the Board of Registration for Professional Engineers and Land Surveyors (BORPELS) may have violated RCW 42.17A.635 for indirectly lobbying the legislature outside of authorized channels for public agency lobbying; and RCW 42.17A.640 for failure to report a grass roots lobbying campaign. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the response provided by the Respondent, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, insufficient evidence supports a a finding of a violation that warrants further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/58005
58004 09/30/2019 Cody Hart Marjorie Lund Lund, Marjorie: Alleged violations of RCW 42.17A.635 for indirectly lobbying the legislature outside of authorized channels and .640 for failure to report a grass roots lobbying campaign (EY 19; Sep 19) RCW 42.17A.640, RCW 42.17A.635 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint Cody Hart filed on September 30, 2019. The complaint alleged that Marjorie Lund (Respondent), a board member for the Board of Registration for Professional Engineers and Land Surveyors may have violated RCW 42.17A.635 for indirectly lobbying the legislature outside of authorized channels for public agency lobbying; and RCW 42.17A.640 for failure to report a grass roots lobbying campaign. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the response provided by the Respondent, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, insufficient evidence supports a finding of a finding of a violation that warrants further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/58004
58003 09/30/2019 Cody Hart Aaron Blaisdell Blaisdell, Aaron: Alleged violations of RCW 42.17A.635 for indirectly lobbying the legislature outside of authorized channels and .640 for failure to report a grass roots lobbying campaign (EY 19; Sep 19) RCW 42.17A.640, RCW 42.17A.630 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint Cody Hart filed on September 30, 2019. The complaint alleged that Aaron Blaisdell (Respondent), a board member for the Board of Registration for Professional Engineers and Land Surveyors may have violated RCW 42.17A.635 for indirectly lobbying the legislature outside of authorized channels for public agency lobbying; and RCW 42.17A.640 for failure to report a grass roots lobbying campaign. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the response provided by the Respondent, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, insufficient evidence supports a finding of a finding of a violation that warrants further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/58003
58001 09/30/2019 Cody Hart Ivan Van De Wege Van De Wege, Ivan: Alleged violations of RCW 42.17A.635 for indirectly lobbying the legislature outside of authorized channels and .640 for failure to report a grass roots lobbying campaign (EY 19; Sep 19) RCW 42.17A.640, RCW 42.17A.635 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint Cody Hart filed on September 30, 2019. The complaint alleged that Ivan Van De Wege (Respondent), a board member for the Board of Registration for Professional Engineers and Land Surveyors may have violated RCW 42.17A.635 for indirectly lobbying the legislature outside of authorized channels for public agency lobbying; and RCW 42.17A.640 for failure to report a grass roots lobbying campaign. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the response provided by the Respondent, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, insufficient evidence supports a finding of a finding of a violation that warrants further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/58001
58000 09/30/2019 Cody Hart Nirmala Gnanapragasam Gnanapragasam, Nirmala: Alleged violations of RCW 42.17A.635 for indirectly lobbying the legislature outside of authorized channels and .640 for failure to report a grass roots lobbying campaign (EY 19; Sep 19) RCW 42.17A.640, RCW 42.17A.635 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint Cody Hart filed on September 30, 2019. The complaint alleged that Nirmala Gnanapragasam (Respondent), a board member for the Board of Registration for Professional Engineers and Land Surveyors may have violated RCW 42.17A.635 for indirectly lobbying the legislature outside of authorized channels for public agency lobbying; and RCW 42.17A.640 for failure to report a grass roots lobbying campaign. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the response provided by the Respondent, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, insufficient evidence supports a finding of a finding of a violation that warrants further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/58000
57964 09/30/2019 Glen Morgan Camille Diaz Hackler Diaz Hackler, Camille: Alleged Violations of RCW 42.17A.205, .210, .215 for failure to timely file C-1 report; RCW 42.17A.235 for failure to timely file contribution and expenditure reports; RCW 42.17A.700 for failure to timely file F-1 reports (EY 19, Sept 19) RCW 42.17A.235, RCW 42.17A.700, RCW 42.17A.215, RCW 42.17A.210, RCW 42.17A.205 Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the complaint Glen Morgan filed 
on September 27, 2019. The complaint alleged that Camille Diaz Hackler (Respondent), a 
Candidate for School Director for Bellingham SD 501 may have violated RCW 42.17A.205, 
.210 and .215 for failure to timely file Campaign Registration reports (C-1 reports), disclosing 
treasurer and depository information; RCW 42.17A.235 for failure to timely and accurately file 
Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and 
Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the 
Campaign; and RCW 42.17A.700 for failure to timely file Personal Financial Affairs Statement 
reports (F-1 reports). 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the 
response provided by the Respondent; and the applicable PDC reports filed by Respondent to 
determine whether the record supports a finding of one or more violations. 
 
Based on our findings staff has determined that, in this instance, failure to timely file C-1 and F- 
1 reports does not amount to a violation that warrants further investigation. 

Pursuant to WAC 390-37-060(1)(d), Camille Diaz Hackler will receive a formal written warning 
concerning failure to timely file Campaign Registration and Personal Financial Affairs Statement 
reports. The formal written warning will include staff’s expectation that Camille Diaz Hackler 
timely files all future required reports. The Commission will consider the formal written warning 
in deciding on further Commission action if there are future violations of PDC laws or rules. 
Based on this information, the PDC finds that no further action is warranted and has dismissed 
this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/57964
57959 09/30/2019 Glen Morgan Seth Fleetwood Fleetwood, Seth: Alleged Violation of RCW 42.17A.240 for failure to accurately and completely report expenditure details on Receipts & Expenditure Summary reports (C-4 reports) (EY 19, Sept 19) WAC 390-16-037, RCW 42.17A.240 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint Glen Morgan filed on September 26, 2019. The complaint alleged that Seth Fleetwood, a Candidate for Mayor for City of Bellingham may have violated RCW 42.17A.235, .240 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the responses provided by the Respondent; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports) does not amount to a violation that warrants further investigation.

PDC staff is reminding Seth Fleetwood about the importance of the timely and accurate disclosure of all contribution and expenditure activities, including the filing fee, and the timely filings of all future PDC reports in accordance with the statutes and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/57959
57854 09/26/2019 Glen Morgan Satpal Sidhu Sidhu, Satpal: Alleged violations of RCW 42.17A.445 for personal use of campaign funds, and RCW 42.17A.240 for failure to accurately and completely report expenditures (EY 19; Sep 19) WAC 390-16-037, WAC 390-16-238, RCW 42.17A.240, RCW 42.17A.445 Case Closed with Reminder

The complaint alleged Satpal Sidhu, a 2019 candidate for Whatcom County Executive, may have violated RCW 42.17A.445 and WAC 390-16-238 for personal use of campaign contributions and RCW 42.17A.240 and WAC 390-16-037 for failing to completely and accurately report expenditure details. 

PDC staff has determined that, in this instance, the alleged personal use of campaign contributions and failing to completely and accurately report expenditure details does not amount a violation warranting further investigation. Staff is reminding Sat pal Sidhu about the importance of completely and accurately reporting expenditure details.  

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/57854
57847 09/26/2019 Cody Hart Ken Fuller Fuller, Ken: Alleged violations of RCW 42.17A.635 for indirectly lobbying the legislature outside of authorized channels and .640 for failure to report a grass roots lobbying campaign (EY 19; Sep 19) RCW 42.17A.640, RCW 42.17A.635 Resolved through Statement of Understanding

A complaint was filed alleging that Ken Fuller, Executive Director of the Washington State Board of Registration for Professional Engineers and Land Surveyors (BORPELS), may have violated RCW 42.17A.635 by indirectly lobbying the legislature outside of authorized channels for public agency lobbying.   

BORPELS is and has been an independent state agency for years, which relied on the Department of Licensing  for certain administrative and other functions, including assistance with management of BORPELS's budget.  During the 2019 Legislative Session, legislation was proposed, House Bill 1176 and Senate Bill 5443, that if approved would make BORPELS an independent state agency responsible for its own budget and administrative functions.  

On December 12, 2019,  PDC staff held an Initial Hearing (Case status review) pursuant to RCW 42.17A.755, and WACs 390-37-060 and 390-37-071, and opened a formal investigation concerning this matter. 

Staff's investigation found that Mr. Fuller sent out emails using his BORPELS computer, state email address, and on state time that were either cc’d or emailed directly to individuals and organizations outside the permitted BORPELS communication channels in violation of RCW 42.17A.635.   While some of the emails were also sent or cc’d to BORPELS Board members, the emails contained “calls to action” and indirect lobbying appeals to contact legislators outside the agency’s normal communication email channel for lobbying as detailed in the Report of Investigation. 

In the responses to the allegations and staff's inquiries, Mr. Fuller estimated that “he spent 20 hours during the 2019 legislative session preparing and sending emails to non-BORPELS members requesting that they contact legislators or the Governor’s office to express support for pending legislation, SB 5443 and HB 1176.   The estimated time includes direct emails Mr. Fuller sent to non-BORPELS members, as well as cc’d copies to non-BORPELS members of emails that were primarily directed to BORPELS members, and also included the time spent Mr. Fuller developing those communications such as preparing sample communications to send to legislators and legislative member email address lists.  

Mr. Fuller estimated that he had an additional two hours of telephone conversations during the 2019 session requesting that non-BORPELS members contact legislators or the Governor’s office in support of the two bills.  He stated he believed this was the extent “for sake of argument, the PDC could consider indirect lobbying” and the emails provided "general information and answered others’ questions about the impact of the legislative proposals, but this was not connected with any request for legislative support and thus is not indirect lobbying.” 

The legislation was overwhelmingly approved during the 2019 Legislative Session, and BORPELS is an independent state agency with its own administrative, budget and management authority.

Mr. Fuller stated “I understand the complaint…also alleged that I acted improperly by directly lobbying legislators and the Governor's office in support of HB 1176 and SB 5443. All such direct lobbying was for official purposes and through official channels and was thus lawful. “The complaint filed also alleged that I engaged in a grass roots lobbying campaign… My conduct did not amount to such a violation, because no covered expenditures were made to present a program to the public within the meaning of the section.  Last, the complaint filed alleged that I personally benefited from the proposed legislation and abused my authority to negotiate with private organizations in exchange for their legislative support." 

“There is no merit to these allegations. I hereby enter this (SOU) with respect to indirect lobbying violations in consideration of and with the understanding that the PDC will close the complaint with no findings of violation with respect to the other complaint allegations. Concurrent herewith, I am also executing a Statement of Understanding as it relates to the failure of BORPELS to timely file lobbying reports for Q1/2019 and Q2/2019, which the PDC raised on its own initiative in the course of investigating the complaint.”

On April 24, 2020, PDC received a completed Statement Of Understanding (SOU) and a $150 civil penalty payment from Ken Fuller. The $150 civil penalty assessed against Mr. Fuller in this matter was done in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule).  By completing the SOU, Mr. Fuller acknowledged violations of RCW 42.17A.635 by using BORPELS equipment, resources and staff time to engage in an indirect lobbying effort in support of legislation.

Based on this information and the facts, the PDC has dismissed the complaint in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/57847
57786 09/24/2019 Brandon Franck Darren LaFavor Lafavor, Darren: Alleged violation of RCW 42.17A.205 for failure to timely register as a candidate with the PDC within two weeks of candidacy. (EY '19) (Sept '19) RCW 42.17A.205 Case Closed with Written Warning

The complaint alleged Darren LaFavor, a 2019 candidate for Clark County Fire Protection District 6 Fire Commissioner, Position 2, may have violated RCW 42.17A.205 by failing to timely file a Candidate Registration (Form C-1) within two weeks of becoming a candidate. 

Staff has determined in this instance, the failure to timely register as a candidate with the PDC within two weeks of his candidacy does not amount to a material violation warranting further investigation. 

However, pursuant to WAC 390-37-060(1)(d), LaFavor will receive a formal written warning concerning his failure to timely register as a candidate with the PDC. The formal written warning will include PDC staff’s expectation Darren LaFavor file a Candidate Registration (C-1) timely in future elections.   

The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/57786
57781 09/24/2019 Glen Morgan Jimmy Matta Matta, Jimmy: Alleged Violations of RCW 42.17A.700 & .710 for failure to report accurate and complete information on Personal Financial Affairs Statement reports (F-1 reports) (EY 19, Sept 19) RCW42.17A.700, RCW 42.17A.710 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint Glen Morgan filed on September 20, 2019. The complaint alleged that Jimmy Matta (Respondent), a current City Council Member for the City of Burien may have violated RCW 42.17A.700, .710 for failure to report accurate and complete information on Personal Financial Affairs Statement reports (F-1 reports). 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the responses provided by the Respondent and the applicable PDC reports filed by the Respondent to determine whether the record supports a finding of one or more violations.

F-1 reports, including all affiliations, customers, assets and obligations for themselves, their partner or spouse and any qualifying dependents.

Based on our findings staff has determined that, in this instance, failure to report accurate and complete information on the Personal Financial Affairs Statements does not amount to a violation that warrants further investigation.

PDC staff is reminding Jimmy Matta about the importance of the importance of complete and accurate disclosure on Personal Financial Affairs Statement reports and complete and accurate disclosure on all future PDC reports in accordance with the statutes and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/57781
57779 09/24/2019 Glen Morgan Cydney Moore Moore, Cydney: Alleged violations of RCW 42.17A.240 & .700 for failure to fully & accurately describe expenditures and report income, board directorship(s). (EY '19; Sept '19) RCW 42.17A.240, RCW 42.17A.700 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on September 21, 2019. The complaint alleged that Cydney Moore, a candidate for Burien City Council in 2019, may have violated: (1) RCW 42.17A.240 & WAC 390-16-037 for failure to accurately describe expenditures for printing on Summary Full Campaign Contribution and Expenditure reports (C-4 reports); and (2) RCW 42.17A.700 & .710 for failure to timely and accurately file Personal Financial Affairs Statement (F-1 report) as a candidate.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response(s) provided by Cydney Moore; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Cydney Moore was a first-time candidate in 2019. It appears that her failure to disclose adequate descriptions for campaign expenditures on C-4 reports and her failure to disclose a reportable directorship position on her candidate F-1, was due to inexperience and general misunderstanding. Ms. Moore responded promptly to the complaint and has not previously been found in violation of PDC laws or rules. 

Based on these findings staff has determined that, in this instance, failure to timely and accurately file the 21-day pre-primary C-4 report and failure to include a reportable position in an association on the candidate F-1 report, does not amount to a finding of a violation warranting further investigation.

PDC staff is reminding Ms. Moore about the importance of the timely disclosure of all expenditure activities, specifically including any required detail and vendor breakdown as prescribed in WAC, and the timely and accurate disclosure of all reportable financial information on F-1 reports in any future PDC reports in accordance with the statutes and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/57779
57761 09/24/2019 Carol Snyder Michelle Rasmussen Rasmussen, Michelle: Alleged Violation of RCW 42.17A.240 & WAC 390-16-037 for failure to provide accurate and complete information on Receipts & Expenditure Summary reports (C-4 reports) WAC 390-16-037, RCW 42.17A.240 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint Carol Snyder filed on September 20, 2019. The complaint alleged that Michelle Rasmussen (the Respondent), a Candidate for City Council Member for City of Spokane Valley may have violated RCW 42.17A.240 for failure to report accurate and complete details on Receipts & Expenditure Summary reports (C-4 reports).

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response(s) provided by the Respondent; the applicable PDC reports filed by Respondent to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to include the expenditure details on C-4 reports, does not amount to a violation that warrants further investigation.

PDC staff is reminding Michelle Rasmussen about the importance of including all required detail for expenditures on all PDC reports in accordance with the statutes and rules. PDC staff expects in the future that Michelle Rasmussen will report timely and with all required detail for expenditures on all PDC reports in accordance with PDC laws and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/57761
57748 09/24/2019 Glen Morgan Anthony Martinelli Martinelli, Anthony: Alleged violations of RCW 42.17A.240 & .700 for failure to fully & accurately describe expenditures and report contributions & income (EY '17 & '19; Sept '19) RCW 42.17A.240, RCW 42.17A.700 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on September 20, 2019. The complaint alleged that Anthony Martinelli, a candidate for Des Moines City Council, Position 6 in 2019, may have violated: (1) RCW 42.17A.235, RCW 42.17A.240 & WAC 390-16-037 for failure to timely and accurately describe expenditures on Summary Full Campaign Contribution and Expenditure reports (C-4 reports) for election year 2017 & 2019; (2) RCW 42.17A.235 & .240 for failure to timely and accurately file Monetary Contribution reports (C-3 reports); and (3) RCW 42.17A.700 & .710 for failure to timely and accurately file Personal Financial Affairs Statement (F-1 report) as a candidate.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Mr. Martinelli; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

The complaint included additional allegations regarding possible inaccurate disclosure of reportable income on the F-1, Section 1. No evidence was found showed that Mr. Martinelli failed to include sources of income required by statute.

Anthony Martinelli was an unsuccessful candidate in 2017 and had a separate individual acting as his treasurer and filing campaign reports. During the 2019 Des Moines City Council campaign, other than approximately one month, he served as his own treasurer and did not list any other officers or committee members. It appears that his failure to disclose adequate descriptions for campaign expenditures on C-4 reports, the mistaken entry of an expenditure as candidate’s personal funds, and his failure to disclose a reportable business ownership interest on his candidate F-1, was due to inexperience and general misunderstanding. Mr. Martinelli responded promptly to the complaint, worked with PDC staff to correct his reports and has not previously been found in violation of PDC laws or rules. 

Based on these findings staff has determined that, in this instance, failure to timely and accurately file a small number of C-3 and C-4 reports and failure to include a reportable business ownership interest on the candidate F-1 report, does not amount to a finding of a violation warranting further investigation.

PDC staff is reminding Mr. Martinelli about the importance of the timely and accurate disclosure of all expenditure activities, specifically including any required detail and vendor breakdown as prescribed in WAC, the timely and accurate disclosure of candidate’s personal funds deposited into the campaign account, and the timely and accurate disclosure of all reportable financial information on F-1 reports in any future PDC reports in accordance with the statutes and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/57748
57742 09/24/2019 Glen Morgan Katherine "Kate" Kruller Kruller, Katherine "Kate" (2): Alleged violations of RCW 42.17A.240 for failure to fully & accurately report & describe expenditures (candidate filing fee & printed campaign materials). (EY '19 Sept '19) RCW 42.17A.240 Case Closed with Reminder

On September 19, 2019, the Public Disclosure Commission (PDC) received a complaint alleging that Katherine Kruller, an incumbent council member for the Tukwila City Council and a candidate seeking re-election to that office in 2019, may have violated RCW 42.17A.240 and WAC 390-16-037 by failing to report an expenditure and for failure to properly describe an expenditure on the Summary Full Campaign Contribution and Expenditure report (C-4 report). 

Staff reviewed the allegations/complaint and determined that Ms. Kruller Campaign failed to include proper description for one expenditure as required by the statute. Staff also determined that Ms. Kruller failed to timely report an in-kind contribution. However, the Campaign amended its report timely and properly disclosed the in-kind contribution and included additional description as required by the statute. 

Based on these findings, staff reminded Ms. Kruller about the importance of filing timely and accurate C-4 reports disclosing contribution and expenditures activities undertaken by her Campaign, including properly describing the expenditures, as required by statute and rule.  

Based on this information, the PDC dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/57742
57738 09/24/2019 Sandra Robson Whatcom County Affordable Housing Council sponsored by the Building Industry Association of Whatcom County Whatcom County Affordable Housing Council: Alleged violation of RCW 42.17A.205(5) & WAC 390-16-011A for failure to include sponsor (BIAWC) in registered committee name. (EY '19 Sep '19) RCW 42.17A.205, wac 390-16-011a Case Closed with Reminder

On September 18, 2019, the Public Disclosure Commission (PDC) received a complaint alleging the Whatcom County Affordable Housing Council, may have violated RCW 42.17A.205(5) and WAC 390-16-011A for failure to include sponsor in the committee's name. 

PDC staff reviewed the allegation; the applicable statute/rule and the reporting requirement; the applicable PDC reports filed by the Whatcom County Affordable Housing Council (Committee); and reviewed their date in the PDC database, to determine whether the record supports a finding of one or more violations. 

Staff's review of the Committee's Monetary Contribution reports (C-3 reports) and the Summary Full Campaign Contribution and Expenditure reports (C-4 reports) found the Committee received more than 80% of its contributions from the Building Industry Association of Whatcom County (BIAWC), making the BIAWC a sponsor. 

On October 2, 2019, the Committee amended its C-1pc and changed the Committee's name to "Whatcom County Affordable Housing Council sponsored by the Building Industry Association of Whatcom County."

Based on these findings, staff determined that, in this instance, failure to include the sponsor name in the name of the committee is a violation that does not warrant further investigation or enforcement action. The Committee made a good faith effort by responding quickly and amending its Committee Registration to reflect BIAWC as the sponsor of the Committee. 

However, staff reminded the Whatcom County Affordable Housing Council about the importance of including the name of the sponsor in the Committee's name in the future. 

Based on this information, the PDC dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/57738
57721 09/23/2019 Glen Morgan Nancy Manos Manos, Nancy: Alleged violations of RCW 42.17A.235 and .240 for failure to report value of candidate's filing fee as an expenditure or in-kind contribution (EY 19; Sep 19) RCW 42.17A.235, RCW 42.17A.240 Resolved as Remedial

The Public Disclosure Commission (PDC) has completed its review of the complaint Glen Morgan filed on September 19, 2019. The complaint alleged that Nancy Manos (Respondent), a 2019 candidate for Tukwila City Council, may have violated RCW 42.17A.235 and .240 for failure to report the value of the candidate’s filing fee as an expenditure or in-kind contribution to the Campaign on Summary Full Campaign Contribution and Expenditure reports (C-4 reports).

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to timely report contributions and expenditures does not amount to a violation that warrants further investigation.

While the alleged non-compliance appears to constitute violations of PDC laws and rules made by Nancy Manos, the violations are remedial in nature, and do not warrant further investigation or enforcement action. The expenditures totaled no more than $1000, occurred more than 30 days before the election, were inadvertent and minor in nature, did not materially affect the public interest. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/57721
57717 09/23/2019 Glen Morgan Cynthia Johnson Johnson, Cynthia: Alleged Violations of RCW 42.17A.205 and .240 for failure to accurately and completely report committee contact information and expenditures (EY 19, Sept 19) RCW 42.17A.205, RCW 42.17A.240 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint Glen Morgan filed on September 19, 2019. The complaint alleged that Cynthia Johnson (Respondent), a candidate for City Council Member for City of Tukwila may have violated RCW 42.17A.205 for failure to timely and accurately file Campaign Registration reports (C-1 reports); RCW 42.17A.235, .240 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the responses provided by the Respondent; the applicable PDC reports filed by the Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to timely and accurately file register as a candidate, update candidate registration information and report contributions and expenditures does not amount to a violation that warrants further investigation.

PDC staff is reminding Cynthia Johnson about the importance of the timely, accurate and complete disclosure of all registration, contribution and expenditure activities, and the timely, accurate and complete filings of all future PDC reports in accordance with the statutes and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/57717
57702 09/23/2019 Sandra Robson Skagit County Republicans bonafide political party committee Skagit County Republicans: Allegation of Violation of RCW 42.17A.225 and .235 for failure to timely report monetary & in-kind contributions and expenditures (EY 19, Sept 19) RCW 42.17A.235, RCW 42.17A.225 Resolved through Statement of Understanding

On September 19, 2019, the Public Disclosure Commission (PDC) received a complaint alleging that the Skagit County Republicans, a Continuing Bona fide County Political Party Committee, may have violated RCW 42.17A.235 by failing to timely file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports) during the 2019 election cycle. 

PDC staff reviewed the allegation, including the applicable statutes, rules and the reporting requirements and found that the Committee failed to timely file 21-Day Pre-Primary Election C-4. This report was required to be filed on July 16, 2019.  On September 2019, the Committee filed the June C-4 report and the July C-4 report on October 2, 2019.  

Based on this finding staff decided to resolve this matter by having the Committee sign a Statement of Understanding and paying a penalty.  On December 10, 2019, the PDC received an executed Statement of Understanding (SOU) signed by the Committee, along with a $150 civil penalty payment. By signing the SOU, the Committee acknowledged violating RCW 42.17A.235 by failing to timely file the 21-Day Pre-Primary Election C-4 report. 

Based on this information , staff dismissed this matter in accordance with RCW 42.17A.755(1).  

https://www.pdc.wa.gov/browse/cases/57702
57690 09/23/2019 Colleen M. Wise Jon Butler Butler, Jon: Allegation of Violation of RCW 42.17A.335 for false statement of incumbency on political advertising; RCW 42.17A.205, .210 & .215 for failure to timely file Campaign Registration (C-1), disclosing treasurer and depository information (EY 19, Sept 19) RCW 42.17A.210, RCW 42.17A.205, RCW 42.17A.335, RCW 42.17A.215 Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the complaint Colleen Wise filed on September 18, 2019. The complaint alleged that Jon Butler (Respondent), Candidate for City Council Member for City of Edgewood may have violated RCW 42.17A.205, .210 and .215 for failure to timely file Candidate Registration (C-1 report), and provide the treasurer and depository information for the candidate and committee; and RCW 42.17A.335 for false statement of incumbency on political advertising. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the responses provided by the Respondent; and the applicable PDC reports filed by Respondent to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to timely file the C-1 report does not amount to a violation that warrants further investigation.

Pursuant to WAC 390-37-060(1)(d), Jon Butler will receive a formal written warning concerning failure to timely file the C-1 report. The formal written warning will include staff’s expectation that Jon Butler timely files all future required reports of registration. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/57690
57544 09/18/2019 Park Llafet Clark County Republican Central Committee Clark County Republican Central Committee (4): Alleged violations of Chapter 42.17A RCW for failure to timely and accurately report and deposit contributions, and report expenditures, reimbursements, and in-kind contributions (EY 19; Sep 19) RCW 42.17A.240, RCW 42.17A.235, RCW 42.17A.220 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint Park Llafet filed on September 13, 2019. The complaint alleged that the Clark County Republican Central Committee (Respondent), a bona fide political party, may have violated RCW 42.17A.220 for failure to deposit anonymous contributions within five business days of receipt; RCW 42.17A.235 for failure to report anonymous contributions; and RCW 42.17A.240 for failure to accurately and completely report contributions, expenditures, reimbursements, and in-kind contributions.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to deposit anonymous contributions within five business days of receipt does not amount to a violation that warrants further investigation.

PDC staff is reminding the Clark County Republican Central Committee about the importance of timely depositing contributions into the designated depository within five business days of receipt. PDC staff expects that the Clark County Republican Central Committee will deposit contributions prior to using them to make expenditures in the future.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/57544
57398 09/13/2019 William Reed, Kevin Taylor Linda Lehman Lehman, Linda: Alleged violations of RCW 42.17A.555 & .320 by using public office or agency facilities (city business cards) to assist an election campaign, and failure to identify sponsor in political advertising. (EY '19; Sep '19) RCW 42.17A.320, RCW 42.17A 555 Case Closed with Written Warning

The complaints alleged Linda Lehman, a 2019 candidate for Mayor of Benton City, may have violated RCW 42.17A.555 by using city facilities, specifically city-purchased business cards, to assist her campaign. Based on the evidence you submitted, PDC staff also included an alleged violation of RCW 42.17A.320 for failing to identify a sponsor on political advertising. 

Staff has determined, because the candidate was the sponsor and there was no apparent attempt to conceal sponsorship information, and because, in this instance, even though the business cards were designed by the City, they were paid for by the candidate, the use of the business cards does not amount to a material violation warranting further investigation. 

However, pursuant to WAC 390-37-060(1)(d), Linda Lehman will receive a formal written warning concerning the lack of sponsor identification and the use of city facilities to assist an election campaign. The formal written warning will include PDC staff’s expectation for Linda Lehman to review PDC guidance for local government agencies in election campaigns and to comply with the underlying statute, RCW 42.17A.555. 

The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/57398
57397 09/13/2019 Shannon Rubin, Patricia Main Crystal Dingler Dingler, Crystal: Alleged violation of RCW 42.17A.320 for failure to identify sponsor of political advertising (e.g. billboard, Facebook) (EY '19; Sept '19) RCW 42.17A.320 Case Closed with Reminder

The complaints alleged Crystal Dingler, a 2019 candidate for City of Ocean Shores Mayor, may have violated RCW 42.17A.320 by failing to identify the sponsor of political advertising.

Based PDC staff findings, and the fact the advertising was sponsored by the Committee and candidate pictured in the advertising, with no intent to conceal sponsorship, staff has determined that, in this instance, the failure to include sponsor identification does not amount a violation warranting further investigation. 

PDC staff is reminding Crystal Dingler and the Committee about the importance of identifying the sponsor's name and address on political advertising in accordance with PDC laws and rules.  

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/57397
57396 09/13/2019 Allen Dauterman, Linda Moschetti-Newing Tom Griffin Griffin, Tom: Alleged violation of RCW 42.17A.555 by using public office or agency facilities (library) to assist an election campaign. (EY '19; Sep '19) RCW 42.17A 555 Case Closed with No Evidence of Violations

The complaint alleged Tom Griffin, a candidate for City of Newcastle City Council, may have violated RCW 42.17A.555 by using public facilities to assist an election campaign. 

Staff has determined, in this instance, the alleged use of facilities by Tom Griffin does not amount to a violation warranting further investigation. Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1). 
 

https://www.pdc.wa.gov/browse/cases/57396
57311 09/11/2019 Glen Morgan Brandi Peetz Peetz, Brandi: Alleged Violation of RCW 42.17A.235, .240 for failure to timely and accurately file reports of expenditures, debts and contributions; RCW 42.17A.320 for failure to identify sponsor on political advertising (EY 19, Sept 19) RCW 42.17A.235, RCW 42.17A.320, RCW 42.17A.240, WAC 390-16-037 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint Glen Morgan filed on September 9, 2019. The complaint alleged that Brandi Peetz (Respondent), a City Council Member candidate for City of Spokane Valley may have violated RCW 42.17A.235, .240 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign; RCW 42.17A.320 for failure to include sponsor identification on political advertising.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the responses provided by Brandi Peetz; the applicable PDC reports filed by the Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to timely and accurately file C-3 and C-4 reports and not disclosing sponsor identification on political advertising does not amount to a violation that warrants further investigation.

PDC staff is reminding Brandi Peetz about the importance of the timely and accurate disclosure of all contribution and expenditure activities, including the description and details such as number of items; as well as the disclosure of sponsor identification on political advertising and the timely filings of all future PDC reports and future disclosure of sponsor identification in accordance with the statutes and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/57311
57294 09/11/2019 CHRISTEN L ELLIS Summer O'Neill O'Neill, Summer: Alleged Violation of RCW 42.17A.320 for failure to include sponsor identification on political advertising, and RCW 42.17A.335 for political advertising that contains false statements constituting libel or defamation (EY 19, Sept 19) RCW 42.17A.320, RCW 42.17A.335 Case Closed with No Evidence of Violations

The complaint alleged Cowlitz County Democrat Central Committee Chairperson Summer O’Neill may have violated RCW 42.17A.320 by failing to include sponsor identification on political advertising and RCW 42.17A.335 for political advertising that contains false statements constituting libel or defamation.

Staff has determined, in this instance, the alleged violation of failing to include sponsor identification on political advertising and political advertising that contains false statements about a candidate constituting libel or defamation, does not amount to a violation warranting further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/57294
57244 09/10/2019 Glen Morgan Lance Gurel Gurel Lance: Alleged Violation of RCW 42.17A.445 for misuse of campaign funds for personal use; .240 for failure to provide expenditure details on required reports (C-4); .320 for failure to include sponsor identification on political advertising (EY 19, Sept 19) WAC 390-16-238, WAC 390-16-037, RCW.42.17A.240, RCW 42.17A.445, RCW 42.17A.320 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint Glen Morgan filed on September 9, 2019. The complaint alleged that Lance Gurel (Respondent), a candidate for City Council Member for City of Spokane Valley may have violated RCW 42.17A.235, .240 for failure to accurately file Summary Full Campaign Contribution and Expenditure reports (C-4 reports) disclosing details of expenditures undertaken by the Campaign; RCW 42.17A.320 for failure to include sponsor identification on political advertising; RCW 42.17A.445 for misuse of campaign funds for personal use. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the responses provided by the Respondent; the applicable PDC reports filed by the Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance for failure to accurately file Summary Full Campaign Contribution and Expenditure reports (C-4 reports) disclosing details of expenditures undertaken by the Campaign and failure to include sponsor identification on political advertising does not amount to a violation that warrants further investigation.

PDC staff is reminding Lance Gurel about the importance of the complete and accurate disclosure of all expenditure activities, as well as the full disclosure of sponsor identification on political advertising, and the importance of future timely, complete and accurate filings of all PDC reports and sponsor identification disclosures in accordance with the statutes and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/57244
57166 09/10/2019 Paul S Williams John Losey Jr. Losey, John Jr.: Alleged Violation of RCW 42.17A.205, .210, .215 for failure to timely file campaign registration (C-1); and Alleged Violation of RCW 42.17A.700 for failure to timely file personal financial affairs statement (F-1) (EY 19, Sept 19) RCW 42.17A.700, RCW 42.17A.215, RCW 42.17A.210, RCW 42.17A.205, RCW 42.17A.235 Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the complaint Paul Williams filed 
on September 10, 2019. The complaint alleged that John Losey Jr., a candidate for School 
Director for Sumner-Bonney Lake School District may have violated RCW 42.17A.205, .210 
and .215 for failure to timely and accurately file Campaign Registration reports (C-1 reports) and 
RCW 42.17A.700 for failure to timely and accurately file Personal Financial Affairs Statement 
reports (F-1 reports). 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the 
response(s) provided by John Losey Jr. and the applicable PDC reports filed by Respondent to 
determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, failure to timely file the F-1 
report and the C-1 report does not amount to a violation that warrants further investigation. 
Pursuant to WAC 390-37-060(1)(d), however, John Losey Jr. will receive a formal written 
warning concerning failure to timely and accurately file Campaign Registration reports (C-1 
reports) and Personal Financial Affairs Statement reports (F-1 reports). The formal written 
warning will include staff’s expectation that John Losey Jr. timely and accurately files all future 
required reports in accordance with PDC laws and rules. The Commission will consider the 
formal written warning in deciding on further Commission action if there are future violations of 
PDC laws or rules. 

Based on this information, the PDC finds that no further action is warranted and has dismissed 
this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/57166
57142 09/09/2019 Carolyn Crain Cowlitz County Republican Central Committee Cowlitz County Republican Central Committee (2): Alleged violations of RCW 42.17A.240 and WAC 390-16-034 for failure to accurately and completely report contributors (Sep 19) RCW 42.17A.240, WAC 390-16-034 Request for Technical Correction

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Carolyn Crain on September 6, 2019. The complaint alleged that the Cowlitz County Republican Central Committee (Respondent), a bona fide political party, may have violated RCW 42.17A.240 and WAC 390-16-034 for failure to accurately report contributor addresses, employers, and occupations.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to report the personal address for contributors does not amount to a violation that warrants further investigation.

The Cowlitz County Republican Party made minor or ministerial errors on required reports, which did not materially impact the public interest. Upon notification of these errors, the Cowlitz County Republican Party timely amended their reports, making the necessary technical corrections as requested by staff.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/57142
57141 09/09/2019 Carolyn Crain Clark County Republican Central Committee Clark County Republican Central Committee (3): Alleged violations of RCW 42.17A.240 and WAC 390-16-034 for failure to accurately and completely report contributors (Sep 19) WAC 390-16-034, RCW 42.17A.240 Request for Technical Correction

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Carolyn Crain on September 6, 2019. The complaint alleged that the Clark County Republican Central Committee (Respondent), a bona fide political party, may have violated RCW 42.17A.240 and WAC 390-16-034 for failure to accurately report contributor addresses, employers, and occupations.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to report the personal address for contributors does not amount to a violation that warrants further investigation.

The Clark County Republican Party made minor or ministerial errors on required reports, which did not materially impact the public interest. Upon notification of these errors, the Clark County Republican Party timely amended their reports, making the necessary technical corrections as requested by staff.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/57141
57140 09/09/2019 Glen Morgan Debbie Bertlin Bertlin, Debbie (3): Alleged violation of RCW 42.17A.555 for misuse of public email to support candidate's own election campaign (EY 19; Sep 19) RCW 42.17A.555 Case Closed with Reminder

On September 6, 2019, the Public Disclosure Commission (PDC) received a complaint alleging that Deborah Bertlin, the incumbent mayor for the City of Mercer Island and a candidate for City Council Member for the City of Mercer Island in 2019, may have violated RCW 42.17A.555 by misusing the City of Mercer Island email to support her own election campaign. 

Staff reviewed the allegation listed int he complaint to determine whether a formal investigation or enforcement action is warranted. Staff reviewed all attachments submitted with the complaint, the statute, rules, and PDC Interpretation 04-02 "Guidelines for Local Government Agencies in Election Campaigns," and the response from Mayor Bertlin's counsel. 

Staff found that the email sent by Mayor Bertlin to two City employees on June 30, 2019, was sent for the purpose of furthering her political campaign. Her email to the two City employees asking for the City's policy was in response/follow-up to a question that the primary candidates had been asked by a reporter and was therefore sent in Mayor Bertlin's role or capacity as political campaign candidate as opposed to her capacity as the Mayor. 

While Mayor Bertlin used her City of Mercer Island email to further or assist her political campaign as political candidate in 2019, this shortcoming is mitigated by (1) No prior PDC violations; and (2) Her dual role or capacity as a Mayor and Candidate overlapped and caused the Mayor to send the email to staff using her City issued email account instead of her dedicated campaign email account or a private email account. 

PDC staff reminded Mayor Bertlin about the importance of not using the City of Mercer Island's email account to assist her political campaign in the future. 

Based on these findings, PDC staff dismissed this matter in accordance with RCW 42.17A.755(1).  

https://www.pdc.wa.gov/browse/cases/57140
57038 09/06/2019 Amy Conway Charles Smith III Smith, Charles III: Alleged Violations of RCW 42.17A.205, .210, .215 for failure to timely file Candidate Registration C-1, and failure to disclose treasurer and depositories; and Alleged Violation of RCW 42.17A.700 for failure to timely file Personal Financial Affairs F-1; and Alleged Violation of RCW 42.17A.235 failure to timely report contributions and expenditures. (EY 19, Sept 19) RCW 42.17A.215, RCW 42.17A.700, RCW 42.17A.235, RCW 42.17A.205, RCW 42.17A.210 Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the complaint Amy Conway filed on September 5, 2019. The complaint alleged that Charles Smith III, a candidate for School Director, for Sequim SD 323 may have violated RCW 42.17A.205, .210 and .215 for failure to timely file their Candidate Registration (C-1 report) and failure to disclose their treasurer and depositories; RCW 42.17A.700 for failure to timely file their Personal Financial Affairs Statement report (F-1 report); and RCW 42.17A.235 for failure to timely file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports). 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the applicable PDC reports filed by Respondent, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to timely file the C-1 and F-1 reports does not amount to a violation that warrants further investigation.

Pursuant to WAC 390-37-060(1)(d), Charles Smith III will receive a formal written warning concerning failure to timely file their Candidate Registration (C-1 report), Personal Financial Affairs Statement (F-1 report) and disclosure of all Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports). The formal written warning will include staff’s expectation that Charles Smith III timely register as a candidate and report financial affairs, contributions and expenditures in the future. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/57038
56970 09/05/2019 Heather Popp Mark Hutson Hutson, Mark: Alleged violations of RCW 42.17A.555 for misuse of public facilities to support Hutson and Tompkins election campaigns (EY 19; Sep 19) RCW 42.17A.555 Case Closed with Written Warning

The complaint alleged Mark Hutson, a 2019 candidate for Milton City Council, may have violated RCW 42.17A.555 by using city facilities, specifically his City of Milton e-mail account, to assist his campaign and the campaign of Mary Tompkins, also a candidate for Milton City Council

PDC staff has determined that in this instance, the use of his City of Milton e-mail to send and receive the e-mails does not amount to a material violation warranting further investigation. However, pursuant to WAC 390-37-060(1)(d), Mark Hutson will receive a formal written warning concerning the use of city facilities to assist an election campaign.  The formal written warning will include PDC staff’s expectation Mark Hutson review PDC guidance for local government agencies in election campaigns. 

The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules. Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/56970
56939 09/04/2019 Evan James Merritt Ron Simmons Simmons, Ron: Allegation of violation of RCW 42.17A.555 for misuse of public facilities (EY 19, Sept19) RCW 42.17A 555 Case Closed with Reminder

On September 3, 2019, the Public Disclosure Commission (PDC) received a complaint alleging that Ron Simmons, fire chief for the Snohomish County Fire District 4, may have violated RCW 42.17A.555 by using a public agency, office or facilities to support multiple candidates for Commissioner Position 4 of the Snohomish County Fire District 4, and to oppose Mr. Merritt's candidacy. 

PDC staff reviewed your allegations, the applicable statutes, rules and interpretations, including  Interpretation 04-02 "Guidelines for Local Government Agencies in Election Campaigns," and the response provided by Chief Ron Simmons to determine whether a formal investigation or enforcement action is warranted. 

Staff's review found that the screenshots depicted Ron Simmons as Fire Chief. However, the Chief's title is not a public facility of Snohomish County Fire Protection District 4.  Additionally, staff also found that the Chief's personal Facebook postings, posted by the Chief on his personal Facebook account were done on the Chief's own time, during non-work hours, and were expressions of his personal views, and were not the view(s) of the Snohomish County Fire Protection District 4. Also, Chief Simmons' Facebook postings did not involve the use of any facilities of Snohomish County  Fire District 4. 

Regarding the second allegation - use of district email to send messages to subordinates to discourage support for a candidate, staff found that Chief Simmons sent three separate emails, including one Memorandum to staff. Staff's review determined that one of the emails sent by the Chief needed to be worded more carefully and with some degree of restraint.

Based on the above review/determination, staff recommended to Chief Simmons that in the future he avoid using wording like he used in the last paragraph of the email that needed to be worded carefully and with some degree of restraint, directing staff to "please stay out of the campaign gaming," because it is important to avoid even the appearance or perception that the Chief, while using public facilities, is directing his staff members to not be involved in election campaigns on their own time, using their own resources. 

PDC staff reminded Chief Simmons about the importance of avoiding even the appearance or perception of using agency facilities to support or oppose candidates for public office by encouraging or limiting support or opposition for candidates. 

Based on this information, PDC staff dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/56939
56889 09/03/2019 Freedom Foundation (Maxford Nelsen) Washington State Council of County and City Employees Washington State Council of County and City Employees: Alleged violations of RCW 42.17A.255 for failure to report independent expenditures in opposition to ballot propositions (EY 19; Sep 19) RCW 42.17A.255 Resolved through Statement of Understanding

A complaint was filed against the WA State Council of County and City Employees, AFL-CIO, a statewide labor council for county and city municipal employees headquartered in Everett, Washington, alleging that the WA State Council of County and City Employees, AFL-CIO (WSCCCE, AFL,CIO) may have violated RCW 42.17A.255 by failing to timely file Independent Expenditures report (C-6 report) disclosing expenditures made for legal services related to City of Chelan Propositions 1 and 2. 

On September 25, 2019, WSCCCE AFL-CIO filed three C-6 reports disclosing expenditures totaling $28,923 made to the law firm of Reid, McCarthy, Ballew & Leahy, LLP for legal services in January, February and March of 2015 for legal services incurred in opposition to the City of Chelan Propositions 1 and 2.  

WSCCCE, AFL-CIO indicated that the independent expenditures made by WSCCCE, AFL-CIO concerned legal services relating to two local proposed ballot propositions submitted to the Chelan City Clerk in the fall of 2014, and that the two proposed ballot propositions “were not proper subjects of the municipal initiative power.”  WSCCCE, AFL-CIO intervened in support of the City of Chelan’s position, and “that the proposed ballot propositions were not proper subjects for the municipal ballot power", and the Court "granted summary judgment in favor of the City and WSCCCE, AFL-CIO and the two proposed propositions were never voted upon.” 

WSCCCE, AFL-CIO’s indicated the failure to timely file the three C-6 reports had minimal impact on the public, since the two proposed propositions were never placed on the ballot by the Chelan City Council, and that the independent expenditures were made for legal services to oppose the two proposed propositions.  WSCCE, AFL-CIO's involvement “was hardly secret (since) the litigation was publicly reported on as it progressed”, and WSCCCE, AFL-CIO promptly took corrective action when its alleged noncompliance was brought to its attention. 

WSCCCE, AFL-CIO indicated they did not realize the requirement to file C-6 reports "prior to the complaint being filed against it, it has since filed reports fully disclosing the costs of legal fees it paid opposing the two propositions.” 

On November 4, 2019, the PDC received a completed Statement of Understanding (SOU) that was signed by Chris Dugovich, President of the WSCCCE, AFL-CIO.  The SOU was accompanied by a $450 payment for the civil penalty that was assessed in this matter in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule).  The $450 civil penalty resolves the allegations listed in your complaint against the WSCCCE, AFL-CIO for failing to timely file three C-6 reports.

By completing the SOU, the WA State Council of County and City Employees, AFL-CIO acknowledged three violations of RCW 42.17A.255 for failing to timely file C-6 reports disclosing legal services incurred in opposition to the City of Sequim Propositions 1 and 2.

Based on the resolution of this matter through an SOU, PDC staff is dismissing this matter in accordance with RCW 42.17A.755(1).  

https://www.pdc.wa.gov/browse/cases/56889
56888 09/03/2019 Freedom Foundation (Maxford Nelsen) International Association of Machinists Lodge W38 International Association of Machinists Lodge W38: Alleged violations of RCW 42.17A.255 for failure to report independent expenditures in opposition to ballot propositions (EY 19; Sep 19) RCW 42.17A.255 Resolved through Statement of Understanding

A complaint was filed against the International Association of Machinists Lodge W38 (IAM W38), a local labor organization in Washington State, alleging that IAM W38 may have violated RCW 42.17A.255 by failing to timely file Independent Expenditures report (C-6 report) disclosing expenditures made for legal services related to City of Shelton Propositions 1 and 2.

On October 8, 2019, IAM Lodge W38 and the International Association of Machinists Lodge W 24 (IAM W24) filed one C-6 report disclosing expenditures totaling $10,535.95 made to the law firm of Reid, McCarthy, Ballew & Leahy, LLP for legal services incurred in opposition to the City of Shelton Propositions 1 and 2 during November and December 2014 and January 2015. 

IAM W38 indicated they were not aware of the C-6 reporting requirement regarding “its litigation expenses” until the complaint was received from PDC staff, and noted that by the time IAM W38 became involved in the litigation, the City of Shelton had already voted not to place either Proposition 1 or 2 on the ballot or to adopt the measures, and the city had already been sued by Diane Good with assistance from the Freedom Foundation.  The response went on to state:

"IAMW 38 incurred the attorneys' fees and costs and was the represented party in the 2014 litigation related to this complaint. IAM District Lodge 24, the parent organization to IAN'1-W38, paid the attorneys' fees and costs for IAM-W38. This is why both IAM District Lodge 24 and IAM Local Lodge 38 are on the C6 PDC form. IAM District Lodge 24 files a LM-2 report (which would include the litigation expenses related to the 2014 litigation) and IAM Local Lodge 38 files a LM-3 report.  Other than not being a direct party to the litigation, the same basic arguments for IAMW 38 (from my' recent submission) would also apply to IAM District Lodge 24.”

On November 12, 2019, the PDC received a completed Statement of Understanding (SOU) that was signed by Rick Simpson, President of IAM W38, and Wayne Thompson on behalf of IAM W24.  The SOU was accompanied by a $450 payment for the civil penalty that was assessed in this matter in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule).

The $450 civil penalty assessed resolves the allegations listed in your complaint against IAM W38, and against IAM W24 as the entity paying for the legal services on behalf of IAM W38 for failing to timely file the C-6 report.  By completing the SOU, both IAM W38 and IAM W24 are acknowledging three violations of RCW 42.17A.255 for failing to timely file C-6 reports disclosing legal services incurred in opposition to the City of Shelton Propositions 1 and 2.

Based on the resolution of this matter through an SOU, PDC staff is dismissing this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/56888
56886 09/03/2019 Freedom Foundation (Maxford Nelsen) Teamsters Local 589 Teamsters Local 589: Alleged violations of RCW 42.17A.255 for failure to report independent expenditures in opposition to ballot propositions (EY 19; Sep 19) RCW 42.17A.255 Resolved through Statement of Understanding

A complaint was filed against the Teamsters Local 589, a local labor organization in Port Angeles Washington, alleging that the Teamsters Local 589 may have violated RCW 42.17A.255 by failing to timely file Independent Expenditures reports (C-6 reports) disclosing expenditures made for legal services related to City of Sequim Propositions 1 and 2. 

On September 23, 2019, Teamsters Local 589 filed a C-6 report disclosing $35,608.70 in total expenditures made to the law firm of Reid, McCarthy, Ballew & Leahy, LLP covering the period July 1 through December 31, 2014,  for legal services incurred in opposition to the City of Sequim Propositions 1 and 2 for July through December of 2014.  

Teamsters Local 589 indicated that it was not aware of a requirement to file a C-6 report with the PDC regarding “its litigation expenses” until the complaint had been filed, and noted a unions hiring of attorneys to defend its members concerning the collective bargaining agreement, or a contractual or statutory provision is typically not reportable to the PDC. 

On November 14, 2019, the PDC received a completed Statement of Understanding (SOU) that was signed by Mark Fuller, on behalf of Teamsters Local 589.  The SOU was accompanied by a $450 payment for the civil penalty that was assessed in this matter in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule).

The $450 civil penalty paid resolves the allegations listed in the complaint against the Teamsters Local 589 for failing to timely file C-6 reports.  By completing the SOU, the Teamsters Local 589 acknowledged three violations of RCW 42.17A.255 for failing to timely file C-6 reports disclosing legal services incurred in October, November and December of 2014, that were paid in November and December of 2014, and January of 2015 in opposition to the City of Sequim Propositions 1 and 2.

Based on the resolution of this matter through a SOU, PDC staff is dismissing this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/56886
56728 08/28/2019 Glen Morgan Valerie O'Halloran O'Halloran, Valerie: Alleged violation of RCW 42.17A.240, and WAC 390-16-037 for failure to accurately and completely report expenditure details (EY19, Aug 19) RCW 42.17A.240, WAC 390-16-037 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint Glen Morgan filed on August 27, 2019. The complaint alleged that Valerie O’Halloran (Respondent), a candidate for Renton City Council Member, may have violated RCW 42.17A.240 and WAC 390-16-037 for failure to provide accurate and complete details on Summary Receipts and Expenditure reports (C-4 reports) for expenditures. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; and the applicable PDC report filed by Respondent, to determine whether the record supports a finding of one or more violations.

PDC staff is reminding Valerie O’Halloran about the importance of including all required detail for expenditures on all PDC reports in accordance with the statutes and rules. PDC staff expects in the future that Valerie O’Halloran will report timely and with all required detail for expenditures on all PDC reports in accordance with PDC laws and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/56728
56694 08/27/2019 Glen Morgan Pacific Northwest Ballet Pacific Northwest Ballet: Alleged violations of RCW 42.17A.207, .235, and .240 for failure to timely and accurately register and report as an incidental committee (EY 19; Aug 19) RCW 42.17A.207, RCW 42.17A.235, RCW 42.17A.240 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on August 12, 2019. The complaint alleged that Pacific Northwest Ballet Association (PNB), a non-profit 501(c)(3) organization registered with the Washington State Secretary of State’s Office, may have violated: (1) RCW 42.17A.207 for failure to submit a C-1IC as an Incidental Committee; and (2) RCW 42.17A.235 and .240 for failure to timely file Incidental Committee Payments and Political Expenditures reports (C-8 reports).

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by David Thorpe, Chief Financial Officer for PNB; and the applicable PDC reports filed by Respondent, to determine whether the record supports a finding of one or more violations.

It appears that PNB was initially unaware of their registration and filing obligations as an incidental committee. The Respondent has not previously been the subject of enforcement action and postmarked the C-1IC and C-8 reports promptly upon PDC staff’s request.

Based on these findings staff has determined that, in this instance, failure to timely register and file reports as an incidental committee disclosing activity for calendar year 2019 does not amount to a finding of a violation warranting further investigation.

PDC staff reminded PNB about the importance of the timely registration and disclosure of all contribution and expenditure activities as an incidental committee, and the timely filings of all future PDC reports in accordance with the statutes and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/56694
56627 08/26/2019 Glen Morgan Seattle Theatre Group Seattle Theatre Group: Alleged violation of RCW 42.17A.207 & WAC 390-16-013 for failure to timely & accurately register as an incidental committee. (EY '19, Aug '19) RCW 42.17A.207 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on August 12, 2019. The complaint alleged that Seattle Theatre Group (STG), a non-profit 501(c)(3) organization registered with the Washington State Secretary of State’s Office, may have violated: (1) RCW 42.17A.207 for failure to submit a C-1IC as an Incidental Committee; and (2) RCW 42.17A.235 and .240 for failure to timely file Incidental Committee Payments and Political Expenditures reports (C-8 reports).

PDC staff reviewed your allegations; the applicable statutes, rules, and reporting requirements; the responses provided by Gary Corrington, Chief Financial Officer for STG; and the applicable PDC reports filed by Respondent, to determine whether the record supports a finding of one or more violations.

It appears that STG was aware of the Disclose Act but did not believe it applied to its 2019 payment because it was not intended to go to political committee or be used in an election campaign. STG has not previously been the subject of enforcement action and postmarked the C-1IC and C-8 reports promptly upon PDC staff’s request.

Based on these findings staff has determined that, in this instance, failure to timely register and file reports as an incidental committee disclosing activity for calendar year 2019 does not amount to a finding of a violation warranting further investigation.

PDC staff reminded STG about the importance of the timely registration and disclosure of all contribution and expenditure activities as an incidental committee, and the timely filings of all future PDC reports in accordance with the statutes and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/56627
56616 08/26/2019 Kevin Mendez James Alberson Alberson, James: Alleged violation of RCW 42.17A.320 for failure to provide sponsor identification on political advertising (EY 19, Aug 19) RCW 42.17A.320 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint Kevin Mendez filed on August 22, 2019. The complaint alleged that James Alberson (Respondent), a candidate for City Council Member for City of Renton may have violated RCW 42.17A.320 for failure to provide complete and accurate sponsor identification on political advertising. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent and the applicable PDC reports filed by the Respondent to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to provide complete and accurate sponsor identification and detailed descriptions of expenditures, as well as the number of items, does not amount to a violation that warrants further investigation.

PDC staff is reminding James Alberson about the importance of complete and accurate sponsor identification on political advertising and the complete and accurate disclosure of all contribution and expenditure activities for all future PDC reports. PDC staff expects in the future that James Alberson will make all required disclosures in accordance with PDC laws and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/56616
56613 08/26/2019 Glen Morgan Experience Learning Community DBA Museum of Pop Culture (aka MoPOP) Experience Learning Community DBA Museum of Pop Culture (aka MoPOP): Alleged violation of RCW 42.17A.207 & WAC 390-16-013 for failure to timely & accurately register as an incidental committee. (EY '19, Aug '19) RCW 42.17A.207 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on August 12, 2019. The complaint alleged that Experience Learning Community DBA Museum of Pop Culture (also known as “MoPOP”), a non-profit 501(c)(3) organization registered with the Washington State Secretary of State’s Office, may have violated: (1) RCW 42.17A.207 for failure to submit a C-1IC as an Incidental Committee; and (2) RCW 42.17A.235 and .240 for failure to timely file Incidental Committee Payments and Political Expenditures reports (C-8 reports).

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by David A. Lawson, an Attorney with Davis Wright Tremaine, on behalf of his client MoPOP; and the applicable PDC reports filed by Respondent, to determine whether the record supports a finding of one or more violations.

It appears that MoPOP was aware of the Disclose Act but did not believe it applied to a payment made in 2019 for accrued liability from the previous calendar year and prior to the Act’s effective date. its activity their registration and filing obligations as an incidental committee. MoPOP has not previously been the subject of enforcement action and postmarked the C-1IC and C-8 reports promptly upon PDC staff’s request.

Based on these findings staff has determined that, in this instance, failure to timely register and file reports as an incidental committee disclosing activity for calendar year 2019 does not amount to a finding of a violation warranting further investigation.

PDC staff reminded MoPOP about the importance of the timely registration and disclosure of all contribution and expenditure activities as an incidental committee, and the timely filings of all future PDC reports in accordance with the statutes and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/56613
56584 08/23/2019 Glen Morgan The Seattle Aquarium Society (aka Seattle Aquarium) The Seattle Aquarium Society (aka Seattle Aquarium): Alleged violation of RCW 42.17A.207 & WAC 390-16-013 for failure to timely & accurately register as an incidental committee. (EY 2019, Aug 2019) RCW 42.17A.207 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on August 12, 2019. The complaint alleged that The Seattle Aquarium Society (also known as “Seattle Aquarium”), a non-profit 501(c)(3) organization registered with the Washington State Secretary of State’s Office, may have violated: (1) RCW 42.17A.207 for failure to submit a C-1IC as an Incidental Committee; and (2) RCW 42.17A.235 and .240 for failure to timely file Incidental Committee Payments and Political Expenditures reports (C-8 reports).

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Rick Johnson, Treasurer for Seattle Aquarium; and the applicable PDC reports filed by Respondent, to determine whether the record supports a finding of one or more violations.

It appears that Seattle Aquarium was initially unaware of their registration and filing obligations as an incidental committee. The Respondent has not previously been the subject of enforcement action and postmarked the C-1IC and C-8 reports promptly upon PDC staff’s request.

Based on these findings staff has determined that, in this instance, failure to timely register and file reports as an incidental committee disclosing activity for calendar year 2019 does not amount to a finding of a violation warranting further investigation.

PDC staff reminded Seattle Aquarium about the importance of the timely registration and disclosure of all contribution and expenditure activities as an incidental committee, and the timely filings of all future PDC reports in accordance with the statutes and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/56584
56572 08/23/2019 Anne Block Michael Scott Scott, Michael: Alleged violation of RCW 42.17A.710 for failure to disclose income and directorships on Personal Financial Affairs Statements (F-1 reports) (Aug 19) RCW 42.17A.710 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint Anne Block filed on August 22, 2019. The complaint alleged that Michael Scott (Respondent), a Superior Court Judge for King County, and a former City Council Member for the City of Bainbridge Island, may have violated RCW 42.17A.710 for failure to disclose a directorship with Full Life Care, and income from the American Civil Liberties Union, on Personal Financial Affairs Statements (F-1 reports).

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; the applicable PDC reports filed by the Respondent; and the Order granting modification to the Respondent’s F-1 filing requirements, to determine whether the record supports a finding of one or more violations.

Based on our findings, staff has determined that in this instance, failure to accurately and completely disclose payments to entities reportable on an F-1 report, does not amount to a violation that warrants further investigation.

PDC staff is reminding Michael Scott about the importance of the complete and accurate disclosure of payments from government and business customers to an entity in which an office, directorship, general partnership, or an ownership interest of ten percent or more is held. PDC staff expects timely requests for modification of reporting requirements, and full disclosure in accordance with PDC statutes and rules in the future.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/56572
56561 08/23/2019 Glen Morgan Approve Prop 1 - EvergreenHealth (Sponsored by EvergreenHealth Foundation) Approve Prop 1 - EvergreenHealth (Sponsored by EvergreenHealth Foundation): Alleged violations of Chapter 42.17A RCW for accepting over-limit contributions, failure to accurately disclose top 5 contributors, and to accurately and completely disclose expenditure details (EY 19; Aug 19) RCW 42.17A.320, RCW 42.17A.420, RCW 42.17A.240, WAC 390-16-037 Case Closed with Written Warning

The complaint alleged, Approve Prop 1 – EvergreenHealth, a Ballot Committee (Committee) formed to support an April 23 and August 6, 2019 bond election for Kirkland’s EvergreenHealth Hospital and Medical Campus, violated: (1) RCW 42.17A.240 by failing to accurately report and describe expenditures and contributions on the Summary Full Campaign Contributions and Expenditures Reports (C-4 reports); (2) RCW 42.17A.420 for accepting a $225,000 contribution from EvergreenHealth within 21 days of the August 6, 2019, primary election and (3) RCW 42.17A.320 for failing to accurately and completely disclose top five contributors in political advertising sponsored by the Committee.

PDC staff has determined that in this instance, the Committee’s failure to include the complete required expenditure detail for political advertisements purchased by the Committee does not amount to a material violation warranting further investigation.  The Committee is continuing to work with PDC staff and making a good faith effort to bring its reports fully into compliance. Pursuant to WAC 390-37-060(1)(d), the Committee will receive a formal written warning concerning its failure to accurately report and describe expenditures and contributions.  

The formal written warning will include staff’s expectation timely and accurately files all future required PDC reports. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules. Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/56561
56501 08/21/2019 Elizabeth Elliott Mike Courts Courts, Mike (2): Alleged violation of RCW 42.17A.555 for authorizing the use of public facilities to support election campaigns (EY 19, Aug 19) RCW 42.17A.555 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint Elizabeth Elliott filed on August 15, 2019. The complaint alleged that Mike Courts, the Mayor of the City of Dupont may have violated RCW 42.17A.555 for authorizing the use of public facilities for support of election campaigns. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the City of Dupont; to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, authorizing candidates to use open public comment to support their candidacies does not amount to a violation that warrants further investigation.

PDC staff is reminding Mike Courts about the importance of not authorizing the use of public facilities to support or appose any candidate or ballot proposition. PDC staff expects Mike Courts to remind members of the public that open public comment may not be used to support or appose election campaigns in the future. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/56501
56489 08/21/2019 Keith Olson Jon Mutchler Mutchler, Jon: Alleged violations of RCW 42.17A.320 for failure to disclose sponsor ID on political advertising & .555 for misuse of public facilities (EY 19, Aug 19) RCW 42.17A.320, RCW 42.17A.555 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Keith Olson on August 16, 2019. The complaint alleged that Jon Mutchler (Respondent), a 2019 candidate for Mayor of the City of Ferndale, may have violated RCW 42.17A.320 for failure to disclose the sponsor's name and address on movable political advertising; and RCW 42.17A.555 for displaying political advertising in support of the candidate's own campaign in city hall parking lot.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the responses provided by Respondent, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to properly disclose sponsor identification on political advertising does not amount to a violation that warrants further investigation.

PDC staff is reminding Jon Mutchler about the importance of complete and accurate disclosure of sponsor identification on political advertising. PDC staff expects Jon Mutchler to provide the required disclosures on all political advertising in the future.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/56489
56380 08/19/2019 Glen Morgan Approve Prop 1 – Our Public Hospital Approve Prop 1 - Our Public Hospital: Alleged violations of RCW 42.17A.240 for failure to accurately report and describe expenditures & contributions. (EY '19) (Aug '19) RCW 42.17A.240 Case Closed with Written Warning

The complaint alleged, Approve Prop 1 – Our Public Hospital, a local 2019 Ballot Committee (Committee) formed to support Proposition 1, a Snohomish County Hospital District levy lid lift on the April 23, 2019 special election ballot, violated RCW 42.17A.240 by failing to accurately report and describe Committee expenditures made and contributions received. 

PDC staff has determined that in this instance, failing to include complete expenditure detail and the sponsor name in the Committee name does not amount to a material violation warranting further investigation. Pursuant to WAC 390-37-060(1)(d), the Committee and its Officers will receive a formal written warning concerning its failure to accurately report and describe expenditures and contributions and include the sponsor name in the Committee name.  

The formal written warning will include staff’s expectation that the Committee will timely and accurately register and file all future required PDC reports, if the Committee should register again as a ballot or political committee. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/56380
56287 08/16/2019 Robert Parker Kristen Deskin Deskin, Kristen: Alleged Violation of RCW 42.17A.205, .210, .215, .235 for failure to file Candidate Registration, designate Treasurer information, disclose Depositories, and failure to file Contribution or Expenditure reports. (EY 2019, AUG 2019) RCW 42.17A.215, RCW 42.17A.210, RCW 42.17A.205, RCW 42.17A.235 Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the complaint Robert Parker filed on August 8, 2019. The complaint alleged that Kristen Deskin (Respondent), a candidate for School Director for Renton School District 403, may have violated RCW 42.17A.205, .210 and .215 for failure to timely file the Campaign Registration report (C-1 report); and RCW 42.17A.235 for failure to timely file Cash Receipts, Monetary Contributions reports (C-3 reports), and Receipts & Expenditure Summary reports. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; and the applicable PDC report filed by Respondent, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to file the C-1 report timely, does not amount to a violation that warrants further investigation.

Pursuant to WAC 390-37-060(1)(d), Kristen Deskin will receive a formal written warning concerning failure to timely file the required Campaign Registration report (C-1 report). Staff expects Kristen Deskin to file all future required reports such as the Campaign Registration (C-1), Cash Receipts, Monetary Contributions (C-3) and Receipts & Expenditure Summary (C-4) timely. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/56287
56286 08/16/2019 Robert Parker Michael Christophersen, Candidate for Seattle School District #1 Christophersen, Michael: Alleged Violation of RCW 42.17A.205, .210, .215 for failure to file Candidate Registration, designate Treasurer information, and disclose Depositories. (EY 2019, AUG 2019) RCW 42.17A.210, RCW 42.17A.205, RCW 42.17A.215 Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the complaint Robert Parker filed on April 4, 2018. The complaint alleged that Michael Christophersen (Respondent), a candidate, in the 2019 Seattle School District 001 election for School Director, may have violated RCW 42.17A.205, .210 and .215 for failure to timely, completely and accurately file both the Campaign Registration report (C-1 report) and Personal Financial Affairs Statement report (F-1 report). 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; and the applicable PDC report filed by Respondent, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to timely, accurately and completely file the C-1 and F-1 reports does not amount to a violation that warrants further investigation.

Pursuant to WAC 390-37-060(1)(d), Michael Christophersen will receive a formal written warning concerning failure to timely file C-1 and F-1 reports. The formal written warning will include staff’s expectation that Michael Christophersen timely files all future required reports such as the registration and personal financial affairs statement. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/56286
56285 08/16/2019 Robert Parker Darcie Kline Kline, Darcie: Alleged Violation of RCW 42.17A.205, .210, .215 for failure to file Candidate Registration, designate Treasurer information, and disclose Depositories. (EY 2019, AUG 2019) Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the complaint Robert Parker filed on August 8, 2019. The complaint alleged that Darcie Kline (Respondent), a candidate for School Director in the Seattle School District 001 may have violated RCW 42.17A.205, .210 and .215 for failure to timely file Candidate Registration report (C-1 report), designate Treasurer information, and disclose Depositories. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the applicable PDC reports filed by Respondent, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to timely, accurately and completely file the C-1 report does not amount to a violation that warrant further investigation.

Pursuant to WAC 390-37-060(1)(d), Darcie Kline will receive a formal written warning concerning the timely filing of the Candidate Registration report (C-1 report). The formal written warning will include staff’s expectation that Darcie Kline timely file all future required reports such as the registration, as well as timely report contributions and expenditures where applicable. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/56285
56284 08/16/2019 Robert Parker Justin Johnson Johnson, Justin: Alleged Violation of RCW 42.17A.205, .210, .215 for failure to file Candidate Registration, designate Treasurer information, and disclose Depositories. (EY 2019, AUG 2019) RCW 42.17A.700, RCW 42.17A.215, RCW 42.17A.710, RCW 42.17A.210, RCW 42.17A.205 Resolved through Statement of Understanding

The Public Disclosure Commission (PDC) has completed its review of the complaint Robert Parker filed on August 8, 2019. The complaint alleged that Justin Johnson, a candidate for City Council Member for City of Lake Forest Park may have violated RCW 42.17A.205, .210, .215 for failure to timely and accurately file Campaign Registration reports (C-1 reports), disclosing the Treasurer and Depositories of the Campaign; RCW 42.17A.700, .710 for failure to timely and accurately file Personal Financial Affairs Statement reports (F-1 reports). 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements, the responses provided by the Respondent, and the applicable PDC reports filed by Respondent to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to timely file the C-1 and F-1 reports does not amount to a violation that warrants further investigation.

Justin Johnson completed a Statement of Understanding (SOU) and paid a $200 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), acknowledging violations of RCW 42.17A.205 and RCW 42.17A.700 for: (1) failing to timely file the required Campaign Registration report (C-1 report); and (2) failing to timely file the Personal Financial Affairs Statement report (F-1 report) during the 2019 election. The $200 penalty assessed resolves the allegations listed in your complaint.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/56284
56252 08/15/2019 Glen Morgan EvergreenHealth Foundation EvergreenHealth Foundation: Alleged violations of Chapter 42.17A RCW for failure to timely register and report as an incidental committee, to disclose sponsor ID on political advertising, and to report independent expenditures (EY 19; Aug 19) RCW 42.17A.255, RCW 42.17A.240, RCW 42.17A.235, RCW 42.17A.320, RCW 42.17A.207 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaints filed on August 9, 2019. The complaints alleged that EvergreenHealth Foundation (“Respondent”), a non-profit 501(c)(3) organization registered with the Washington State Secretary of State’s Office, may have violated: (1) RCW 42.17A.207 for failure to submit a C-1IC as an Incidental Committee; (2) RCW 42.17A.235 and .240 for failure to timely file Incidental Committee Payments and Political Expenditures reports (C-8 reports); (3) RCW 42.17A.320 for failure to disclose top five contributors in electioneering communication; and (4) RCW 42.17A.235 and .240 for failure to timely and accurately report expenditures for political advertising; or RCW 42.17A.255 for failure to report independent expenditures in support of ballot propositions on Independent Expenditure and Electioneering Communication reports (C-6 reports).

PDC staff reviewed allegations; the applicable statutes, rules, and reporting requirements; the response provided by Mark Lamb on behalf of his client EvergreenHealth Foundation; and the applicable PDC reports filed by Respondent, to determine whether the record supports a finding of one or more violations.

It appears that EvergreenHealth Foundation was unaware of their registration and filing obligations as an incidental committee. The Respondent has not previously been the subject of enforcement action and postmarked the C-1IC and C-8 reports two days prior to the date when the complaint was received.

Based on these findings staff has determined that, in this instance, failure to timely register and file reports as an incidental committee disclosing activity for calendar year 2019 does not amount to a finding of a violation warranting further investigation.

PDC staff reminded EvergreenHealth Foundation about the importance of the timely registration and disclosure of all contribution and expenditure activities as an incidental committee, and the timely filings of all future PDC reports in accordance with the statutes and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/56252
56147 08/13/2019 Kendra Shirley Eliana Macias Macias, Eliana: Alleged violations of RCW 42.17A.320 for failure to disclose sponsor ID on political advertising, and .335 for false statements of material fact in political advertising (EY 19; Aug 19) RCW 42.17A.320, RCW 42.17A.335 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Kendra Shirley on August 10, 2019. The complaint alleged that Eliana Macias (Respondent), a 2019 candidate for Yakima City Council may have violated RCW 42.17A.320 for failure to disclose sponsor identification on digital political advertising; and RCW 42.17A.335 for sponsoring with actual malice, false statements of material fact meant to cause injury to candidate Gartrell.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation that warrants further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/56147
56012 08/12/2019 Thomas Fancher Steven D Verhey Verhey, Steven: Alleged Violation of RCW 42.17A.235, .240 for failure to file accurate contribution reports. (AUG 2019) RCW 42.17A.240 Request for Technical Correction
  • Allegation: Violation of RCW 42.17A.235, .240 for failure to file accurate contribution reports. 
https://www.pdc.wa.gov/browse/cases/56012
56009 08/12/2019 Nancy Jean Majors Fa'izah Bradford Bradford, Fa'izah: Alleged Violation of WAC 390-18-040 for inaccurate use of the term "reelect" in political advertising. (AUG 2019) RCW 42.17A.335, WAC 390-18-040 Case Closed with No Evidence of Violations
  • Allegation: Violation of WAC 390-18-040 for misuse of the term "reelect" in political advertising. 
https://www.pdc.wa.gov/browse/cases/56009
56008 08/12/2019 Tarn Ohana Moms for Seattle Moms for Seattle: Alleged Violation of RCW 42.17A.255, .305 for failure to file a C-6 report that meets electioneering communication requirements. (AUG 2019) RCW 42.17A.305 Case Closed with Reminder

On August 1, 2019, the Public Disclosure Commission (PDC) received a complaint alleging that the Moms for Seattle (Committee), may have violated RCW 42.17A.255 and .305 for failure to file a C-6 report that meets electioneering communication requirements. 

PDC staff reviewed the allegations/complaint and found the Committee originally filed a C-6 report on July 16, 2019, wherein it did not fully describe/include the identity of the sub-vendor digital platforms for the digital ads as required by RCW 42.17A.305(1)(c). However, on the same day, the Committee also filed a C-4 report and amended the same report to include sub-vendor information related to the digital ads at issue in this matter. 

On September 10, 2019 and October 10, 2019, the Committee amended its C-4 and C-6 reports, respectively, to facilitate additional transparency. 

Based on these findings staff determined that, in this instance, the failure to fully describe and/or include sub-vendor platforms for the digital ads in the original C-6, did not amount to a violation warranting further investigation.  

Staff reminded the Committee about the importance of fully and accurately describing expenditures regarding digital ads in the future, specifically to include the names of the sub-vendor digital information. 

Based on this information, PDC staff dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/56008
55901 08/09/2019 James Lazar The City of Olympia, a municipal corporation, and Steve Hall in his capacity as City Manager, City of Olympia City of Olympia: Alleged Violation of RCW 42.17A.555, .575 for using public facilities to support a political campaign and for distributing a Public Service Announcement in which a municipal officer in the PSA is a political candidate. (AUG 2019, EY 2019) RCW 42.17A.555, RCW 42.17A.575 Case Closed with Reminder

On October 5, 2018, the Public Disclosure Commission (PDC) received a complaint alleging that the City of Olympia, a municipal corporation, may have violated RCW 42.17A.555 by using City of Olympia facilities to support Mayor Cheryl Shelby's 2019 re-election campaign by featuring her in a video on the City of Olympia's website during an election year; and (2) RCW42.17A.575 by featuring Mayor Shelby in a Public Service Announcement (PSA) when she was up for re-election in 2019. 

PDC staff reviewed the allegation, including the video evidence submitted with the complaint and determined that video was not a PSA in accordance with RCW 42.17A.575 and WAC 390-05-525.  Based on an interview with the City of Olympia attorney and his response to the allegations, the videos were only providing citizens with information about the budget and encouraging their participation in the annual budget process, which is part of the normal and regular conduct of the the City of Olympia. In addition, the City of Olympia proactively pulled down the "An invitation from the Mayor" video featuring Mayor Shelby from its website on August 1, 2019, the same day the complaint was filed. 

The City of Olympia attorney also stated the other videos were all related to the budget process and included one video from 2018, and the main budget video produced in 2019 prominently featured two current City of Olympia employees, with the narrator being a former city employee who has since accepted a new position with a different employer. 

While the video featured Mayor Shelby during an election year, there was no mention about her being a candidate for re-election to that office in 2019. However, PDC staff reminded the City of Olympia about the prohibitions of using city employees and facilities to support or oppose any candidate or ballot proposition, and encouraged the city to not feature any elected official in city business related videos or any other communications concerning the budget or other relevant city issues when that official is up for election or re-election. 

Based on these findings, staff determined that no evidence supported supports a finding of a violation warranting further investigation.

Based on the above, PDC staff dismissed this matter in accordance with RCW 42.17A.755(1). 

 

https://www.pdc.wa.gov/browse/cases/55901
55739 08/06/2019 Heidi Whaley Deborah “Sunny” Hemphill Hemphill, Deborah "Sunny": Alleged violation of RCW 42.17A.205 & .235 by failing to timely register as a candidate w/the PDC within two weeks of candidacy, and timely report contributions & expenditures. (EY '19) (Jul `19) RCW 42.17A.235, RCW 42.17A.205 Case Closed with Reminder
  • Allegation One: Alleged violation of RCW 42.17A.205 by failing to timely register as a candidate w/the PDC within two weeks of candidacy
  • Allegation Two: Alleged violation of RCW 42.17A.235 for failing to timely report contributions & expenditures. 
https://www.pdc.wa.gov/browse/cases/55739
55726 08/06/2019 Kristjan K Gorshkov Gerry "Tiger" Budbill Budbill, Gerry "Tiger": Alleged violation of RCW 42.17A.205 & .700 by failing to timely register as a candidate w/the PDC & file statement of financial affairs within two weeks of candidacy. (EY '19) (Jul '19) RCW 42.17A.205, RCW 42.17A.700 Case Closed with Written Warning
  • Allegation: Alleged violation of RCW 42.17A.205 & .700 by failing to timely register as a candidate w/the PDC within two weeks of candidacy & timely file a financial affairs statement.
https://www.pdc.wa.gov/browse/cases/55726
55723 08/06/2019 Robert Parker Mark D. Emerson Emerson, Mark: Alleged violation of RCW 42.17A.205 by failing to timely register as a candidate w/the PDC within two weeks of candidacy and disclose Treasurer, depository. (EY '19) (Jul '19) RCW 42.17A.205 Case Closed with Reminder
  • Alleged violation of RCW 42.17A.205 by failing to timely register as a candidate w/the PDC within two weeks of candidacy and disclose Treasurer, depository. 
https://www.pdc.wa.gov/browse/cases/55723
55719 08/06/2019 Robert Parker Drayton Jackson Jackson, Drayton: Alleged violation of RCW 42.17A.205 by failing to register as a candidate w/the PDC within two weeks of candidacy and disclose Treasurer, depository. (EY '19) (Jul '19) RCW 42.17A.205 Case Closed with Written Warning
  • Alleged violation of RCW 42.17A.205 by failing to timely register as a candidate w/the PDC within two weeks of candidacy and disclose Treasurer, depository. 
https://www.pdc.wa.gov/browse/cases/55719
55714 08/06/2019 David Lee Sandretto Michelle McLeod McLeod Michelle: Alleged Violation of WAC 390-18-040 for inaccurate of use of reelection terms in political advertising. (JULY 2019, EY 2019) WAC 390-18-040, RCW 42.17A.335 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by David Sandretto on July 31, 2019. The complaint alleged that Michelle McLeod (Respondent), a 2019 candidate for City Council in Benton City, may have violated RCW 42.17A.335 and WAC 390-18-040 for making false statements of incumbency in political advertising.

PDC staff reviewed the allegations; and the applicable statutes, rules, and reporting requirements, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, insufficient evidence supports a finding of a violation that warrants further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/55714
55704 08/05/2019 Jason Ritchie Layna Crofts Crofts, Layna: Alleged violations of RCW 42.17A.205, .235, and .700 for failure to register as a candidate and report contributions, expenditures, and financial affairs (EY 19; Jul 19) RCW 42.17A.700, RCW 42.17A.235, RCW 42.17A.205 Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Jason Ritchie on July 28, 2019. The complaint alleged that Layna Crofts (Respondent), a 2019 candidate for Issaquah School Director, may have violated RCW 42.17A.205 for failure to timely file a Candidate Registration (C-1 report) within two weeks of becoming a candidate; RCW 42.17A.235 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign; and RCW 42.17A.700 for failure to file a Personal Financial Affairs Statement (F-1 report), certifying financial affairs for twelve calendar months prior to becoming a candidate, within two weeks of becoming a candidate.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to timely register as a candidate and disclose personal financial affairs do not amount to violations that warrants further investigation.

Pursuant to WAC 390-37-060(1)(d), Layna Crofts will receive a formal written warning concerning failure to timely register as a candidate and to disclose personal financial affairs for twelve calendar months prior to becoming a candidate, within two weeks of becoming a candidate. The formal written warning will include staff’s expectation that Layna Crofts timely files all future required reports. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/55704
55701 08/05/2019 Andrew Saturn People for Seattle People for Seattle: Alleged violations of RCW 42.17A.240 for failure to disclose value of mailing lists, and RCW 42.17A.260 for failure to timely report independent expenditures for political advertising (EY 19; Jul 19) RCW 42.17A.240, RCW 42.17A.260 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Andrew Saturn on July 27, 2019. The complaint alleged that People for Seattle (Respondent), a continuing political committee, may have violated RCW 42.17A.240 for failure to disclose the value of expenditures or in-kind contributions for mailing lists on Summary Full Campaign Contribution and Expenditure reports (C-4 reports); and RCW 42.17A.260 for failure to disclose independent expenditures for political advertising appearing within 21 days of an election on Independent Expenditure and Electioneering Communications reports (C-6 reports).

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation that warrants further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/55701
55700 08/05/2019 Freedom Foundation (Maxford Nelsen) Temp-Control Mechanical Corporation Temp-Control Mechanical Corporation (2): Alleged violations of RCW 42.17A.495 and WAC 390-17-100 by failing to obtain written authorization from employees before deducting wages or salaries for political contributions (July 19) WAC 390-17-100, RCW 42.17A.495 Investigation of Possible Violation

Allegation: Violations of RCW 42.17A.495 & WAC 390-17-100 by failing to obtain written authorization from employees before deducting wages or salaries for political contributions

https://www.pdc.wa.gov/browse/cases/55700
55699 08/05/2019 Andrew Saturn John Weidenfeller Weidenfeller, John: Alleged violation of RCW 42.17A.555 by authorizing use of public office or agency facilities to assist an election campaign. (EY 2018) (Jun 2019) RCW 42.17A 555 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) completed its review of the complaint Andrew Saturn filed on June 21, 2019. The complaint alleged that John Weidenfeller may have violated RCW 42.17A.555 by authorizing the use of public office/agency facilities to assist an election campaign in 2018. Specifically, Andrew Saturn alleged that the Thurston County Public Utility District (PUD) paid for candidate Linda Oosterman to attend four Chamber of Commerce events in 2018, thereby potentially violating .555.

In the original complaint, it was alleged that Linda Oosterman and the Thurston County PUD also violated RCW 42.17A.555 by using or authorizing the use of public office/agency facilities to assist Linda Oosterman’s re-election campaign. Therefore:

  • A separate case was opened to address the allegation made against Linda Oosterman (PDC Case 53838). 
  • RCW 42.17A.555 prohibits specific types of individuals – namely elected or appointed officials and public agency or office employees – from engaging in certain activities. Whereas Thurston County PUD is not an individual, it cannot violate .555. Therefore, the allegation against Thurston County PUD was dismissed.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the response provided by John Weidenfeller (the “Respondent”) to determine whether the record supports a finding of one or more violations. 

Based on the findings, staff determined that, in this instance, reimbursing Linda Oosterman for a documented PUD Commissioner expenditure that was not clearly identified as an election-related event does not amount to a violation warranting further investigation.

Based on the information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/55699
55698 08/05/2019 Freedom Foundation (Maxford Nelsen) Waste Treatment Completion Company Waste Treatment Completion Company, LLC (3): Alleged violations of RCW 42.17A.495 and WAC 390-17-100 by failing to obtain written authorization from employees before deducting wages or salaries for political contributions (July 19) RCW 42.17A.495, WAC 390-17-100 Investigation of Possible Violation

Allegation: Violations of RCW 42.17A.495 & WAC 390-17-100 by failing to obtain written authorization from employees before deducting wages or salaries for political contributions

https://www.pdc.wa.gov/browse/cases/55698
55606 08/02/2019 Marylou Eckart, Charles Eakins, Glen Morgan Naz Lashgari Lashgari, Naz: Alleged violation of RCW 42.17A.320 for failure to identify sponsor on campaign website (EY '19) (Jul '19) RCW 42.17A.320 Case Closed with Reminder

The Public Disclosure Commission (PDC) completed its review of the complaints Marylou Eckart, Charles Eakins and Glen Morgan filed July 11, 2019 through July 16, 2019. The complaints alleged that Naz Lashgari, co-owner of the slate website Lynnwood Forward, may have violated RCW 42.17A..320 by failing to identify sponsors on political advertising (e.g. the Lynnwood Forward website). 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the response provided by Naz Lashgari (the “Respondent”) to determine whether the record supports a finding of one or more violations. 

Based on these findings, staff has determined that, in this instance, failure to identify the sponsor on political advertising does not amount to a violation warranting further investigation.

PDC staff reminded Naz Lashgari about the importance of timely & accurately identifying and disclosing the sponsor on all political advertising, including campaign websites.

Based on the information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/55606
55605 08/02/2019 Marylou Eckart, Charles Eakins, Glen Morgan Ashkan Amouzegar Amouzegar, Ashkan: Alleged violation of RCW 42.17A.320 for failure to identify sponsor on campaign website (EY '19) (Jul '19) RCW 42.17A.320 Case Closed with Reminder

The Public Disclosure Commission (PDC) completed its review of the complaints Marylou Eckart, Charles Eakins and Glen Morgan filed July 11, 2019 through July 16, 2019. The complaints alleged that Ashkan Amouzegar, co-owner of the slate website Lynnwood Forward, may have violated RCW 42.17A.320 by failing to identify sponsors on political advertising (e.g. the Lynnwood Forward website).

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the response provided by Ashkan Amouzegar (the “Respondent”) to determine whether the record supports a finding of one or more violations. 

Based on these findings, staff determined that, in this instance, failure to identify the sponsor on political advertising does not amount to a violation warranting further investigation.

PDC staff reminded Ashkan Amouzegar about the importance of timely & accurately identifying and disclosing the sponsor on all political advertising, including campaign websites.

Based on the information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/55605
55603 08/02/2019 Marylou Eckart, Charles Eakins & Glen Morgan Nicholas Coelho Coelho, Nicholas: Alleged violation of RCW 42.17A.320 for failure to identify sponsor on campaign website. (EY '19) (Jul '19) RCW 42.17A.320 Case Closed with Reminder

The Public Disclosure Commission (PDC) completed its review of the complaints Marylou Eckart, Charles Eakins and Glen Morgan filed July 11, 2019 through July 16, 2019. The complaints alleged that Nicholas Coelho, co-owner of the slate website Lynnwood Forward, may have violated RCW 42.17A..320 by failing to identify sponsors on political advertising (e.g. the Lynnwood Forward website). 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the response provided by Nicholas Coelho (the “Respondent”) to determine whether the record supports a finding of one or more violations. 

Based on the findings, staff  determined that, in this instance, failure to identify the sponsor on political advertising does not amount to a violation warranting further investigation.

PDC staff reminded Nicholas Coelho about the importance of timely & accurately identifying and disclosing the sponsor on all political advertising, including campaign websites.

Based on the information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/55603
55601 08/02/2019 Robert Parker Sanjay Pal Pal, Sanjay: Alleged Violation of RCW 42.17A.205, .210, .215 for failure to file Candidate Registration (C-1 Report), failure to disclose designated Treasurer, and failure to disclose depositories. (JULY 2019, EY 2019) RCW 42.17A.205 Case Closed with Reminder
  • Allegation One: Violation of RCW 42.17A.205 for failure to file Candidate Registration (C-1 Report)
  • Allegation Two: Violation of RCW 42.17A.210 for failure to disclose designated Treasurer
  • Allegation Three: Violation of RCW 42.17A.215 for failure to disclose depositories.
https://www.pdc.wa.gov/browse/cases/55601
55599 08/02/2019 Robert Parker Breane Martinez Martinez, Breane: Alleged Violation of RCW 42.17A.205, .210, .215 for failure to file Candidate Registration (C-1 Report), failure to disclose designated Treasurer, and failure to disclose depositories. (JULY 2019, EY 2019) RCW 42.17A.205 Case Closed with Reminder
  • Allegation One: Violation of RCW 42.17A.205 for failure to file Candidate Registration (C-1 Report).
  • Allegation Two: Violation of RCW 42.17A.210 for failure to disclose designated Treasurer. 
  • Allegation Three: Violation of RCW 42.17A.215 for failure to disclose depositories. 
https://www.pdc.wa.gov/browse/cases/55599
55598 08/02/2019 Robert Parker Mike Desmond Desmond, Mike: Alleged Violation of RCW 42.17A.205, .210, .215 for failure to file the Candidate Registration (C-1 Report), failure to disclose designated Treasurer, and failure to disclose depositories. (JULY 2019, EY 2019) RCW 42.17A.205 Case Closed with Reminder
  • Allegation One: Violation of RCW 42.17A.205 for failure to file Candidate Registration (C-1 Report).
  • Allegation Two: Violation of RCW 42.17A.210 for failure to disclose designated Treasurer. 
  • Allegation Three: Violation of RCW 42.17A.215 for failure to disclose depositories.
https://www.pdc.wa.gov/browse/cases/55598
55594 08/02/2019 Robert Parker Jonee Dubos Dubos, Jonee: Alleged Violation of RCW 42.17A.205, .210, .215 for failure to file Candidate Registration (C-1 Report), failure to disclose designated Treasurer, and failure to disclose depositories. (JULY 2019, EY 2019) RCW 42.17A.205 Case Closed with Reminder
  • Allegation One : Violation of RCW 42.17A.205 for failure to file Candidate Registration (C-1 Report).
  • Allegation Two: Violation of RCW 42.17A.210 for failure to disclose a designated Treasurer.
  • Allegation Three: Violation of RCW 42.17A.215 for failure to disclose depositories. 
https://www.pdc.wa.gov/browse/cases/55594
55593 08/02/2019 Glen Morgan Tony Anderson Anderson, Anthony D.: Alleged Violation of RCW 42.17A.700, .710 for failure to disclose 2017 & 2018 financial interest & directorship on the F-1 Statement of Personal Financial Affairs (Jul 2019). RCW 42.17A.710, RCW42.17A.700 Case Closed with Reminder
  • Allegation: Violation of RCW 42.17A.700 for failure to disclose financial entities on the Statement of Personal Financial Affairs (F-1 Report).
https://www.pdc.wa.gov/browse/cases/55593
55589 08/02/2019 Robert Parker Rob MacDermid MacDermid, Robert: Alleged Violation of RCW 42.17A.205 for failure to file the C-1 Candidate Registration) (JULY 2019) (EY 2019) RCW 42.17A.205 Case Closed with Written Warning
  • Allegation: Violation of RCW 42.17A.205 for failure to file the candidate registration (C-1 Report)
https://www.pdc.wa.gov/browse/cases/55589
55568 08/01/2019 PDC Staff Robert Bonnett III Bonnett, Robert III: Alleged violation of RCW 42.17A.700 for failure to timely disclose financial activities after appointment, and in calendar year 2018 (F-1 Report) (Aug 19) RCW 42.17A.700 Resolved through Statement of Understanding

The PDC has completed its review of a staff generated complaint concerning Robert Bonnett III, a former School Director for Pioneer School District, alleging violations of RCW 42.17A.700 for failure to file Personal Financial Affairs Statements (F-1 reports).

On September 19, 2019, the PDC received two F-1 reports, signed Statement of Understanding acknowledging two violations of RCW 42.17A.700, and payment of a $200 civil penalty for failure to file. The PDC has dismissed this matter in accordance with RCW 42.17A.755(1) and will not conduct a more formal investigation into these allegations or take further enforcement action in this matter.  

https://www.pdc.wa.gov/browse/cases/55568
55534 08/01/2019 Ron Anderson Tom Sund Sund, Thomas: Alleged violation of RCW 42.17A.205, .235 & .240 for failure to timely register as a candidate with the PDC, and timely & accurately report contributions & expenditures. (EY '19) (July '19) RCW 42.17A.235, RCW 42.17A.240, RCW 42.17A.205 Case Closed with Reminder
  • Allegation One: Alleged violation of RCW 42.17A.205 for failure to timely register as a candidate with the PDC within two weeks of declaring candidacy.
  • Allegation Two: Alleged violation of RCW 42.17A.235 & .240 for failure to timely & accurately report contributions & expenditures.
https://www.pdc.wa.gov/browse/cases/55534
55529 08/01/2019 Whatcom County Democratic Central Committee (Andrew Reding) Whatcom County Republican Party Whatcom County Republican Party (3): Alleged violations of RCW 42.17A.220, .235, and .240 for failure to accurately and timely deposit and report contributions and expenditures (EY 19; Aug 19) RCW 42.17A.235, RCW 42.17A.220, RCW 42.17A.240 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint the Whatcom County Democratic Central Committee (Andrew Redding) filed on July 29, 2019. The complaint alleged that the Whatcom County Republican Party (Respondent), a bona fide political party may have violated RCW 42.17A.220 for failure to timely deposit contributions within five business days of receipt; RCW 42.17A.235 for failure to timely report contributions and deposits on Monetary Contribution reports (C-3 reports); and RCW 42.17A.240 and WAC 390-16-205 for failure to accurately and completely disclose contributions from auctions, and expenditures made to sub-vendors, with the amounts attributable to each, on Summary Full Campaign Contribution and Expenditure reports (C-4 reports).

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to accurately report contributions and provide itemized break downs of expenditures, do not amount to violations that warrant further investigation.

PDC staff is reminding Whatcom County Republican Party about the importance of accurately reporting contribution details, and providing complete and accurate details for all expenditures. PDC staff expects the complete and accurate reporting of contribution and expenditure details in the future.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/55529
55460 07/31/2019 Glen Morgan People for Moon PAC People for Moon PAC: Alleged Violation of RCW 42.17A.240 for failure to accurately describe expenditure. (EY '17, Jul '19) RCW 42.17A.240, WAC 390-16-037 Case Closed with Reminder
  • Allegation: Violation of RCW 42.17A.240 for failure to accurately describe expenditure.
https://www.pdc.wa.gov/browse/cases/55460
55351 07/29/2019 Tallman Trask Facebook, Inc. Facebook, Inc. (5): Alleged violations of RCW 42.17A.345 and WAC 390-18-050 for failure to maintain and provide documents and books of account as a commercial advertiser, promptly upon request from any person (EY 19; Jul 19) WAC 390-18-050, RCW 42.17A.345 Referred to Attorney General by Commission

Allegation: Violations of RCW 42.17A.345 and WAC 390-18-050 for failure to maintain and provide documents and books of account as a commercial advertiser, promptly upon request from any person. The Commission met on January 23, 2020 and February 27, 2020 to consider a stipulation jointly presented by PDC staff and Respondent Facebook, Inc.  At the February meeting, the Commission voted to reject the stipulation and refer the matter to the Attorney General's Office for further action pursuant to RCW 42.17A.755(4).

https://www.pdc.wa.gov/browse/cases/55351
55345 07/29/2019 Tallman Trask UniteHere Local 8 PAC UniteHere Local 8 PAC: Alleged violations of Chapter 42.17A RCW for failure to register as a political committee, report expenditure activities, and disclose sponsor identification (EY 19; July 19) RCW 42.17A.240, RCW 42.17A.255, RCW 42.17A.320, RCW 42.17A.305, RCW 42.17A.260, RCW 42.17A.235 Investigation of Possible Violation
  • Allegation One: Violations of RCW 42.17A.320 for failure to completely and accurately disclose sponsor identification on digital political advertising.
  • Allegation Two: Violations of RCW 42.17A.235 and .240 for failure to timely, accurately, and completely report contributions and expenditures.
  • Allegation Three: Violations of RCW 42.17A.255, .260, and .305 for failure to timely, accurately, and completely disclose independent expenditures and electioneering communications.
https://www.pdc.wa.gov/browse/cases/55345
55344 07/29/2019 Tallman Trask Unite Here Unite Here: Alleged violations of Chapter 42.17A RCW for failure to register as an out-of-state committee, to report expenditure activity, and to disclose sponsor identification (EY 19; July 19) RCW 42.17A.320, RCW 42.17A.255, RCW 42.17A.305, RCW 42.17A.250, RCW 42.17A.260 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint Tallman Trask filed on July 23, 2019. The complaint alleged that Unite Here (Respondent), a labor organization, may have violated RCW 42.17A.320 for failure to completely and accurately disclose sponsor identification on digital political advertising; RCW 42.17.250 for failure to register as an out-of-state political committee and to report contributions and expenditures; and RCW 42.17A.255, .260, and .305 for failure to timely, accurately, and completely disclose independent expenditures and electioneering communications.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; and the response provided by Unite Here Local 8 PAC, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation that warrants further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/55344
55341 07/29/2019 Glen Morgan Natalie McClendon McClendon, Natalie: Alleged violations of RCW 42.17A.240 for failure to accurately and completely disclose expenditures (EY 19; July 19) WAC 390-16-037, RCW 42.17A.240 Request for Technical Correction

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Glen Morgan on July 22, 2019. The complaint alleged that Natalie McClendon (Respondent), a 2019 candidate for Whatcom County Council, District 5, may have violated RCW 42.17A.240 and WAC 390-16-037 for failure to accurately and completely disclose details of expenditures undertaken by the Campaign, including the number of items printed for printed political advertising and run dates for digital advertising.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the responses provided by the Respondent; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to provide accurate and complete descriptions of expenditures undertaken by the Campaign does not amount to a violation that warrants further investigation.

Natalie McClendon made minor or ministerial errors on required reports, which did not materially impact the public interest. Upon notification of these errors, Natalie McClendon timely amended their reports, making the necessary technical corrections as requested by staff.

PDC staff is also reminding Natalie McClendon about the importance of the complete and accurate disclosure of all expenditure details, including the number of items printed for political advertising. PDC staff expects in the future that Natalie McClendon will file complete and accurate reports in accordance with statute and rule.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/55341
55339 07/29/2019 Glen Morgan Sofia Aragon Aragon, Sofia: Alleged violations of RCW 42.17A.240 for failure to accurately report expenditures, and .320 for failure to disclose sponsor identification on political advertising (EY 19; Jul 19) RCW 42.17A.240, WAC 390-16-037, RCW 42.17A.320 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Glen Morgan on July 21, 2019. The complaint alleged that Sofia Aragon (Respondent), a 2019 candidate for Burien City Council, may have violated RCW 42.17A.240 and WAC 390-16-037 for failure to accurately and completely disclose in-kind contributions or expenditures undertaken by the Campaign; and RCW 42.17A.320 for failure to accurately and completely disclose sponsor identification on digital political advertising.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the responses provided by the Respondent; the applicable PDC reports filed by the Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, minor and ministerial errors on required reports that did not materially impact the public interest, and failure to include complete and accurate sponsor identification on digital political advertising, do not amount to violations that warrant further investigation.

PDC staff is reminding Sofia Aragon about the importance of the complete and accurate disclosure of in-kind contributions and expenditures, including the number of items printed for political advertising, and the complete and accurate disclosure of sponsor identification on political advertising in the future.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/55339
55287 07/26/2019 Tallman Trask Chistopher Rufo Rufo, Christopher: Alleged violation of RCW 42.17A.430 by donating surplus funds to an unregistered charity. (EY '19) (Jul '19) RCW 42.17A.430 Case Closed with Reminder

A complaint was filed against Christopher Rufo, a first-time candidate for Seattle City Council in 2019, alleging that he may have violated RCW 42.17A.430 by donating funds remaining from his 2019 Campaign to a charitable organization that was not properly registered in accordance with RCW 19.09. 

Staff's review found that Mr. Rufo: 

(1) Was a first-time candidate for public office in 2019 and unfamiliar with the PDC laws, rules and reporting requirements for a candidate.

(2) Terminated his Campaign in November of 2018, more than six months prior to Candidate Filing week (May of 2019).

(3) Contacted PDC staff after terminating his candidacy for Seattle City Council seeking advice on the disposal of his remaining campaign funds. 

(4) Made a good-faith effort to dispose of his 2019 surplus funds by timely disclosing the two surplus funds expenditures on a C-4 report, that included the $10,000 expenditure made to the Documentary Foundation, a charitable organization that he is involved with. 

(5) Took steps to remedy the error by promptly registering the Documentary Foundation with the Secretary of State's Office in accordance with RCW 19.09 once staff informed him of the requirement.

Based on these findings, and the facts listed above, staff determined that in this instance, the allegations do not warrant further investigation, and has dismissed this matter in accordance with RCW 42.17A.755(1). 

 

https://www.pdc.wa.gov/browse/cases/55287
55284 07/26/2019 Philip L. Johnson Shauna Walters Walters, Shauna: Alleged violations of WAC 390-16-105 & .125 and RCW 42.17A.220 by accepting a contribution greater than $500, failure to change from mini to full reporting, and exceeding $300 in anonymous donations. (EY '19) (Jul '19). WAC 390-16-125, RCW 42.17A.220, WAC 390-16-105 Case Closed with Reminder

The Public Disclosure Commission (PDC) completed its review of the complaint Philip Johnson filed on July 22, 2019. The complaint alleged that Shauna Walters may have violated RCW 42.17A.220, WAC 390-16-105 & .125 by exceeding $300 in anonymous contributions, accepting a contribution greater than $500, and failure to change reporting options from mini to full.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Shauna Walters (the “Respondent”); and the applicable PDC reports filed by Respondent to determine whether the record supports a finding of one or more violations. 

Based on the findings, staff determined that, in this instance, the receipt of two over-limit contributions, which were refunded to the donors, does not amount to a violation warranting further investigation.

PDC staff reminded Shauna Walters about the importance of not accepting over-limit contributions, including in-kind contributions. Ms. Walters is further reminded to refund any over-limit contributions immediately.

Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/55284
55283 07/26/2019 Glen Morgan Ricky Moon Moon, Ricky: Alleged Violation of RCW 42.17A.205, .235, .240, .700 for failure to timely or accurately file Candidate Registration, Financial Affairs Statement, and Contribution or Expenditure Reports (JULY 2019, EY 2019). RCW.42.17A.240, RCW 42.17A.235, RCW 42.17A.205, RCW 42.17A.700 Case Closed with Reminder
  • Allegation One: Violation of RCW 42.17A.205 for failure to timely file the Candidate Registration (C-1 report).
  • Allegation Two: Violation of RCW 42.17A.700 for failure to timely file the Financial Affairs Statement (F-1 report).
  • Allegation Three: Violation of RCW 42.17A.235 for failure to timely disclose Contributions or Expenditures (C-3 or C-4 Reports).
  • Allegation Four: Violation of RCW 42.17A.240 for failure to accurately describe expenditures..

 

https://www.pdc.wa.gov/browse/cases/55283
55282 07/26/2019 Glen Morgan Debbie Bertlin Bertlin, Debbie (2): Alleged violations of RCW 42.17A.555 for misuse of public facilities to support candidate's own election campaign (EY 19; Jul 19) RCW 42.17A.555 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Glen Morgan on July 21, 2019. The complaint alleged that Debbie Bertlin (Respondent), the 2019 incumbent candidate for Mayor of the City of Mercer Island, may have violated RCW 42.17A.555 for misuse of phones, computers, servers, and other public facilities owned and operated by the City of Mercer Island to support the candidate's own election campaign.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the responses provided by the Respondent; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance no evidence supports a finding of a violation that warrants further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/55282
55276 07/26/2019 Glen Morgan Lillian (Randy) Slovic Slovic, Lillian (Randy): Alleged violations of RCW 42.17A.235 for failure to report contributions and expenditures (EY 19; Jul 19) RCW 42.17A.235 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Glen Morgan on July 26, 2019. The complaint alleged that Lillian (Randy) Slovic (Respondent), 2019 candidate for Richland City Council may have violated RCW 42.17A.235 for failure to timely file Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; the applicable PDC reports filed by the Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to timely, completely, and accurately report in-kind contributions for the candidate’s filing fee and political advertising  do not amount to violations that warrants further investigation.

PDC staff is reminding Lillian (Randy) Slovic about the importance of the timely, complete, and accurate disclosure of all contribution and expenditure activities, including in-kind contributions. PDC staff expects timely, complete, and accurate filings of all future PDC reports in accordance with the statutes and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/55276
55267 07/26/2019 Glen Morgan Darcy Burner Burner, Darcy: Alleged Violation of RCW 42.17A.220 for accepting anonymous over-limit contributions during the 2016 campaign. (JULY 2019, EY 2016) RCW 42.17A.220 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on July 17, 2019. Your complaint alleged that Darcy Burner, a Candidate for State Representative in Legislative District 5 in 2016, may have violated RCW 42.17A.220(4) for accepting over limit anonymous contributions.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Jason Bennett, Treasurer; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database], to determine whether the record supports a finding of one or more violations.

Staff’s review of the Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports) filed by Friends of Darcy Burner found the campaign could accept the greater amount of up to 1 percent of the total accumulated contributions.

Based on these findings, staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/55267
55265 07/26/2019 Michael Kelly Preserve Reasonable Shoreline Management Preserve Reasonable Shoreline Management: Alleged violations of Chapter 42.17A RCW for failure to register as a political committee, report contributions and expenditures, and disclose sponsor identification on political advertising (EY 19; July 19) RCW 42.17A.207, RCW 42.17A.235, RCW 42.17A.205, RCW 42.17A.320 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on July 18, 2019. Your complaint alleged that Preserve Reasonable Shoreline Management (PRSM), a 501 (c )(3) organization created by Bainbridge Island shoreline homeowners, may have violated: (1) RCW 42.17A.205 or .207 for failure to register as a political committee or incidental committee; (2) RCW 42.17A.235 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures; and (3) RCW 42.17A.320 for failure to disclose sponsor identification on political advertising.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the response provided by Dick Haugan on behalf of PRSM, to determine whether the record supports a finding of one or more violations.

Staff’s review found that PRSM receives contributions and makes expenditures to support the mission of Bainbridge Island Shoreline Homeowners and that their activities do not appear to meet the definition of a political committee or incidental committee requiring them to register and report as either.

In addition, staff found that that the email communication was sent to specific recipients identified as supporters of PRSM and not “mass communication” that would make the message political advertisement requiring sponsor identification and disclosure.

Based on these findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/55265
55221 07/25/2019 Guy Thompson Washington Association of Realtors Washington Association of Realtors: Alleged violations of RCW 42.17A.320 for failure to disclose sponsor identification on digital political advertising (EY 19; Jul 19) RCW 42.17A.320 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on July 17, 2019. Your complaint alleged that the Washington Association of Realtors (WA Assn. of Realtors), a membership organization and lobbyist employer registered for calendar year 2019, may have violated RCW 42.17A.320 for failure to include sponsor identification on digital political advertising done in support of People for Nadine Woodward, a 2019 candidate for Spokane mayor.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided in a related case by WA Realtors PAC, PDC Case #55218; and the applicable PDC reports filed by Respondent, to determine whether the record supports a finding of one or more violations.

It appears that the online advertisements presented in support of the People for Nadine Woodward 2019 campaign were sponsored by WA Realtors PAC and that the advertisements contained sponsor identification required by RCW 42.17.320 and WAC 390-18-030 and were accessible through one click on the ad. The WA Assn. of Realtors did not sponsor the advertisements although they were identified as one of the top three contributors in the sponsor identification.

Based on these findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/55221
55220 07/25/2019 Guy Thompson Concerned Taxpayers of Washington State Concerned Taxpayers of Washington State: Alleged violations of RCW 42.17A.320 for failure to disclose sponsor identification on digital political advertising (EY 19; Jul 19) RCW 42.17A.320 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on July 17, 2019. Your complaint alleged that Concerned Taxpayers of Washington State, a continuing political committee registered for calendar year 2019, may have violated RCW 42.17A.320 for failure to include sponsor identification on digital political advertising done in support of People for Nadine Woodward, a 2019 candidate for Spokane mayor.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Dan Brady on behalf of his client Concerned Taxpayers of Washington State; the response provided in a related case by WA Realtors PAC, PDC Case #55218; and the applicable PDC reports filed by Respondent, to determine whether the record supports a finding of one or more violations.

It appears that the online advertisements presented in support of the People for Nadine Woodward 2019 campaign were sponsored by WA Realtors PAC and that the advertisements contained sponsor identification required by RCW 42.17.320 and WAC 390-18-030 and were accessible through one click on the ad. Although Concerned Taxpayers of Washington State has disclosed on C-6 reports, other expenditures done in support of the Woodward campaign, they did not sponsor the online advertisements in this complaint.

Based on these findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/55220
55219 07/25/2019 Guy Thompson Spokane Good Government Alliance Spokane Good Government Alliance: Alleged violations of RCW 42.17A.320 for failure to disclose sponsor identification on digital political advertising (EY 19; Jul 19) RCW 42.17A.320 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on July 17, 2019. Your complaint alleged that Spokane Good Government Alliance (SGGA), a continuing political committee registered for calendar year 2019, may have violated RCW 42.17A.320 for failure to include sponsor identification on digital political advertising done in support of People for Nadine Woodward, a 2019 candidate for Spokane mayor.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Jake Mayson, Chairman for SGGA; the response provided in a related case by WA Realtors PAC, PDC Case #55218; and the applicable PDC reports filed by Respondent, to determine whether the record supports a finding of one or more violations.

It appears that the online advertisements presented in support of the People for Nadine Woodward 2019 campaign were sponsored by WA Realtors PAC and that the advertisements contained sponsor identification required by RCW 42.17.320 and WAC 390-18-030 and were accessible through one click on the ad. Although SGGA has disclosed on C-6 reports, expenditures done in support of the Woodward campaign, they did not sponsor the online advertisements in this complaint.

Based on these findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/55219
55218 07/25/2019 Guy Thompson Washington Realtors Political Action Committee Washington Realtors Political Action Committee (2): Alleged violations of RCW 42.17A.320 for failure to disclose sponsor identification on digital political advertising (EY 19; July 19) RCW 42.17A.320 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on July 17, 2019. Your complaint alleged that the Washington Realtors Political Action Committee (WA Realtors PAC), a continuing political committee registered for calendar year 2019, may have violated RCW 42.17A.320 for failure to include sponsor identification on digital political advertising done in support of People for Nadine Woodward, a 2019 candidate for Spokane mayor.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Mark Lamb on behalf of his client WA Realtors PAC; and the applicable PDC reports filed by Respondent, to determine whether the record supports a finding of one or more violations.

It appears that the online advertisements presented in support of the People for Nadine Woodward 2019 campaign were sponsored by WA Realtors PAC and that the advertisements contained sponsor identification required by RCW 42.17.320 and WAC 390-18-030 and were accessible through one click on the ad.

Based on these findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/55218
55217 07/25/2019 Guy Thompson Nadine Woodward Woodward, Nadine: Alleged violations of RCW 42.17A.320 for failure to disclose sponsor identification on digital political advertising (EY 19; July 19) RCW 42.17A.320 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on July 17, 2019. Your complaint alleged that Nadine Woodward (People for Nadine Woodward), a candidate for Spokane Mayor in the 2019 election, may have violated RCW 42.17A.320 for failure to include sponsor identification on digital political advertising done in support of her campaign.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided in a related case by WA Realtors PAC, PDC Case #55218; and the applicable PDC reports filed by Respondent, to determine whether the record supports a finding of one or more violations.

It appears that the online advertisements presented in support of the People for Nadine Woodward 2019 campaign were sponsored by WA Realtors PAC and that the advertisements contained sponsor identification required by RCW 42.17.320 and WAC 390-18-030 and were accessible through one click on the ad. Nadine Woodward did not sponsor the advertisements done in support of her campaign.

Based on these findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/55217
55069 07/22/2019 Glen Morgan Thurston County Democratic Central Committee Thurston County Democratic Central Committee: Alleged violation of RCW 42.17A.220 by accepting over-limit anonymous contributions. (EY '16) (July '19) RCW 42.17A.220 Case Closed with No Evidence of Violations

On July 17, 2019, the Public Disclosure Commission (PDC) received a complaint alleging that the Thurston County Democratic Central Committee, may have violated RCW 42.17A.220(4) for accepting over the limit anonymous contributions. 

PDC staff reviewed the complaint/allegation and determined that the Committee could accept the greater amount of up to 1% of the total accumulated contributions.  

Based on the above, the PDC found no evidence to support a finding of a violation warranting further investigation. 

Accordingly, the PDC dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/55069
55065 07/22/2019 Glen Morgan Ben Stuckart Stuckart, Ben: Alleged violation of RCW 42.17A.220 by accepting over-limit anonymous contributions. (EY '19) (July '19) RCW 42.17A.220 Case Closed with No Evidence of Violations

On July 17, 2019, the Public Disclosure Commission (PDC) received a complaint alleging that Ben Stuckart (respondent), a candidate for mayor for the City of Spokane in 2019, may have violated RCW 42.17A.220(4) for accepting over the limit anonymous contributions. 

The complaint alleged that in calendar year 2019, the respondent accepted anonymous contributions in the amount of $521, which was $221 more than the allowable limit of $300. PDC staff reviewed the complaint and determined that the respondent could accept the greater amount of up to 1% of the total accumulated contributions. 

Based on these findings, staff determined that no evidence supported a finding of a violation warranting further investigation. 

Accordingly, staff dismissed the complaint in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/55065
55057 07/22/2019 Glen Morgan Yes for Libraries! Yes for Libraries!: Alleged violation of RCW 42.17A.220 by accepting over-limit anonymous contributions. (EY '18) (July '19) RCW 42.17A.220 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on July 17, 2019. Your complaint alleged that Yes for Libraries!, a Political Committee, supporting Proposition 1 in Snohomish County in the April 24, 2018 special election, may have violated RCW 42.17A.220(4) for accepting over limit anonymous contributions.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Robert Taylor, Treasurer; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution database, to determine whether the record supports a finding of one or more violations.

Staff’s review of the Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports) filed by Yes for Libraries! found the committee could accept the greater amount of up to 1 percent of the total accumulated contributions.

Based on these findings, staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/55057
55052 07/22/2019 Glen Morgan Fire Services Fund of Washington Fire Services Fund of Washington: Alleged violation of RCW 42.17A.220 by accepting over-limit anonymous contributions. (EY '18) (July '19) RCW 42.17A.220 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on July 17, 2019. Your complaint alleged that Fire Services Fund of Washington, a Continuing Political Committee, may have violated RCW 42.17A.220(4) for accepting over limit anonymous contributions.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Roger Ferris, Committee Officer; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution database, to determine whether the record supports a finding of one or more violations.

Although the original C-3 report electronically submitted on December 10, 2018, inaccurately identified $2,632 in funds received from unknown or “anonymous” sources, it appears that the error was unintentional and not done in order to mislead the public.

PDC staff reminded Fire Services Fund of Washington about the importance of the accurate disclosure of all contribution received, specifically funds that are not itemized including anonymous funds, small contributions of $25 or less and proceeds from low-cost fundraisers, on future PDC reports in accordance with the statutes and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/55052
55049 07/22/2019 Glen Morgan Debra Entenman Entenman, Debra: Alleged violation of RCW 42.17A.220 by accepting over-limit anonymous contributions. (EY '18) (July '19) RCW 42.17A.220 Case Closed with No Evidence of Violations

The complaint alleged that Debra Entenman, a Candidate for State Representative from the 47th Legislative District in 2018 may have violated RCW 42.17A.220(4) for accepting over limit anonymous contributions.

PDC staff has determined in this instance the alleged acceptance of anonymous contributions in excess of the allowable limit without forfeiting the excess amount to the State of Washington does not appear to be a violation warranting further investigation. 

The PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/55049
55044 07/22/2019 Glen Morgan Victoria Mena Mena, Victoria: Alleged violation of RCW 42.17A.220 by accepting over-limit anonymous contributions. (EY '18) (July '19) RCW 42.17A.220 Case Closed with No Evidence of Violations

On July 22, 2019, the Public Disclosure Commission (PDC) received a complaint alleging that Victoria Mena violated RCW 42.17A.220(4) for accepting over the limit anonymous contributions. 

PDC staff reviewed the complaint/allegation and determined that Ms. Mena's campaign could accept the greater amount of up to 1% of the total accumulated contributions. 

Based on this review, staff determined that, in this instance, no evidence supports a finding of a violation warranting further investigation. 

Accordingly, the PDC dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/55044
55043 07/22/2019 Glen Morgan Debra Lekanoff Lekanoff, Debra: Alleged violation of RCW 42.17A.220 by accepting over-limit anonymous contributions. (EY '18) (July '19) RCW 42.17A.220 Case Closed with No Evidence of Violations

The complaint alleged Debra Lekanoff, a Candidate for State Representative from the 40th Legislative District may have violated RCW 42.17A.220(4) for accepting anonymous contributions in excess of the allowable limit without forfeiting the excess amount to the State of Washington.

PDC staff’s review of the Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports) filed by the Committee found the Committee could accept the greater amount of up to 1 percent of the total accumulated contributions.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/55043
55041 07/22/2019 Glen Morgan Pinky Vargas Vargas Pinky: Alleged violation of RCW 42.17A.220 by accepting over-limit anonymous contributions. (EY '18) (July '19) RCW 42.17A.220 Case Closed with No Evidence of Violations

On July 16, 2019, the Public Disclosure Commission received a complaint alleging that Pinky Vargas (respondent), a candidate for State Senator in the 42nd Legislative District in 2018, may have violated RCW 42.17A.220(4) for accepting over the limit anonymous contributions. 

PDC staff reviewed the complaint and determined that the respondent's campaign could accept the greater amount of up to 1% of the total accumulated contributions.

Based on staff's determination, no evidence supports a finding of a violation warranting further investigation. 

Accordingly, the PDC staff dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/55041
55035 07/22/2019 Glen Morgan Clean Air Clean Energy Washington Clean Air Clean Energy Washington: Alleged violation of RCW 42.17A.220 by accepting over-limit anonymous contributions. (EY '18) (July '19) RCW 42.17A.220 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on July 17, 2019. Your complaint alleged that Clean Air Clean Energy Washington, a Political Committee, supporting statewide ballot measure 1631 in the November 6, 2018 general election, may have violated RCW 42.17A.220(4) for accepting over limit anonymous contributions.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution database, to determine whether the record supports a finding of one or more violations.

Staff’s review of the Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports) filed by Clean Air Clean Energy Washington found the committee could accept the greater amount of up to 1 percent of the total accumulated contributions.

Based on these findings, staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/55035
54991 07/19/2019 Glen Morgan Martha Cunningham Cunningham, Martha: Alleged violations of RCW 42.17A.205 & .700 for failure to timely register as a candidate & file financial affairs statement within 2 weeks of declaring candidacy. (EY '19) (Jul '19) RCW 42.17A.700, RCW 42.17A.205 Case Closed with Reminder

The Public Disclosure Commission (PDC) completed its review of the complaint Glen Morgan filed on July 16, 2019. The complaint alleged that Martha Cunningham (the “Respondent”) may have violated RCW 42.17A.205, .700 & .235 by failing to register as a candidate and file a financial affairs statement within two weeks of declaring candidacy, and timely report contributions & expenditures. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements: the response provided by the Respondent; and the applicable PDC reports filed by Respondent to determine whether they support a finding of one or more violations.  

Based on the findings, staff determined that, in this instance, failure to timely file the Candidate Registration (C-1) and Personal Statement of Financial Affairs (F-1) reports does not amount to a violation warranting further investigation.

PDC staff  reminded Martha Cunningham about the importance of the timely filing all future PDC reports, including the Candidate Registration and Personal Financial Affairs Statement.

Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/54991
54984 07/19/2019 Glen Morgan Alliance for Gun Responsiblity (ERP Committee) PAC Alliance for Gun Responsibility ERP Committee: Alleged Violation of RCW 42.17A.220 for accepting over-limit anonymous contributions. (JULY 2019) RCW 42.17A.220 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Glen Morgan on July 17, 2019. The complaint alleged that the Alliance for Gun Responsibility ERP Committee (Respondent), a political committee in support of the 2016 ballot proposition for the Temporary Prevention of Owning Firearms, may have violated RCW 42.17A.220(4) for accepting over limit anonymous contributions.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on these findings, staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/54984
54979 07/19/2019 Michele Levenite Matthew J Bishop Bishop, Matthew (5): Alleged Violation of RCW 42.17A.700 for failure to file the Personal Financial Affairs Statement (F-1 report) (JULY 2019, EY 2019) RCW 42.17A.700 Violation Found by Commission

Allegation: Violation of RCW 42.17A.700 for failing to file the Personal Financial Affairs Statement (F-1 report), certifying financial affairs for twelve calendar months prior to becoming a candidate, due within two weeks of becoming a candidate or no later than May 14, 2019.

https://www.pdc.wa.gov/browse/cases/54979
54975 07/19/2019 Kevin Mendez Mason Thompson Thompson, Mason: Alleged violation of RCW 42.17A.320 for failure to accurately disclose complete sponsor ID on political advertising. (EY '19) (Jul '19)) RCW 42.17A.320 Case Closed with Reminder

The Public Disclosure Commission (PDC) completed its review of the complaint Kevin Mendez filed on July 12, 2019. The complaint alleged that Mason Thompson (the “Respondent”) may have violated RCW 42.17A.320 by failing to disclose complete sponsor identification (ID) on political advertising.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the response provided by the Respondent to determine whether the record supports a finding of one or more violations. 

Based on the findings, staff determined that, in this instance, failure to disclose sponsor address on political advertising does not amount to a violation warranting further investigation.

PDC staff reminded Mason Thompson about the importance of providing complete sponsor identification information on all political advertising 

Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/54975
54972 07/19/2019 Glen Morgan Richard W. Robinson Robinson, Richard W.: Alleged violations of RCW 42.17A.205, .700 & .235 for failure to timely register as a candidate & file financial affairs statement within 2 weeks of declaring candidacy & timely report contributions & expenditures. (EY '19) (Jul '19) RCW 42.17A.700, RCW 42.17A.205, RCW 42.17A.235 Case Closed with Reminder
  • Allegation One: Alleged violation of RCW 42.17A.205 for failure to register as a candidate with PDC within two weeks of declaring candidacy.  
  • Allegation Two:  Alleged violation of RCW 42.17A.700 for failure to timely file a statement of financial affairs with PDC within two weeks of declaring candidacy.  
  • Allegation Three:  Alleged violation of RCW 42.17A.235 for failure to timely report contributions & expenditures.
https://www.pdc.wa.gov/browse/cases/54972
54968 07/19/2019 Glen Morgan Jared Hofer Hofer, Jared: Alleged violations of RCW 42.17A.205 & .235 for failure to register as a candidate within 2 weeks of declaring candidacy & timely report contributions & expenditures. (EY '19) (Jul '19) RCW 42.17A.235, RCW 42.17A.205 Case Closed with Reminder

The Public Disclosure Commission (PDC) completed its review of the complaint Glen Morgan filed on July 15, 2019. The complaint alleged that Jared Hofer (the “Respondent”) may have violated RCW 42.17A.205 & .235 by failing to timely register as a candidate within two weeks of declaring candidacy & timely report contributions & expenditures.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; and the applicable PDC reports filed by Respondent to determine whether they support a finding of one or more violations. 

Based on the findings, staff determined that, in this instance, failure to timely file the Candidate Registration (C-1 report) does not amount a violation warranting further investigation

PDC staff reminded Jared Hofer about the importance of timely filing all future PDC reports, including the Candidate Registration.

Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/54968
54966 07/19/2019 Michele Levenite Lisa Thomas Thomas, Lisa: Alleged violations of RCW 42.17A.700 & .240 for failure to timely & accurately file statement of financial affairs (F-1 report) & accurately report expenditures (EY '19) (Jul '19) RCW 42.17A.240, RCW 42.17A.710, 42.17A.700 Case Closed with Reminder

The Public Disclosure Commission (PDC) completed its review of the complaints and supplemental information Michele Levenite submitted between July 7, 2019 and July 30, 2019. The complaints alleged that Lisa Thomas (the “Respondent”) may have violated RCW 42.17A.700 and .240 by failing to timely & accurately file a financial affairs statement (F-1 report) and accurately report expenditures. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response(s) provided by the Respondent; and the applicable PDC reports filed by Respondent to determine whether the record supports a finding of one or more violations. 

Based on the findings, staff determined that, in this instance, failure to timely file an F-1 report certifying financial activity for 2018 and failure to timely & accurately report contributions & expenditures does not amount to a violation warranting further investigation.

The Respondent made minor or ministerial errors on required reports, which did not materially impact the public interest. Upon notification of these errors, the Respondent timely amended reports, making the necessary technical corrections.

PDC staff reminded Lisa Thomas about the importance of timely filing an F-1 report within two weeks of declaring candidacy, and timely and accurately reporting contributions & expenditures, including in-kind contributions and in-kind loans.

Based on the information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/54966
54934 07/18/2019 Michael Eckart Nicola Smith Nicola Smith: Alleged violation of RCW 42.17A.555 by allowing the use of public facilities to assist an election campaign. (EY '19) (Jul '19) RCW 42.17A.555 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) completed its review of the complaint Michael Eckart filed on July 15, 2019. The complaint alleged that Mayor Nicola Smith (the “Respondent”) may have violated RCW 42.17A.555 by allowing the use of public facilities (the City of Lynnwood website) to assist an election campaign. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response(s) provided by Respondent, and additional evidence provided by Lynnwood Forward to determine whether the record supports a finding of one or more violations. 

Based on these findings, staff has determined that, in this instance, the unauthorized linking of the Respondent’s name to the city’s website does not amount to a violation warranting further investigation.

Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/54934
54918 07/18/2019 Glen Morgan Erinn Howell Howell, Erinn: Alleged violations of RCW 42.17A.205, .700 & .235 for failure to register as a candidate & file financial affairs statement within 2 weeks of declaring candidacy & timely report contributions & expenditures. (EY '19) (Jul '19) RCW 42.17A.205, RCW 42.17A.235, RCW 42.17A.700 Resolved through Statement of Understanding
  • Allegation One: Alleged violation of RCW 42.17A.205 for failure to register as a candidate with PDC within two weeks of declaring candidacy.  
  • Allegation Two:  Alleged violation of RCW 42.17A.700 for failure to file a statement of financial affairs with PDC within two weeks of declaring candidacy.  
  • Allegation Three:  Alleged violation of RCW 42.17A.235 for failure to timely report contributions & expenditures.
https://www.pdc.wa.gov/browse/cases/54918
54873 07/17/2019 Marylou Eckart, Charles Eakins, Glen Morgan Lynnwood Forward PAC Lynnwood Forward: Alleged violations of RCW 42.17A.205, .235, .240, .255 & .320 for failure to register as a political committee, report contributions & expenditures, disclose independent expenditures or electioneering communication, and identify sponsor RCW 42.17A.205, RCW 42.17A.320, RCW 42.17A.240, RCW 42.17A.255, RCW 42.17A.235 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) completed its review of the complaints Marylou Eckart, Charles Eakins and Glen Morgan filed July 11, 2019 through July 16, 2019. The complaints alleged that Lynnwood Forward (the “Respondent”) may have violated RCW 42.17A.205, .235, .240, .255 and .320 for failure to register as a political committee, report contributions & expenditures, disclose independent expenditures or electioneering communications, and identify the sponsor on political advertising (e.g. Lynnwood Forward website).

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the response provided by the Respondent to determine whether the record supports a finding of one or more violations. 

Based on the findings, staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.

Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/54873
54867 07/17/2019 Sean McGee Patrick Guettner Guettner, Patrick: Alleged violations of RCW 42.17A.205 for failure to timely register as a candidate, and RCW 42.17A.700 for failure to timely disclose personal financial affairs (EY 19; July 19) RCW 42.17A.700, RCW 42.17A.205 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Sean McGee on July 15, 2019. The complaint alleged that Patrick Guettner (Respondent), a 2019 candidate for Pasco City Council may have violated RCW 42.17A.205 for failure to timely file a Candidate Registration (C-1 report), and .700 for failure to timely file a Personal Financial Affairs Statement (F-1 report), both due within two weeks of declaring candidacy, or not later than June 3, 2019.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the applicable PDC reports filed by the Respondent, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to timely file the C-1 and F-1 reports do not amount to violations that warrant further investigation.

PDC staff is reminding Patrick Guettner about the importance of timely registering as a candidate in an election campaign, and timely disclosing financial affairs for twelve calendar months prior to declaring candidacy. PDC staff expects the timely filing of all future reports as required by statute and rule.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/54867
54865 07/17/2019 Glen Morgan 37th LD Democrats 37th Legislative District Democratic Central Committee: alleged violation of RCW 42.17A.220 for accepting anonymous contributions in excess of the allowable limit without forfeiting the excess amount to the State of Washington. RCW 42.17A.220 Case Closed with Reminder

The complaint alleged that the 37th Legislative District Democratic Central Committee (Committee) may have violated RCW 42.17A.220 for accepting anonymous contributions in excess of the allowable limit without forfeiting the excess amount to the State of Washington.

The complaint alleged that in calendar year 2018, the Committee accepted anonymous contributions in the amount of $658.51 which was $358.51 more than the allowable limit of $300. In response to this allegation, the Committee reported a November 27, 2017 expenditure to the State of Washington for $358.51 for Contribution to the General Fund per RCW 42.17A.220(4).

In issuing its findings in PDC Case 26340, PDC staff inadvertently left off wording regarding a reminder concerning the Committee’s failure to comply with the anonymous contributions limit. PDC staff is reminding he 37th Legislative District Democrats about the importance of compliance with the anonymous contributions limit and rules. Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/54865
54863 07/17/2019 Glen Morgan Washington State Democratic Party Committee Washington State Democratic Central Committee (5): Alleged violations of RCW 42.17A.220 for accepting and retaining over-limit anonymous contributions (EY 16; Jul 19) RCW 42.17A.220 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on July 17, 2019. Your complaint alleged that the Washington State Democratic Central Committee (WSDCC), a statewide bona fide committee, may have violated RCW 42.17A.220(4) for accepting over limit anonymous contributions during calendar year 2016.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Laura Ewan, an attorney with Schwerin, Campbell, Barnard, Iglitzin & Lavitt, LLP on behalf of WSDCC; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Staff’s review of the Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports) filed by WSDCC found the committee could accept the greater amount of up to 1 percent of the total accumulated contributions.

Based on these findings, staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/54863
54861 07/17/2019 Glen Morgan Citizens for Sequim Schools Bond 4 Citizens for Sequim Schools Bond 4: Alleged violations of RCW 42.17A.220 for over-limit anonymous contributions and failure to timely deposit; and .235 for failure to timely report contributions and expenditures. (EY 16 Jul 19) RCW 42.17A.235, RCW 42.17A.220 Resolved through Statement of Understanding

The complaint alleged the Citizens for Sequim Schools, a 2016 committee formed to support a February 9, 2016 Sequim School District Bond election, may have violated: RCW 42.17A.235 for failure to timely and accurately file Monetary Contribution (C-3) reports and Summary Full Campaign Contribution and Expenditure (C-4) reports disclosing contributions and expenditures undertaken by the Committee; RCW 42.17A.220(1) by failing to timely deposit contributions received on C-3 reports within five business days of receipt; and RCW 42.17A.220(4) for accepting over limit anonymous contributions.

The Citizens for Sequim Schools completed a Statement of Understanding (SOU) and paid a $150 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), acknowledging violations of RCW 42.17A.235 for failing to timely file the C-4 reports in 2016. The $150 penalty assessed in this matter resolves the allegations listed in your complaint. PDC staff is also reminding the Committee about the importance of timely and accurately reporting anonymous contributions.

Based on the above findings and the SOU, staff has determined that, in this instance, this matter does not warrant further investigation. The PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/54861
54859 07/17/2019 Andrew Saturn Linda Oosterman Oosterman, Linda (9): Alleged violation of RCW 42.17A.555 by using public facilities to assist an election campaign. (EY '18 ) (Jul '19) RCW 42.17A.555 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) completed its review of the complaint filed July 13, 2019 alleging Linda Oosterman violated RCW 42.17A.555 by using agency facilities to assist her 2018 campaign for Thurston County Public Utilities District Commissioner, specifically using official photos and video from a training event on her campaign Facebook page. 

In response to the complaint, Oosterman stated the photos and video were taken and posted to her Facebook page with her personal cell phone, not with public-agency owned equipment or facilities.  

Based on these findings staff has determined, in this instance, the alleged use of public facilities does not amount to a violation warranting further investigation. The PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).  

https://www.pdc.wa.gov/browse/cases/54859
54858 07/17/2019 Glen Morgan Citizens for Ridgefield Schools Citizens for Ridgefield Schools: Alleged violations of RCW 42.17A.220 for accepting and retaining over-limit anonymous contributions (EY 16; Jul 19) RCW 42.17A.220 Case Closed with Reminder

On July 17, 2019, the Public Disclosure Commission (PDC) received a complaint alleging that the Citizens for Ridgefield Schools, may have violated RCW 42.17A.220(4) for accepting over the limit anonymous contributions. 

PDC staff reviewed the complaint/allegation and determined that the Citizens for Ridgefield Schools could accept the greater amount of up to 1% of the total accumulated contributions.  

In it's response, the Citizens for Ridgefield Schools stated..."The larger sum deposited as anonymous appears to be from our January auction and fundraiser that year. A series of of auction item purchases and mostly paddle raises that were paid for with cash that was lumped together, but not deposited as individual donations."

On September 30, 2019, the PDC received all the amendments with all the deposits correctly attributed showing the Citizen for Ridgefield Schools accepted only $81 in true anonymous funds, which is below the statutory threshold of $300. 

Based on the above, the PDC found no evidence to support a finding of a violation warranting further investigation. However, the PDC staff reminded the Citizens for Ridgefield Schools about the importance of filing accurate C-3 and C-4 reports in the future to reflect the actual/true source of contributions received by the committee. 

Accordingly, the PDC dismissed this matter in accordance with RCW 42.17A.755(1). 

 

https://www.pdc.wa.gov/browse/cases/54858
54857 07/17/2019 Glen Morgan Jay Inslee Inslee, Jay (3): Alleged violations of RCW 42.17A.220 for accepting and retaining over-limit anonymous contributions (EY 16; Jul 19) RCW 42.17A.220 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on July 17, 2019. Your complaint alleged that Jay Inslee, incumbent Governor and candidate for re-election in 2016, may have violated RCW 42.17A.220(4) for accepting over limit anonymous contributions.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution database, to determine whether the record supports a finding of one or more violations.

Staff’s review of the Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports) filed by Jay Inslee for Washington found the campaign could accept the greater amount of up to 1 percent of the total accumulated contributions.

Based on these findings, staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/54857
54856 07/17/2019 Andrew Saturn Linda Oosterman Oosterman, Linda (8): Alleged violations of RCW 42.17A.235 & .240 by failing to timely & accurately report in-kind contributions, expenditures & proceeds from Champagne Brunch. (EY '18) (Jul '19) RCW 42.17A.240, RCW 42.17A.235 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) completed its review of the complaint Andrew Saturn filed on July 13, 2019. The complaint alleged that Linda Oosterman (the “Respondent”) may have violated RCW 42.17A.235 & .240 by not timely & accurately reporting in-kind contributions, expenditures & proceeds from a Champagne Brunch held in 2018. Specifically, the complaint alleged that the Respondent failed to 1) report fundraising income (contributions) from the event; 2) report expenditures for the venue and banquet permit; and 3) adequately describe the brunch expenditures reported on the campaign’s August and October, 2018 C-4 reports.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; and the applicable PDC reports filed by Respondent to determine whether the record supports a finding of one or more violations. 

Based on the findings, staff determined that, in this instance, no evidence supports a finding of a violation warranting further investigation. 

Based on the information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/54856
54855 07/17/2019 Glen Morgan Don Orange Orange, Don: Violations of RCW 42.17A.220 for accepting and retaining over-limit anonymous contributions (EY 17; July 17) RCW 42.17A.220 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Glen Morgan on July 17, 2019. The complaint alleged that Don Orange (Respondent), a 2017 candidate for Vancouver Port Commissioner may have violated RCW 42.17A.220(4) for accepting over limit anonymous contributions.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on these findings, staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/54855
54852 07/17/2019 Glen Morgan Kshama Sawant Sawant, Kshama (2): Alleged violations of RCW 42.17A.220 for accepting and retaining over-limit anonymous contributions (EY 19; Jul 19) RCW 42.17A.220 Case Closed with No Evidence of Violations

On July 17, 2019, the Public Disclosure Commission (PDC) received a complaint alleging that Kshama Sawant (respondent), a candidate for City Council Member for the City of Seattle in 2019, may have violated RCW 42.17A.220(4) for accepting over the limit anonymous contributions. 

The complaint alleged that in calendar year 2019, the respondent accepted anonymous contributions in the amount of $408.54, which was $108.54 more than the allowable limit of $300. PDC staff reviewed the complaint and determined that the respondent could accept the greater amount of up to 1% of the total accumulated contributions. 

Based on these findings, staff determined that no evidence supported a finding of a violation warranting further investigation. 

Accordingly, staff dismissed the complaint in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/54852
54849 07/17/2019 Andrew Saturn Linda Oosterman Oosterman, Linda (7): Alleged violations of Chapter 42.17A RCW and WAC 390-32, the Fair Campaign Practices Code (EY 18; July 18) WAC 390-32-010 Resolved through Complaint Publication Process

On July 15, 2019, the Public Disclosure Commission (PDC) received a complaint from Andrew Saturn, alleging a violation of one or more specific provisions of WAC 390-32-010, the Fair Campaign Practices Code (FCPC).  The complaint concerned Linda Oosterman, a 2018 candidate for Thurston County Public Utility Commissioner.

The Campaign Fair Practices Code requires the PDC to forward the complaint to the party alleged to have violated the FCPC, request a response within five days, and then send the complaint and the response, if one is received, to news media.  Linda Oosterman supplied a response to the complaint's allegations on July 24, 2019. WAC 390-32-030 prevents the Commission and staff from commenting on the complaint or the response. 

On July 25, 2019, a copy of the complaint and response were sent to news media.

https://www.pdc.wa.gov/browse/cases/54849
54841 07/17/2019 Glen Morgan Whatcom County Democratic Central Commitee Whatcom County Democratic Central Committee (2): Alleged violations of RCW 42.17A.220 for accepting and retaining over-limit contributions (EY 18; Jul 19) RCW 42.17A.220 Case Closed with No Evidence of Violations

The complaint alleged the Whatcom County Democratic Central Committee, may have violated RCW 42.17A.220(4) for accepting over limit anonymous contributions. 

PDC  staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation. Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1). 
 

https://www.pdc.wa.gov/browse/cases/54841
54840 07/17/2019 Glen Morgan Washington Association of Nurse Anesthetists PAC (WANA PAC) Washington Association of Nurse Anesthetists PAC (WANA PAC): Alleged violations of RCW 42.17A.220 for accepting and retaining over-limit anonymous contributions (EY 19; Jul 19) RCW 42.17A.220 Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on July 17, 2019. Your complaint alleged that Washington Association of Nurse Anesthetists PAC (“WANA PAC” or “Respondent”), a Continuing Political Committee, may have violated RCW 42.17A.220(4) for accepting over limit anonymous contributions during calendar year 2016, 2017, 2018 and 2019.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response(s) provided by Joanna Starratt, Treasurer; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

It appears that WANA PAC held a small number of fundraising events each calendar year from 2016 to 2019 and that the committee treasurer, other officers and volunteers involved in planning the events and recording receipt of the proceeds, misunderstood the distinction between proceeds from a qualifying low-cost fundraiser described in RCW 42.17A.230 and unidentified or “anonymous” contributions and their restrictions described in RCW 42.17A.220.

In addition, WANA PAC has no previous violations of RCW 42.17A and has stated its intent to change the committee’s fundraising activities in order to ensure compliance in the future.

Based on these findings staff has determined that, in this instance, failure to accurately identify proceeds from low-cost fundraisers separate from contributions received from anonymous sources, and based on the committee escheating all funds that could not be identified as required by RCW 42.17A, does not amount to a finding of a violation warranting further investigation.

Pursuant to WAC 390-37-060(1)(d), WANA PAC will receive a formal written warning concerning the statutory restrictions on the receipt of funds from unidentified sources and the importance of the accurate disclosure of all contribution received, specifically funds that are not itemized including anonymous funds, small contributions of $25 or less and proceeds from low-cost fundraisers. The formal written warning will include staff’s expectation that WANA PAC track all small donations in a manner that will ensure accurate and timely disclosure for all future required reports of contributions and expenditures. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/54840
54839 07/17/2019 Glen Morgan My-Linh Thai Thai, My-Linh (2): Alleged violations of RCW 42.17A.220 for accepting and retaining over-limit anonymous contributions (EY 18; July 19) RCW 42.17A.220 Case Closed with No Evidence of Violations

On July 16, 2019, the Public Disclosure Commission (PDC) received a complaint alleging that My-Linh Thai violated RCW 42.17A.220(4) for accepting over the limit anonymous contributions.  

PDC staff reviewed the complaint/allegation and determined that Ms. Thai's campaign could accept the greater amount of up to 1% of the total accumulated contributions. 

Based on this review, staff determined that, in this instance, no evidence supports a finding of a violation warranting further investigation. 

Accordingly, the PDC dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/54839
54838 07/17/2019 Glen Morgan Jennifer Tyler Tyler, Jennifer (2): Alleged violations of RCW 42.17A.220 for accepting and retaining over-limit anonymous contributions (EY 18; Jul 18) RCW 42.17A.220 Investigation of Possible Violation

After conducting a preliminary review and assessment of a complaint filed July 16, 2019 concerning the Tyler for Sheriff Campaign, PDC staff opened a formal investigation and held a case status review, referred to as an initial hearing, on October 7, 2019, pursuant to RCW 42.17A.755, and WACs 390-37-060 and 390-37-071.

The complaint alleges the Tyler for Sheriff Campaign may have violated RCW 42.17A.220 for accepting and retaining anonymous contributions exceeding the limit of 1 percent of total contributions received in the calendar year, or $300, whichever is more.

https://www.pdc.wa.gov/browse/cases/54838
54830 07/17/2019 Glen Morgan Matthew Stroe Stroe, Matthew: Alleged violations of RCW 42.17A.220 for accepting and retaining over-limit anonymous contributions (EY 18; July 19) RCW 42.17A.220 Case Closed with Written Warning

The complaint alleged Matthew Stroe, a 2018 candidate for Walla Walla County Sheriff, may have violated RCW 42.17A.220(4) by accepting anonymous contributions in excess of the allowable limit without forfeiting the excess amount to the State of Washington. 

In response, the Committee stated there was initial confusion regarding $950 in contributions and amended C-4 and C-3 reports. 

Staff has determined that in this instance, accepting and retaining over-limit anonymous contributions during the 2018 election year, does not amount to a material violation warranting further investigation.

However, pursuant to WAC 390-37-060(1)(d), Matthew Stroe will receive a formal written warning concerning the Committee’s failure to comply with PDC requirements. The formal written warning will include staff’s expectation Stroe comply with the anonymous contributions limit and rules should he be a future candidate for elective office. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/54830
54827 07/17/2019 Glen Morgan Dan Satterberg Satterberg, Dan: Alleged violations of RCW 42.17A.220 for accepting and retaining over-limit anonymous contributions (EY 18; July 19) RCW 42.17A.220 Case Closed with Reminder

On July 16, 2019, the Public Disclosure Commission (PDC) received a complaint from Glen Morgan alleging that Daniel Satterberg (Respondent), an incumbent King County Prosecuting Attorney and a candidate seeking re-election to that office in 2018, may have violated RCW 42.17A.220(4) for accepting over limit anonymous contributions. 

PDC staff reviewed the Monetary Contribution reports (C-3 reports) and the Summary Full Campaign Contribution and Expenditure reports (C-4 reports) filed by the Respondent and determined  that his campaign could only accept $758.82 of the total $1,223 in anonymous contribution received by his campaign.

On September 9, 2019, the PDC received a check in the amount of $464.18 from the Respondent for exceeding the anonymous contribution limits, that was forwarded to the Department of Enterprise Services, for deposit into the General Fund in accordance with the statutory scheme. 

Based on this information, the PDC dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/54827
54826 07/17/2019 Glen Morgan Charlie McCaughan McCaughan, Charlie: Alleged violations of RCW 42.17A.205 and .235 for failure to register as a candidate, and report contributions and expenditures (EY 19; July 19) RCW 42.17A.235, RCW 42.17A.205 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Glen Morgan on July 15, 2019. The complaint alleged that Charlie McCaughan (Respondent), a 2019 candidate for Pasco City Council may have violated RCW 42.17A.205 for failure to timely file a Candidate Registration (C-1 report); and RCW 42.17A.235 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the applicable PDC reports filed by the Respondent, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to timely file the C-1 report does not amount to a violation that warrants further investigation.

PDC staff is reminding Charlie McCaughan about the importance of timely registering as a candidate in an election campaign. PDC staff expects the timely filing of all future reports as required by statute and rule.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/54826
54823 07/17/2019 Glen Morgan Artur Wojnowski Wojnowski, Artur: Alleged violations of RCW 42.17A.205, .235, and .700 for failure to timely register as a candidate and report contributions, expenditures, and financial affairs (EY 19; July 19) RCW 42.17A.235, RCW 42.17A.700, RCW 42.17A.205 Violation Found by Commission
  • Allegation One: Violation of RCW 42.17A.205 for failure to file a Candidate Registration (C-1 report)
  • Allegation Two: Violation of RCW 42.17A.235 for failure to report contributions and expenditures (C-3 and C-4 reports)
  • Allegation Three: Violation of RCW 42.17A.700 for failure to timely file Personal Financial Affairs Statement (F-1 report)
https://www.pdc.wa.gov/browse/cases/54823
54818 07/17/2019 Freedom Foundation (Maxford Nelsen) Intermech, Inc. Intermech, Inc. (3): Alleged violations of RCW 42.17A.495 and WAC 390-17-100 by failing to obtain written authorization from employees before deducting wages or salaries for political contributions (July 19) RCW 42.17A.495, WAC 390-17-100 Investigation of Possible Violation
  • Allegation: Violations of RCW 42.17A.495 & WAC 390-17-100 by failing to obtain written authorization from employees before deducting wages or salaries for political contributions 
https://www.pdc.wa.gov/browse/cases/54818
54751 07/16/2019 Michele Levenite Radona Devereaux Devereaux, Radona: Alleged violations of RCW 42.17A.235 and .700 for failure to timely report contributions, expenditures, and financial affairs (EY 19; July 19) RCW 42.17A.235, RCW 42.17A.700 Violation Found by Commission

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Michele Levenite on July 9, 2019. The complaint alleged that Radona (Liz) Devereaux (Respondent) may have violated RCW 42.17A.235 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign; and RCW 42.17A.700 for failure to time file a Personal Financial Affairs Statement (F-1 report), certifying financial activities for twelve calendar months prior to becoming a candidate.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the applicable PDC reports filed by the Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Pursuant to the brief enforcement hearing (brief adjudicative proceeding) notice sent to Radona (Liz) Devereaux on August 6, 2019, A brief adjudicative proceeding was held on August 20, 2019, in Room 206, Evergreen Plaza Building, 711 Capitol Way, Olympia, Washington, to consider whether the Respondent violated RCW 42.17A.700 by failing to file a Personal Statement of Financial Affairs (F-1 report) as a candidate for the 2019 election cycle, disclosing campaign information and financial activities for the previous 12 calendar months. The F-1 report was due to be filed within two weeks of declaring candidacy, or not later than May 27, 2019,  

The hearing was held in accordance with Chapters 34.05 RCW and 42.17A RCW and Chapter 390-37 WAC.  Commission Vice-Chair David Ammons was the Presiding Officer.  The Commission staff was represented by Tabatha Blacksmith, Compliance Coordinator.  The Respondent did not participate in the hearing or submit any written materials. 

Having considered the evidence, the Presiding Officer finds as follows: 
 

CONCLUSIONS OF LAW

  1. This matter was duly and properly convened and all jurisdictional, substantive, and procedural requirements have been satisfied.
  2. The Respondent violated RCW 42.17A.700 by failing to file the F-1 report within two weeks of declaring candidacy, or not later than May 27, 2019.

ORDER

IT IS HEREBY ORDERED that the Respondent is assessed a civil penalty of $250, in accordance with the F-1 penalty schedule set forth in WAC 390-37-143, payable within 30 days of the date of the Order. 

In the event the Respondent fails to pay the $250 civil penalty within 30 days of the date of the Order, PDC staff is directed to refer the matter to the Department of Enterprise Services (DES) for collection of the amount owed. 

 

WARNING

Based on our findings staff has determined that, in this instance, failure to report contributions and expenditures does not amount to a violation that warrants further investigation.

Pursuant to WAC 390-37-060(1)(d), Radona (Liz) Devereaux will receive a formal written warning concerning your failure to report contributions and expenditures as required of a candidate running for election to public office. The formal written warning will include staff’s expectation that Radona (Liz) Devereaux timely files all future required reports of contributions and expenditures. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/54751
54746 07/16/2019 Freedom Foundation (Maxford Nelsen) Apollo Mechanical Contractors Apollo Mechanical Contractors (3): Alleged violations of RCW 42.17A.495 and WAC 390-17-100 by failing to obtain written authorization from employees before deducting wages or salaries for political contributions (July 19) WAC 390-17-100, RCW 42.17A.495 Investigation of Possible Violation

Allegation: Violations of RCW 42.17A.495 & WAC 390-17-100 by failing to obtain written authorization from employees before deducting wages or salaries for political contributions

https://www.pdc.wa.gov/browse/cases/54746
54633 07/15/2019 Omaha Sternberg Lucy Krakowiak Krakowiak, Lucy: Alleged Violation of RCW 42.17A.205 for failure to timely file Candidate Registration (C-1 report). RCW 24.17A.205 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Omaha Sternberg on July 2, 2019. The complaint alleged that Lucy Krakowiak (Respondent), a 2019 candidate for Burien City Council may have violated RCW 42.17A.205 for failure to file a Candidate Registration (C-1 report) within two weeks of becoming a candidate; RCW 42.17A.235 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign; and RCW 42.17A.700 for failure to timely file a Personal Financial Affairs Statement (F-1 report), certifying financial activities in calendar year 2018, no later than April 15, 2019.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to timely register as a candidate does not amount to a violation that warrants further investigation.

PDC staff is reminding Lucy Krakowiak about the importance of timely registering as a candidate. PDC staff expects the timely, complete, and accurate of all future required reports in accordance with the statutes and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/54633
54487 07/12/2019 Michael Fertakis Larry Gossett Gossett, Larry: Alleged violation of RCW 42.17A.555 by using public facilities to assist an election campaign. (EY '19) (Jul '19) RCW 42.17A.555 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on July 10, 2019. Your complaint alleged that Larry Gossett, incumbent King County Councilmember and candidate in the 2019 election, may have violated RCW 42.17A.555 by using a photograph taken outside of an open public meeting held by the King County Council on his re-election Facebook page and by authorizing Council Chief of Staff, Cindy Domingo, to post the photo on his behalf.

PDC staff reviewed the allegations; the applicable statutes and rules; PDC Interpretation 04-02; and the response provided by Councilman Gossett, to determine whether the record supports a finding of one or more violations.

Based on these findings staff has determined that no evidence supports a finding of a violation warranting further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/54487
54348 07/11/2019 William Miano James Barnfather Barnfather, James: Alleged violation of RCW 42.17A.205 & .235 for failure to timely register as a candidate within two weeks of declaring candidacy & timely report contributions & expenditures. (EY '19) (Jul '19) RCW 42.17A.205, RCW 42.17A.235 Case Closed with Reminder

The Public Disclosure Commission (PDC) completed its review of the complaint William Miano filed on July 10, 2019. The complaint alleged that James Barnfather (the “Respondent”) may have violated RCW 42.17A.205 & .235 by failing to timely register as a candidate within two weeks of declaring candidacy & timely report contributions & expenditures.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; and the applicable PDC reports filed by Respondent to determine whether they support a finding of one or more violations. 

Based on the findings, staff determined that, in this instance, failure to timely file the Candidate Registration (C-1 report) does not amount a violation warranting further investigation.

PDC staff reminded James Barnfather about the importance of timely filing all future PDC reports, including the candidate registration.

Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/54348
54324 07/10/2019 Freedom Foundation (Maxford Nelsen) JH Kelly, LLC JH Kelly, LLC (3): Alleged violations of RCW 42.17A.495 & WAC 390-17-100 by failing to obtain written authorization from employees before deducting wages or salaries for political contributions. (EY '19) (Jul '19) WAC 390-17-100, RCW 42.17A.495 Investigation of Possible Violation
  • Alleged violations of RCW 42.17A.495 & WAC 390-17-100 by failing to obtain written authorization from employees before deducting wages or salaries for political contributions
https://www.pdc.wa.gov/browse/cases/54324
54177 07/08/2019 CLAUD WILHITE ROBERT SAMSON Samson, Robert: Alleged Violation of RCW 42.17A.335 for political advertising that contains false statements about a candidate constituting libel or defamation. Case Closed with Reminder

The Public Disclosure Commission (PDC) completed its review of the complaint filed against Robert Joseph "Rocky" Samson III, a 2019 candidate for City of Spokane Valley City Council Member Pos. 2. The complaint alleged Samson violated RCW 42.17A.335 for political advertising that contains false statements about a candidate constituting libel or defamation. 

Staff has determined, in this instance, the alleged violation of political advertising that contains false statements about a candidate constituting libel or defamation, does not amount to a violation warranting further investigation. 

PDC staff is reminding Robert Joseph "Rocky" Samson III to list the complete sponsor identification on all political advertising in accordance with PDC laws and rules should he be a future candidate for elective office. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).     

https://www.pdc.wa.gov/browse/cases/54177
54170 07/08/2019 Dori Gilmour & Michele Levenite Wendi Warner Wendi Warner: Alleged Violation of RCW 42.17A.205 for failure to timely file the Candidate Registration (C-1 report) RCW 42.17A.700, RCW 42.17A.205, RCW 42.17A.235 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaints filed by Dori Gilmour and Michele Levenite on June 12 and July 8, 2019. The complaints alleged that Wendi Warner (Respondent), a 2019 candidate for Richland City Council may have violated RCW 42.17A.205 for failure to timely file a Candidate Registration (C-1 report) within two weeks of becoming a candidate; RCW 42.17A.235 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign; and RCW 42.17A.700 for failure to file a Personal Financial Affairs Statement (F-1 report) within two weeks of becoming a candidate.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the responses provided by Wendi Warner; the applicable PDC reports filed by the Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to accurately select the candidate’s election year, and to timely file the F-1 report, do not amount to violations that warrant further investigation.

PDC staff is reminding Wendi Warner about the importance of timely and accurately registering as a candidate, and disclosing personal financial affairs. PDC staff expects timely, complete, and accurate filings of all future required reports in accordance with the statutes and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/54170
54145 07/08/2019 Freedom Foundation (Maxford Nelsen) American Federation of State, County and Municipal Employees Special Account American Federation of State, County and Municipal Employees Special Account: Alleged violations of Chapter 42.17A RCW for failure to accurately and completely report as an out-of-state political committee, and to report independent expenditures/electioneering communications (July 19) RCW 42.17A.305, RCW 42.17A.260, RCW 42.17A.255, RCW 42.17A.250 Violation Found by Commission

A complaint was filed against American Federation of State, County and Municipal Employees Special Account (AFSCME) alleging violations of: (1) RCW 42.17A.250 for failing to timely and accurately file reports disclosing contributions and expenditures as an out-of-state political committee on the C-5 reports; and (2) RCW 42.17A.255, .260, and .305 for failure to timely, accurately, and completely report independent expenditures and/or electioneering communications.

On September 26, 2019, an Enforcement Hearing will be held before the Commission concerning allegations that AFSCME violated RCW 42.17A.250 by: (1) failing to timely file Out-of-State Committee Contribution Reports (C-5 reports) disclosing $250,000 in monetary contributions made to three political committees in Washington State during calendar years 2015 and 2016; and (2) failing to timely file C-5 reports disclosing contributions received from AFSCME International into AFSCME’s segregated account covering the period October 1, 2014 through August 31, 2018.

A Stipulation to Facts, Violations and Penalties has been agreed to between the two parties, was presented and accepted by the Commission at the hearing finding AFSCME, AFL-CIO violated: 

  1. RCW 42.17A.250 by failing to timely file Out-of-State Committee Contribution Reports (C-5 reports) disclosing $250,000 in monetary contributions made to three political committees in Washington State during calendar years 2015 and 2016.
  2. RCW 42.17A.250 by failing to timely file C-5 reports disclosing contributions received from AFSCME International into AFSCME’s segregated account covering the period October 1, 2014 through August 31, 2018.

AFSCME, AFL-CIO agreed to pay a total civil penalty of $5,250, representing $750 for each late filed C-5 report in accordance with the Stipulation Penalty Schedule found in WAC 390-37-062, of which $2,000 of the penalty is suspended on the conditions AFSCME AFL-CIO: 

(1) Is not found to have committed any further violations of RCW 42.17A or WAC 390 within four years of the date of the final order in this matter.  The suspended penalty shall not be assessed based solely upon any remediable violation, minor violation, or error classified by the Commission as appropriate to address by a technical correction; 

(2) Is in compliance with all reporting requirements; and 

(3) The non-suspended portion of the penalty ($3,250) is paid by AFSCME within 30 days of the date of the final order in this matter.

 

https://www.pdc.wa.gov/browse/cases/54145
53838 06/28/2019 Andrew Saturn Linda Oosterman Oosterman, Linda (6): Alleged violation of RCW 42.17A.555 by using public office or agency facilities to assist an election campaign. (EY 2018) (Jun 2019) RCW 42.17A 555 Case Closed with Written Warning

The Public Disclosure Commission (PDC) completed its review of the complaint Andrew Saturn filed on June 21, 2019. The complaint alleged that Linda Oosterman may have violated RCW 42.17A.555 by using public office/agency facilities to assist an election campaign in 2018. Specifically, the complaint alleged that the Thurston County Public Utility District (PUD) paid for Linda Oosterman to attend four Chamber of Commerce events in 2018, thereby potentially violating .555.

In the original complaint, Andrew Saturn alleged that the PUD’s general manager, John Weidenfeller, and the Thurston County PUD also violated RCW 42.17A.555 by authorizing the use of public office/agency facilities to assist the Linda Oosterman’s election campaign. Therefore:

  • A separate case was opened to address the allegation made against John Weidenfeller (PDC Case 55699). 
  • RCW 42.17A.555 prohibits specific types of individuals – namely elected or appointed officials and public agency or office employees – from engaging in certain activities. Whereas Thurston County PUD is not an individual, it cannot violate .555. Therefore, the allegation against Thurston County PUD was dismissed.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response(s) provided by Linda Oosterman (the “Respondent”); and the applicable PDC reports filed by Respondent to determine whether the record supports a finding of one or more violations. 

Based on the findings, staff determined that, in this instance, the Respondent’s use of public office/agency funds to pay for event that could directly or indirectly assist her election campaign does not amount to a violation warranting further investigation. 

Pursuant to WAC 390-37-060(1)(d), Linda Oosterman receives a formal written warning regarding the use of public office/agency facilities to assist an election campaign. The formal written warning included staff’s expectation that Linda Oosterman not use public office/agency facilities to pay for political, election-related events. The Commission may consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Based on the information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/53838
53596 06/24/2019 Sheri Connor Julieta Altamirano-Crosby Altamirano-Crosby, Julieta: Alleged violation of RCW 42.17A.235 for failure to timely report contributions & expenditures. (EY '19) (Jun '19) RCW 42.17A.235 Case Closed with Reminder

The Public Disclosure Commission (PDC) completed its review of the complaint Sheri Conner filed on June 23, 2019. The complaint alleged that Julieta Altamirano-Crosby (the “Respondent”) may have violated RCW 42.17A.235 by failing to timely report contributions and expenditures during election year 2019.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; and the applicable PDC reports filed by Respondent to determine whether they support a finding of one or more violations. 

Based on the findings, staff determined that, in this instance, failure to timely report contributions and expenditures does not amount to a violation warranting further investigation.

PDC staff reminded Julieta Altamirano-Crosby about the importance of timely and accurately disclosing all contribution and expenditure activities, including the filing fee, and the timely filing of all future PDC reports. 

Based on the information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/53596
53590 06/24/2019 Sheri Connor Maggie Mae Mae, Maggie: Alleged violations of RCW 42.17A.205, .700 & .235 for failure to register as a candidate & file financial affairs statement within 2 weeks of declaring candidacy & timely report contributions & expenditures. (EY '19) (Jun '19) RCW 42.17A.205, RCW 42.17A.700, RCW 42.17A.235 Case Closed with Reminder

The Public Disclosure Commission (PDC) completed its review of the complaint Sheri Connor filed on June 23, 2019. Your complaint alleged that Maggie Mae (the “Respondent”) may have violated RCW 42.17A.205, .700 & .235 by failing to register as a candidate and file a financial affairs statement within two weeks of declaring candidacy and timely report contributions & expenditures. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements: the response provided by the Respondent; and the applicable PDC reports filed by Respondent to determine whether they support a finding of one or more violations. 

Based on these findings, staff determined that, in this instance, failure to timely file the Candidate Registration (C-1) and Personal Statement of Financial Affairs (F-1) reports does not amount to a violation warranting further investigation.

PDC staff reminded Maggie Mae about the importance of the timely filing all future PDC reports, including the candidate registration and financial affairs statement. 

Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/53590
53461 06/21/2019 Amanda Zimmerman Ramon Llanos Llanos, Ramon: Alleged violation of RCW 42.17A.205, .700 & .235 for failure to register as a candidate & file financial affairs statement within 2 weeks of declaring candidacy & timely report contributions & expenditures. (EY '19) (Jun '19) RCW 42.17A 700, RCW 42.17A.235, RCW 42.17A.205 Case Closed with Reminder

The Public Disclosure Commission (PDC) completed its review of the complaint Amanda Zimmerman filed on June 20, 2019. The complaint alleged that Ramon Llanos may have violated RCW 42.17A.205, .700 & .235 by failing to register as a candidate and file a financial affairs statement within two weeks of declaring candidacy and timely report contributions & expenditures. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Ramon Llanos (the "Respondent"); and the applicable PDC reports filed by Respondent to determine whether the record supports a finding of one or more violations. 

Based on the findings, staff determined that, in this instance, failure to timely file the Candidate Registration (C-1) and Personal Statement of Financial Affairs (F-1) reports does not amount to a violation warranting further investigation.

PDC staff reminded Ramon Llanos about the importance of the timely filing all future PDC reports, including the candidate registration and financial affairs statement. 

Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/53461
53456 06/21/2019 Elizabeth Hallock Soneya Lund Lund, Soneya (2): Alleged violations of RCW 42.17A.240 for failure to accurately and completely report expenditures and in-kind contributions, and .710 for failure to disclose board membership (EY 19; June 19) RCW 42.17A.710, RCW 42.17A.240 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Elizabeth Hallock on June 21, 2019. The complaint alleged that Soneya Lund (Respondent), a 2019 candidate for Yakima City Council, may have violated RCW 42.17A.240 for failure to accurately and completely disclose in-kind contributions and expenditures undertaken by the Campaign; and RCW 42.17A.710 for failure to disclose officership or directorship on the board of directors for Rod’s House, a non-profit organization, on the Personal Financial Affairs Statement (F-1 report).

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the responses provided by the Respondent; the applicable PDC reports filed by the Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to accurately and completely disclose an officership on a non-profit board of directors, and to accurately and completely disclose in-kind contributions, do not amount to violations that warrant further investigation.

PDC staff is reminding Soneya Lund about the importance of accurately and completely disclosing financial affairs and in-kind contributions. PDC staff expects the timely, accurate, and complete disclosure filing of future reports in accordance with statutes and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/53456
53454 06/21/2019 Glen Morgan One Washington Equality Campaign One Washington Equality Campaign: Alleged violations of RCW 42.17A.235, .240, and .255 for failure to report expenditures or in-kind contributions for legal services, and independent expenditures in support or opposition to ballot propositions (EY 19; June 19) RCW 42.17A.255, RCW 42.17A.240 Investigation of Possible Violation
  • Allegation One: Violations of RCW 42.17A.240 for failure to report expenditures or in-kind contributions for legal services in support of 2018 State Initiative 1000, and in opposition to 2019 State Referendum 88.
  • Allegation Two: Violations of RCW 42.17A.255 for failure to report independent expenditures for legal services in support of 2018 State Initiative 1000, and in opposition to 2019 State Referendum 88.
https://www.pdc.wa.gov/browse/cases/53454
53443 06/21/2019 Arthur David Churchman Shelly Schlumpf Schlumpf, Shelly: Alleged violation of RCW 42.17A.700 for failure to file statement of financial affairs (F-1 report) with the PDC within two weeks of candidacy. (EY 2019) (Jun '19) RCW 42.17A.700 Case Closed with Reminder

The Public Disclosure Commission (PDC) completed its review of the complaint Arthur David Churchman filed on June 20, 2019. The complaint alleged that Shelly Schlumpf (the “Respondent”) may have violated RCW 42.17A.700 by failing to timely file a Personal Statement of Financial Affairs (F-1 report) with the PDC within two weeks of candidacy.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; and the applicable PDC reports filed by Respondent to determine whether they support a finding of one or more violations. 

Based on the findings, staff determined that, in this instance, failure to timely file the F-1 report does not amount to a violation warranting further investigation.

PDC staff reminded Shelly Schlumpf about the importance of timely filing a financial affairs statement (F-1 report) and the timely filing of all future PDC reports.

Based on the information, the PDC found that no further action was warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/53443
53400 06/20/2019 Amanda Zimmerman, Mike Olson, and Bill Pate Daniel Sydney Hevenor Sydney Hevenor, Daniel: Alleged violations of RCW 42.17A.205, .235, and .700 for failure to register and report contributions, expenditures, and financial affairs as a candidate (EY 19; June 19) RCW 42.17A.205, RCW 42.17A.700, RCW 42.17A.235 Violation Found by Commission

The Public Disclosure Commission (PDC) has completed its review of the complaints filed by Amanda Zimmerman, Keith Olson, and Bill Pate on June 20, June 21, and July 17, 2019. The complaints alleged that Daniel Sydney Hevenor may have violated RCW 42.17A.205 for failure to file a Candidate Registration (C-1 report) within two weeks of becoming a candidate; RCW 42.17A.235 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign; and RCW 42.17A.700 for failure to file a Personal Financial Affairs Statement (F-1 report). 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Pursuant to the brief enforcement hearing (brief adjudicative proceeding) notice sent to Daniel Sydney Hevenor on August 6, 2019, A brief adjudicative proceeding was held on August 20, 2019, in Room 206, Evergreen Plaza Building, 711 Capitol Way, Olympia, Washington, to consider whether the Respondent violated RCW 42.17A.205 by failing to file a Candidate Registration (C-1 report) as a candidate for the 2019 election cycle, and RCW 42.17A.700 by failing to file a Personal Statement of Financial Affairs (F-1 report) as a candidate for the 2019 election cycle, disclosing campaign information and financial activities for the previous 12 calendar months. Both reports were due to be filed within two weeks of declaring candidacy, or not later than May 30, 2019,  

The hearing was held in accordance with Chapters 34.05 RCW and 42.17A RCW and Chapter 390-37 WAC.  Commission Vice-Chair David Ammons was the Presiding Officer.  The Commission staff was represented by Tabatha Blacksmith, Compliance Coordinator.  The Respondent did not participate in the hearing or submit any written materials. 

Having considered the evidence, the Presiding Officer finds as follows: 
 

CONCLUSIONS OF LAW

  1. This matter was duly and properly convened and all jurisdictional, substantive, and procedural requirements have been satisfied.
  2. The Respondent violated RCW 42.17A.205 and RCW 42.17A.700 by failing to file the C-1 and F-1 reports within two weeks of declaring candidacy or by May 30, 2019.

ORDER

  1. IT IS HEREBY ORDERED that the Respondent is assessed a civil penalty of $500, in accordance with the C-1 and F-1 penalty schedule set forth in WAC 390-37-143, payable within 30 days of the date of the Order. 

WARNING

Based on our findings staff has determined that, in this instance, failure to report contributions and expenditures do a violation that warrants further investigation.

Pursuant to WAC 390-37-060(1)(d), Daniel Sydney Hevenor will receive a formal written warning concerning your failure to report contributions and expenditures as required of a candidate running for public office. The formal written warning will include staff’s expectation that Daniel Sydney Hevenor timely files all future required reports of contributions and expenditures. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/53400
53381 06/20/2019 William White Dorel Singeorzan Singeorzan, Dorel: Alleged violation of RCW 42.17A.205 for failure to register as a candidate with PDC within two weeks of declaring candidacy. (EY 2019) (Jun ’19) RCW 42.17A.205 Case Closed with Reminder

The Public Disclosure Commission (PDC) completed its review of the complaint William White filed on June 19, 2019. The complaint alleged that Dorel Singeorzan (the “Respondent”) may have violated RCW 42.17A.205 by failing to register as a candidate with the PDC within two weeks of declaring candidacy.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements: the response provided by the Respondent; and the applicable PDC reports filed by Respondent to determine whether they support a finding of one or more violations. 

Based on these findings, staff has determined that, in this instance, failure to timely file the candidate registration (C-1 report) does not amount to a violation warranting further investigation.

PDC staff reminded Dorel Singeorzan about the importance of timely registering as a candidate and the timely filing of all future PDC reports, including the C-1 report.

Based on this information, the PDC found that no further action was warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/53381
53342 06/19/2019 Michelle Kaplan Patrick M. Shanahan Shanahan, Patrick: Alleged violations of RCW 42.17A.710 for failure to accurately and completely disclose personal financial affairs (June 19) RCW 42.17A.710 Case Closed with Written Warning

On June 13, 2019, the Public Disclosure Commission (PDC) received a complaint alleging the Patrick Shanahan (Respondent), a University of Washington Board of Regents trustee from January 17, 2012 to September 30, 2016, may have violated RCW 42.17A.710 by failing to accurately and completely disclose real property, creditors and intangible personal property on the Personal Statement of Financial Affairs (F-1 report) for the reporting  periods of calendar 2014, 2015 and 2016. 

PDC staff reviewed the F-1 forms filed by the respondent between April 2012 and May 2017 and determined that he did not disclose his residence and brokerage accounts. However, he has since amended his F-1 reports to reflect the disclosure of both his residence and brokerage accounts. 

Based on these findings, PDC staff determined that, in this instance, failure to accurately and completely disclose certain financial information and intangible personal property on the F-1 report by the respondent is a violation that warrants no further investigation. 

However, pursuant to WAC 390-37-060(1)(b), the respondent received a formal written warning concerning his failure to disclose his residence on the F-1 report covering calendar year 2014, and for failing to report a broker-managed stock account on the F-1 report covering calendar years 2014 and 2015. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules. 

Based on this information, the PDC found no further action and dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/53342
53323 06/18/2019 Glen Morgan Debbie Bertlin Bertlin, Debbie: Alleged violations of RCW 42.17A.205 and .235 for failure to register and report contributions and expenditures as a candidate (EY 19; Jun 19) RCW 42.17A.235, RCW 42.17A.205 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Glen Morgan on June 18, 2019. The complaint alleged that Debbie Bertlin (Respondent), a 2019 candidate for Mercer Island City Council, may have violated RCW 42.17A.205 for failure to timely file a Candidate Registration (C-1 report) within two weeks of becoming a candidate; and RCW 42.17A.235 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Respondent.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; the applicable PDC reports filed by the Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to timely register as a candidate and report contributions do not amount to violations that warrant further investigation.

PDC staff is reminding Debbie Bertlin about the importance of timely candidate registration, and subsequent timely disclosure of all contribution and expenditure activities, and the timely filings of all future PDC reports in accordance with the statutes and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/53323
53320 06/18/2019 Elizabeth Hallock Soneya Lund Lund, Soneya: Alleged violations of RCW 42.17A.235 for failure to timely report contributions and expenditures (EY 19; June 19) RCW 42.17A.235 Request for Technical Correction

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Elizabeth Hallock on June 12, 2019. The complaint alleged that Soneya Lund, a 2019 candidate for Yakima City Council, may have violated RCW 42.17A.235 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; correspondence provided by Soneya Lund; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, filing reports under the wrong Filer ID does not amount to a violation warranting further investigation.

Soneya Lund made minor or ministerial errors on required reports, which did not materially impact the public interest. Upon notification of these errors, PDC staff migrated the data to the correct Filer ID, and Soneya Lund timely amended their ORCA records for the correct campaign, making the necessary technical corrections as requested by staff.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/53320
53230 06/17/2019 Lynda Gerpheide Daniel R. Miller Miller, Daniel R.: Alleged violations of RCW 42.17A.205 & .700 for failure to timely register as a candidate & file statement of financial affairs. (EY '19) (Jun '19) RCW 42.17A.700, RCW 42.17A.205 Case Closed with Reminder

The Public Disclosure Commission (PDC) completed its review of the complaint Lynda Gerpheide filed on June 13, 2019. The complaint alleged that Daniel R. Miller (the “Respondent”) may have violated RCW 42.17A.205 & .770 by failing to timely register as a candidate and file a statement of financial affairs for election year 2019.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements: the response(s) provided by Respondent; and the applicable PDC reports filed by Respondent to determine whether the record supports a finding of one or more violations. 

Based on these findings, staff determined that, in this instance, failure to timely file the Candidate Registration (C-1) and Personal Statement of Financial Affairs (F-1) reports does not amount to a violation warranting further investigation.

PDC staff reminded Daniel Miller about the importance of the timely filing all future PDC reports, including the candidate registration and financial affairs statement, and responding quickly to PDC requests. 

Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/53230
53227 06/17/2019 Dori Luzzo Gilmour Brad Anderson Anderson Brad: Alleged violation of RCW 42.17A.205 for failure to timely register as a candidate with PDC for election year 2019. (Jun 19) RCW 42.17A.205 Case Closed with Reminder

The Public Disclosure Commission (PDC) completed its review of the complaint Dori Luzzo Gilmour filed on June 12, 2019. The complaint alleged that Brad Anderson may have violated RCW 42.17A.205 by failing to timely register as a candidate with the PDC for election year 2019 within two weeks of candidacy.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Brad Anderson (the “Respondent”); and the applicable PDC reports filed by the Respondent to determine whether the record supports a finding of one or more violations. 

Based on these findings, staff determined that, in this instance, failure to timely file the candidate registration (C-1 report) did not amount to a violation warranting further investigation.

PDC staff reminded Brad Anderson about the importance of timely registering as a candidate and the timely filing of all future PDC reports, including the C-1 report. 

Based on the information, the PDC found that no further action was warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/53227
52905 06/13/2019 Carrie L. Barrow Robert (Rocky) Samson III Samson, Robert (Rocky) III: Alleged violations of Chapter 42.17A RCW for failure to timely register and report contributions, expenditures, and financial affairs as a candidate; and for false statements in political advertising (EY 19; June 19) RCW 42.17A.205, RCW 42.17A.700, RCW 42.17A.335, RCW 42.17A.235 Case Closed with Written Warning

The complaint alleged that Samson violated RCW 42.17A.205 for failure to file a Candidate Registration (C-1 report) within two weeks of declaring candidacy; RCW 42.17A.235 for failure to report contributions and expenditures as a candidate; RCW 42.17A.700 for failure to timely file the Personal Statement of Financial Affairs (F-1 report) within two weeks of declaring candidacy; and RCW 42.17A.335 for sponsoring false statements of material fact about a candidate in political advertising.

RCW 42.17A.335 prohibits a person from sponsoring, with actual malice, a false statement of material fact about a candidate for public office that constitutes libel or defamation per se. The violation must be proven by clear and convincing evidence. There was no clear and convincing evidence of defamatory or libelous statements made with actual malice. 

Staff has determined, in this instance, the alleged failure to timely file a Candidate Registration (C-1 report) and to comply with the requirement to include proper sponsor identification on political advertising, do not amount to violations warranting further investigation. 

However, pursuant to WAC 390-37-060(1)(d), Robert Joseph "Rocky" Samson III will receive a warning letter concerning his failure to comply with PDC requirements.  

Should Robert Joseph "Rocky" Samson III be a future candidate for elective office, PDC staff expects Samson to timely file the C-1 and other required reports and list the complete sponsor identification on all political advertising in future years in accordance with PDC laws and rules. 

The Commission will consider this formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).     

https://www.pdc.wa.gov/browse/cases/52905
52903 06/13/2019 Donald Sorensen Jr. Jim Hill Hill, James (Jim): Alleged violations of RCW 42.17A.205, 235, and .700 for failure to register and report contributions, expenditures, and financial affairs as a candidate (EY 19; June 19) RCW 42.17A.235, RCW 42.17A.205, RCW 42.17A.700 Request for Technical Correction

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Donald Sorensen Jr. on June 5, 2019. The complaint alleged that James (Jim) Hill may have violated RCW 42.17A.205 for failure to timely file a Candidate Registration (C-1 report) with the PDC, within two weeks of declaring candidacy. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; correspondence provided by Jim Hill; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, selecting the wrong office and jurisdiction on the C-1 report does not amount to a violation warranting further investigation. 

James (Jim) Hill made minor or ministerial errors on required reports, which did not materially impact the public interest. Upon notification of these errors, Jim Hill timely amended their reports, making the necessary technical corrections as requested by staff. 
 
Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1). 
 

https://www.pdc.wa.gov/browse/cases/52903
52901 06/13/2019 Glen Morgan Kathryn Campbell Campbell, Kathryn (2): Alleged violation of RCW 42.17A.700 for failure to timely disclose personal financial affairs in calendar year 2017 (EY 19; June 19) RCW 42.17A.700 Violation Found by Commission

Pursuant to the brief enforcement hearing (brief adjudicative proceeding) notice sent to Kathryn Campbell on August 6, 2019, A brief adjudicative proceeding was held on August 20, 2019, in Room 206, Evergreen Plaza Building, 711 Capitol Way, Olympia, Washington, to consider whether the Respondent violated RCW 42.17A.700 by failing to file a Personal Financial Affairs Statement (F-1 report) as an incumbent official, which was due to be filed not later than April 16, 2018, disclosing financial activities for calendar year 2017. 

The hearing was held in accordance with Chapters 34.05 RCW and 42.17A RCW and Chapter 390-37 WAC.  Commission Vice-Chair David Ammons was the Presiding Officer.  The Commission staff was represented by Tabatha Blacksmith, Compliance Coordinator.  The Respondent participated in the hearing in-person. 

Having considered the evidence, the Presiding Officer finds as follows: 
 

CONCLUSIONS OF LAW

  1. This matter was duly and properly convened and all jurisdictional, substantive, and procedural requirements have been satisfied.
  2. The Respondent violated RCW 42.17A.700 by failing to file the F-1 report by April 16, 2018.

ORDER

IT IS HEREBY ORDERED that the Respondent is assessed a civil penalty of $150, with $150 of the penalty suspended, in accordance with the F-1 penalty schedule set forth in WAC 390-37-143, upon condition that the Respondent:

  1. Commit no further violations of Chapter 42.17A RCW or Title 390 WAC for a period of four years from the date of this Order.

 

https://www.pdc.wa.gov/browse/cases/52901
52807 06/12/2019 Avi Neal Elliott Shapiro Preeti Shridhar Shridhar, Preeti: Alleged Violation of RCW 42.17A.320 for failure to include sponsor identification in political advertising. RCW 42.17A.320 Case Closed with Reminder

Allegation: Violation of RCW 42.17A.320 for failure to include sponsor identification in political advertising 

https://www.pdc.wa.gov/browse/cases/52807
52387 06/05/2019 Glen Morgan Kate Kruller Kruller, Kate: Alleged violations of RCW 42.17A.205, .235 & .240 for failure to timely register as a candidate and timely & accurately report contributions & expenditures. (EY '18 & '19) (Jun 2019) RCW 42.17A.205 Case Closed with Reminder

The complaint alleged Kate Kruller, a candidate for Tukwila City Council Member, Pos. 6 may have violated RCW 42.17A.205 for failure to timely register as a candidate and RCW 42.17A .235 and .240 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the responses provided by Kate Kruller; the applicable PDC reports filed by Kruller; and reviewed Kruller’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign does not amount to a violation warranting further investigation. 

Kate Kruller made minor or ministerial errors on her required C-1 report, which did not materially impact the public interest. Upon notification of these errors, Kruller timely re-filed the report, making the necessary technical corrections as requested by staff. 

Kate Kruller also made minor or ministerial errors on her initial C-4 report, which did not materially impact the public interest. Upon notification of these errors, Kruller timely re-filed the report, making the necessary technical corrections as requested by staff. 

PDC staff is also reminding Kate Kruller about the importance of timely disclosure of all contribution and expenditure activities, including personal property used for campaign purposes, and the timely filings of all future PDC reports in accordance with the statutes and rules. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/52387
52310 06/04/2019 Nikolas Battle & Tiffany Chang Diana White White, Diana K.: Alleged violations of RCW 42.17A.235 & .240 for failure to timely & accurately report contributions and expenditures. (Jun 2019) RCW 42.17A.235, RCW 42.17A.240 Case Closed with Reminder

The Public Disclosure Commission (PDC) completed its review of the complaints filed by Nikolas Battle and Tiffany Chang on May 28, 2019 and June 4, 2019. The complaints alleged that Diana White (the “Respondent”) may have violated RCW 42.17A.235 & .240 for failure to timely and accurately report contributions and expenditures. The complaints specifically alleged that the Respondent failed to report expenditures related to her campaign kick-off event, printed materials, buttons, rally signs, and website.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; and the applicable PDC reports filed by Respondent to determine whether the record supports a finding of one or more violations. 

Based on the findings, staff determined that, in this instance, failure to 1) timely report contributions and expenditures; and 2) accurately report an in-kind loan and expenditure descriptions does not amount to a violation warranting further investigation.

PDC staff reminded the Respondent about the importance of timely and accurately reporting contributions, expenditures and in-kind loans and providing detailed expenditure descriptions on all future PDC reports.

The Respondent made minor or ministerial errors on required reports, which did not materially impact the public interest. Upon notification of these errors, the Respondent timely amended the campaign’s reports, making the necessary technical corrections.

Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/52310
51819 05/24/2019 Freedom Foundation (Maxford Nelsen) Williams Plant Services Williams Plant Services (2): Alleged violations of RCW 42.17A.495 & WAC 390-17-100 for failure to obtain proper employee authorization forms for political contribution payroll deductions and maintain for public inspection. (May 19) WAC 390-17-100, RCW 42.17A.495 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by the Freedom Foundation on May 20, 2019. The complaint alleged that the 19 named respondents may have violated RCW 42.17A.495 and WAC 390-17-100 for failure to maintain copies of payroll deduction authorizations for public inspection, deducting employee wages for contributions to political committees without first obtaining proper employee authorization forms, and for failure to allow employees to determine the amount of their wages to deduct for contributions to political committees on employee authorization forms. 
PDC staff reviewed the allegations; the applicable statutes and rules; and a response provided by Wayne Gold Jr. on behalf of Doubl-Kold to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.  The PDC’s action was taken because Freedom Foundation did not submit evidence of violations obtained from individual employers/contractors. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).  The PDC’s action does not preclude Freedom Foundation from contacting individual employers/contractors and refiling a complaint based on evidence obtained from individual employers/contractors. 

https://www.pdc.wa.gov/browse/cases/51819
51818 05/24/2019 Freedom Foundation (Maxford Nelsen) Washington Building Trades Washington Building Trades (2): Alleged violations of RCW 42.17A.495 & WAC 390-17-100 for failure to obtain employee authorization forms for political contribution payroll deductions. (May 19) WAC 390-17-100, RCW 42.17A.495 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by the Freedom Foundation on May 20, 2019. The complaint alleged that the 19 named respondents may have violated RCW 42.17A.495 and WAC 390-17-100 for failure to maintain copies of payroll deduction authorizations for public inspection, deducting employee wages for contributions to political committees without first obtaining proper employee authorization forms, and for failure to allow employees to determine the amount of their wages to deduct for contributions to political committees on employee authorization forms. 
PDC staff reviewed the allegations; the applicable statutes and rules; and a response provided by Wayne Gold Jr. on behalf of Doubl-Kold to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.  The PDC’s action was taken because Freedom Foundation did not submit evidence of violations obtained from individual employers/contractors. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).  The PDC’s action does not preclude Freedom Foundation from contacting individual employers/contractors and refiling a complaint based on evidence obtained from individual employers/contractors. 

https://www.pdc.wa.gov/browse/cases/51818
51817 05/24/2019 Freedom Foundation (Maxford Nelsen) Waste Treatment Completion Company, LLC Waste Treatment Completion Company, LLC (2): Alleged violations of RCW 42.17A.495 & WAC 390-17-100 for failure to obtain employee authorization forms for political contribution payroll deductions. (May 19) WAC 390-17-100, RCW 42.17A.495 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by the Freedom Foundation on May 20, 2019. The complaint alleged that the 19 named respondents may have violated RCW 42.17A.495 and WAC 390-17-100 for failure to maintain copies of payroll deduction authorizations for public inspection, deducting employee wages for contributions to political committees without first obtaining proper employee authorization forms, and for failure to allow employees to determine the amount of their wages to deduct for contributions to political committees on employee authorization forms. 
PDC staff reviewed the allegations; the applicable statutes and rules; and a response provided by Wayne Gold Jr. on behalf of Doubl-Kold to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.  The PDC’s action was taken because Freedom Foundation did not submit evidence of violations obtained from individual employers/contractors. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).  The PDC’s action does not preclude Freedom Foundation from contacting individual employers/contractors and refiling a complaint based on evidence obtained from individual employers/contractors. 

https://www.pdc.wa.gov/browse/cases/51817
51816 05/24/2019 Freedom Foundation (Maxford Nelsen) S2 Industrial, Inc. S2 Industrial, Inc: Alleged violations of RCW 42.17A.495 & WAC 390-17-100 for failure to obtain proper employee authorization forms for political contribution payroll deductions and maintain for public inspection. (May 19) WAC 390-17-100, RCW 42.17A.495 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by the Freedom Foundation on May 20, 2019. The complaint alleged that the 19 named respondents may have violated RCW 42.17A.495 and WAC 390-17-100 for failure to maintain copies of payroll deduction authorizations for public inspection, deducting employee wages for contributions to political committees without first obtaining proper employee authorization forms, and for failure to allow employees to determine the amount of their wages to deduct for contributions to political committees on employee authorization forms. 
PDC staff reviewed the allegations; the applicable statutes and rules; and a response provided by Wayne Gold Jr. on behalf of Doubl-Kold to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.  The PDC’s action was taken because Freedom Foundation did not submit evidence of violations obtained from individual employers/contractors. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).  The PDC’s action does not preclude Freedom Foundation from contacting individual employers/contractors and refiling a complaint based on evidence obtained from individual employers/contractors. 

https://www.pdc.wa.gov/browse/cases/51816
51815 05/24/2019 Freedom Foundation (Maxford Nelsen) McKinstry Company, LLC McKinstry Company, LLC (2): Alleged violations of RCW 42.17A.495 & WAC 390-17-100 for failure to obtain proper employee authorization forms for political contribution payroll deductions and maintain for public inspection. (May 19) WAC 390-17-100, RCW 42.17A.495 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by the Freedom Foundation on May 20, 2019. The complaint alleged that the 19 named respondents may have violated RCW 42.17A.495 and WAC 390-17-100 for failure to maintain copies of payroll deduction authorizations for public inspection, deducting employee wages for contributions to political committees without first obtaining proper employee authorization forms, and for failure to allow employees to determine the amount of their wages to deduct for contributions to political committees on employee authorization forms. 
PDC staff reviewed the allegations; the applicable statutes and rules; and a response provided by Wayne Gold Jr. on behalf of Doubl-Kold to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.  The PDC’s action was taken because Freedom Foundation did not submit evidence of violations obtained from individual employers/contractors. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).  The PDC’s action does not preclude Freedom Foundation from contacting individual employers/contractors and refiling a complaint based on evidence obtained from individual employers/contractors. 

https://www.pdc.wa.gov/browse/cases/51815
51814 05/24/2019 Freedom Foundation (Maxford Nelsen) JH Kelly, LLC JH Kelly, LLC (2): Alleged violations of RCW 42.17A.495 & WAC 390-17-100 for failure to obtain proper employee authorization forms for political contribution payroll deductions and maintain for public inspection. (May 19) WAC 390-17-100, RCW 42.17A.495 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by the Freedom Foundation on May 20, 2019. The complaint alleged that the 19 named respondents may have violated RCW 42.17A.495 and WAC 390-17-100 for failure to maintain copies of payroll deduction authorizations for public inspection, deducting employee wages for contributions to political committees without first obtaining proper employee authorization forms, and for failure to allow employees to determine the amount of their wages to deduct for contributions to political committees on employee authorization forms. 
PDC staff reviewed the allegations; the applicable statutes and rules; and a response provided by Wayne Gold Jr. on behalf of Doubl-Kold to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.  The PDC’s action was taken because Freedom Foundation did not submit evidence of violations obtained from individual employers/contractors. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).  The PDC’s action does not preclude Freedom Foundation from contacting individual employers/contractors and refiling a complaint based on evidence obtained from individual employers/contractors. 

https://www.pdc.wa.gov/browse/cases/51814
51813 05/24/2019 Freedom Foundation (Maxford Nelsen) Joint Apprenticeship and Training Committee Joint Apprenticeship and Training Committee (2): Alleged violations of RCW 42.17A.495 & WAC 390-17-100 for failure to obtain proper employee authorization forms for political contribution payroll deductions and maintain for public inspection. (May 19) RCW 42.17A.495, WAC 390-17-100 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by the Freedom Foundation on May 20, 2019. The complaint alleged that the 19 named respondents may have violated RCW 42.17A.495 and WAC 390-17-100 for failure to maintain copies of payroll deduction authorizations for public inspection, deducting employee wages for contributions to political committees without first obtaining proper employee authorization forms, and for failure to allow employees to determine the amount of their wages to deduct for contributions to political committees on employee authorization forms. 
PDC staff reviewed the allegations; the applicable statutes and rules; and a response provided by Wayne Gold Jr. on behalf of Doubl-Kold to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.  The PDC’s action was taken because Freedom Foundation did not submit evidence of violations obtained from individual employers/contractors. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).  The PDC’s action does not preclude Freedom Foundation from contacting individual employers/contractors and refiling a complaint based on evidence obtained from individual employers/contractors. 

https://www.pdc.wa.gov/browse/cases/51813
51812 05/24/2019 Freedom Foundation (Maxford Nelsen) Iron Mountain Management Iron Mountain Management (2): Alleged violations of RCW 42.17A.495 & WAC 390-17-100 for failure to obtain proper employee authorization forms for political contribution payroll deductions and maintain for public inspection. (May 19) WAC 390-17-100, RCW 42.17A.495 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by the Freedom Foundation on May 20, 2019. The complaint alleged that the 19 named respondents may have violated RCW 42.17A.495 and WAC 390-17-100 for failure to maintain copies of payroll deduction authorizations for public inspection, deducting employee wages for contributions to political committees without first obtaining proper employee authorization forms, and for failure to allow employees to determine the amount of their wages to deduct for contributions to political committees on employee authorization forms. 
PDC staff reviewed the allegations; the applicable statutes and rules; and a response provided by Wayne Gold Jr. on behalf of Doubl-Kold to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.  The PDC’s action was taken because Freedom Foundation did not submit evidence of violations obtained from individual employers/contractors. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).  The PDC’s action does not preclude Freedom Foundation from contacting individual employers/contractors and refiling a complaint based on evidence obtained from individual employers/contractors. 

https://www.pdc.wa.gov/browse/cases/51812
51811 05/24/2019 Freedom Foundation (Maxford Nelsen) Intermech, Inc. Intermech, Inc. (2):Alleged violations of RCW 42.17A.495 & WAC 390-17-100 for failure to obtain proper employee authorization forms for political contribution payroll deductions and maintain for public inspection. (May 19) WAC 390-17-100, RCW 42.17A.495 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by the Freedom Foundation on May 20, 2019. The complaint alleged that the 19 named respondents may have violated RCW 42.17A.495 and WAC 390-17-100 for failure to maintain copies of payroll deduction authorizations for public inspection, deducting employee wages for contributions to political committees without first obtaining proper employee authorization forms, and for failure to allow employees to determine the amount of their wages to deduct for contributions to political committees on employee authorization forms. 
PDC staff reviewed the allegations; the applicable statutes and rules; and a response provided by Wayne Gold Jr. on behalf of Doubl-Kold to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.  The PDC’s action was taken because Freedom Foundation did not submit evidence of violations obtained from individual employers/contractors. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).  The PDC’s action does not preclude Freedom Foundation from contacting individual employers/contractors and refiling a complaint based on evidence obtained from individual employers/contractors. 

https://www.pdc.wa.gov/browse/cases/51811
51810 05/24/2019 Freedom Foundation (Maxford Nelsen) Infrasource Services, LLC Infrasource Services, LLC (2): Alleged violations of RCW 42.17A.495 & WAC 390-17-100 for failure to obtain proper employee authorization forms for political contribution payroll deductions and maintain for public inspection. (May 19) WAC 390-17-100, RCW 42.17A.495 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by the Freedom Foundation on May 20, 2019. The complaint alleged that the 19 named respondents may have violated RCW 42.17A.495 and WAC 390-17-100 for failure to maintain copies of payroll deduction authorizations for public inspection, deducting employee wages for contributions to political committees without first obtaining proper employee authorization forms, and for failure to allow employees to determine the amount of their wages to deduct for contributions to political committees on employee authorization forms. 
PDC staff reviewed the allegations; the applicable statutes and rules; and a response provided by Wayne Gold Jr. on behalf of Doubl-Kold to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.  The PDC’s action was taken because Freedom Foundation did not submit evidence of violations obtained from individual employers/contractors. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).  The PDC’s action does not preclude Freedom Foundation from contacting individual employers/contractors and refiling a complaint based on evidence obtained from individual employers/contractors. 

https://www.pdc.wa.gov/browse/cases/51810
51809 05/24/2019 Freedom Foundation (Maxford Nelsen) Indian Eyes, LLC Indian Eyes, LLC (2): Alleged violations of RCW 42.17A.495 & WAC 390-17-100 for failure to obtain proper employee authorization forms for political contribution payroll deductions and maintain for public inspection. (May 19) WAC 390-17-100, RCW 42.17A.495 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by the Freedom Foundation on May 20, 2019. The complaint alleged that the 19 named respondents may have violated RCW 42.17A.495 and WAC 390-17-100 for failure to maintain copies of payroll deduction authorizations for public inspection, deducting employee wages for contributions to political committees without first obtaining proper employee authorization forms, and for failure to allow employees to determine the amount of their wages to deduct for contributions to political committees on employee authorization forms. 
PDC staff reviewed the allegations; the applicable statutes and rules; and a response provided by Wayne Gold Jr. on behalf of Doubl-Kold to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.  The PDC’s action was taken because Freedom Foundation did not submit evidence of violations obtained from individual employers/contractors. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).  The PDC’s action does not preclude Freedom Foundation from contacting individual employers/contractors and refiling a complaint based on evidence obtained from individual employers/contractors. 

https://www.pdc.wa.gov/browse/cases/51809
51808 05/24/2019 Freedom Foundation (Maxford Nelsen) Doubl-Kold Doubl-Kold (2): Alleged violations of RCW 42.17A.495 & WAC 390-17-100 for failure to obtain employee authorization forms for political contribution payroll deductions. (May 19) RCW 42.17A.495, WAC 390-17-100 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by the Freedom Foundation on May 20, 2019. The complaint alleged that the 19 named respondents may have violated RCW 42.17A.495 and WAC 390-17-100 for failure to maintain copies of payroll deduction authorizations for public inspection, deducting employee wages for contributions to political committees without first obtaining proper employee authorization forms, and for failure to allow employees to determine the amount of their wages to deduct for contributions to political committees on employee authorization forms. 
PDC staff reviewed the allegations; the applicable statutes and rules; and a response provided by Wayne Gold Jr. on behalf of Doubl-Kold to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.  The PDC’s action was taken because Freedom Foundation did not submit evidence of violations obtained from individual employers/contractors. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).  The PDC’s action does not preclude Freedom Foundation from contacting individual employers/contractors and refiling a complaint based on evidence obtained from individual employers/contractors. 

https://www.pdc.wa.gov/browse/cases/51808
51807 05/24/2019 Freedom Foundation (Maxford Nelsen) Day & Zimmerman NPS Day & Zimmerman NPS (2): Alleged violations of RCW 42.17A.495 & WAC 390-17-100 for failure to obtain proper employee authorization forms for political contribution payroll deductions and maintain for public inspection. (May 19) WAC 390-17-100, RCW 42.17A.495 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by the Freedom Foundation on May 20, 2019. The complaint alleged that the 19 named respondents may have violated RCW 42.17A.495 and WAC 390-17-100 for failure to maintain copies of payroll deduction authorizations for public inspection, deducting employee wages for contributions to political committees without first obtaining proper employee authorization forms, and for failure to allow employees to determine the amount of their wages to deduct for contributions to political committees on employee authorization forms. 
PDC staff reviewed the allegations; the applicable statutes and rules; and a response provided by Wayne Gold Jr. on behalf of Doubl-Kold to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.  The PDC’s action was taken because Freedom Foundation did not submit evidence of violations obtained from individual employers/contractors. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).  The PDC’s action does not preclude Freedom Foundation from contacting individual employers/contractors and refiling a complaint based on evidence obtained from individual employers/contractors. 

https://www.pdc.wa.gov/browse/cases/51807
51806 05/24/2019 Freedom Foundation (Maxford Nelsen) Cogen Cleaning Technology Cogen Cleaning Technology: Alleged violations of RCW 42.17A.495 & WAC 390-17-100 for failure to obtain proper employee authorization forms for political contribution payroll deductions and maintain for public inspection. (May 19) WAC 390-17-100, RCW 42.17A.495 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by the Freedom Foundation on May 20, 2019. The complaint alleged that the 19 named respondents may have violated RCW 42.17A.495 and WAC 390-17-100 for failure to maintain copies of payroll deduction authorizations for public inspection, deducting employee wages for contributions to political committees without first obtaining proper employee authorization forms, and for failure to allow employees to determine the amount of their wages to deduct for contributions to political committees on employee authorization forms. 
PDC staff reviewed the allegations; the applicable statutes and rules; and a response provided by Wayne Gold Jr. on behalf of Doubl-Kold to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.  The PDC’s action was taken because Freedom Foundation did not submit evidence of violations obtained from individual employers/contractors. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).  The PDC’s action does not preclude Freedom Foundation from contacting individual employers/contractors and refiling a complaint based on evidence obtained from individual employers/contractors. 

https://www.pdc.wa.gov/browse/cases/51806
51805 05/24/2019 Freedom Foundation (Maxford Nelsen) Central Washington Refrigeration Central Washington Refrigeration (2): Alleged violations of RCW 42.17A.495 & WAC 390-17-100 for failure to obtain proper employee authorization forms for political contribution payroll deductions and maintain for public inspection. (May 19) WAC 390-17-100, RCW 42.17A.495 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by the Freedom Foundation on May 20, 2019. The complaint alleged that the 19 named respondents may have violated RCW 42.17A.495 and WAC 390-17-100 for failure to maintain copies of payroll deduction authorizations for public inspection, deducting employee wages for contributions to political committees without first obtaining proper employee authorization forms, and for failure to allow employees to determine the amount of their wages to deduct for contributions to political committees on employee authorization forms. 
PDC staff reviewed the allegations; the applicable statutes and rules; and a response provided by Wayne Gold Jr. on behalf of Doubl-Kold to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.  The PDC’s action was taken because Freedom Foundation did not submit evidence of violations obtained from individual employers/contractors. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).  The PDC’s action does not preclude Freedom Foundation from contacting individual employers/contractors and refiling a complaint based on evidence obtained from individual employers/contractors. 

https://www.pdc.wa.gov/browse/cases/51805
51804 05/24/2019 Freedom Foundation (Maxford Nelsen) BNB Mechanical, LLC BNB Mechanical, LLC (2): Alleged violations of RCW 42.17A.495 & WAC 390-17-100 for failure to obtain proper employee authorization forms for political contribution payroll deductions and maintain for public inspection. (May 19) WAC 390-17-100, RCW 42.17A.495 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by the Freedom Foundation on May 20, 2019. The complaint alleged that the 19 named respondents may have violated RCW 42.17A.495 and WAC 390-17-100 for failure to maintain copies of payroll deduction authorizations for public inspection, deducting employee wages for contributions to political committees without first obtaining proper employee authorization forms, and for failure to allow employees to determine the amount of their wages to deduct for contributions to political committees on employee authorization forms. 
PDC staff reviewed the allegations; the applicable statutes and rules; and a response provided by Wayne Gold Jr. on behalf of Doubl-Kold to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.  The PDC’s action was taken because Freedom Foundation did not submit evidence of violations obtained from individual employers/contractors. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).  The PDC’s action does not preclude Freedom Foundation from contacting individual employers/contractors and refiling a complaint based on evidence obtained from individual employers/contractors. 

https://www.pdc.wa.gov/browse/cases/51804
51803 05/24/2019 Freedom Foundation (Maxford Nelsen) Apollo Mechanical Contractors Apollo Mechanical Contractors (2): Alleged violations of RCW 42.17A.495 & WAC 390-17-100 for failure to obtain proper employee authorization forms for political contribution payroll deductions and maintain for public inspection. (May 19) WAC 390-17-100, RCW 42.17A.495 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by the Freedom Foundation on May 20, 2019. The complaint alleged that the 19 named respondents may have violated RCW 42.17A.495 and WAC 390-17-100 for failure to maintain copies of payroll deduction authorizations for public inspection, deducting employee wages for contributions to political committees without first obtaining proper employee authorization forms, and for failure to allow employees to determine the amount of their wages to deduct for contributions to political committees on employee authorization forms. 
PDC staff reviewed the allegations; the applicable statutes and rules; and a response provided by Wayne Gold Jr. on behalf of Doubl-Kold to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.  The PDC’s action was taken because Freedom Foundation did not submit evidence of violations obtained from individual employers/contractors. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).  The PDC’s action does not preclude Freedom Foundation from contacting individual employers/contractors and refiling a complaint based on evidence obtained from individual employers/contractors. 

https://www.pdc.wa.gov/browse/cases/51803
51802 05/24/2019 Freedom Foundation (Maxford Nelsen) American Electric, Inc American Electric, Inc. (2): Alleged violations of RCW 42.17A.495 & WAC 390-17-100 for failure to obtain proper employee authorization forms for political contribution payroll deductions and maintain for public inspection. (May 19) RCW 42.17A.495, WAC 390-17-100 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by the Freedom Foundation on May 20, 2019. The complaint alleged that the 19 named respondents may have violated RCW 42.17A.495 and WAC 390-17-100 for failure to maintain copies of payroll deduction authorizations for public inspection, deducting employee wages for contributions to political committees without first obtaining proper employee authorization forms, and for failure to allow employees to determine the amount of their wages to deduct for contributions to political committees on employee authorization forms. 
PDC staff reviewed the allegations; the applicable statutes and rules; and a response provided by Wayne Gold Jr. on behalf of Doubl-Kold to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.  The PDC’s action was taken because Freedom Foundation did not submit evidence of violations obtained from individual employers/contractors. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).  The PDC’s action does not preclude Freedom Foundation from contacting individual employers/contractors and refiling a complaint based on evidence obtained from individual employers/contractors. 

https://www.pdc.wa.gov/browse/cases/51802
51796 05/24/2019 Carly Coburn Lisa Thomas Thomas, Lisa: Alleged Violation of RCW 42.17A.205 for failure to file C-1 Candidate Registration Report within two weeks of declaring candidacy. Case Closed with Reminder

Allegation: Violation of RCW 42.17A.205 for failure to file C-1 Candidate Registration within two weeks of declaring candidacy.

https://www.pdc.wa.gov/browse/cases/51796
51330 05/15/2019 Andrew Saturn Linda Oosterman Oosterman, Linda (5): Alleged violation of Chapter 42.17A RCW for receiving and failing to report over-limit contributions reported as independent expenditures by Up for Thurston County (EY 18; May 19) RCW 42.17A.310, RCW 42.17A.270, RCW 42.17A.265, WAC 390-05-210, RCW 42.17A.205, RCW 42.17A.235, RCW 42.17A.240 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Andrew Saturn on April 23, 2019. The complaint alleged that Linda Oosterman, a 2018 candidate for Public Utility Commissioner for Thurston County, may have violated RCW 42.17A.205 for failure to report Paul Berendt as a committee officer; RCW 42.17A.235, .240, .310, and WAC 390-05-210 for failure to accurately and timely report in-kind contributions from expenditures coordinated with Up for Thurston County (Sponsored by Puget Sound Energy); RCW 42.17A.265 for failure to timely report last minute in-kind contributions from coordinated expenditures with Up for Thurston County (Sponsored by Puget Sound Energy) within 48 hours of receipt; and RCW 42.17A.270 for failure to timely and accurately report contributions made by Puget Sound Energy to Up for Thurston County (Sponsored by Puget Sound Energy), allegedly earmarked for coordinated expenditures with Linda Oosterman; and RCW 42.17A.420 for accepting contributions from coordinated expenditures made by Up for Thurston County exceeding $5,000 within 21 days of the general election.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the responses provided by the Re-Elect Linda Oosterman Campaign (Campaign); the minutes from the Thurston County Democratic Party Endorsement Meeting; the applicable PDC reports filed by the Campaign and Up for Thurston County (Sponsored by Puget Sound Energy); and queried the Campaign and Up for Thurston County (Sponsored by Puget Sound Energy)’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

The complaint alleged the Committee failed to disclose Paul Berendt as a Committee officer based on: (1) a letter Paul Berendt allegedly distributed at a meeting of the Thurston County Democratic Party in coordination with the Oosterman Campaign; and (2) a $16.39 in-kind contribution made from Paul Berendt to the Committee for a high-resolution copy of a photograph of Linda Oosterman was taken from a photo-sharing website and used to facilitate the electioneering communication mailer.

The evidence provided, which staff reviewed, does not support a finding that Paul Berendt served as an officer for the Oosterman Campaign in the capacity to “make, direct, or authorize contributions, expenditure, strategic or policy decisions on behalf of the committee.” 

The complaint alleged that the electioneering communication sponsored and mailed by the Committee totaling $9,952 in support of Linda Oosterman, was made in cooperation and coordination with the Campaign, and should have been reported as an in-kind contribution in accordance with RCW 42.17A.240 and WAC 390-05-210, based on the same facts concerning officer status as noted in the letters dismissing this case.  In addition, the complaint alleged that the factors listed in WAC 390-05-210 of presumptive coordination were met by the ‘Dear Friends’ letter, and the quality of a photograph used on a mailer printed by Capitol City Press, stating “[g]eneral members of the public would have no way to know about this letter or receive a copy unless they were working in close coordination with the Linda Oosterman campaign as a member of the executive committee” citing an email from the Campaign’s consultant Joe Hyer, which states “I don’t remember any significant quantity of that letter being produced- I was given a copy to review, but the candidate didn’t have much of a mailing list that would work with this letter.

No evidence was provided that the Committee expenditures were made in “cooperation, concert or collaboration with, or at the request or suggestion” of a Linda Oosterman, authorized campaign, or an agent of the campaign.

The remaining alleged violations of failure to timely report last minute in-kind contributions, failure to timely and accurately report earmarked in-kind contributions, and accepting contributions exceeding $5,000 within 21 days of the general election rely upon a finding that the expenditures undertaken by Up for Thurston County (Sponsored by Puget Sound Energy) constituted in-kind contributions to the Campaign, which the evidence does not support.

Based on our findings staff has determined that, in this instance, the evidence does not support a finding of a violation warranting further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/51330
51097 05/10/2019 Darrell Lambert Fuzzy Fletcher Fletcher Fuzzy: Alleged violations of RCW 42.17A.205 & .700 for failure to timely register candidate committee & file a Personal Financial Affairs Statement within two weeks of publicly declaring candidacy. (May 19) RCW 42.17A.700, RCW 42.17A.205 Case Closed with Reminder

This case alleged that Fuzzy Fletcher (the "Respondent") may have violated RCW 42.17A.205 and .700 by failing to timely register as a candidate and file a statement of financial affairs within two weeks of publicly declaring candidacy. 

PDC staff reviewed the allegations, applicable statutes, rules and reporting requirements, the response provided by the Respondent, and the applicable PDC reports filed by the Respondent to determine whether they supported a finding of one or more violations.

Based on staff's review, the PDC found that the Respondent publicly announced his candidacy for Snoqualmie City Council position #4 at a Snoqualmie City Council Meeting on April 8, 2019. Pursuant to RCW 42.17A.205 and .700, the Respondent was required to file a Candidate Registration (C-1 report) and a Personal Financial Affairs Statement (F-1 report) with the PDC within two weeks of becoming a candidate (e.g. publicly announcing candidacy). The Respondent indicated that the late reports were the result of his erroneous belief that they were not due until after a candidate officially files with the appropriate Elections office.

Upon being notified of the missing reports, the Respondent quickly contacted the PDC and made a good-faith effort to resolve the matter by filing the required reports. The PDC received the Respondent's F-1 report on 5/14/19 and C-1 report on 5/16/19. 

The Respondent's noncompliance was the result of a good-faith error or omission, the impact to the public was minimal, the oversight did not occur during a critical election period, and the Respondent quickly took corrective action.  PDC reminded the Respondent about the importance of timely registering as a candidate and submitting a statement of financial affairs with the PDC within two weeks of becoming a candidate, and timely filing all future PDC reports. Based on this information, the PDC found that no further action was warranted and dismissed the matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/51097
51086 05/10/2019 Freedom Foundation (Maxford Nelsen) Washington State Council of County and City Employees Washington State Council of County and City Employees (WSCCCE): Alleged violation of RCW 42.17A.235, .240 for failure to timely and accurately report in-kind contributions, and timely report contributions and expenditures, for 2014-2019. (May 19) RCW 42.17A.235, RCW 42.17A.240 Case Closed with Written Warning

A complaint was filed against the Washington State Council of County and City Employees PAC (Committee), a continuing political committee registered with the PDC, alleging violations of RCW 42.17A.235 and .240 by failing to timely file Campaign Full Summary Contributions and Expenditures reports (C-4 reports) disclosing contribution and expenditure activities, including staff time and the overhead costs to operate and maintain the committee for calendar years 2014 through 2018.

PDC staff's review found  the Committee failed to timely report $3,843.78 for in-kind contributions received from Washington State Council of County and City Employees (WSCCE) for calendar years 2014 through 2018, and that information was not disclosed until July 23, 2019, when the amended C-4 reports were filed. 

However, based on staff's findings and the information listed below, PDC staff has determined that the facts in this instance do not amount to a finding of a violation warranting further investigation.  Staff considered several mitigating factors that included: (1) the $3,843.78 in late disclosed in-kind contributions received by the Committee from WSCCE for staffing and overhead costs of running the PAC was not material in amount and had no impact on the public; (2) the Committee timely disclosed the majority of the C-3 and C-4 reports for calendar years 2014 through 2018; and (3) neither the WSCCE nor the Committee has any prior PDC violations.

Pursuant to WAC 390-37-060(1)(d), PDC staff formally warned the Committee concerning the importance of timely and accurately filing C-3 and C-4 reports disclosing contribution and expenditure activities undertaken by a continuing political committee, in accordance with PDC laws, rules and reporting requirements.  This formal written warning conveys staff’s expectation that the Committee will fully comply with the reporting requirements for a continuing political committee in the future, including the timely disclosure of the WSCCE staffing and overhead costs of running the PAC. The Commission will consider this formal written warning if there are any future PDC law or rule violations by Committee.

Based on this information, PDC staff is dismissing the remaining allegations in this matter against the Washington State Council of County and City Employees PAC in accordance with RCW 42.17A.755(1).  

https://www.pdc.wa.gov/browse/cases/51086
50825 05/02/2019 Reece A. Williams Dale Ragan Ragan, Dale: Alleged violation of RCW 42.17A.255 by failing to report independent expenditure for political advertising. (Apr 2019) RCW 42.17A.255 Case Closed with Reminder

This case alleged that the Respondent may have violated RCW 42.17A.255 by failing to report independent expenditure(s) for political advertising (e.g. No on Fire Bond signs). PDC staff reviewed the allegations, applicable statutes, rules and reporting requirements, the response provided by the Respondent, and the applicable PDC reports filed by the Respondent to determine whether they support a finding of one or more violations.

Based on staff's review, the PDC found that the Respondent purchased 50 signs from SignRocket on March 20, 2019 for $253.50. The signs contained an opposition ad concerning a fire bond and were distributed in Mt. Vernon in late March/early April of 2019. The signs were purchased and paid for by the Respondent using his own funds. 

Pursuant to RCW 42.17A.255, a person who makes an independent expenditure equaling $100 or more (aggregate, per election campaign) in support or opposition to a candidate or ballot proposition is required to file a C-6 report with the PDC within 5 days. The Respondent indicated he was unaware of the need to report independent expenditures but quickly took corrective action upon being notified of his registration requirements.

PDC staff reminded the Respondent about the importance of timely disclosing any independent expenditures for political advertising and timely filing all future PDC reports, as applicable. The PDC found that no further action was warranted and dismissed the matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/50825
50704 04/29/2019 Susan Wilkins Lake Washington School District Officials (Jane Stavem, Superintendent) Lake Washington School District Officials: Alleged violations of RCW 42.17A.555 for misuse of public facilities to support levy measure (EY 19; Apr 19) RCW 42.17A 555 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Susan Wilkins on April 23, 2019. The complaint alleged that Officials and Public Employees of the Lake Washington School District may have violated RCW 42.17A.555 for misuse of public facilities to support a levy measure.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Lake Washington School District (District); the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, the evidence does not support a finding of a violation warranting further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/50704
50698 04/29/2019 Nikita Minkin Ginny Scantlebury Scantlebury, Ginny: Alleged violation of RCW 42.17A.320 for failure to include sponsor identification in political advertising. (Apr 2019) RCW 42.17A.320 Case Closed with Reminder

This case alleged that the Respondent may have violated RCW 42.17A.320 by failing to include sponsor identification in political advertising (e.g. brochures, website). PDC staff reviewed the allegations, applicable statutes, rules and reporting requirements, and the responses provided by the Respondent to determine whether they support a finding of one or more violations.

Based on staff's review, the PDC found that the Respondent's campaign created and distributed brochures in approximately April of 2019 that lacked the sponsor's name and address. This sponsor ID information was also omitted from the Respondent's website, which was created on April 8, 2019.

Upon being notified of the missing sponsor ID information, the Respondent ceased using its brochures and quickly resolved the matter by updating its website and adding stickers containing sponsor name and address to its existing brochures.

PDC staff reminded the Respondent about the importance of including sponsor ID on all future political advertising. Based on the information, the PDC found that no further action was warranted and dismissed the matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/50698
50640 04/26/2019 David Churchman Paul M Herrera Herrera, Paul: Alleged Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 Report) within two weeks of becoming a candidate. (APR 2019, EY 2019) Case Closed with Reminder

Allegation: Violation of RCW 42.17A.700 for failure to timely file the F-1 Personal Financial Affairs Statement within two weeks of becoming a candidate. 

https://www.pdc.wa.gov/browse/cases/50640
50639 04/26/2019 Nick Minkin Ginny Scantleburry Scantlebury, Virginia: Alleged Violation of RCW 42.17A.320 for failure to disclose complete sponsorship information. (APR 2019, EY 2019) RCW 42.17A.320 Closed Administratively

This case was closed administratively because the PDC received two, substantially similar complaints from a single Complainant alleging potential violations of the same statute by a single Respondent. The Respondent's use of a nickname also made it appear that the complaints concerned two, different individuals. 

For clarity and the convenience of the parties involved, the PDC consolidated the complaints, evidence and response in a single case, which is retained as PDC Case 50698. Conversely, PDC Case 50639 is now closed.

https://www.pdc.wa.gov/browse/cases/50639
50329 04/18/2019 Andrew Saturn Jay Rodne Rodne, Jay: Alleged violations of RCW 42.17A.600 and WAC 390-20-143 for failure to register PacRim Bridges as a lobbyist firm, and Jay Rodne as a lobbyist agent (EY 19; Apr 19) RCW 42.17A.600, WAC 390-20-143 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Andrew Saturn on April 10, 2019. The complaint alleged that Jay Rodne may have violated: (1) RCW 42.17A.600 and WAC 390-20-143 for failure to register Pac Rim Bridges, LLC as a lobbyist firm; and (2) RCW 42.17A.600 for failure to register himself as a lobbyist with Pac Rim Bridges, LLC.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the response(s) provided by Jay Rodne and Senator Doug Ericksen in a related case (PDC Case 50328), to determine whether the record supports a finding of one or more violations.

The written responses from Jay Rodne and Senator Doug Ericksen, confirm that Pac Rim Bridges, LLC and its two named governors, do not meet the statutory definition of a lobbyist and that neither Pac Rim nor Mr. Rodne have engaged in lobbying activities that would require registration with the PDC.

Based on these findings staff has determined that, in this instance, no evidence supports a finding of an actual violation warranting further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/50329
50328 04/18/2019 Andrew Saturn Doug Ericksen Ericksen, Doug: Alleged violations of RCW 42.17A.600 and WAC 390-20-143 for failure to register PacRim Bridges as a lobbyist firm, and Doug Ericksen as a lobbyist agent (EY 19; Apr 19) WAC 390-20-143, RCW 42.17A.600 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Andrew Saturn on April 10, 2019. The complaint alleged that Doug Ericksen, a Senator in Legislative District 42, may have violated: (1) RCW 42.17A.600 and WAC 390-20-143 for failure to register Pac Rim Bridges, LLC as a lobbyist firm; and (2) RCW 42.17A.600 for failure to register himself as a lobbyist with Pac Rim Bridges, LLC.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the response(s) provided by Senator Ericksen and Jay Rodne in a related case (PDC Case 50329), to determine whether the record supports a finding of one or more violations.

The written responses from Senator Ericksen and Jay Rodne, confirm that Pac Rim Bridges, LLC and its two named governors, do not meet the statutory definition of a lobbyist and that neither Pac Rim nor Senator Ericksen have engaged in lobbying activities that would require registration with the PDC.

Based on these findings staff has determined that, in this instance, no evidence supports a finding of an actual violation warranting further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/50328
50297 04/18/2019 Robert L Fiedler, Glenn Ash International Association of Firefighters Local 1983 International Association of Firefighters Local 1983: Alleged violation of RCW 42.17A.555 by using public facilities to promote a ballot measure. (Apr 2019) RCW 42.17A.555 Case Closed with No Evidence of Violations

This case alleged that International Association of Firefighters Local 1983 (the "Respondent") may have violated RCW 42.17A.555 by using public facilities (Mt. Vernon Fire Department's address) to promote a ballot measure (advertisement supporting Prop 1 fire bond).

PDC staff reviewed the allegations, applicable statutes, rules and reporting requirements, and the responses provided by the Respondent to determine whether they supported a finding of one or more violations. Staff's review found the following: 

The Respondent sponsored a political ad supporting Prop 1 fire bond that included an address of "1901 N LaVenture, ATTN Union Mail Box, Mount Vernon, WA 98273," the address used by the City of Mt. Vernon Fire Dept., its administrative staff, and Fire Station 2. The mailer clearly identified the Respondent as its sponsor, as required under RCW 42.17A.320, and included a specific reference to the union's mailbox. The Respondent timely filed the necessary C-6 reports with the PDC, disclosing its independent expenditures pertaining to Prop 1. 

RCW 42.17A.555 prohibits elected officials and employees of public offices and agencies from using or authorizing the use of public office/agency facilities to promote or oppose any ballot proposition. Activities exempted from this prohibition include, but are not limited to, activities that are "part of the normal and regular conduct of the office or agency." However, whereas a union is not an elected official or public employee, it cannot violate RCW 42.17A.555.

 The Respondent stated it has maintained a mailbox at 1901 N LaVenture Rd Mt. Vernon, WA 98273 for approximately 20 years and such access is a prevailing right under its collective bargaining agreement with the City of Mt. Vernon. The Respondent indicated that the mailer was created by union members during non-work hours on personal, home computers and sent to a printer via personal email. The Respondent also indicated that "no materials were created or distributed at or from any facility at any time and no campaign activity took place outside of regularly scheduled union meetings." 

As a public agency, the City of Mt. Vernon is subject to RCW 42.17A.555. However, the city's practice of allowing the Respondent to use a mailbox located at its fire station appears to be normal and regular conduct for the city under WAC 390-05-273 because the activity is lawful, authorized by the city, and usual (not extraordinary) given the fact that the Respondent has received correspondence of all kinds via the mailbox for several years. 

Based on these findings, PDC staff determined that the Respondent's use of a mailbox located on city property - and the disclosure of this address in political advertising - does not amount to a violation warranting further investigation. The PDC found that no further action was warranted and dismissed the matter in accordance with RCW 42.17A.755(1).

 

 

 

https://www.pdc.wa.gov/browse/cases/50297
50292 04/18/2019 Kaidi Williams Evergreen Yes (Randy Pepple) Evergeen Yes: Alleged Violation of RCW 42.17A.320 for failure to include complete sponsor identification on political advertising. RCW 42.17A.320 Case Closed with Reminder

Allegation: Violation of RCW 42.17A.320 for failure to include complete sponsor identification on political advertising. 

https://www.pdc.wa.gov/browse/cases/50292
50178 04/15/2019 James Busey Barry DePaoli DePaoli, Barry: Alleged violations of RCW 42.17A.555 for use of school district resources to distribute political advertising from Citizens Campaign Committee (EY 19; April 19) RCW 42.17A 555 Resolved through Statement of Understanding

Allegation: Violation of RCW 42.17A.555 for misuse of school district emails to distribute political advertising sponsored by the Citizens Campaign Committee, a political committee in favor of a bond measure for the Lake Chelan School District.

https://www.pdc.wa.gov/browse/cases/50178
49906 04/11/2019 Tony Guzman Juan Eddie Orozco (aka) John Edward Orozco Orozco, Juan: Alleged Violation of RCW 42.17A.555 for use of public facilities to support political campaign expenditures. RCW 42.17A 555 Case Closed with No Evidence of Violations

Allegation: Violation of RCW 42.17A.555 for use of public facilities to support political campaign expenditures.

https://www.pdc.wa.gov/browse/cases/49906
49439 04/03/2019 Andrew Saturn VerifyMore VerifyMore: Alleged Violation of RCW 42.17A.207 for failure to register as an incidental committee as required by SB 5991 which took effect on January 1, 2019. (MARCH 2019) Case Closed with No Evidence of Violations

Allegation: Violation of RCW 42.17A.207 for failure to register as an incidental committee following the creation of the Washington State DISCLOSE Act (SB 5991), which took effect on January 1, 2019.  

https://www.pdc.wa.gov/browse/cases/49439
49254 03/29/2019 Andrew Saturn Linda Oosterman Oosterman, Linda (2): Alleged violations of RCW 42.17A.305, .235 & .310 for failure to report electioneering communications & in-kind contributions, and fully describe advertising expenditures. (Mar 2019) RCW 42.17A.310, RCW 42.17A.305, RCW 42.17A.235 Case Closed with Reminder

This case alleged that Linda Oosterman (the “Respondent”) may have violated RCW 42.17A.305, .235 & .310 by failing to report electioneering communications and in-kind contributions, and fully disclose advertising expenditures for a “Dear Friends” letter and “Vote Linda” color copy & cardstock “strips.” 

PDC staff reviewed the allegations, the applicable statutes, rules and reporting requirements, the responses provided by the Respondent, and the applicable PDC reports filed by the Respondent to determine whether the record supports a finding of one or more violations. 

Based on its findings, staff determined that, in this instance, the Respondent’s failure to fully describe expenditures reported on C-4 reports does not amount to an actual violation warranting further investigation. PDC staff reminded Linda Oosterman about the importance of fully describing advertising and other expenditure details on C-4 reports pursuant to RCW 42.17A.235. 

The Respondent made minor or ministerial errors on required reports, which did not materially impact the public interest. Upon notification of these errors, the Respondent timely amended her reports, making the necessary technical corrections. The PDC found that no further action was warranted and dismissed the matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/49254
48963 03/25/2019 Andrew Saturn Linda Oosterman Oosterman, Linda: Alleged violations of RCW 42.17A.330, .240 & .555 for failure use a recent photo in political advertising, report in-kind contribution; and by using public facilities to assist an election campaign. (Mar 2019) RCW 42.17A.330, RCW 42.17A.555, RCW 42.17A.240 Case Closed with No Evidence of Violations

This case alleged violations of RCW 42.17A.330, .240 & .555 1) for failure to use at least one photo, taken within the last 5 years, in all political advertising (e.g. 2012 photo used for profile image on campaign Facebook page), 2) failure to report use of the photograph as an in-kind contribution to the current campaign; and 3) by using public facilities (e.g. an agency photo) to assist an election campaign. PDC staff reviewed the allegations, applicable statutes, rules, and reporting requirements, the response provided by the Respondent, and the applicable PDC reports filed by the Respondent to determine if they support a finding of one or more violations. Staff’s review found the following:

The Respondent is an elected Commissioner for the Thurston County Public Utility District (PUD) and was a candidate for this office & jurisdiction during election year 2018. As a result, the Respondent is subject to RCW 42.17A.330 and .240, which require 1) at least one photograph used in any political advertising to have been taken within the last five years; and 2) the monetary value of any contributions to be reported. The Respondent is also subject to .555, which prohibits elected officials from using a public office or agency facilities to assist an election campaign. 

The evidence provided by the Complainant included four photos that appeared on the Respondent's campaign Facebook account and a 2012 photo that appears on the PUD's official website, the website of the non-profit organization Pro Truth Pledge, and was published in a county voter's pamphlet. Of the photographic evidence provided, only the Facebook photo(s) appear to constitute political advertising. 

The photos used on the Respondent's campaign Facebook page were taken in 2017 & 2018 by volunteer supporters, who are not professional photographers, using cell phones; the photos were provided to the Respondent at no cost. Subsequently, the photos comply with the age requirements of .330. Per WAC 390-17-405, photos taken by unpaid persons who do not normally charge a fee are "volunteer services" that do not need to be reported as contributions. The value of the photos themselves appear to be de minimis in nature. 

The 2012 photo was taken by Vento Photography and the expenditure was reported by the Respondent to the PDC in April, 2012; this professional photo was gifted by the Respondent to the PUD in 2013, was not used for campaign purposes, and need not be reported as an in-kind contribution to the Respondent under .240. Pro Truth Pledge obtained the 2012 photo from another source & re-posted it without the Respondent's knowledge. The evidence provided by the Complainant was insufficient to demonstrate the 2012 photo was used for political advertising during the Respondent's 2018 election campaign. Furthermore, the professional photo paid for by the Respondent in 2012 was not produced by a public office or agency and therefore does not constitute use of public facilities under .555.

https://www.pdc.wa.gov/browse/cases/48963
48709 03/18/2019 Dave Churchman David Prutzman Prutzman, David: Alleged violations of Chapter 42.17A RCW for failure to register and report as a political committee, and failure to disclose sponsor ID on political advertising (EY 19; Mar 19) RCW 42.17A.205, RCW 42.17A.320, RCW 42.17A.235 Case Closed with Reminder

The complaint alleged David Prutzman violated RCW 42.17A.205 for failing to timely register a political committee, RCW 42.17A.235 for failing to report contributions and expenditures as a political committee and RCW 42.17A.320 for failing to disclose true sponsors. All allegations relate to the of Strong Mayor initiative in Puyallup.

Staff has determined that in this instance, the failure to report expenditures of $108.63 does not amount to an actual violation warranting further investigation. PDC staff is reminding David Prutzman about the importance of the requirements regarding filing accurately and timely in future years in accordance with PDC laws and rules. Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/48709
48521 03/14/2019 Andrew Saturn Up for Thurston County Up for Thurston County (3): Alleged violations of RCW 42.17A.205 for failure to disclose committee officers, .320 for failure to include officer name in on political advertising, .750 for filing false documents with the Commission (EY 18; Mar 19) rcw 42.17a.750, RCW 42.17A.205, RCW 42.17A.320 Case Closed with Written Warning

On March 13, 2019, the Public Disclosure Commission (PDC) received a complaint alleging that the Up for Thurston County (Committee) may have violated RCW 42.17A.205, .320 and .750 (1) by failing to disclose any full committee officer(s) on the Committee Registration (C-1pc) at the time of the initial registration; (2) by knowingly filing a false C-1pc reports with the Commission; and (3) by failing to list Jason Bennett in sponsor identification on political advertising  as the sole controlling individual for Up for Thurston County. 

PDC reviewed the complaint and noted that the Committee did not initially include the information expressly required by law on the C-1pc, but later amended its C-1pc and included both the sponsor and the committee officer. While the Committee failed to include the full committee officer(s) and the name of the committee sponsor on the initial C-1pc and the subsequent two amended C-1pcs, it did eventually include both the sponsor's name and name of the controlling officer of the Committee after reaching out to the PDC for guidance /advice. 

Based on these findings, staff determined that, in this instance, the failure to file an accurate and complete Committee Registration (C-1pc), which was later amended to include all the required information, is a violation that does not warrant further investigation. 

Based on this information, PDC staff dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/48521
48424 03/13/2019 Eli Sanders Google, LLC. Google, LLC (2): Alleged violation of RCW 42.17A.345 and WAC 390-18-050 for failure to promptly provide documents and books of account concerning political advertising, upon request from any person (EY 19; Mar 19) WAC 390-18-050, RCW 42.17A.345 Investigation of Possible Violation

Allegation: Violation of RCW 42.17A.345 and WAC 390-18-050 for failure to provide documents and books of account detailing the exact nature and extent of political advertising services rendered, within 24 hours of request from any person.

https://www.pdc.wa.gov/browse/cases/48424
48311 03/11/2019 Edward Horejs III Jennifer Robertson Robertson, Jennifer: Alleged violations of RCW 42.17A.240 and WAC 390-16-205 for failure to accurately report expenditures (EY 15; Mar 19) WAC 390-16-207, wac 390-16-205, RCW 42.17A.240 Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Edward Horejs on March 5, 2019. The complaint alleged that Jennifer Robertson, a 2015 candidate for Bellevue City Council may have violated RCW 42.17A.240 for failure to accurately and completely disclose in-kind contributions and debts on Summary Full Campaign Contribution and Expenditure reports (C-4 reports), and WAC 390-16-037 and WAC 390-16-205 for failure to accurately disclose sub-vendor breakdowns for expenditures undertaken by the campaign. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Jennifer Robertson; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to accurately and completely break down expenditure details does not amount to a violation warranting further investigation.

Pursuant to WAC 390-37-060(1)(d), Jennifer Robertson will receive a formal written warning concerning failure to accurately and completely disclose expenditure details, including the number of items and sub-vendors actually providing the goods and services for the campaign. The formal written warning will include staff’s expectation that Jennifer Robertson provides detailed descriptions of expenditure details on all future required reports. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/48311
48307 03/11/2019 Andrew Saturn Facebook, Inc. Facebook, Inc. (4): Alleged violations of RCW 42.17A.345 and WAC 390-18-050 for failure to maintain and provide documents and books of account for public inspection (EY 19; Mar 19) WAC 390-18-050, RCW 42.17A.345 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Andrew Saturn on March 1, 2019. The complaint alleged that Facebook Inc., a commercial advertiser, may have violated RCW 42.17A.345 for failure to promptly provide documents and books of account regarding political advertising upon request.

PDC staff reviewed the allegations; the applicable statutes and rules; and the response provided by Facebook Inc. to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, no evidence supports a finding that the complainant made a request for commercial advertiser records relating to political advertising, or that Facebook Inc. denied the complainant access to these records.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/48307
48011 03/06/2019 Roger Lenk Brian Brooks Brooks, Brian & Kennewick SD #17 Board of Directors: Alleged violation of RCW 42.17A.555 by failing to provide required notice of a Prop. 1 bond-related topic & allow the public to express opposing views at its Jan. 9, 2019 Board Meeting. (Mar 19) RCW 42.17A.555 Case Closed with Reminder

This case alleged that Kennewick School District No. 17 Board of Directors Dawn Adams, Brian Brooks, Heather Kintzley, Ron Mabry & Ben Messinger (collectively “the Respondents”) may have violated RCW 42.17A.555 by failing to provide notice of – and give the public an opportunity to express opposing views about – action taken at its January 9, 2019 Board Meeting that supported a ballot proposition.

PDC staff reviewed the allegations and evidence, the applicable statutes, rules and reporting requirements, and the response provided by the Respondents to determine whether they support a finding of one or more violations. 

Based on its findings, staff determined that, in this instance, the Respondent’s January 9, 2019 approved motions to move, adopt, and later rescind a suggestion to send a letter to the newspaper supporting Prop. 1 does not amount to an actual violation warranting further investigation. PDC staff reminded Kennewick School District No. 17 Board of Directors about the importance of 1) not using public facilities to directly or indirectly promote or oppose any ballot propositions; and 2) ensuring the public is provided with adequate notice and an opportunity to express opposing views when the Board takes any action at a public meeting that concerns a ballot proposition. The PDC found that no further action was warranted and dismissed the matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/48011
48010 03/06/2019 Roger Lenk Ron Mabry Mabry, Ron & Kennewick SD #17 Board of Directors: Alleged violation of RCW 42.17A.555 by failing to provide required notice of a Prop. 1 bond-related topic & allow the public to express opposing views at its Jan. 9, 2019 Board Meeting. (Mar 19) RCW 42.17A.555 Case Closed with Reminder

This case alleged that Kennewick School District No. 17 Board of Directors Dawn Adams, Brian Brooks, Heather Kintzley, Ron Mabry & Ben Messinger (collectively “the Respondents”) may have violated RCW 42.17A.555 by failing to provide notice of – and give the public an opportunity to express opposing views about – action taken at its January 9, 2019 Board Meeting that supported a ballot proposition.

PDC staff reviewed the allegations and evidence, the applicable statutes, rules and reporting requirements, and the response provided by the Respondents to determine whether they support a finding of one or more violations. 

Based on its findings, staff determined that, in this instance, the Respondent’s January 9, 2019 approved motions to move, adopt, and later rescind a suggestion to send a letter to the newspaper supporting Prop. 1 does not amount to an actual violation warranting further investigation. PDC staff reminded Kennewick School District No. 17 Board of Directors about the importance of 1) not using public facilities to directly or indirectly promote or oppose any ballot propositions; and 2) ensuring the public is provided with adequate notice and an opportunity to express opposing views when the Board takes any action at a public meeting that concerns a ballot proposition. The PDC found that no further action was warranted and dismissed the matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/48010
48009 03/06/2019 Roger Lenk Ben Messinger Messinger, Ben & Kennewick SD #17 Board of Directors: Alleged violation of RCW 42.17A.555 by failing to provide required notice of a Prop. 1 bond-related topic & allow the public to express opposing views at its Jan. 9, 2019 Board Meeting. (Mar 19) RCW 42.17A.555 Case Closed with Reminder

This case alleged that Kennewick School District No. 17 Board of Directors Dawn Adams, Brian Brooks, Heather Kintzley, Ron Mabry & Ben Messinger (collectively “the Respondents”) may have violated RCW 42.17A.555 by failing to provide notice of – and give the public an opportunity to express opposing views about – action taken at its January 9, 2019 Board Meeting that supported a ballot proposition.

PDC staff reviewed the allegations and evidence, the applicable statutes, rules and reporting requirements, and the response provided by the Respondents to determine whether they support a finding of one or more violations. 

Based on its findings, staff determined that, in this instance, the Respondent’s January 9, 2019 approved motions to move, adopt, and later rescind a suggestion to send a letter to the newspaper supporting Prop. 1 does not amount to an actual violation warranting further investigation. PDC staff reminded Kennewick School District No. 17 Board of Directors about the importance of 1) not using public facilities to directly or indirectly promote or oppose any ballot propositions; and 2) ensuring the public is provided with adequate notice and an opportunity to express opposing views when the Board takes any action at a public meeting that concerns a ballot proposition. The PDC found that no further action was warranted and dismissed the matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/48009
48008 03/06/2019 Roger Lenk Heather Kintzley Kintzley, Heather & Kennewick SD #17 Board of Directors: Alleged violation of RCW 42.17A.555 by failing to provide required notice of a Prop. 1 bond-related topic & allow the public to express opposing views at its Jan. 9, 2019 Board Meeting. (Mar 19) RCW 42.17A.555 Case Closed with Reminder

This case alleged that Kennewick School District No. 17 Board of Directors Dawn Adams, Brian Brooks, Heather Kintzley, Ron Mabry & Ben Messinger (collectively “the Respondents”) may have violated RCW 42.17A.555 by failing to provide notice of – and give the public an opportunity to express opposing views about – action taken at its January 9, 2019 Board Meeting that supported a ballot proposition.

PDC staff reviewed the allegations and evidence, the applicable statutes, rules and reporting requirements, and the response provided by the Respondents to determine whether they support a finding of one or more violations. 

Based on its findings, staff determined that, in this instance, the Respondent’s January 9, 2019 approved motions to move, adopt, and later rescind a suggestion to send a letter to the newspaper supporting Prop. 1 does not amount to an actual violation warranting further investigation. PDC staff reminded Kennewick School District No. 17 Board of Directors about the importance of 1) not using public facilities to directly or indirectly promote or oppose any ballot propositions; and 2) ensuring the public is provided with adequate notice and an opportunity to express opposing views when the Board takes any action at a public meeting that concerns a ballot proposition. The PDC found that no further action was warranted and dismissed the matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/48008
48006 03/06/2019 Roger Lenk Dawn Adams Adams, Dawn & Kennewick SD #17 Board of Directors: Alleged violation of RCW 42.17A.555 by failing to provide required notice of a Prop. 1 bond-related topic & allow the public to express opposing views at its Jan. 9, 2019 Board Meeting. (Mar 19) RCW 42.17A.555 Case Closed with Reminder

This case alleged that Kennewick School District No. 17 Board of Directors Dawn Adams, Brian Brooks, Heather Kintzley, Ron Mabry & Ben Messinger (collectively “the Respondents”) may have violated RCW 42.17A.555 by failing to provide notice of – and give the public an opportunity to express opposing views about – action taken at its January 9, 2019 Board Meeting that supported a ballot proposition.

PDC staff reviewed the allegations and evidence, the applicable statutes, rules and reporting requirements, and the response provided by the Respondents to determine whether they support a finding of one or more violations. 

Based on its findings, staff determined that, in this instance, the Respondent’s January 9, 2019 approved motions to move, adopt, and later rescind a suggestion to send a letter to the newspaper supporting Prop. 1 does not amount to an actual violation warranting further investigation. PDC staff reminded Kennewick School District No. 17 Board of Directors about the importance of 1) not using public facilities to directly or indirectly promote or oppose any ballot propositions; and 2) ensuring the public is provided with adequate notice and an opportunity to express opposing views when the Board takes any action at a public meeting that concerns a ballot proposition. The PDC found that no further action was warranted and dismissed the matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/48006
47998 03/06/2019 Jeanne Martin Our Olympic Communities Enterprise Washington Our Olympic Communities Enterprise Washington: Alleged violations of RCW 42.17A.320 & .335 by failing to identify Top Five Contributors & including false statements of material fact in political adverting (Mar 2019) RCW 42.17A.320, RCW 42.17A.335, RCW 42.17A.240, RCW 42.17A.255, RCW 42.17A.260, WAC 390-18, RCW 42.17A.305 Violation Found by Commission

A complaint was filed with the PDC against Our Olympic Communities Enterprise Washington alleging the committee may have violated RCW 42.17A.320 for failing to fully identify the top five contributors on political advertising; RCW 42.17A.335 by making a false statement of material fact in opposition ads; RCW 42.17A.335 by sponsoring an ad that falsely represents Irene Bowling as an incumbent; RCW 42.17A.320 and WAC 390-18 by failing to clearly identify sponsor identification on political advertising; and RCW 42.17A.260 by failing to timely file Independent Spending and Electioneering Communications (C-6) reports., alleging the Committee may have violated RCW 42.17A.220 by failing to timely deposit contributions within five business days of receipt and RCW 42.17A.235 by failing to timely file Monetary Contribution reports (C-3 reports) and Campaign Summary Receipts and Expenditure reports (C-4 reports). 

At its May 28, 2020 meeting, the Commission found Our Olympic Communities Enterprise WA violated RCW 42.17A.305 by failing to timely file Independent Expenditure reports (C-6 reports) disclosing $151,772.81 in Committee expenditures made for electioneering communications advertisements that supported Tim Sheldon and opposed Irene Bowling and assessed a total civil penalty of $14,000 of which $7,000 is suspended on the following conditions:

  1. The Committee is not found to have committed any further violations of RCW 42.17A or WAC 390 within four years of the date of the final order in this matter. The suspended penalty shall not be assessed based solely upon any remediable violation, minor violation, or error classified by the commission as appropriate to address by a technical correction. 
     
  2. The Committee complies with all PDC reporting requirements.
     
  3. The non-suspended portion of the penalty ($7,000) is paid by the Committee within 30 days of the date of the final order in this matter. If the Committee fails to make timely payment of the non-suspended portion of the penalty, the suspended portion of the penalty shall be immediately become due without further action by the Commission.

Staff determined that in this instance, the remaining allegations do not amount to actual violations warranting further investigation. However, pursuant to WAC 390-37-060(1)(d), Our Olympic Communities Enterprise Washington will receive a formal written warning concerning the Committee’s failure to comply with filing and disclosure requirements.

The formal written warning will include staff’s expectation the Committee will: (1) fully identify Top Five Contributors on all future political advertising, independent expenditures (IE) or electioneering communications (EC); (2) provide the required sponsor identification on all future political advertisements, IE’s and EC’s in accordance with statutes and rules; and (3) file timely and complete C-4 and C-6 reports in future years in accordance with PDC laws and rules, including disclosing the required expenditure detail in accordance with RCW 42.17A.240.  The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules. 

https://www.pdc.wa.gov/browse/cases/47998
47572 02/26/2019 Eli Sanders Facebook, Inc. Facebook, Inc. (3): Alleged violations of RCW 42.17A.345 and WAC 390-18-050 for failure to provide documents and books of account for public inspection as a commercial advertiser (EY 19; Feb 19) WAC 390-18-050, RCW 42.17A.345 Referred to Attorney General by Commission

Allegation: Violation of RCW 42.17A.345 and WAC 390-18-050 for failure to maintain and provide documents and books of account as a commercial advertiser, promptly upon request from any person. The Commission met on January 23, 2020 and February 27, 2020 to consider a stipulation jointly presented by PDC staff and Respondent Facebook, Inc.  At the February meeting, the Commission voted to reject the stipulation and refer the matter to the Attorney General's Office for further action pursuant to RCW 42.17A.755(4).

https://www.pdc.wa.gov/browse/cases/47572
47514 02/25/2019 Andrew Saturn The Olympian The Olympian: Alleged violations of RCW 42.17A for failure to allow public inspection of commercial advertiser records & disclose sponsor ID on ads, and by publishing false statements about a candidate. (Feb 19) RCW 42.17A.335, RCW 42.17A.345, RCW 42.17A.240, RCW 42.17A.320 Case Closed with Reminder

This case alleged that The Olympian (the "Respondent") violated RCW 42.17A.345 by failing to allow public inspection of commercial advertiser records, .335 by publishing false statements re: a candidate (e.g. editorials), and .320 for failure to disclose sponsor information on political ads. 

PDC staff reviewed the allegations, applicable statutes, rules, and the response provided by the Respondent to determine whether it supported a finding of one or more violations. Staff's review showed that the Respondent is a commercial advertiser required to make its documents & books of accounts concerning political advertising & electioneering communications available for public inspection in-person during normal business hours or, if requested electronically, by email or online publication. 

The Respondent published two advertisements for Linda Oosterman's campaign in October, 2018, both of which included sponsor identification as required under RCW 42.17A.320. Between October 19, 2018 and February 12, 2019, the Complainant sent three emails to the Respondent's employees and a message via its website portal requesting commercial advertiser records related to the Oosterman campaign ads, but never received a response. The Complainant indicated he visited the Respondent in-person on February 14, 2019 but was denied access to records, a charge the Respondent denied.

The Complainant failed to fully identify the records sought prior to February 12, 2019 and requested some information outside the scope of RCW 42.17A.345. However, the Respondent failed to respond to the requests, ask for missing information and timely fulfill the portion of the request that fell within the scope of .345 and WAC 390-18-050. The Respondent indicated its belief the such requests were required to be made in-person. However, PDC laws and rules do not specify how requests for commercial advertiser records must be made and WAC 390-18-050 allows the public to request records electronically, which can be satisfied by email or online publication. The Respondent provided the requested records to the Complainant by email on April 22, 2019. 

This complaint also alleged that three editorial articles published by the Respondent between October 27 and November 9, 2018 contained false statements about him, in violation of RCW 42.17A.335, which prohibits a person from sponsoring, with actual malice, a false statement of material fact about a candidate for public office in political advertising or electioneering communications. However, WAC 390-05-290(4) and RCW 42.17A.005(22)(b)(iii) define political advertising and electioneering communications to exclude editorial content in a regularly scheduled new medium that is not controlled by a candidate or committee where payment for the space or time is not normally required. Subsequently, the editorials did not meet the criteria for libel and defamation set forth in .335. 

Based on the information, the PDC found that no further action was warranted and dismissed the matter in accordance with RCW 42.17A.755(1). 

PDC staff reminded the Respondent about the importance of making commercial advertiser documents and books of account open for public inspection during normal business hours for three years following the election to which they pertain. PDC staff clarified that this information can be requested electronically or in-person & conveyed its expectation that the Respondent make such information available to the public in future years in accordance with PDC laws and rules. 



 

https://www.pdc.wa.gov/browse/cases/47514
47381 02/21/2019 Glen Morgan Eric Newman Newman, Eric: Alleged violations of RCW 42.17A.235 & .240 & WAC 390-16-037 for failure to timely report contributions & expenditures and fully describe expenditures in election year 2016. (Feb 2019) RCW 42.17A.240, WAC 390-16-037, RCW 42.17A.235 Case Closed with Reminder
  • Allegation One: Alleged violations of RCW 42.17A.235 & .240 for failure to timely report contributions & expenditures in election year 2016. 
  • Allegation Two: Alleged violations of RCW 42.17A.240 & WAC 390-16-037 by not fully describing expenditures in election year 2016.
https://www.pdc.wa.gov/browse/cases/47381
47303 02/19/2019 Freedom Foundation (Maxford Nelsen) Gerald Hudson SEIU Political Education and Action Fund: Alleged Violation of RCW 42.17A.250, .405, .442 for failure to timely file Out-of-State Poltiical Committee Reports (C-5) and for failure to meet WA registered voter requirements. (FEB 2019) RCW 42.17A.205, RCW 42.17A.405, RCW 42.17A.442 Case Closed with Written Warning

A complaint was filed against Service Employees International Union Political Education & Action Fund (SEIU PEAF), a federal political committee, alleging violations of: (1) RCW 42.17A.250 by failing to timely and accurately file Out-of State Political Committee reports (C-5 reports) as an out-of-state committee: (2) RCW 42.17A.405 by failing to receive $10 from ten registered voters in Washington State prior to making contributions to candidates; and (3) RCW 42.17A.442 by failing to received $10 from ten registered voters in Washington State prior to making contributions to another political committee.

As noted in the complaint return letter, SEIU PEAF failed to timely report $1,534,947 in contributions received from SEIU in Washington, DC for the 2018 elections, and that information was not disclosed until March 12, 2019 when the amended C-5 reports were filed.  While the amount of late reported contributions was significant, there were several mitigating factors considered by staff that included SEIU PEAF: 

(1) disclosed no additional expenditures as having been made in 2018 on the amended C-5 reports; 

(2) timely disclosed the $747,983 in expenditures made as contributions to political committees in Washington state and registered with the PDC on the initial C-5 reports; 

(3) did not spend any of the $1,534,947 in late reported contributions received from SEIU in Washington state; and 

(4) received a total of $8,128,222 in aggregate contributions from SEIU in Washington, DC, so the $747,983 spent in Washington state in 2018 by SEIU PEAF, represented 9.2% of total expenditure activities.

Based on these findings, PDC staff has determined that the facts in this instance do not amount to a finding of an actual violation warranting further investigation.  However, pursuant to WAC 390-37-060(1)(b), PDC staff will be formally warning SEIU PEAF concerning the importance of timely and accurately filing C-5 reports disclosing contribution and expenditure activities undertaken by an out-of-state political committee as required by PDC laws and rules. 

This formal written warning conveys staff’s expectation that SEIU PEAF will fully comply with the C-5 reporting requirements in the future, should the committee make additional contributions to candidates or political committees registered with the PDC in Washington State. The Commission will consider this formal written warning if there are any future PDC law or rule violations by SEIU PEAF.

Based on this information, PDC staff is dismissing the remaining allegations in this matter against the Service Employees International Union Political Education & Action Fund PAC in accordance with RCW 42.17A.755(1).  

 

https://www.pdc.wa.gov/browse/cases/47303
47265 02/19/2019 Delina Cline Don Bradshaw Bradshaw, Don: Alleged violations of RCW 42.17A.320 for failure to disclose sponsor ID on political advertising (EY 17; Feb 19) RCW 42.17A.320 Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Delina Cline on February 14, 2019. The complaint alleged that Don Bradshaw, write-in candidate for Winlock City Council, may have violated RCW 42.17A.320 for failure to disclose sponsor identification on political advertising.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Don Bradshaw; the applicable PDC reports filed by Respondent; and a commercial advertiser disclosure from the Town Crier Community Newspaper, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to disclose sponsor identification on political advertising does not amount to an actual violation warranting further investigation.

Pursuant to WAC 390-37-060(1)(b), Don Bradshaw will receive a formal written warning concerning failure to disclose sponsor identification on political advertising sponsored by the candidate. The formal written warning will include staff’s expectation that Don Bradshaw accurately and completely discloses sponsor identification on any future political advertising. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/47265
47250 02/19/2019 Northwest Accountability Project We the Governed We the Governed: Alleged violations of Chapter 42.17A RCW for failure to report contributions and expenditures, failure to disclose sponsor ID, and failure to report independent expenditures/electioneering communications (Feb 19) RCW 42.17A.235, RCW 42.17A.255, RCW 42.17A.260, RCW 42.17A.305, RCW 42.17A.320 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by the Northwest Accountability Project on March 29, 2019. The complaint alleged that We the Governed, a 2016 political committee, may have violated RCW 42.17A.235 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign; RCW 42.17A.255, .260, and .305 for failure to timely and accurately file Independent Spending and Electioneering Communication reports (C-6 reports), disclosing independent expenditures and electioneering communications; and RCW 42.17A.320 for failure to include sponsor identification and top five contributors on political advertising. 

The complaint also alleged that We the Governed, LLC, may have violated RCW 42.17A.205 for failure to file a Political Committee Registration report (C-1pc report); RCW 42.17A.235 for failure to timely and accurately file C-3 reports and C-4 reports, disclosing contributions and expenditures undertaken by the Campaign; RCW 42.17A.255, .260, and .305 for failure to timely and accurately file C-6 reports, disclosing independent expenditures and electioneering communications; and RCW 42.17A.320 for failure to include sponsor identification and top five contributors on political advertising.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the responses provided by We the Governed; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, insufficient evidence has been provided to support a finding of a violation warranting further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/47250
47222 02/18/2019 Andrew Saturn Thurston County Democratic Women Thurston County Democratic Women: Alleged violations of Chapter 42.17A RCW for failure to re-register as mini-reporting, exceeding mini-reporting limits, and failure to timely report contributions and expenditures (Feb 19) RCW 42.17A.205, RCW 42.17A.235, RCW 42.17A.240, WAC 390-16-125 Case Closed with Reminder
  • Allegation One: Violation of RCW 42.17A.205 for failure to re-register as mini-reporting in 2019.
  • Allegation Two: Violation of WAC 390-16-125 for exceeding mini-reporting limitations without written approval from PDC in 2018.
  • Allegation Three: Violations of RCW 42.17A.235 for failure to timely report contributions and expenditures after exceeding mini-reporting limitations in 2018.
https://www.pdc.wa.gov/browse/cases/47222
47219 02/18/2019 Freedom Foundation (Maxford Nelsen) Washington State Labor Council AFL-CIO PPP Committee Washington State Labor Council AFL-CIO PPP Cmte: Alleged violations of RCW 42.17A.235, RCW 42.17A.235, RCW 42.17A.240, RCW 42.17A.435 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Maxford Nelsen on behalf of the Freedom Foundation on February 14, 2019. The complaint alleged that Washington State Labor Council AFL-CIO PPP Committee (WSLC AFL-CIO PPP), a Continuing Political Committee may have violated: (1) RCW 42.17A.235 and 42.17A.240 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports) disclosing campaign activities and for failure to disclose contributions from individuals identified as “President’s Club” members for calendar years 2014, 2015, 2016 and 2017; and (2) RCW 42.17A.435 for failure to accurately disclose the true source of contributions from “President’s Club” members on C-3 reports. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Dmitri Iglitzin, on behalf of his client WSLC AFL-CIO PPP; and the applicable PDC reports filed by Respondent, to determine whether the record supports a finding of one or more violations.

Although staff’s review of the C-3 and C-4 reports filed by WSLC AFL-CIO PPP for calendar years 2014, 2015, 2016 and 2017, and the committee’s response did not warrant further investigation, staff’s general review of the committee’s campaign activity reports did find instances during 2014, 2015, 2016 and 2017 of late reporting and reports requiring amendments in order to accurately disclose receipts and expenditures. 

Based on these findings staff has determined that, in this instance, failure to timely and accurately disclose WSLC AFL-CIO PPP’s campaign activity for calendar years 2014, 2015, 2016 and 2017 does not amount to an actual violation warranting further investigation or enforcement action.

PDC staff reminded WSLC AFL-CIO PPP about the importance of the timely disclosure of all contribution and expenditure activities, specifically those occurring during the accelerated reporting schedule prior to and after any election in which WSLC AFL-CIO PPP is participating, and the timely filings of all future PDC reports in accordance with the statutes and rules.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/47219
47218 02/18/2019 Glen Morgan Laurie Dolan Dolan, Laurie: Alleged violation of RCW 42.17A.435 for failure to identify source of contribution (EY 16; Feb 19) RCW 42.17A.435 Request for Technical Correction
Allegation: Violation of RCW 42.17A.435 for failure to identify source of refunded contribution from Chris Marr as coming from Regence.
https://www.pdc.wa.gov/browse/cases/47218
47130 02/14/2019 Glen Morgan Laurie Jinkins Jinkins, Laurie: Alleged Violation of RCW 42.17A.700, 710 for failing to disclose a corporation, association, or entity in which an office, ownership, partnership, or financial interest is held. (FEB 2019) RCW 42.17A.700, RCW 42.17A.710 Case Closed with No Evidence of Violations

The complaint alleged Laurie Jinkins may have violated RCW 42.17A.700 and RCW 42.17A.710 by “failing to disclose a corporation, association, or entity on the F-1 Personal Financial Affairs Statement in which an office, ownership, partnership, or financial interest is held.” Specifically, it alleged Jinkins failed to report her controlling interest in LM PAC. 

PDC staff reviewed the allegations listed in the complaint you filed, the statutes, rules and reporting requirements, and the response to the complaint provided by Taki V. Flevaris, attorney representing Laurie Jinkins. 

Based on staff’s review, we found RCW 42.17A.710(1)(g) does not include “political committee” in the list of entities required to be reported on the F-1 Supplement, and historically, PDC staff has not advised F-1 filers to include political committees on the F-1 Supplement when the filer holds a position of committee officer in a political committee. 

Based on these findings staff has determined that, in this instance, the failure to list LM PAC on an F-1 Supplement does not appear to be an actual violation warranting further investigation.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/47130
47128 02/14/2019 Glen Morgan Matthew Randazzo Randazzo, Matthew: Alleged Violation of RCW 42.17A.605 for failure to submit recent photograph at time of lobbyist registration. (FEB 2019) RCW 42.17A.605 Case Closed with No Evidence of Violations
Allegation: Violation of RCW 42.17A.605 for failure to submit recent photograph at time of registration.
https://www.pdc.wa.gov/browse/cases/47128
47080 02/13/2019 Glen Morgan Kittitas County Democratic Central Committee Kittitas County Democratic Central Committee: Alleged violations of RCW 42.17A.235 & .240 for failure to timely & accurately report debt and accurately report expenditures. (Feb 2019) RCW 42.17A.235, RCW 42.17A.240 Case Closed with Reminder
  • Allegation One: Alleged violation of RCW 42.17A.235 & .240 for failure to timely & accurately report debt resulting from March 2, 2018 Stipulation & Judgment with State of WA including $7,912.50 non-suspended portion of civil penalty, $6,740 in fees & costs, and the unpaid portion of $5,217.17 forfeited for over-limit contributions.
  • Allegation Two: Alleged violation of RCW 42.17A.240 by failing to accurately report settlement payments made to State of WA (e.g. recipient name & description of expense fields for 6/21/18 & 12/21/18 payments)
https://www.pdc.wa.gov/browse/cases/47080
47065 02/13/2019 Glen Morgan Pierce County Democratic Central Committee Pierce County Democratic Central Committee (5): Alleged violations of RCW 42.17A.240 for failure to report debt for settlement judgment (Feb 19) RCW 42.17A.240 Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the complaints filed by Glen Morgan on February 3, 2019 and February 5, 2019. Your complaints alleged that the Pierce County Democratic Central Committee (PCDCC), a bona fide political party committee may have violated: (1) RCW 42.17A.235 and .240 by failing to timely and accurately file Monetary Contribution reports (C-3 reports) disclosing proceeds from a low-cost fundraiser; and (2) RCW 42.17A.240 by failing to accurately disclose the unsuspended portion of a penalty as a debt.

PDC staff reviewed the allegations listed in the two complaints filed; the applicable statutes, rules, and reporting requirements; the response provided by Rick Offner, Treasurer for Pierce County Democratic Central Committee; and the applicable PDC reports filed by Respondent, to determine whether the record supports a finding of one or more violations.

Based on staff’s review, the late filed C-3 report cited in PDC Case 46474 was the result of an internal audit conducted by the PCDCC. The Commission encourages the practice of internal review and the submittal of missing or incorrect reports of campaign activities.

Based on these findings staff has determined that, in this instance, failure to timely file one C-3 report disclosing proceeds from a low-cost fundraiser and failure to disclose the October 27, 2017 unsuspended penalty owed to the AGO as a debt, does not warrant further investigation or enforcement action.

Pursuant to WAC 390-37-060(1)(d), the PCDCC received a formal written warning concerning failure to timely and accurately file Summary Full Campaign Contribution and Expenditure reports (C-4 reports) disclosing debt. The formal written warning included staff’s expectation that the PCDCC timely file accurate and complete C-4 reports in future years in accordance with PDC laws and rules. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

In addition, PDC staff reminded the PCDCC about the importance of timely filing all Monetary Contributions reports (C-3 reports) disclosing deposits made, no matter the source of contributions or the amount. The reminder included staff’s expectation that the PCDCC continue utilizing internal controls and audits to ensure timely and accurate reporting of all campaign activities in the future. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/47065
46701 02/07/2019 Glen Morgan Campaign to Prevent Fraud and Protect Seniors Campaign to Prevent Fraud and Protect Seniors: Alleged violation of RCW 42.17A.235 & .240 for failure to timely and accurately report contributions & expenditures. (Feb 2019) RCW 42.17A.240, RCW 42.17A.235 Case Closed with Reminder

This complaint alleged that Campaign to Prevent Fraud and Protect Seniors (the "Respondent" violated RCW 42.17A.235 & .240 by failing to timely & accurately report contributions & expenditures. PDC staff reviewed the allegations, statutes, rules and reporting requirements, and the Respondent's registrations, and found that it submitted its post-general C-4 report disclosing November, 2018 contribution & expenditure activities 30 days late. All other C-4 reports for 2018 were timely filed by the Respondent and the vast majority of the expenditures reported were for legal/compliance and accounting purposes, as opposed to electoral activity. The late-reported contributions & expenditures represented less than 1% of the Respondent's total contributions & expenditures for 2018. 

The Respondent made a good-faith effort to remedy its omission by filing the missing report for November on January 9, 2019. The Respondent indicated that it is a 2016 ballot committee so the financial activity disclosed on the late report did not pertain to an upcoming election or deprive the public of critical information. Based on the findings, PDC staff determined that, in this instance, failure to timely & accurately report contributions & expenditures for November, 2018 does not amount to an actual violation warranting further investigation. 

PDC staff reminded the Respondent about the importance of timely disclosing all contribution & expenditure activities and the timely filing of all future PDC reports, including the C-4 report. The PDC dismissed the matter and did not conduct a more formal investigation into the complaint or pursue further enforcement action in this case. 

https://www.pdc.wa.gov/browse/cases/46701
46694 02/07/2019 Glen Morgan Walla Walla County Demo Central Committee Walla Walla County Demo Central Committee: Alleged violations of RCW 42.17A.235 & .240 for failure to timely and accurately file contributions & expenditures. (Feb 2019) RCW 42.17A.235, RCW 42.17A.240 Case Closed with Written Warning

On February 3, 2019, the Public Disclosure Commission (PDC) received a complaint alleging that the Walla Walla County Democratic Central Committee (Committee), may have violated RCW 42.17A.235 by failing to timely and accurately file contribution and expenditure reports.  

PDC staff reviewed the allegations/complaint and found that the Committee failed to timely file C-3 and C-4 reports in 2018. However, these deficiencies are mitigated by the fact that the Committee showed a good faith effort by putting measures in place to ensure timely filing of all future reports as required by the PDC laws and rules.  Additionally, staff found no prior violations against the Committee. 

Based on these findings, staff determined that the deficiencies found based on the review of the complaint did not warrant further investigation. However, staff issued a warning letter to the Committee regarding the importance of filing timely and accurate contribution and expenditure reports in the future. 

Accordingly, the PDC dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/46694
46655 02/06/2019 Glen Morgan Matthew Haney Haney, Matthew: Alleged violation of RCW 42.17A.605 by failing to submit a recent photograph for lobbyist registration. (Feb 2019) RCW 42.17A.605 Case Closed with Reminder
  • Alleged violation of RCW 42.17A.605 by failing to submit a recent photograph for lobbyist registration
https://www.pdc.wa.gov/browse/cases/46655
46650 02/06/2019 Glen Morgan Paula Swedeen Swedeen, Paula: Alleged violation of RCW 42.17A.605 by failing to submit a recent photograph for lobbyist registration. (Feb 2019) RCW 42.17A.605 Case Closed with Reminder
  • Alleged violation of RCW 42.17A.605 by failing to submit a recent photograph for lobbyist registration
https://www.pdc.wa.gov/browse/cases/46650
46645 02/06/2019 Glen Morgan Melanie Smith Smith, Melanie: Alleged violation of RCW 42.17A.605 by failing to submit a recent photograph for lobbyist registration. (Feb 2019) RCW 42.17A.605 Case Closed with Reminder
  • Allegation: Alleged violation of RCW 42.17A.605 by failing to submit a recent photograph for lobbyist registration
https://www.pdc.wa.gov/browse/cases/46645
46642 02/06/2019 Glen Morgan Nonemacher, Darcy Nonemacher, Darcy: Alleged violation of RCW 42.17A.605 by failing to submit a recent photograph for lobbyist registration. (Feb 2019) RCW 42.17A.605 Case Closed with Reminder
  • Alleged violation of RCW 42.17A.605 by failing to submit a recent photograph for lobbyist registration
https://www.pdc.wa.gov/browse/cases/46642
46636 02/06/2019 Glen Morgan Abbie Zulock Zulock, Abbie: Alleged violation of RCW 42.17A.605 by failing to submit a recent photograph for lobbyist registration. (Feb 2019) RCW 42.17A.605 Case Closed with Reminder

The Respondent is a registered lobbyist, employed by WA Public Employees Association, who failed to submit a recent photograph to the PDC as required per RCW 42.17A.605. The Respondent took corrective action and uploaded the missing photograph on March 25, 2019. Prior attempts to upload the photo were unsuccessful due to technical and account access issues. 

Based on its findings, PDC staff determined that, in this instance, failure to submit a photograph for a lobbyist registration does not amount to an actual violation warranting further investigation. PDC staff reminded the Respondent about the importance of submitting a recent photograph when registering as a lobbyist, maintaining current contact and lobbyist information with the PDC, and the timely filing of all future required lobbyist registration information. The PDC dismissed the matter and did not conduct a more formal investigation into the complaint or pursue further enforcement action in this case.

https://www.pdc.wa.gov/browse/cases/46636
46514 02/05/2019 Glen Morgan Yes for Public Safety Yes for Public Safety: Alleged violation of RCW 42.17A.320 for failure to accurately disclose Top 5 contributors on political advertising. (Jan 2019) RCW 42.17A.320 Case Closed with Reminder

The Respondent sponsored an advertisement supporting Proposition 1 that was mailed out on January 25, 2019. The cost of the mailer was $5,200 and was timely & accurately reported by the Respondent to the PDC. The Respondent disclosed two organizations as the Top 5 Contributors on the mailer. McDaniel Projects made an in-kind contribution of $1,000 to the Respondent on January 16, 2019 and the Respondent failed to include this third contributor in its Top 5 disclosure. When it became aware of the omission, the Respondent made a good-faith effort to remedy the error by updating subsequent ads, including another mailer that was sent to a broader, overlapping audience. Based on these findings, PDC staff has determined that, in this instance, failure to include the third contributor in its Top 5 disclosure did not amount to an actual violation warranting further investigation. 

PDC reminded the Respondent about the importance of timely & accurately disclosing the Top 5 Contributors on all political advertising. The PDC dismissed the matter and did not conduct a more formal investigation into the complaint or pursue further enforcement in this case. 

https://www.pdc.wa.gov/browse/cases/46514
46509 02/05/2019 Glen Morgan Ben Stuckart Stuckart, Ben: Alleged violations of RCW 42.17A.240 and .405 by not accurately reporting in-kind contribution & accepting an over limit in-kind contribution. (Jan 2019) RCW 42.17A.405, RCW 42.17A.240 Case Closed with No Evidence of Violations

A photo of, and quote from, the Respondent appeared in a advertisement supporting Proposition 1 that was sponsored by Yes for Public Safety and mailed on January 25, 2019. The Respondent was President of the Spokane City Council & a mayoral candidate at the time of the mailing. The mailer did not identify the Respondent as a mayoral candidate, was mailed several months before the election for which the Respondent was a candidate, and sought to influence the outcome of an election for which the Respondent was not a candidate. 

The mailer did not appear to be an in-kind contribution to the Respondent because its purpose was to support Proposition 1 and any indirect benefit to the Respondent's mayoral candidacy was incidental and below the contribution limit for the office sought. Based on these findings, staff determined that, in this instance, the Respondent's appearance in an ad supporting a ballot measure did not amount to a finding of an actual violation warranting further investigation. The PDC dismissed the matter and did not conduct a more formal investigation into the complaint or pursue further enforcement in this case.

https://www.pdc.wa.gov/browse/cases/46509
46474 02/04/2019 Glen Morgan Pierce County Democratic Central Committee Pierce County Democratic Central Committee (4): Alleged violation of RCW 42.17A.235 for failure to timely report contributions (EY 18; Feb 19) RCW 42.17A.235 Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the complaints filed by Glen Morgan on February 3, 2019 and February 5, 2019. Your complaints alleged that the Pierce County Democratic Central Committee (PCDCC), a bona fide political party committee may have violated: (1) RCW 42.17A.235 and .240 by failing to timely and accurately file Monetary Contribution reports (C-3 reports) disclosing proceeds from a low-cost fundraiser; and (2) RCW 42.17A.240 by failing to accurately disclose the unsuspended portion of a penalty as a debt.

PDC staff reviewed the allegations listed in the two complaints filed; the applicable statutes, rules, and reporting requirements; the response provided by Rick Offner, Treasurer for Pierce County Democratic Central Committee; and the applicable PDC reports filed by Respondent, to determine whether the record supports a finding of one or more violations.

Based on staff’s review, the late filed C-3 report cited in PDC Case 46474 was the result of an internal audit conducted by the PCDCC. The Commission encourages the practice of internal review and the submittal of missing or incorrect reports of campaign activities.

Based on these findings staff has determined that, in this instance, failure to timely file one C-3 report disclosing proceeds from a low-cost fundraiser and failure to disclose the October 27, 2017 unsuspended penalty owed to the AGO as a debt, does not warrant further investigation or enforcement action.

Pursuant to WAC 390-37-060(1)(d), the PCDCC received a formal written warning concerning failure to timely and accurately file Summary Full Campaign Contribution and Expenditure reports (C-4 reports) disclosing debt. The formal written warning included staff’s expectation that the PCDCC timely file accurate and complete C-4 reports in future years in accordance with PDC laws and rules. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

In addition, PDC staff reminded the PCDCC about the importance of timely filing all Monetary Contributions reports (C-3 reports) disclosing deposits made, no matter the source of contributions or the amount. The reminder included staff’s expectation that the PCDCC continue utilizing internal controls and audits to ensure timely and accurate reporting of all campaign activities in the future. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/46474
46472 02/04/2019 Glen Morgan Tanisha Harris Harris, Tanisha (3): Alleged violation of RCW 42.17A.235 for failure to timely report contributions (EY 16; Feb 16) RCW 42.17A.235 Request for Technical Correction
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Glen Morgan on February 4, 2019. The complaint alleged that Tanisha Harris may have violated RCW 42.17A.235 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing a $1,000 contribution to the 2016 Clark County Council Campaign. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Tanisha Harris; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Tanisha Harris made minor or ministerial errors on required reports, which did not materially impact the public interest. Upon notification of these errors, Tanisha Harris timely amended their reports, making the necessary technical corrections as requested by staff. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).
https://www.pdc.wa.gov/browse/cases/46472
46470 02/04/2019 Glen Morgan Margaret Heldring Heldring, Margaret: Alleged violation of RCW 42.17A.605 for failure to provide recent photograph at time of Lobbyist Registration (EY 19; Feb 19) RCW 42.17A.605 Case Closed with Reminder
Allegation: Violation of RCW 42.17A.605 for failure to provide recent photograph at time of Lobbyist Registration
https://www.pdc.wa.gov/browse/cases/46470
46468 02/04/2019 Glen Morgan Renee Hopkins Hopkins, Renee: Alleged violation of RCW 42.17A.605 for failure to provide photograph at time of registration, and .615 for failure to timely file monthly lobbyist reports (EY 19; Feb 19) RCW 42.17A.605, RCW 42.17A.615 Case Closed with No Evidence of Violations
  • Allegation One: Violation of RCW 42.17A.605 for failure to provide recent photograph at time of Lobbyist Registration.
  • Allegation Two: Violations of RCW 42.17A.615 for failure to file monthly lobbyist reports.
https://www.pdc.wa.gov/browse/cases/46468
46467 02/04/2019 Glen Morgan Johnson Arledge Strategies Johnson Arledge Strategies: Alleged violation of RCW 42.17A.605 for failure to submit recent photograph for Rebecca Johnson at Lobbyist Registration (EY 19; Feb 19) RCW 42.17A.605 Case Closed with Reminder
Allegation: Violation of RCW 42.17A.605 for failure to provide a recent photograph of Rebecca Johnson at the time of Lobbyist Registration.
https://www.pdc.wa.gov/browse/cases/46467
46466 02/04/2019 Glen Morgan Cody Arledge Arledge, Cody: Alleged violation of RCW 42.17A.605 for failure to provide recent photograph at time of Lobbyist Registration (EY 19; Feb 19) RCW 42.17A.605 Case Closed with Reminder
Allegation: Violation of RCW 42.17A.605 for failure to provide a recent photograph at the time of Lobbyist Registration.
https://www.pdc.wa.gov/browse/cases/46466
46465 02/04/2019 Glen Morgan Daniel Strauss Strauss, Daniel: Alleged violation of RCW 42.17A.605 for failure to provide recent photograph at time of Lobbyist Registration (EY 19; Feb 19) RCW 42.17A.605 Case Closed with Reminder
Allegation: Violation of RCW 42.17A.605 for failure to provide a recent photograph at the time of Lobbyist Registration
https://www.pdc.wa.gov/browse/cases/46465
46357 02/01/2019 Peggy Shepard Matthew Larson Larson, Matthew: Alleged violation of RCW 42.17A.575 by appearing in public service announcements during an election year 2017. (Jan 19) RCW 42.17A.575 Case Closed with No Evidence of Violations
  • Allegation: Alleged violation of RCW 42.17A.575 by appearing in public service announcements (e.g. a 4-part series on growth, economic development, adult living community & new hotel) during election year 2017.
https://www.pdc.wa.gov/browse/cases/46357
46332 02/01/2019 Glen Morgan Kevin Ranker Ranker, Kevin (2): Alleged violation of RCW 42.17A.700 for failure to accurately and timely report financial interest in a business entity on Personal Financial Affairs Statement (F-1 report). (Jan 2019) RCW 42.17A.700 Case Closed with Reminder
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Glen Morgan on January 28, 2019. The complaint alleged that Senator Kevin Ranker may have violated RCW 42.17A.700 by failing to accurately and timely report financial interest in a business entity on his Personal Financial Affairs Statement (F-1 report). 

Based on our findings, staff has determined that, in this instance, failure to report financial interest in Coast Policy Group, LLC on F-1 reports for 2014 - 2017 does not amount to an actual violation warranting further investigation. PDC staff is reminding Senator Kevin Ranker about the importance of accurately disclosing all business interests and offices held on his Personal Financial Affairs Statement (F-1 report). 

Senator Kevin Ranker made minor or ministerial errors on required reports, which did not materially impact the public interest. Upon notification of these errors, Senator Kevin Ranker amended his reports, making the necessary technical corrections. The PDC has dismissed the matter and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case.
https://www.pdc.wa.gov/browse/cases/46332
46093 01/29/2019 Glen Morgan Ehren Flygare Advocates, Inc.: Alleged violations of RCW 42.17A.615 for failure to timely report lobbying activities as a lobbyist and .605 for failure to submit recent photograph at time of registration (EY 18; Jan 19) RCW 42.17A.605, RCW 42.17A.615 Resolved through Statement of Understanding

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Glen Morgan on January 28, 2019. The complaint alleged that Ehren Flygare/Advocates Inc., a registered lobbyist with a contract lobbying firm registered with the PDC, may have violated RCW 42.17A.615 by failing to timely file Lobbyist Monthly Expense Reports (L-2 Reports) disclosing lobbying expenditures for calendar years 2016, 2017, and 2018, and RCW 42.17A.605 by failing to provide a recent photograph of Ehren Flygare at the time he filed his Lobbyist Registration  (L-1 report). 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the responses provided by Ehren Flygare; the applicable PDC reports filed by Respondent; and the Lobbyist Application revision history screen; and queried the Respondent’s data in the PDC lobbyist compensation and expenses by source database, to determine whether the record supports a finding of one or more violations.  

The $450 penalty assessed resolves the allegations concerning the failure to timely and accurately file L-2 reports for calendar years 2016, 2017, and 2018, disclosing lobbying compensation and activities, including personal contributions made to legislators. In addition, Mr. Flygare has provided a photograph to comply with the lobbyist picture requirement as part of the L-1 filing requirements.  

Based on this information and the facts that Ehren Flygare/Advocates, Inc. has no prior PDC violations, demonstrated a good-faith effort to bring reports into compliance, and has hired a professional to file his PDC lobbying reports going forward, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1). 
 

https://www.pdc.wa.gov/browse/cases/46093
46091 01/29/2019 Andreas Koeppen John Marchione Marchione, John: Alleged violation of RCW 42.17A.555 for misuse of public facilities to support Candidate Birney (EY 19; Jan 19) RCW 42.17A.555 Case Closed with No Evidence of Violations
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Andrew Koeppen on January 24, 2019. The complaint alleged that Angela Birney, Tanika Padhye, and John Marchione (Respondents) may have violated RCW 42.17A.555 by misusing public facilities to support the election campaign of candidate Birney.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the response provided by Respondents to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, no evidence supports a finding of an actual violation warranting further investigation.
Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).
https://www.pdc.wa.gov/browse/cases/46091
46090 01/29/2019 Andreas Koeppen Tanika Padhye Padhye, Tanika: Alleged violation of RCW 42.17A.555 for misuse of public facilities to support election campaign of Candidate Birney (EY 19; Jan 19) RCW 42.17A.555 Case Closed with No Evidence of Violations
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Andrew Koeppen on January 24, 2019. The complaint alleged that Angela Birney, Tanika Padhye, and John Marchione (Respondents) may have violated RCW 42.17A.555 by misusing public facilities to support the election campaign of candidate Birney.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the response provided by Respondents to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, no evidence supports a finding of an actual violation warranting further investigation.
Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).
https://www.pdc.wa.gov/browse/cases/46090
46089 01/29/2019 Andreas Koeppen Angela Birney Birney, Angela: Alleged violation of RCW 42.17A.555 for authorizing the use of public facilities to support an election campaign. (EY 19; Jan 19) RCW 42.17A.555 Case Closed with No Evidence of Violations
Dear Andrew Koeppen:
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Andrew Koeppen on January 24, 2019. The complaint alleged that Angela Birney, Tanika Padhye, and John Marchione (Respondents) may have violated RCW 42.17A.555 by misusing public facilities to support the election campaign of candidate Birney.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the response provided by Respondents to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, no evidence supports a finding of an actual violation warranting further investigation.
Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).
https://www.pdc.wa.gov/browse/cases/46089
45913 01/25/2019 James Brewer Seattle School District Seattle School District: Alleged violation of RCW 42.17A.555 by using public facilities to promote a ballot proposition. (Jan 19) RCW 42.17A.555 Case Closed with Reminder

A complaint was filed against officials of the Seattle School District (SSD) alleging violations of RCW 42.17A.555 by using school district facilities to produce and distribute information that supported two SSD levy measures, Proposition #1, the Educational Program and Operations (EP&O) levy, and Proposition #2, the Building Excellence V (BEX V) Capital levy, both of which appeared on the February 12, 2019 special election ballot.

Staff's review found that SSD officials produced and distributed information about Proposition #1 and #2 for the February 12, 2019 special election, and that information was communicated in the district’s normal and regular manner.  Staff found that the majority of the information reviewed was a fair and objective presentation of the facts, however there was information that contained statements of opinion rather than facts or were not completely objective concerning the two levies.  

PDC staff has determined the facts in this instance do not warrant further investigation.  However, PDC staff reminded officials of the Seattle School District concerning the importance of communicating factual and objective bond and levy election information to all citizens of the district, without including potential statements of opinions, as required by PDC laws, rules and PDC Interpretation #01-03.  

Based on this information, the PDC has dismissed the complaint in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/45913
44956 01/11/2019 Dave Churchman Reachout Washington PAC Reachout Washington PAC: Alleged violations of RCW 42.17A.205 and .235 for failure to timely register as a political committee and report contributions and expenditures (EY 19; Jan 19) RCW 42.17A.235, RCW 42.17A.205 Case Closed with No Evidence of Violations
The complaint alleged that Reachout Northwest may have violated RCW 42.17A.205 by failing to timely register as a political committee within two weeks of the expectation of contributions and expenditures in support of a ballot proposition and RCW 42.17A.235 for failing to timely report contributions and expenditures as a political committee under the Full Reporting option.

PDC staff reviewed the allegations; the applicable statutes, rules and reporting requirements, and the response provided by David McMullen, Registered Agent, Reachout Northwest and Tom Perry, Treasurer Reachout Washington.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/44956
44870 01/10/2019 John Kelly 26th Legislative District Democrats 26th Legislative District Democrats: Alleged violation of RCW 42.17A.205 for failure to timely report changes to Political Committee Registration (C-1pc) within 10 days of the change. (Jan 2019) RCW 42.17A.205 Resolved as Remedial
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by John Kelly on January 9, 2019. The complaint alleged that 26th Legislative District Democrats may have violated RCW 42.17A.205 by failing to timely report changes to its Political Committee Registration (C-1pc) within ten days of the change. 

Based on our findings, staff has determined that, in this instance, failure to timely file a C-1pc reporting officer changes does not amount to a violation warranting further investigation.
The alleged non-compliance that appears to constitute a violation of PDC laws and rules made by 26th Legislative District Democrats is remedial in nature and does not warrant further investigation or enforcement action. The violation involved expenditures totaling no more than $1000, occurred more than 30 days before the election, were inadvertent and minor in nature, and did not materially affect the public interest. The 26th Legislative District Democrats took corrective action as required by law for a remedial violation (within 5 business days after notification by PDC staff, or within 21 days after a report was due to be filed). The 26th Legislative District Democrats also substantially met all other required filing due dates within the previous 12-month period.
The PDC has dismissed the matter and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case.
https://www.pdc.wa.gov/browse/cases/44870
44855 01/10/2019 Daniel White Peninsula School District Peninsula School District: Alleged violations of RCW 42.17A.555 for using public agency facilities to promote or oppose a ballot proposition. (Jan 19) RCW 42.17A.555 Case Closed with Reminder
A complaint was filed against officials of the Peninsula School District (PSD) alleging violations of RCW 42.17A.555 by using school district facilities to produce and distribute information that supported a PSD bond measure that appeared on the April 24, 2018 special  election ballot.

Staff’s review found that officials of the Peninsula School District produced and distributed information about the April 24, 2018 bond measure and communicated that information in their normal and regular manner.  Staff noted that other than the one exception listed in the letter, the information distributed by the district was an objective and fair presentation of the facts, which staff has determined in this instance does not warrant further investigation.   

However, PDC staff reminded officials of the Peninsula School District concerning the importance of communicating factual bond and levy election related information to all citizens of the district, without including potential statements of opinions for all future elections, as required by PDC laws, rules and PDC Interpretation #01-03.   

Based on this information, the PDC has dismissed the complaint in accordance with RCW 42.17A.755(1).  
https://www.pdc.wa.gov/browse/cases/44855
44695 01/07/2019 Glen Morgan Pierce County Democratic Central Committee Pierce County Democratic Central Committee: Alleged violation of RCW 42.17A.205 for failure to timely report changes to Political Committee Registration (C-1pc) within 10 days of the change. (Jan 2019) RCW 42.17A.205 Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the complaints filed by Glen Morgan on October 23, 2018 and January 3, 2019. The complaints alleged that the Pierce County Democratic Central Committee (PCDCC), a bona fide political party committee may have violated: (1) RCW 42.17A.235 and .240 by failing to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign; and (2) RCW 42.17A.205 by failing to timely file an amended Committee Registration (C-1pc report) within ten days disclosing any material change in the committee information.

PDC staff reviewed the allegations listed in the two complaints filed; the applicable statutes, rules, and reporting requirements; the response provided by Dominick Bergeron, former Treasurer for Pierce County Democratic Central Committee; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on staff’s review, the alleged late and incomplete filed C-3 and C-4 reports cited in the two complaints were primarily caused by a Committee reorganization and changes in officers, but we noted that the Committee implemented additional internal controls to ensure compliance by creating an oversight committee, by conducting an internal audit, and additional training.  These steps were taken, in part, by the Pierce County Democratic Central Committee to comply with the provisions of the settlement agreement. 

Based on these findings staff has determined that, in this instance, failure to timely and accurately file 19 filed C-3 and C-4 reports, including amendments, mostly disclosed little monetary activity, or were filed as a result of an internal audit process conducted by PCDCC, and therefore does not warrant further investigation or enforcement action.

Pursuant to WAC 390-37-060(1)(d), the PCDCC received a formal written warning concerning failure to timely and accurately file Monetary Contributions reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports) disclosing contribution and expenditure activities and failure to timely file an amended Committee Registration (C-1pc report) disclosing material changes. The formal written warning included staff’s expectation that PCDCC timely file accurate and complete C-3, C-4 and C-1pc reports in future years in accordance with PDC laws and rules. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.
 

https://www.pdc.wa.gov/browse/cases/44695
44685 01/07/2019 Glen Morgan Kevin Ranker Ranker, Kevin: Alleged violation of RCW 42.17A.700 for failure to accurately and timely report real estate activity on Personal Financial Affairs Statement (F-1 report). (Jan 2019) RCW 42.17A.700 Case Closed with Reminder
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Glen Morgan on January 3, 2019. The complaint alleged that Senator Kevin Ranker may have violated RCW 42.17A.700 by failing to accurately and timely report real estate activity on his Personal Financial Affairs Statement (F-1 report). 

Based on our findings, staff has determined that, in this instance, failure to report financial interest in the lot property on F-1 reports for 2013 - 2017 does not amount to an actual violation warranting further investigation. 
PDC staff is reminding Senator Kevin Ranker about the importance of accurately disclosing all real estate activity on his Personal Financial Affairs Statement (F-1 report). 

Senator Kevin Ranker made minor or ministerial errors on required reports, which did not materially impact the public interest. Upon notification of these errors, Senator Kevin Ranker amended his reports, making the necessary technical corrections. 

The PDC has dismissed the matter and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case.
https://www.pdc.wa.gov/browse/cases/44685
44372 12/27/2018 Conner Edwards Up for Thurston County Up for Thurston County (2): Alleged violations of Chapter 42.17A RCW for failure to include sponsor name on registration, disclose proper sponsor ID, and designate earmarked contributions (EY 18; Dec 18) RCW 42.17A.205, RCW 42.17A.270, RCW 42.17A.320, RCW 42.17A.405, RCW 42.17A.420 Case Closed with Written Warning
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Conner Edwards on December 18, 2018. The complaint alleged that Up for Thurston County may have violated RCW 42.17A.320 for failure to disclose the name of controlling individuals or entities on political advertising; RCW 42.17A.205 for failure to disclose committee sponsorship by Puget Sound Energy after they made a contribution, constituting 100% of total contributions, on the day the committee was formed; RCW 42.17A.270 for failure to designate contributions earmarked to support election campaign of Candidate Oosterman; and RCW 42.17A.420 for making an earmarked in-kind contribution to Candidate Oosterman exceeding $5000, in the period beginning 21 days before an election. 

PDC staff reviewed your allegations; the applicable statutes, rules, and reporting requirements; the responses provided by Up for Thurston County; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, failure to disclose Puget Sound Energy as the 100% sponsor of Up for Thurston County on the day the committee was formed, and to include their sponsorship on political advertising, do not amount to actual violations warranting further investigation. 

Pursuant to WAC 390-37-060(1)(b), Up for Thurston County will receive a formal written warning concerning their failure to disclose the committee’s sponsorship by Puget Sound Energy at the time of registration, and failure to disclose the committee’s sponsorship by Puget Sound Energy on political advertising mailed within 21 days of the General Election. The formal written warning will include staff’s expectation that Up for Thurston County timely, accurately, and completely discloses committee sponsorship in the future. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).
https://www.pdc.wa.gov/browse/cases/44372
44370 12/27/2018 Jason Raines John Henry Henry, John (2): Alleged violation of RCW 42.17A.710 for failure to accurately and completely disclose financial activities in calendar year 2017. RCW 42.17A.710 Case Closed with Reminder
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Jason Raines on December 18, 2018. The complaint alleged that John Henry may have violated RCW 42.17A.710 for failure to accurately file a Personal Statement of Financial Affairs (F-1 report), certifying financial activities for calendar year 2017. 

PDC staff reviewed your allegations; the applicable statutes, rules, and reporting requirements; the response provided by John Henry; and the applicable PDC reports filed by Respondent to determine whether the record supports a finding of one or more violations. 

Based on these findings staff has determined that, in this instance, filing an F-1 report certifying the wrong reporting period does not amount to an actual violation warranting further investigation. PDC staff is reminding John Henry about the importance of the accurate, complete, and timely disclosure of financial affairs, and the complete and correct submission of reports of financial affairs in the future, in accordance with PDC laws and rules. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).
https://www.pdc.wa.gov/browse/cases/44370
44063 12/17/2018 Cheryl Aichele Southwest WA Electricians PAC 48 of WA Southwest WA Electricians PAC 48 of WA: Alleged violations of RCW 42.17A.405 and .460 for making over-limit earmarked contributions (EY 18; Dec 18) RCW 42.17A.405, RCW 42.17A.460 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on December 12, 2018. Your complaint alleged that Southwest WA Electricians PAC 48 of WA (PAC 48), a registered political committee, may have violated RCW 42.17A.405 for making over-limit contributions to two candidate campaigns and RCW 42.17.460 for failure to report contributions earmarked for the same two candidates.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by IBEW 48 Business Manager & Financial Secretary on behalf of PAC 48; the applicable C-3 and C-4 reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

No evidence was found that PAC 48 made over-limit contributions to either of the 2018 candidate campaigns referenced above or to indicate that that funds received by CCDCC were earmarked as defined in RCW 42.17A.460 by PAC 48 or were otherwise specifically intended to benefit any of the same candidates.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/44063
44062 12/17/2018 Cheryl Aichele Monica Stonier Stonier, Monica (2): Alleged violations of RCW 42.17A.405 for accepting over-limit contributions (EY 18; Dec 18) RCW 42.17A.405 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on December 12, 2018. Your complaint alleged that Monica Stonier, State Representative, in the 49th Legislative District running for re-election in the 2018 election, may have violated RCW 42.17A.405 for accepting over-limit contributions from the committee Southwest Wa Electricians PAC of WA (PAC 48), including a direct monetary contribution and a contribution made through the Clark County Democratic Central Committee earmarked for the Elect Monica Stonier campaign.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Marsha Manning, Treasurer for Elect Monica Stonier; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

No evidence was found to indicate that funds received by CCDCC from PAC 48 were earmarked as defined in RCW 42.17A.460 by PAC 48 or otherwise specifically intended to benefit the Elect Monica Stonier campaign.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/44062
43945 12/13/2018 David Hammond Lincoln County Republican Central Committee Lincoln County Republican Central Committee: Alleged violations of RCW 42.17A.220 & .235 for failure to timely deposit contributions and timely & accurately report contributions for 2016 & 2018. (Dec 18) RCW 42.17A.220, RCW 42.17A.235 Case Closed with Written Warning
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by David Hammond on December 5, 2018. The complaint alleged that the Lincoln County Republican Central Committee (Committee), a bona fide county political party committee, may have violated RCW 42.17A.220 by failing to timely deposit monetary contributions received into the committee bank account, and RCW 42.17A.235 and .240 by failing to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports) disclosing contribution and expenditure activities undertaken by the Committee in 2016 and 2018.

PDC staff reviewed the allegations listed in the complaint, relevant statutes, rules and reporting requirements, the C-3 and C-4 reports filed by the Committee, and the response from the Committee’s Officers. 

Based on these findings, staff has determined that, in this instance, the Committee’s failure to timely file C-3 reports for calendar years 2016 and 2018 does not warrant further investigation or pursuing further enforcement action in this case.
Pursuant to WAC 390-37-060(1)(b), the Lincoln County Republican Central Committee will receive a formal written warning concerning its failure to timely file C-3 reports for calendar years 2016 and 2018.  The formal written warning will include staff’s expectation that the Lincoln County Republican Central Committee will timely file C-3 reports in future years in accordance with PDC laws and rules. The Commission may consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.
Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1).
https://www.pdc.wa.gov/browse/cases/43945
43940 12/13/2018 Freedom Foundation (Maxford Nelsen) Amalgamated Transit Union Legislative Council of Washington Amalgamated Transit Union Legislative Council of Washington: Alleged violation of RCW 42.17A.205 for failure to timely & accurately register as a political committee. (Dec 18) RCW 42.17A.205 Resolved through Statement of Understanding

A complaint was filed against the Amalgamated Transit Union Legislative Council of Washington State (ATULC) alleging possible violations of: (1) RCW 42.17A.205 by failing to register as a political committee by completing a Committee Registration (C-1pc report) disclosing committee information; and (2) RCW 42.17A.235 and .240 by failing to timely file Monetary Contributions reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports) as required for a political committee disclosing contribution and expenditure activities undertaken during calendar years 2014 through 2018.

ATULC has been registered with the PDC as a Lobbyist Employer dating back to at least 1996, filing Annual Report of Lobbyist Employers (L-3 reports) and the Monthly Lobbyist Employer Contributions report (L-3c reports) reports disclosing expenditures made to hire a contract lobbyist to lobby, and contributions that were made to candidates and political committees.

Staff's investigation (See hyperlink for the Report of Investigation with Exhibits PDF below) focused on ATULC activities undertaken during CY 2016, that involved ATULC making a total of $101,443 in expenditures that included $35,451 in monetary contributions made to 2016 candidates for public office.  In the response, ATULC’s percentage of expenditures for contributions made to total contributions represented 35% for calendar year 2016, and PDC staff’s review of the L-3 report filed by the ATULC disclosed that Johnson Arledge Strategies, a contract lobbying firm, received a total of $25,200 in compensation to lobby during calendar year 2016.  The L-3 report for 2016 was required to have been filed the last day of February 2017 and was filed almost one year late on January 31, 2018. 

In addition, staff’s review found the L-3c reports filed by ATULC for calendar year 2016 were timely filed disclosing 41 monetary contributions totaling $34,500 except for one contribution disclosed one day late.

ATULC is a Lobbyist Employer registered and reporting with the PDC and one of its primary purposes is to support legislation through lobbying efforts, to which ATULC devotes significant resources and time on.  ATULC also spends resources for ATU local members and membership services, transportation and transit issues, and overhead, and ATULC’s stated goals and mission extend beyond making contributions to candidates for public office and political committees. 

PDC staff found no evidence of a material violation that would require conducting a more formal investigation into your complaint or pursuing enforcement action in this instance concerning ATULC being a political committee.  Based on our review of the facts, the majority of ATULC activities do not involve making contributions to candidates for public office, and do not appear to involve electoral political activity at all.  ATULC’s percentage of expenditures for monetary contributions to candidates and political committees was 35% in 2016, and 30% in 2018, respectively, however staff noted that 33 of the 41 contributions made in 2016, were made on two dates, June 3, 2016 (21 contributions), and September 16, 2016 (11 contributions).

PDC staff noted that more than 80% of the ATULC contributions made to candidates for public office in 2016, were made over the course of two days, whereas its lobbying and membership outreach and services were pretty much ongoing throughout the calendar year.  Although the ATULC made expenditures in support of candidates, the totality of the evidence does not suggest that ATULC is a political committee, because the making of those expenditures was not its primary purpose, or even one of its primary purposes.

On April 2, 2020, ATULC completed a Statement of Understanding (SOU) and paid a $150 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), acknowledging a violation of RCW 42.17A.630 for failing to timely file the Annual Report of Lobbyist Employers (L-3 reports) for calendar year 2016.  The $150 penalty assessed in this matter resolves the issue of the late filed L-3 report for 2016. 

Based on this information, PDC staff is dismissing this matter against the Amalgamated Transit Union Legislative Council of Washington State in accordance with RCW 42.17A.755(1).  

https://www.pdc.wa.gov/browse/cases/43940
43895 12/12/2018 Cheryl Aichele 17th Legislative District Democrats 17th Legislative District Democrats (3): Alleged violations of Chapter 42.17A RCW for failure to timely and accurately deposit and report contributions and committee officers (Dec 18) RCW 42.17A.205, RCW 42.17A.220, RCW 42.17A.270, RCW 42.17A.425, RCW 42.17A.460, WAC 390-17-015 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on December 7, 2018. Your complaint alleged that the 17th Legislative District Democrats, a bona fide legislative district party committee, may have violated: (1) RCW 42.17A.205 by failing to accurately and completely disclose committee officers on the Committee Registration (C-1pc report); (2) RCW 42.17A.425 for allowing persons not identified as committee officers on the C-1pc to authorize expenditures; (3) RCW 42.17A.220 for failure to timely deposit contributions within five business days of receipt; (4) RCW 42.17A.270 for failure to timely and accurately report earmarked contributions and WAC 390-17-015 for improper transfer of earmarked contributions; and (5) RCW 42.17A.460 for failure to report earmarked contributions as made from both the original contributor and the party as a conduit of earmarked contributions.

The complaint also alleged violations RCW 42.17A.490 regarding the limitations on use of contributions for a different office which is not applicable to bona fide party committees. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response(s) provided by the 17th Legislative District Democrats and Committee Chair, Harrison Toepfer; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on these findings staff has determined that, in this instance, failure to timely and accurately file a small number of C-3 and C-4 reports that included minor data entry errors, does not amount to an actual violation warranting further investigation.

PDC staff reminded the 17th LD about the importance of the timely disclosure of all contribution and expenditure activities, including the received date of contributions, and the timely filing of the C-1pc disclosing material changes, in future calendar years in accordance with the statutes and rules.

https://www.pdc.wa.gov/browse/cases/43895
43859 12/11/2018 Cheryl Aichele Tanisha Harris Harris, Tanisha (2): Alleged violations of Chapter 42.17A RCW for accepting over-limit contributions and failure to accurately report contributions and expenditures (EY 16; Dec 18) RCW 42.17A.240, RCW 42.17A.405, WAC 390-16-034 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaints filed on December 7 and December 12, 2018. Your complaints alleged that Tanisha Harris, candidate for State Representative in 17th Legislative District in the 2016 and 2018 elections, and a candidate for Clark County Council in the 2016 election, may have violated: (1) RCW 42.17A.405 by accepting over-limits contributions for her two 2016 election campaigns, and the 2018 election campaign; (2) RCW 42.17A.240 by failing to accurately report aggregate totals for monetary and in-kind donations and by failing to report receipt of in-kind contributions on Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports); and (3) RCW 42.17A.240 and WAC 390-16-034 by failing to disclose the required occupation and employer information for individuals contributing more than $100 in the aggregate.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Marsha Manning, Treasurer for the three Elect Tanisha Harris campaigns referenced in the complaints; the applicable C-3 and C-4 reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on these findings staff has determined that, in this instance, failure to accurately disclose aggregate totals for individual contributors to the 2016 State Representative and 2016 County Council campaigns and failure to accurately disclose the occupation for one donor after their aggregate total exceeded $100 for the 2018 State Representative campaign, does not amount to an actual violation warranting further investigation.

PDC staff reminded Tanisha Harris about the importance of the timely and accurate disclosure of all contribution and expenditure activities, including individual donor information and aggregate totals of all future PDC reports in accordance with the statutes and rules.

https://www.pdc.wa.gov/browse/cases/43859
43855 12/11/2018 Cheryl Aichele Clark County Democratic Central Committee Clark County Democratic Central Committee (3): Alleged violations of Chapter 42.17A RCW (Dec 18) RCW 42.17A.230, RCW 42.17A.235, RCW 42.17A.240, RCW 42.17A.270, WAC 390-16-037, WAC 390-17-015 Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the complaints filed on December 7 and December 12, 2018. The complaints alleged that the Clark County Democratic Central Committee, a bona fide county party committee registered with the Public Disclosure Commission, may have violated: (1) RCW 42.17A.230 for failure to timely and accurately report contributions from low-cost fundraisers, and failure to timely deposit contributions from fundraisers; (2) RCW 42.17A.235 for failure to timely report contributions and expenditures and failure to maintain sufficient books of account; (3) RCW 42.17A.240 and WAC 390-16-037 for failure to accurately report in-kind contributions and expenditures, expenditure details generally, and failure to report proceeds from fundraisers; (4) RCW 42.17A.270 for failure to timely and accurately report earmarked contributions and WAC 390-17-015 for improper transfer of earmarked contributions; and (5) RCW 42.17A.460 for failure to report earmarked contributions as made from both the original contributor and the party as a conduit of earmarked contributions.

The complaint also alleged violations RCW 42.17A.430 regarding the disposal of funds and RCW 42.17A.555 regarding the use of public facilities, neither of which are applicable to bona fide party committees. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Walter Smith, legal counsel for the Clark County Democratic Central Committee (CCDCC); the applicable C-3 and C-4 reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Staff found that CCDCC made several errors in reporting their 2016, 2017 and 2018 campaign activities that required amendments to be submitted to correct missing, incorrect or incomplete data regarding contributions and expenditures. Many of these errors were corrected by the committee after receiving the complaint and none of those errors appear to have been intentional or otherwise meant to mislead the public, and they were not material. 

Based on these findings, staff has determined that, in this instance, for calendar years 2016, 2017 and 2018, CCDCC’s failure to disclose specific expenditures timely and include the required description, failure to timely report a monetary contribution, reporting incorrect employer and occupation information for individual contributors giving more than $100 in the aggregate, and depositing a small number of contributions late, does not amount to an actual violation warranting further investigation.

Pursuant to WAC 390-37-060(1)(b), the Clark County Democratic Central Committee received a formal written warning concerning failure to accurately and timely disclose all contribution and expenditures, including detailed expenditure descriptions, all occupation and employer information for individual donors and timely deposits of contributions received. The formal written warning included staff’s expectation that CCDCC accurately and timely files all future required reports of contributions and expenditures and makes deposits within five business days of receipt of contributions. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.
 

https://www.pdc.wa.gov/browse/cases/43855
43709 12/07/2018 Freedom Foundation (Maxford Nelsen) Williams Plant Services Williams Plant Services: Alleged violations of RCW 42.17A.495 & WAC 390-17 for failure to obtain employee authorization forms that comply with requirements & annually provide required notices. (Nov 18) RCW 42.17A.495, WAC 390-17-100, WAC 390-17-110 Case Closed with Written Warning

The complaint alleged that United Association of Plumbers and Pipefitters Local 598, PDC Case 43672, Plumbers & Steamfitters Local 598 PAC, PDC Case 43673, and 35 employer/contractors, PDC Cases 43675-43709, may have violated RCW 42.17A.495, WAC 390-17-100, and WAC 390-17-110: (1) by failing to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) by failing to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination for not contributing.   The statute and rules primarily apply to the employer/contractors, but also prohibit the union and the employer/contractors from discriminating against a union member who does not make political contributions.


Staff found that the current authorization form does not conform to the requirements in RCW 42.17A.495 and WAC 390-17-100, and that many of the employer/contractors have not been sending out the required annual notification to employees who have funds withheld for PAC contributions, as required by WAC 390-17-110.  The employer/contractors rely on the union to provide an authorization form that complies with the law and rules.  Staff made it clear what changes need to be made to the written authorization and annual notification.  The union, working with and on behalf of the employer/contractors, has developed an authorization form and annual notification that meets the requirement of the statute and rules.  The respondents have stated that they will incorporate the changes to the authorization form and annual notification.


Staff determined that, in this instance, the failure of the 35 employer/contractor respondents to fully comply with the law does not amount to an actual violation warranting further investigation.  However, pursuant to WAC 390-37-060(1)(b), the 35 employer/contractor respondents received a formal written warning concerning: (1) their failure to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) their failure to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination by the employer and the union for not contributing.  The employer/contractors were informed that the Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.  Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).
https://www.pdc.wa.gov/browse/cases/43709
43708 12/07/2018 Freedom Foundation (Maxford Nelsen) Washington Building Trades Washington Building Trades: Alleged violations of RCW 42.17A.495 & WAC 390-17 for failure to obtain employee authorization forms that comply with requirements & annually provide required notices. (Nov 18) RCW 42.17A.495, WAC 390-17-100, WAC 390-17-110 Case Closed with Written Warning

The complaint alleged that United Association of Plumbers and Pipefitters Local 598, PDC Case 43672, Plumbers & Steamfitters Local 598 PAC, PDC Case 43673, and 35 employer/contractors, PDC Cases 43675-43709, may have violated RCW 42.17A.495, WAC 390-17-100, and WAC 390-17-110: (1) by failing to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) by failing to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination for not contributing.   The statute and rules primarily apply to the employer/contractors, but also prohibit the union and the employer/contractors from discriminating against a union member who does not make political contributions.


Staff found that the current authorization form does not conform to the requirements in RCW 42.17A.495 and WAC 390-17-100, and that many of the employer/contractors have not been sending out the required annual notification to employees who have funds withheld for PAC contributions, as required by WAC 390-17-110.  The employer/contractors rely on the union to provide an authorization form that complies with the law and rules.  Staff made it clear what changes need to be made to the written authorization and annual notification.  The union, working with and on behalf of the employer/contractors, has developed an authorization form and annual notification that meets the requirement of the statute and rules.  The respondents have stated that they will incorporate the changes to the authorization form and annual notification.


Staff determined that, in this instance, the failure of the 35 employer/contractor respondents to fully comply with the law does not amount to an actual violation warranting further investigation.  However, pursuant to WAC 390-37-060(1)(b), the 35 employer/contractor respondents received a formal written warning concerning: (1) their failure to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) their failure to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination by the employer and the union for not contributing.  The employer/contractors were informed that the Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.  Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/43708
43707 12/07/2018 Freedom Foundation (Maxford Nelsen) Waste Treatment Completion Company, LLC Wa