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
89804 05/04/2021 Richard Hall Steve Kirby Kirby, Steve (2): Alleged Violation of RCW 42.17A.405 for receiving a contribution designated for the August 4, 2020 Primary Election, after that date (EY20, May21) RCW 42.17A.405 Assessment of Facts
  • Allegation: Violation of RCW 42.17A.405 and WAC 390-17-302 for receiving a contribution designated for the August 4, 2020 Primary Election, after that date (EY20, May21)
https://www.pdc.wa.gov/browse/cases/89804
89585 04/29/2021 Charles Torelli William (Will) McKay Jr. McKay, William JR (3): Alleged Violation of RCW 42.17A.710 for failure to accurately disclose personal financial information on Personal Financial Affairs Statements (F-1 reports) (April 2021) RCW 42.17A.710 Assessment of Facts
  • Alleged Violation of RCW 42.17A.710 for failure to accurately disclose personal financial information on Personal Financial Affairs Statements (2019-2020 F-1 reports)
https://www.pdc.wa.gov/browse/cases/89585
89531 04/28/2021 Charles Torelli William McKay Sr. McKay, William SR: Alleged Violation of RCW 42.17A.710 for failure to accurately disclose personal financial information on Personal Financial Affairs Statements (F-1 reports) (April 2021) RCW 42.17A.710 Assessment of Facts
  • Allegation: Violation of RCW 42.17A.710 for failure to accurately disclose personal financial information on Personal Financial Affairs Statements (2017-2020 F-1 reports)
https://www.pdc.wa.gov/browse/cases/89531
89335 04/22/2021 Carolyn Armanini David Maehren Maehren, David: Alleged Violation of RCW 42.17A.700 for failure to timely file Personal Financial Affairs Statement (F-1 report) (April 21) RCW 42.17A.700 Assessment of Facts
  • Allegation: 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/89335
89286 04/21/2021 Krysta Strasbaugh Randy Corman Corman, Randy: Alleged Violation of RCW 42.17A.235 & .240 for failure to timely and accurately report contributions and expenditures (EY21, Apr21) RCW 42.17A.235, RCW 42.17A.240 Assessment of Facts
  • Allegation: Violation of RCW 42.17A.235 & .240 for failure to timely and accurately report contributions and expenditures (C-3 & C-4 reports)
https://www.pdc.wa.gov/browse/cases/89286
89278 04/21/2021 Maxford Nelsen Washington Federation of State Employees/AFSCME Council 28 WA Federation of State Employees/AFSCME Council 28: Alleged violation of RCW 42.17A.205 by failing to register as a political committee. (Apr '21) RCW 42.17A.205 Assessment of Facts
  • Allegation: Alleged violation of RCW 42.17A.205 by failing to register as a political committee
https://www.pdc.wa.gov/browse/cases/89278
89263 04/21/2021 Jeremy Jamerson and Richard Verlinda Officials of King County Fire Protection District 16 Officials of King County Fire Protection District 16: Alleged violation of RCW 42.17A.555 by using public office/agency facilities to promote a ballot proposition. (EY 21; Apr '21) RCW 42.17A.555 Assessment of Facts
  • Allegation: Alleged violation of RCW 42.17A.555 by using public office/agency facilities to promote a ballot proposition (Prop. 1)
https://www.pdc.wa.gov/browse/cases/89263
89226 04/20/2021 Lori Shavlik Adam Fortney Fortney, Adam: Alleged violations of RCW 42.17A.555 & .710 by using county facilities to assist election campaign & oppose a ballot prop (Recall) & failing to disclose Dawson Place directorship & position w/Pennies for Puppies on F-1 report(s) RCW 42.17A 555, RCW 42.17A.710 Assessment of Facts
  • Allegation One: Alleged violation of RCW 42.17A.555 by using public office/agency facilities to assist an election campaign & oppose a ballot proposition (Recall)
  • Allegation Two: Alleged violation of RCW 42.17A.710 by failing to disclose directorship with Dawson Place on F-1 report(s) and position with Pennies for Puppies on F-1 report covering 2020 
https://www.pdc.wa.gov/browse/cases/89226
89175 04/19/2021 Kenton Gartrell Tony Sandoval Sandoval, Anthony (Tony): Alleged violation of RCW 42.17A.205 for failure to register as a candidate within two weeks of declaring candidacy. (EY 21; Apr 21) RCW 42.17A.205 Assessment of Facts
  • Allegation: Alleged violation of RCW 42.17A.205 for failure to register as a candidate within two weeks of declaring candidacy (e.g. news article, press release) by filing a C-1 report with the PDC.
https://www.pdc.wa.gov/browse/cases/89175
89166 04/19/2021 Kenton Gartrell Janice Deccio Deccio Janice: Alleged violation of RCW 42.17A.235 & .240 by failing to timely report contributions & expenditures. (EY '20; Apr '21) RCW 42.17A.240, RCW 42.17A.235 Case Closed with No Evidence of Violations

The PDC received a complaint alleging that Janice Deccio (the “Respondent”) may have violated RCW 42.17A.235 & .240 by failing to timely report contributions & expenditures to the PDC. PDC staff reviewed the allegations; the applicable statutes, rules and reporting requirements; the response provided by the Respondent; and the Respondent’s reporting history to determine whether they support a finding of one or more violations. 

Staff’s review found the following:

Pursuant to RCW 42.17A.235 & .240, candidates are required to report contributions deposited and expenditures made during the months of January through April on monthly C-3 and C-4 reports that are due the 10th day of each following month. If the 10th falls on a weekend, the report is due the next business day. The requirement to file the monthly reports is triggered when the candidate’s committee 1) receives a contribution or makes an expenditure in the preceding calendar month; and 2) either its total contributions or total expenditures made since the last report exceed $200. 

The Respondent timely filed a C-3 report on April 17, 2021, disclosing receipt of two $125 contributions on April 16, 2021. In her response to the complaint, the Respondent indicated her campaign had no activity to report prior to April 16, 2021. Her website/domain, which was launched on April 7, 2021, was obtained by the campaign for free on a four-week trial basis.

Based on this information, the PDC finds that no further actions 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/89166
89014 04/15/2021 William Broughton Greg Wheeler Wheeler, Greg: Alleged violation of RCW 42.17A.555 by using photos of himself in Mayoral role on an election campaign website. (EY '21; Apr '21) RCW 42.17A.555 Case Closed with No Evidence of Violations

A complaint was filed alleging that Greg Wheeler, the incumbent Mayor of the City of Bremerton, and a candidate seeking re-election to that office in 2021, may have violated RCW 42.17A.555 by using City of Bremerton facilities to support his candidacy for re-election.

Pursuant to RCW 42.17A.555 no public facilities can be used by or authorized to be used directly or indirectly by any local elected or appointed official or public employee, to support or oppose any candidate or ballot proposition.

Specifically, the complaint alleged that Mayor Wheeler posted photographs on his re-election website “of himself wearing City clothing and posing in front of City vehicles. He also posts ribbon cutting events and other events where he is pictured in his capacity as Mayor of Bremerton.”  Mayor Wheeler stated in his response:

  • The photographs posted on his “website were obtained from the candidate, his family, his supporters, or photographers paid by the campaign.” He stated the photographs were received by his Campaign “via social media/tagging and email.”
  • The photographs taken at the ribbon cutting ceremonies and other City of Bremerton “sponsored events were taken by friends of the candidate and the candidate’s wife. Many of these people share their photos with the City of Bremerton for social media use as well.”
  • No City of Bremerton staff took any of the photographs or involved with any of the photographs that were posted on his Campaign website, and that the “City of Bremerton does not employ photographers and no City employee was directed to take photos for the campaign.”

There was no evidence provided or found that Mayor Wheeler wore City of Bremerton clothing in any of the photographs taken by friends of the candidate or the candidate’s spouse, and that were subsequently posted on his Campaign website. 

Based on these findings, PDC staff found no evidence of a violation that would require conducting a more formal investigation into the complaint or pursuing enforcement action in this instance.  The PDC has dismissed this matter in accordance with RCW 42.17A.755(1).  

 

https://www.pdc.wa.gov/browse/cases/89014
89001 04/15/2021 Roger Smith City of Shoreline City of Shoreline: Alleged violation of RCW 42.17A.555 by using public agency/office facilities to promote a ballot proposition. (EY '21; Apr '21) RCW 42.17A.555 Assessment of Facts
  • Allegation: Alleged violation of RCW 42.17A.555 by using public agency/office facilities to promote a ballot proposition (Prop 1)
https://www.pdc.wa.gov/browse/cases/89001
88948 04/14/2021 IAFF Local 2459, and Carolyn Armanini Citizens 4 Fire Merger Citizens 4 Fire Merger: Alleged violations of RCW 42.17A.235, .240, .255, .260, .305 & .320 by failing to timely & accurately report contributions & political advertising (ballot prop mailer) & accurately identify sponsor of mailer . (EY '21; Apr '21) RCW 42.17A.240, RCW 42.17A.235, RCW 42.17A.255, RCW 42.17A.260, RCW 42.17A.305, RCW 42.17A.320 Assessment of Facts
  • Allegation One: Alleged violation of RCW 42.17A.255, .260 & .305 for failure to timely & accurately report political advertising published within 21 days of an election on a C-6 report 
  • Allegation Two: Alleged violation of RCW 42.17A.320 by failing to accurately identify sponsor of a mailer supporting Prop 1 
  • Allegation Three: Alleged violation of RCW 42.17A.235 & 240 for failure to timely & accurately report contributions
https://www.pdc.wa.gov/browse/cases/88948
88768 04/12/2021 Mary Margaret Winkes Tyler LeMasters Tyler LeMasters: Alleged violation of RCW 42.17A.235 & .240 for failure to timely & accurately report contributions & expenditures. (EY '21; Apr '21) RCW 42.17A.235, RCW 42.17A.240 Assessment of Facts
  • Allegation: Alleged violation of RCW 42.17A.235 & .240 for failure to timely & accurately report contributions & expenditures
https://www.pdc.wa.gov/browse/cases/88768
87818 03/31/2021 Renee Slocumb Bryan Pratt Pratt, Bryan: Alleged violation of RCW 42.17A.405(3) by making an over-limit contribution to the Recall Jerry Hatcher committee. (EY '20: Mar '20) RCW 42.17A.405 Assessment of Facts
  • Allegation: Alleged violation of RCW 42.17A.405 by making an over-limit contribution to the Recall Jerry Hatcher committee
https://www.pdc.wa.gov/browse/cases/87818
87806 03/31/2021 Renee Slocumb Kathlen Wierschke Wierschke, Kathlen: Alleged violation of RCW 42.17A.405(3) by making an over-limit contribution to the Recall Jerry Hatcher committee. (EY '20: Mar '20) RCW 42.17A.405 Assessment of Facts
  • Allegation: Alleged violation of RCW 42.17A.405 by making an over-limit contribution to the Recall Jerry Hatcher committee
https://www.pdc.wa.gov/browse/cases/87806
87792 03/31/2021 Renee Slocumb Benton County Deputy Sheriff's Guild Benton County Deputy Sheriff's Guild: Alleged violation of RCW 42.17A.405(3) by making an over-limit contribution to the Recall Jerry Hatcher committee. (EY '20: Mar '20) RCW 42.17A.405 Assessment of Facts
  • Allegation: Alleged violation of RCW 42.17A.405 by making an over-limit contribution to the Recall Jerry Hatcher committee
https://www.pdc.wa.gov/browse/cases/87792
87767 03/30/2021 Myst Beal, Nancy Bocek, Lawrence Goldman Don Benton Benton, Don: Alleged Violation of RCW 42.17A.320 for lack of sponsor identification on political advertising (EY21, March21) RCW 42.17A.320 Case Closed with No Evidence of Violations
  • Allegation: Violation of RCW 42.17A.320 for lack of sponsor identification on political advertising
https://www.pdc.wa.gov/browse/cases/87767
87409 03/23/2021 Kevin Morton, Shayla Noon and Kyle Noon Recall Jerry Hatcher Recall Jerry Hatcher: Alleged violation of RCW 42.17A.405 by accepting contributions that exceed contribution limits. (EY '20: Mar '20) RCW 42.17A.405 Investigation of Possible Violation
  • Allegation: Alleged violation of RCW 42.17A.405 by accepting over-limit contributions from Benton Co Deputy Sheriffs Guild, Kathlen Wierschke & Bryan Pratt
https://www.pdc.wa.gov/browse/cases/87409
SC 20-2-15134-3 03/17/2021 State of Washington Twitter, Inc. SC 20-2-15134-3 Twitter (King County Superior Court)

For case information visit: https://www.atg.wa.gov/enforcement-campaign-finance-laws

https://www.pdc.wa.gov/browse/cases/SC 20-2-15134-3
SC 18-2-00523-34 03/17/2021 State of Washington EX REL Glen Morgan James Cooper, Jr. SC 18-2-00523-34 James Cooper, Jr (Thurston County Superior Court) https://www.pdc.wa.gov/browse/cases/SC 18-2-00523-34
SC 14-2-00647-8 03/17/2021 State of Washington Public Disclosure Commission David Schmidt SC 14-2-00647-8 David Schmidt (Thurston County Superior Court)

For case information visit: https://www.atg.wa.gov/enforcement-campaign-finance-laws

See Also: https://www.pdc.wa.gov/browse/cases/11-018  

https://www.pdc.wa.gov/browse/cases/SC 14-2-00647-8
87070 03/16/2021 Stefan Sharkansky King County Elections Officials King County Elections Officials: Alleged violation of RCW 42.17A.555 by using public office or agency facilities to promote or oppose ballot propositions by making grants to organizations engaged in express advocacy. (EY 2018-2021; Mar '20) RCW 42.17A.555 Assessment of Facts
  • Allegation: Alleged violation of RCW 42.17A.555 by using public office or agency facilities to directly or indirectly promote or oppose ballot propositions by making Voter Education Fund grants to community-based organizations engaged in express advocacy
https://www.pdc.wa.gov/browse/cases/87070
86767 03/09/2021 PDC Staff PDC Staff Apple, Robert "Bob": Alleged violations of RCW 42.17A.225, .235 & .240 by failing to maintain & preserve books of account, and timely & accurately report contributions & expenditures. (EY 2020) RCW 42.17A.225, RCW 42.17A.235, RCW 42.17A.240 Assessment of Facts
  • Allegation One: Alleged violation of RCW 42.17A.225 by failing to maintain & preserve campaign books of account. 
  • Allegation Two: Alleged violation of RCW 42.17A.235 & .240 for failure to timely & accurately report contributions & expenditures on paper filed C-3 and C-4 reports in accordance with an electronic filing hardship exemption granted pursuant to RCW 42.17A.055. 
https://www.pdc.wa.gov/browse/cases/86767
86689 03/08/2021 PDC Staff Two Degrees Consulting, LLC Two Degrees Consulting, LLC: Alleged Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020 (GE Mar21) RCW 42.17A.615 Closed Administratively
  • Allegation: Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020
https://www.pdc.wa.gov/browse/cases/86689
86688 03/08/2021 PDC Staff Sophia Ressler Ressler, Sophia: Alleged Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020 (GE Mar21) RCW 42.17A.615 Closed Administratively
  • Allegation: Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020
https://www.pdc.wa.gov/browse/cases/86688
86687 03/08/2021 PDC Staff Sean Morales-Doyle Morales-Doyle, Sean: Alleged Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020 (GE Mar21) RCW 42.17A.615 Closed Administratively
  • Allegation: Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020
https://www.pdc.wa.gov/browse/cases/86687
86686 03/08/2021 PDC Staff Sean Bagsby Bagsby, Sean: Alleged Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020 (GE Mar21) RCW 42.17A.615 Closed Administratively
  • Allegation: Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020
https://www.pdc.wa.gov/browse/cases/86686
86685 03/08/2021 PDC Staff Ryan Pricco Pricco, Ryan: Alleged Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020 (GE Mar21) RCW 42.17A.615 Closed Administratively
  • Allegation: Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020
https://www.pdc.wa.gov/browse/cases/86685
86684 03/08/2021 PDC Staff Rashea Dickey Dickey, Rashea: Alleged Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020 (GE Mar21) RCW 42.17A.615 Closed Administratively
  • Allegation: Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020
https://www.pdc.wa.gov/browse/cases/86684
86683 03/08/2021 PDC Staff Mike Pugsley Pugsley, Mike: Alleged Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020 (GE Mar21) RCW 42.17A.615 Closed Administratively
  • Allegation: Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020
https://www.pdc.wa.gov/browse/cases/86683
86682 03/08/2021 PDC Staff Marcos Martinez Martinez, Marcos: Alleged Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020 (GE Mar21) RCW 42.17A.615 Closed Administratively
  • Allegation: Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020
https://www.pdc.wa.gov/browse/cases/86682
86681 03/08/2021 PDC Staff Madeline Kovacs Kovacs, Madeline: Alleged Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020 (GE Mar21) RCW 42.17A.615 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020
https://www.pdc.wa.gov/browse/cases/86681
86680 03/08/2021 PDC Staff Landlord Solutions Government Affairs Landlord Solutions Government Affairs: Alleged Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020 (GE Mar21) RCW 42.17A.615 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020
https://www.pdc.wa.gov/browse/cases/86680
86679 03/08/2021 PDC Staff Katy Warren Warren, Katy: Alleged Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020 (GE Mar21) RCW 42.17A.615 Closed Administratively
  • Allegation: Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020 
https://www.pdc.wa.gov/browse/cases/86679
86678 03/08/2021 PDC Staff Joel Ryan Ryan, Joel: Alleged Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020 (GE Mar21) RCW 42.17A.615 Closed Administratively
  • Allegation: Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020 
https://www.pdc.wa.gov/browse/cases/86678
86676 03/08/2021 PDC Staff Jeffrey Bissonnette Bissonnette, Jeffrey: Alleged Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020 (GE Mar21) RCW 42.17A.615 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020 
https://www.pdc.wa.gov/browse/cases/86676
86675 03/08/2021 PDC Staff Heather Navarre Navarre, Heather: Alleged Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020 (GE Mar21) RCW 42.17A.615 Closed Administratively
  • Allegation: Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020
https://www.pdc.wa.gov/browse/cases/86675
86674 03/08/2021 PDC Staff Erik Ashlie-Vinke Ashlie-Vinke, Erik: Alleged Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020 (GE Mar21) RCW 42.17A.615 Closed Administratively
  • Allegation: Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020
https://www.pdc.wa.gov/browse/cases/86674
86673 03/08/2021 PDC Staff Ed Dennis Dennis, Ed: Alleged Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020 (GE Mar21) RCW 42.17A.615 Closed Administratively
  • Allegation: Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020
https://www.pdc.wa.gov/browse/cases/86673
86672 03/08/2021 PDC Staff Dillon Hosier Hosier, Dillon: Alleged Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020 (GE Mar21) RCW 42.17A.615 Closed Administratively
  • Allegation: Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020
https://www.pdc.wa.gov/browse/cases/86672
86671 03/08/2021 PDC Staff Deborah Gath Gath, Deborah: Alleged Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020 (GE Mar21) RCW 42.17A.615 Closed Administratively
  • Allegation:  Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020
https://www.pdc.wa.gov/browse/cases/86671
86670 03/08/2021 PDC Staff Darin James Dorsey Dorsey, Darin: Alleged Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020 (GE Mar21) RCW 42.17A.615 Closed Administratively
  • Allegation:  Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020
https://www.pdc.wa.gov/browse/cases/86670
86669 03/08/2021 PDC Staff Darci Ladwig Ladwig, Darci: Alleged Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020 (GE Mar21) RCW 42.17A.615 Closed Administratively
  • Allegation:  Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020
https://www.pdc.wa.gov/browse/cases/86669
86668 03/08/2021 PDC Staff Courtney Blatz Blatz, Courtney: Alleged Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020 (GE Mar21) RCW 42.17A.615 Scheduled for Full Commission Hearing
  • Allegation:  Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020
https://www.pdc.wa.gov/browse/cases/86668
86667 03/08/2021 PDC Staff Chelsea Mason Mason, Chelsea: Alleged Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020 (GE Mar21) RCW 42.17A.615 Closed Administratively
  • Allegation:  Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020
https://www.pdc.wa.gov/browse/cases/86667
86666 03/08/2021 PDC Staff Alise Hegle Hegle, Alise: Alleged Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020 (GE Mar21) RCW 42.17A.615 Closed Administratively
  • Allegation:  Violation of RCW 42.17A.615 for failure to file monthly Lobbying Reports (L2) during the CY 2020
https://www.pdc.wa.gov/browse/cases/86666
86408 03/03/2021 John A Kesler III Yen Huynh Huynh, Yen: Alleged Violations of RCW 42.17A.205, .700 & WAC 390-18-040 for failure to timely register (C-1) & failure to file Personal Financial Affairs (F-1) within two weeks of becoming a candidate & for using "re-elect" in political advertising RCW 42.17A.205, WAC 390-18-040, RCW 42.17A.700 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint John Kesler III filed on March 1, 2021. The complaint alleged that Yen Huynh (Respondent), a Candidate for City Councilmember, for City of Olympia may have violated RCW 42.17A.205, .700 and WAC 390-18-040 for failure to register as a candidate (C-1) and file Personal Financial Affairs (F-1) within two weeks of becoming a candidate; and for using "re-elect" in 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, the F-1 being filed two (2) days beyond the statutory requirement and the use of re-elect versus retain does not amount to a violation that warrants further investigation.

PDC staff is reminding Yen Huynh about the importance of the timely filings of all future PDC reports and the importance of ensuring political advertising is in accordance with the PDC 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/86408
86016 02/22/2021 Johanna Baxter Matthew Adams Adams, Matthew: Alleged Violation of RCW 42.17A.205, .700 for failure to timely register as a candidate (C-1) and failure to timely file Personal Financial Affairs Statement (F-1) (EY21, Feb21) RCW 42.17A.205, RCW 42.17A.700 Case Closed with No Evidence of Violations

The complaint alleged Matthew Adams violated RCW 42.17A.205 and .700 by failing to timely register as a candidate (C-1) and file a Personal Financial Affairs Statement (F-1). PDC staff reviewed the allegations, evidence you provided, applicable statutes and rules and the response provided by Matthew Adams to determine whether the record supports a finding of one or more violations. 

In response to the evidence provided in the complaint, Adams stated “I am a concerned citizen who loves his city. The hosts of The Outlaw Radio Network, posted that information and it is not correct. I have no interest in running for public office, as I stated on the show that night.” 

There is no evidence Adams raised or spent any funds for a campaign or authorized any other person to raise or spend money towards a campaign. 

Staff has determined, in this instance, the alleged violations ofRCW 42.17A.205 and .700 for failing to timely register as a candidate (C-1) and file a Personal Financial Affairs Statement (F-1)do 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/86016
85715 02/16/2021 Robert Parker South Kitsap School Supporters (SKSS) (2) Alleged violations of RCW 42.17A.235, .240 & .320 for failure to timely & accurately report expenditures & identify sponsor of digital ads. (EY '21; Feb '21) RCW 42.17A.320, WAC 390-16-037, RCW 42.17A.240, RCW 42.17A.235, wac 390-16-205 Assessment of Facts
  • Allegation One: Alleged violation of RCW 42.17A.235, .240, WAC 390-16-037 & 390-16-205 for failure to timely & accurately report & fully describe expenditures on C-4 reports (e.g. web design & hosting svcs, digital ads, processing fees) 
  • Allegation Two: Alleged violation of RCW 42.17A.320 for failure to identify sponsor of digital advertising 
     
https://www.pdc.wa.gov/browse/cases/85715
85424 02/09/2021 Larry Mann, and Robert Parker South Kitsap School District South Kitsap School District: Alleged violation of RCW 42.17A.555 by using public office or agency facilities to promote a ballot proposition. (EY '21; Feb '21) RCW 42.17A.555 Assessment of Facts
  • Allegation: Alleged violation of RCW 42.17A.555 by using public office or agency facilities to publish five mailers promoting a ballot proposition
  • Allegation Two: Alleged violation of RCW 42.17A.555 by using public office or agency facilities (school buses) to promote a ballot proposition
https://www.pdc.wa.gov/browse/cases/85424
85423 02/09/2021 Larry L. Mann South Kitsap School Supporters (SKSS) South Kitsap School Supporters (SKSS): Alleged violations of RCW 42.17A.235, .240 & .260 for failure to timely & accurately report contributions, expenditures & debt. (EY '21; Feb '21) RCW 42.17A.240, RCW 42.17A.235, RCW 42.17A.260 Case Closed with No Evidence of Violations
  • Allegation One: Alleged violation of RCW 42.17A.235 & .240 for failure to timely & accurately report contributions, expenditures & debt on C-3 and C-4 reports, including identifying all contributors & disclosing the full cost of yard signs
  • Allegation Two: Alleged violation of RCW 42.17A.260 by failing to timely & accurately report independent expenditure political advertising supporting a ballot proposition (e.g. flyers), which is published within 21 days of an election and valued at $1,000 or more, on a C-6 report within 24 hours
https://www.pdc.wa.gov/browse/cases/85423
84488 01/29/2021 Gerry Austin Larry Mann Mann, Larry: Alleged Violation of RCW 42.17A.205, .235, .240, .255, & .260 for failure to report expenditures (EY 21, Jan 21) RCW 42.17A.240, RCW 42.17A.260, RCW 42.17A.205, RCW 42.17A.235, RCW 42.17A.255 Case Closed with No Evidence of Violations
  • Allegation: Violation of RCW 42.17A.205, .235, .240, .255, & .260 for failure to report expenditures
https://www.pdc.wa.gov/browse/cases/84488
84478 01/29/2021 Gerry Austin Committee Against South Kitsap SD 2021 Levy Committee Against South Kitsap SD 2021 Levy: Alleged Violation of RCW 42.17A.205, .235 and .240 for failure to timely register as a committee; failure to timely and accurately disclose in-kind contributions, contributions and expenditures RCW 42.17A.205, RCW 42.17A.240, RCW 42.17A.235 Case Closed with No Evidence of Violations
  • Allegation One: Violation of RCW 42.17A.205 for failure to timely register as a committee
  • Allegation Two: Violation of RCW 42.17A.235 and .240 for failure to timely and accurately disclose in-kind contributions, contributions and expenditures
https://www.pdc.wa.gov/browse/cases/84478
84416 01/28/2021 Sean Gannon James (Mike) Volz Volz, James M.: Alleged violations of RCW 42.17A.235 & .240 for failure to file or timely file C-4 reports disclosing contributions & expenditures for election years 2016, 2018 & 2020. (Jan '20) RCW 42.17A.240, RCW 42.17A.235 Case Closed with Reminder

The complaint alleged James M. (Mike) Volz violated RCW 42.17A.235 and .240 by failing to timely and accurately disclose contributions and expenditures, specifically for failing to timely file Full Campaign Contribution and Expenditure (C-4) reports in 2016, 2018 and 2020 election years. 

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

Regarding the reports not filed in July, August, September and October 2017 and February and March 2020, Volz stated there was no activity by the campaign those months. C-4 reports are required monthly from the beginning of the campaign through May of the election year. However, the monthly report is only required if the campaign has more than $200 in contributions or expenditures during a month. 

Based on these findings, staff has determined, in this instance, the failure to timely file C-4 reports does not amount a violation warranting further investigation. PDC staff is reminding James M. (Mike) Volz about the importance of filing timely, accurate and complete reports in accordance with PDC laws and rules and expects in the future Volz will timely file accurate and complete 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/84416
83824 01/15/2021 Kathlen Wierschke Retain Sheriff Hatcher Committee Retain Sheriff Hatcher: Alleged Violation of RCW 42.17A.205, .235 and .240 for failure to timely register the committee and failure to timely and accurately disclose contributions and expenditures (EY 21, Jan 21) RCW 42.17A.240, RCW 42.17A.235, RCW 42.17A.205 Case Closed with Written Warning

The complaint alleged Retain Sheriff Hatcher (Committee) violated 42.17A.205 by failing to timely register the committee and RCW 42.17A.235 and .240 by failing to timely and accurately disclose contributions and expenditures.

PDC staff reviewed the allegations; the materials provided; the applicable statutes, rules, and reporting requirements; the relevant PDC reports; and the response from Patrick Bauguess, Treasurer for Retain Sheriff Hatcher (Committee), to determine whether the record supports a finding of one or more violations. 

Based on staff’s findings, and the fact the recall has not been set for an election, and thus the public has not been deprived of important information at a critical juncture, staff has determined in this instance, the Committee’s failure to timely register and disclose contributions and expenditures does not amount to a finding of a violation that warrants further investigation. 

However, pursuant to WAC 390-37-060(1)(d), Retain Sheriff Hatcher will receive a formal written warning concerning the failure to timely register, and file and report contributions and expenditures. The formal written warning includes staff’s expectation the Committee will, in the future, timely and accurately file PDC reports and disclose contributions and expenditures as required by law.

The Commission will consider the formal written warning in deciding on future 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/83824
83664 01/13/2021 Jake H. Mayson The Instagram page @wa.elex The Instagram page @wa.elex: Alleged violation of RCW 42.17A.255, .260 & .305 by failing to report independent expenditures & electioneering communications on C-6 reports. (EY '20; Oct '20) RCW 42.17A.255, RCW 42.17A.260, RCW 42.17A.305 Case Closed with No Evidence of Violations
  • Allegation: Alleged violation of RCW 42.17A.255, .260 & .305 by failing to report independent expenditures & electioneering communications on C-6 reports
https://www.pdc.wa.gov/browse/cases/83664
83341 01/11/2021 PDC Staff Tom Taylor Tom Taylor: Alleged violations of RCW 42.17A.205 and 700 for failure to timely file Candidate Registration (C-1) and Personal Financial Affairs Statement (F-1) within two weeks of becoming a candidate (Group Enforcement 2020) RCW 42.17A.700, RCW 42.17A.205 Closed Administratively
  • Allegation One: Violation of RCW 42.17A.205 for failure to timely file the Candidate Registration (C-1 report) within two weeks of becoming a candidate, or no later than June 1, 2020.
  • Allegation Two: 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, or no later than June 1, 2020.
https://www.pdc.wa.gov/browse/cases/83341
83340 01/11/2021 PDC Staff Richelle MacKersie Richelle MacKersie: Alleged violations of RCW 42.17A.700 for failure to timely file Personal Financial Affairs Statement (F-1) within two weeks of becoming a candidate (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: 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, or no later than June 1, 2020.
https://www.pdc.wa.gov/browse/cases/83340
83202 01/08/2021 PDC Staff Shaney Frame Crosby Shaney Frame Crosby: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission

This matter was heard by the Presiding Officer on April 1, 2021,  who found that Shaney Frame Crosby violated RCW 42.17A.700 by failing to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019 that was due no later than April 15, 2020. 

The Commission assessed a $250 civil penalty and ordered the missing F-1 report to be filed, both within 30 days of the Order, which was entered on April 20, 2021. 

https://www.pdc.wa.gov/browse/cases/83202
83201 01/08/2021 PDC Staff PEREZ DIANA H PEREZ DIANA H: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Resolved through Statement of Understanding https://www.pdc.wa.gov/browse/cases/83201
83200 01/08/2021 PDC Staff MCCOY JOHN R MCCOY JOHN R: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission https://www.pdc.wa.gov/browse/cases/83200
83199 01/08/2021 PDC Staff Kristine M. Reeves Kristine M. Reeves: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission https://www.pdc.wa.gov/browse/cases/83199
83198 01/08/2021 PDC Staff Justin A. Cristelli Justin A. Cristelli: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019
https://www.pdc.wa.gov/browse/cases/83198
83196 01/08/2021 PDC Staff BAILEY BARBARA F BAILEY BARBARA F: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 
https://www.pdc.wa.gov/browse/cases/83196
82523 12/29/2020 Peter Starzynski Freedom Foundation Freedom Foundation (3): Alleged Violation of RCW 42.17A.205, .235, .240 and .320 for failure to timely register as a committee, failure to report contributions and expenditures, and failure to disclose complete sponsor identification (Dec 20) RCW 42.17A.240, RCW 42.17A.320, RCW 42.17A.235, RCW 42.17A.205 Case Closed with Reminder

The complaint alleged the Freedom Foundation violated RCW 42.17A.205, .235, .240 and .320 by failing to timely register as a committee, failing to report contributions and expenditures, and failing to disclose complete sponsor identification.

PDC staff found no evidence to support the allegation that FF meets the definition of a political committee under the "receiver of contributions" prong in accordance with PDC Interpretation 07-04, or that FF failed to file a Committee Registration. Since FF is not a political committee, there are no filing requirements or contribution and expenditure activities to disclose under RCW 42.17A.235 and .240.

Based on these findings, staff has determined, in this instance, the failure to disclose complete sponsor identification does not amount a violation warranting further investigation. PDC staff is reminding the Freedom Foundation about the importance of filing timely electioneering communications 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/82523
82263 12/23/2020 Washington Against Discrimination Everywhere Washington Against Discrimination Everywhere (WADE) Washington Against Discrimination Everywhere (WADE): Alleged violation of RCW 42.17A.240 for failure to report and/or sufficiently describe expenditures & debt supporting a ballot proposition & identify a contributor. (EY '20; Dec '20) RCW 42.17A.240 Investigation of Possible Violation

After conducting a preliminary review and assessment of a complaint filed December 20, 2020 against WADE concerning alleged violations of RCW 42.17A.240 for failing to report and/or sufficiently describe expenditures and debt supporting a ballot proposition and for failing to report a contributor's name, PDC staff opened a formal investigation and held an initial hearing, (also referred to as a case status review) on February 23, 2021, pursuant to RCW 42.17A.755, and WACs 390-37-060 and 390-37-071.

https://www.pdc.wa.gov/browse/cases/82263
82111 12/18/2020 Willie Russell 21st Legislative Democrats 21st Legislative Democrats (3): Alleged Violation of RCW 42.17A.235, .240 for failure to timely and accurately disclose contributions, in-kind, expenditures, debts, and loans (EY20, Dec20) RCW 42.17A.240, RCW 42.17A.235 Case Closed with No Evidence of Violations

The complaint alleged the 21st District Democrats violated RCW 42.17A.235 and RCW 42.17A.240 for failing to timely and accurately disclose contributions, in-kind, expenditures, debts, and loans, specifically failing to report a March 2019 donation of $100 from the 21st Legislative District Cascade Precinct and the use of a personal Zoom account during 2020. 

PDC staff reviewed the allegations, evidence you provided, applicable statutes and rules and the response provided by the 21st Legislative District Democratic Central Committee to determine whether the record supports a finding of one or more violations. PDC staff did not investigate allegations outside of PDC jurisdiction. 

Staff has determined, in this instance, the alleged violation of RCW 42.17A.235 and RCW 42.17A.240 for failing to timely and accurately disclose contributions, in-kind, expenditures, debts, and loans 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/82111
82098 12/18/2020 Gerry Austin Citizen's Supporting South Kitsap Schools Citizen's Supporting South Kitsap Schools: Alleged Violation of RCW 42.17A.205, .235, .240 for failure to timely register (PDC Form C-1pc), failure to timely report contributions, in-kind, expenditures, loans and debts (PDC Forms C-3 & C-4)(EY21, Dec20) RCW 42.17A.240, RCW 42.17A.205, RCW 42.17A.235 Case Closed with No Evidence of Violations
  • Allegation One: Violation of RCW 42.17A.205 for failure to timely register (PDC Form C-1pc)
  • Allegation Two: Violation of RCW 42.17A.235, .240 for failure to timely report contributions, in-kind, expenditures, loans and debts (PDC Forms C-3 & C-4)
https://www.pdc.wa.gov/browse/cases/82098
82077 12/18/2020 Alex Bond Kitsap County Republican Party Kitsap County Republican Party (2): Alleged Violation of RCW 42.17A.405 for accepting contributions that exceed the contribution limitations (EY20, Dec20) RCW 42.17A.405 Investigation of Possible Violation

After conducting a preliminary review and assessment of a complaint filed December 12, 2020 concerning the Kitsap County Republican Party and alleged violations of RCW 42.17A.405 for accepting contributions that exceed contribution limitations, PDC staff opened a formal investigation and held an initial hearing, (also referred to as a case status review) on March 9, 2021 pursuant to RCW 42.17A.755, and WACs 390-37-060 and 390-37-071.

https://www.pdc.wa.gov/browse/cases/82077
82004 12/16/2020 PDC Staff Mercer Islanders for Sustainable Spending Alleged violations of RCW 42.17A.240, .260 & .305 for failure to timely report & sufficiently describe independent expenditures & electioneering communications undertaken during election year 2019. (Dec '20) RCW 42.17A.260, RCW 42.17A.240, RCW 42.17A.305 Resolved through Statement of Understanding

A PDC staff generated complaint was filed against Mercer Islanders for Sustainable Spending PAC, a political committee registered with the PDC in 2019, alleging violations of: (1) RCW 42.17A.240 by failing to provide the required expenditure details for independent expenditures and electioneering communications undertaken by MISS during the 2019 election cycle and disclosed on Summary Full Campaign Contributions and Expenditures reports (C-4 reports); and (2) RCW 42.17A.260 and .305 by failing to timely file Independent Expenditure reports (C-6 reports) disclosing independent expenditure and electioneering communication activities undertaken in support of or opposition to candidates for Mercer Island City Council during the 2019 election cycle.

During the 2019 election, MISS filed Summary Full Campaign Contributions and Expenditures reports (C-4 reports) and Independent Expenditures/Electioneering Communications reports (C-6 reports) disclosing expenditures that supported and opposed 2019 candidates for the Mercer Island City Council.  MISS made a number of expenditures for political advertisements in the form of independent expenditures, and/or electioneering communications during 2019.

On November 4, 2019, MISS filed four C-6 reports one day before the November 5, 2019 general election indicating that the expenditures were for Independent Expenditures of $100 or more, Independent Expenditure Advertisements of more than $1,000 undertaken within 21 days of an election, and Electioneering Communications.  The C-6 reports disclosed the following expenditures made by MISS:

  • A $1,433 expenditure was made to FedEx on October 3, 2019, to print a letter and envelopes for an electioneering communication advertisement that was presented to the public on October 11, 2019 and supported or opposed ten 2019 candidates for Mercer Island City Council.  MISS was required to file a C-6 report within 24 hours of the advertisements being presented to the public, or no later than October 12, 2020.  The expenditure information was disclosed 23 days late on a C-6 report. 
  • A $5,201,90 expenditure was made to FedEx on October 21, 2019, to print a half page mailer for an independent expenditure advertisement of more than $1,000 that was presented to the public on October 25, 2019.  The advertisement was in support of Daniel Jacobsen and in opposition to Deborah Bertlin, two candidates for Mercer Island City Council, and MISS was required to file a C-6 report no later than October 26, 2020.  The expenditure information was disclosed nine days late on a C-6 report. 
  • Four $949 expenditures totaling $3,796 were made to Sound Publishing by MISS for four full page independent expenditure newspaper advertisements that appeared in the Mercer Island Reporter, all in support of five 2019 candidates for Mercer Island City Council.  The C-6 report disclosed: (1) a $949 expenditure made on October 3, 2019, and presented to the public on 10/9; (2) two $949 expenditures were made on October 15, 2019, for advertisements presented to the public on 10/16 and 10/23; and (3) one expenditure made on October 23, 2019, for an advertisement presented to the public on October 26, 2019.  MISS disclosed the four independent expenditure newspaper advertisements on C-6 reports that were filed between nine and 19 days late 
     

On October 15, 2019, MISS timely filed the 21-Day Pre-General Election C-4 report disclosing $3,448 in total expenditures. The MISS expenditures included a $1,433 expenditure made to FedEx on October 3, 2019, and listing the description as “Mailer, letter and envelopes”, and a $949 expenditure made to Sound Publishing on October 3, 2019, and listing the description as “10/9 Full Page Color Ad.”  

On October 29, 2019, MISS timely filed the 7-Day Pre-General Election C-4 report disclosing a $20,197.24 in total expenditures, minus a $4,385 refund for one of the expenditures.  The expenditures included: (1) a $5,201.90 expenditure made to FedEx on October 21, 2019, for a half page mailer; (2)  a $4,241 expenditure made to FedEx on October 23, 2019, for a quarter page mailer; (3) a $2,815 expenditure made to FedEx on October 28, 2019, for a half page mailer; and (4) three $949 expenditures made to Sound Publishing, including two expenditures on October 15, 2019, and one expenditure on October 24, 2019, and listing the descriptions as “10/16, 10/23 and 10/30 Full Page Ads.”  

The expenditure descriptions for the mailers and newspaper advertisements disclosed on both the 21-Day and 7-Day Pre-General Election C-4 reports failed to identify the expenditures were for an independent expenditure or electioneering communication advertisement.  In addition, both C-4 reports failed to identify any of the Mercer Island City Council candidates supported or opposed by the advertisements, the date of the mailer, or the number of mail pieces printed and mailed. 

On January 7, 2021, on behalf of MISS Mr. Cero filed four amended C-4 reports that included the 21-Day and 7-Day Pre-General Election C-4 reports, identifying the Mercer Island City Council candidates supported or opposed by the advertisements, and the number of mail pieces printed and mailed. 

On February 23, 2021, Mr. Cero completed a Statement of Understanding (SOU) on behalf of MISS acknowledging violations of RCW 42.17A.240, 260 and .305 and paying a $600 civil penalty in accordance with the Penalty Schedule adopted by the Commission for Brief Enforcement Hearings set forth in WAC 390-37-143, to resolve this matter.

Based on these findings, staff has determined that in this instance, no further investigation is warranted, or any additional enforcement action shall be taken.  The PDC has dismissed the staff generated complaint filed against Mercer Islanders for Sustainable Spending PAC in accordance with RCW 42.17A.755(1) and WAC 390-37-070 
 

https://www.pdc.wa.gov/browse/cases/82004
81034 12/01/2020 Joseph Shoji Lachman A+ Learning Center A+ Learning Center: Alleged violations of RCW 42.17A.320 for failure to include sponsor identification on political advertising, and .435 for concealment of source of contributions (EY 19; Oct 20) RCW 42.17A.435, RCW 42.17A.320 Case Closed with No Evidence of Violations

The complaint alleged A+ Learning Center, a business that donated to Let People Vote (Committee), a ballot measure committee formed to oppose Referendum 88, a statewide ballot proposition on the 2019 general election ballot, violated RCW 42.17A.435 by concealing the true source of contributions.

PDC staff reviewed the allegations, evidence you provided, applicable statutes and rules and the response provided by A+ Learning Center to determine whether the record supports a finding of one or more violations. 

Staff has determined, in this instance, the alleged violation of RCW 42.17A.435 does not amount to a violation warranting further investigation as there is no evidence purchases were made for items and services at other than market value. 

Based on 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 390-37-070.

https://www.pdc.wa.gov/browse/cases/81034
81032 12/01/2020 Joseph Shoji Lachman Let People Vote / Reject R-88 Let People Vote / Reject R-88 (3): Alleged violations of RCW 42.17A.435 for concealment of source of contributions (EY 19; Oct 20) RCW 42.17A.435 Case Closed with No Evidence of Violations

The complaint alleged Let People Vote, a ballot measure committee formed to oppose Referendum 88, a statewide ballot proposition on the 2019 general election ballot, violated RCW 42.17A.435 by concealing the true source of contributions received by the ballot committee.

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

Staff has determined, in this instance, the alleged violation of RCW 42.17A.435 does not amount to a violation warranting further investigation as there is no evidence purchases were made for items and services at other than market value. 

Based on 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 390-37-070.

https://www.pdc.wa.gov/browse/cases/81032
80835 11/25/2020 Elliott Harvey Timothy Eyman Eyman, Timothy (5): Alleged Violation of RCW 42.17A.445 for misuse of campaign funds (EY20, Nov20) RCW 42.17A.445 Investigation of Possible Violation
  • Allegation: Violation of RCW 42.17A.445 for misuse of campaign funds.
https://www.pdc.wa.gov/browse/cases/80835
80733 11/23/2020 Justin Allen Shukri Olow Olow, Shukri: Alleged Violation of RCW 42.17A.235, .240 for failure to timely and accurately disclose contributions (EY21, Nove20) RCW 42.17A.235, RCW 42.17A.240 Request for Technical Correction

The complaint alleged Shukri Olow, a 2021 candidate for King County Council, District 5, may have violated RCW 42.17A.235 and .240 for failure to timely and accurately disclose contributions, specifically for reporting four $1,000 donations from the same individual. 

PDC staff has determined, in this instance, the allegation of failing to timely and accurately disclose contributions, specifically for reporting four $1,000 donations from the same individual, does not amount to a violation warranting further investigation.

The Campaign made minor or ministerial errors on required reports, which did not materially impact the public interest. Upon notification of these errors, Shukri Olow timely amended 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/80733
80600 11/20/2020 Elaina Gonzales-Blanton 23rd Leg Dist Republican Committee 23rd LD Repub Comm: Alleged Violation of RCW 42.17A.220, 235, .240 for failure to timely deposit contributions, timely & accurately report contributions & expenditures and fully comply with public inspection request (EY20, Nov20) RCW 42.17A.220, WAC 390-16-043, RCW 42.17A.240, RCW 42.17A.235 Investigation of Possible Violation
  • Allegation One: Violation of RCW 42.17A.220 for failure to timely deposit contributions
  • Allegation Two: Violation of RCW 42.17A.235 & .240 for failure to timely and accurately report contributions and expenditures (C-3 & C-4 reports)
  • Allegation Three: Violation of RCW 42.17A.235 & WAC 390-16-043 for failure to fully comply with request for inspection of books
https://www.pdc.wa.gov/browse/cases/80600
80548 11/19/2020 Benjamin Karpelman Preserve Mukilteo (Sponsored by Peter Zieve) Preserve Mukilteo (Sponsored by Peter Zieve): Alleged violations of RCW 42.17A.235 for failure to timely report contributions and expenditures (EY 20; Nov 20) RCW 42.17A.235 Case Closed with Reminder
  • Allegation: Violations of RCW 42.17A.235 for failure to timely report contributions and expenditures.
https://www.pdc.wa.gov/browse/cases/80548
80391 11/16/2020 PDC Staff RODGERS ROBERT J RODGERS ROBERT J: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80391
80390 11/16/2020 PDC Staff DAVIS KHALIA DAVIS KHALIA: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80390
80290 11/13/2020 PDC Staff Zabrina Jenkins Zabrina Jenkins: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Resolved through Statement of Understanding
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80290
80289 11/13/2020 PDC Staff VANQUILL RYAN P VANQUILL RYAN P: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80289
80288 11/13/2020 PDC Staff TAGEANT MARCUS A TAGEANT MARCUS A: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Resolved through Statement of Understanding
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80288
80287 11/13/2020 PDC Staff WRIGHT TROY A WRIGHT TROY A: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80287
80286 11/13/2020 PDC Staff RULLI JAMES E RULLI JAMES E: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Resolved through Statement of Understanding
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80286
80285 11/13/2020 PDC Staff WALLING DANNY L WALLING DANNY L: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80285
80284 11/13/2020 PDC Staff TYRONE V. GREEN TYRONE V. GREEN: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Resolved through Statement of Understanding
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80284
80283 11/13/2020 PDC Staff TURNER JUSTYN A TURNER JUSTYN A: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80283
80281 11/13/2020 PDC Staff SULLIVAN JEROMY C SULLIVAN JEROMY C: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80281
80280 11/13/2020 PDC Staff THORPE ROBERT J THORPE ROBERT J: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80280
80278 11/13/2020 PDC Staff TOMPKINS MARY M TOMPKINS MARY M: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80278
80275 11/13/2020 PDC Staff WITHROW HAROLD WITHROW HAROLD: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Resolved through Statement of Understanding
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80275
80274 11/13/2020 PDC Staff RUUD RICHARD E RUUD RICHARD E: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Closed Administratively
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80274
80273 11/13/2020 PDC Staff STILLINGS DANIEL C STILLINGS DANIEL C: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80273
80272 11/13/2020 PDC Staff YOUNG JOAN E YOUNG JOAN E: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80272
80271 11/13/2020 PDC Staff WORTHINGTON BETH L WORTHINGTON BETH L: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Resolved through Statement of Understanding
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80271
80270 11/13/2020 PDC Staff WARD WILLIAM S WARD WILLIAM S: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Resolved through Statement of Understanding
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80270
80269 11/13/2020 PDC Staff Joseph Romero Joseph Romero: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80269
80268 11/13/2020 PDC Staff LE RODENBERG LE RODENBERG: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80268
80267 11/13/2020 PDC Staff Leah Bowen Leah Bowen: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80267
80266 11/13/2020 PDC Staff NEUMAN CHARLA R NEUMAN CHARLA: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80266
80265 11/13/2020 PDC Staff Jesse Campos Jesse Campos: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80265
80264 11/13/2020 PDC Staff Jerry Lord Jerry Lord: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80264
80263 11/13/2020 PDC Staff Jessie L. Deardorff Jessie L. Deardorff: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80263
80262 11/13/2020 PDC Staff Katie Marks Katie Marks: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80262
80261 11/13/2020 PDC Staff JONATHON RODEBACK JONATHON RODEBACK: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission

At a brief enforcement hearing (brief adjudicative proceeding) held on December 17, 2020, the Presiding Officer found Jonathon Rodeback (the "Respondent") to be in violation of RCW 42.17A.700 for failure to file the Personal Financial Affairs Statement (F-1 report) that is required annually of elected officials. The F-1 report, disclosing financial information for 2019, was due no later than April 15, 2020. The Respondent was assessed a civil penalty of $250 and ordered to file the missing report within 30 days of the date of the Order, which was entered on January 11, 2021. 

At an enforcement hearing held on February 25, 2021, the full Commission considered the Respondent's request to Review the December 17, 2020 Order and affirmed the Findings of Fact, Conclusions of Law and $250 civil penalty assessed at the December 17, 2020 hearing.

https://www.pdc.wa.gov/browse/cases/80261
80260 11/13/2020 PDC Staff MORROW JOEDY MORROW JOEDY: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Closed Administratively
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80260
80259 11/13/2020 PDC Staff JERRY F. MORRIS JERRY F. MORRIS: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Closed Administratively
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80259
80258 11/13/2020 PDC Staff HYMAS JOHN H HYMAS JOHN H: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Resolved through Statement of Understanding
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80258
80257 11/13/2020 PDC Staff MCCARDLE ERIN N MCCARDLE ERIN N: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80257
80256 11/13/2020 PDC Staff MCGLASHAN KEITH A MCGLASHAN KEITH A: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Resolved through Statement of Understanding
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80256
80255 11/13/2020 PDC Staff KELLY MCGILL KELLY MCGILL : Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80255
80254 11/13/2020 PDC Staff MOSS JAMES P MOSS JAMES P: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80254
80253 11/13/2020 PDC Staff LARRY AYRE LARRY AYRE: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Resolved through Statement of Understanding
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80253
80252 11/13/2020 PDC Staff LITTLE RONNIE B LITTLE RONNIE B: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80252
80251 11/13/2020 PDC Staff Loren Rux Loren Rux: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80251
80250 11/13/2020 PDC Staff Joseph A. Brusic Joseph A. Brusic: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80250
80249 11/13/2020 PDC Staff LEITA MICHAEL D LEITA MICHAEL D: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Resolved through Statement of Understanding
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80249
80248 11/13/2020 PDC Staff PATU AIOMANU B PATU AIOMANU B: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission

This matter was heard by the Commission on March 25, 2021, which found that that Aiomanu Betty Patu violated RCW 42.17A.700 by failing to file the Personal Financial Affairs Statement (F-1 report) for calendar years 2018 & 2019 that were due no later than April 15, 2019 & April 15, 2020. 

The Commission assessed a $500 civil penalty and ordered the missing F-1 reports to be filed, both within 30 days of the Order, which was entered on April 20, 2021. 

https://www.pdc.wa.gov/browse/cases/80248
80247 11/13/2020 PDC Staff RANSOM ROBERT L RANSOM ROBERT L: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80247
80246 11/13/2020 PDC Staff Kim Roscoe Kim Roscoe: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80246
80245 11/13/2020 PDC Staff Jasmine Dickhoff Jasmine Dickhoff: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80245
80244 11/13/2020 PDC Staff MCIRVIN RYAN A MCIRVIN RYAN A: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Resolved through Statement of Understanding
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80244
80243 11/13/2020 PDC Staff MACOLL EILEEN M MACOLL EILEEN M: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80243
80242 11/13/2020 PDC Staff KAYSER MICHAEL L KAYSER MICHAEL L: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80242
80241 11/13/2020 PDC Staff JIMENEZ JOSE ELIGIO JIMENEZ JOSE E: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission

This matter was heard by the Presiding Officer on April 1, 2021,  who found that Jose Eligio Jimenez violated RCW 42.17A.700 by failing to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019 that was due no later than April 15, 2020. 

The Commission assessed a $150 civil penalty, of which $50 is suspended, payable within 30 days of the Order, which was entered on April 20, 2021. 

https://www.pdc.wa.gov/browse/cases/80241
80240 11/13/2020 PDC Staff Judy Williams Judy Williams: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80240
80239 11/13/2020 PDC Staff KINZER BRENDA J KINZER BRENDA J: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80239
80238 11/13/2020 PDC Staff LEONARD JONATHAN F LEONARD JONATHAN F: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80238
80237 11/13/2020 PDC Staff MIEHE LAUREN J MIEHE LAUREN J: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Resolved through Statement of Understanding
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80237
80236 11/13/2020 PDC Staff KAUNDAL MANDEEP S KAUNDAL MANDEEP S: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80236
80235 11/13/2020 PDC Staff MARTIN JOHN R MARTIN JOHN R: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80235
80234 11/13/2020 PDC Staff MILLER KAREN M MILLER KAREN M: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Closed Administratively
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80234
80233 11/13/2020 PDC Staff ROBINSON RANDY J ROBINSON RANDY J: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80233
80232 11/13/2020 PDC Staff NORRIS DARIEL L NORRIS DARIEL L: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Resolved through Statement of Understanding
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80232
80231 11/13/2020 PDC Staff LUTZ DAVID G LUTZ DAVID G: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80231
80230 11/13/2020 PDC Staff QUANTRELL JOSHUA M QUANTRELL JOSHUA M: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission

This matter was heard by the Commission on March 25, 2021, which found that that Joshua Quantrell violated RCW 42.17A.700 by failing to file the Personal Financial Affairs Statement (F-1 report) for calendar years 2018 & 2019 that were due no later than April 15, 2019 & April 15, 2020. 

The Commission assessed a $500 civil penalty and ordered the missing F-1 reports to be filed, both within 30 days of the Order, which was entered on April 20, 2021. 

https://www.pdc.wa.gov/browse/cases/80230
80229 11/13/2020 PDC Staff MAKSIMOS MARIANA M MAKSIMOS MARIANA M: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80229
80228 11/13/2020 PDC Staff RADOSEVICH STEVEN M RADOSEVICH STEVEN M: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Resolved through Statement of Understanding
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80228
80227 11/13/2020 PDC Staff Neal Martin Neal Martin: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80227
80226 11/13/2020 PDC Staff Leslie Jo Wells Leslie Jo Wells: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Resolved through Statement of Understanding
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80226
80225 11/13/2020 PDC Staff ROHRICK ROBERT A ROHRICK ROBERT A: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80225
80224 11/13/2020 PDC Staff RICE DALE Q RICE DALE Q: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Resolved through Statement of Understanding
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80224
80223 11/13/2020 PDC Staff ROESLER MARY K ROESLER MARY K: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80223
80222 11/13/2020 PDC Staff JERNIGAN JEFF M JERNIGAN JEFF M: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission

At a February 25, 2021 enforcement hearing, the Commission found that Jeff Jernigan (the “Respondent”) violated RCW 42.17A.700 for failure to file F-1 reports (Personal Financial Affairs Statements) as an elected official who held office in 2019 and 2020. The F-1 reports, disclosing financial information for 2018 & 2019, were due to be filed no later than April 15, 2019 and April 15, 2020 respectively. 

At the hearing, the Commission ordered a $3,000 civil penalty, $3,000 of which is suspended based on the following conditions: The Respondent must 1) file the missing F-1 reports within 30 days of the date of the Order; 2) pay $4,000 in civil penalties for prior violations within 120 days; and 3) not commit any further violations of Chapter 42.17A RCW or Title 390 WAC within four years of the date of the Order, which was issued on March 11, 2021. 

The PDC received the Respondent's F-1 reports covering 2019 and 2020 financial activity on February 19, 2021 and his F-1 reports covering calendar years 2015-2018 on March 2, 2021.

https://www.pdc.wa.gov/browse/cases/80222
80221 11/13/2020 PDC Staff MERZ KURT S MERZ KURT S: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80221
80220 11/13/2020 PDC Staff Gladys Gillis Gladys Gillis: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80220
80219 11/13/2020 PDC Staff GONZALEZ CANDELARIO GONZALEZ CANDELARIO: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Resolved through Statement of Understanding
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80219
80218 11/13/2020 PDC Staff ELLISON JOSIE ELLISON JOSIE: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80218
80217 11/13/2020 PDC Staff Gary K. Anderson Gary K. Anderson: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80217
80216 11/13/2020 PDC Staff HUIE MYRON J HUIE MYRON J: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Resolved through Statement of Understanding
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80216
80215 11/13/2020 PDC Staff Gerald George Gerald George: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Scheduled for Brief Hearing
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80215
80214 11/13/2020 PDC Staff Dianna Galvan Dianna Galvan: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Resolved through Statement of Understanding
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80214
80213 11/13/2020 PDC Staff GEHRKE RONALD A GEHRKE RONALD A: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80213
80212 11/13/2020 PDC Staff HELMONDS RONALD A HELMONDS RONALD A: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80212
80211 11/13/2020 PDC Staff HAYNES JERRALL J HAYNES JERRALL J: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80211
80210 11/13/2020 PDC Staff DELEON OLIVIA DELEON OLIVIA: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020 and failure to file a Personal Financial Affairs Statement (F-1 report) due no later than April 15, 2019, disclosing financial information for calendar year 2018. 
https://www.pdc.wa.gov/browse/cases/80210
80209 11/13/2020 PDC Staff FARRER ERIN A FARRER ERIN A: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Resolved through Statement of Understanding
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80209
80208 11/13/2020 PDC Staff HUTSON MARK E HUTSON MARK E: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80208
80207 11/13/2020 PDC Staff DONNER CRYSTAL L DONNER CRYSTAL L: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Resolved through Statement of Understanding
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80207
80206 11/13/2020 PDC Staff DYBALL KENNETH J DYBALL KENNETH J: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80206
80205 11/13/2020 PDC Staff GRASSI KENNETH J GRASSI KENNETH J: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80205
80204 11/13/2020 PDC Staff DE JONG KARL DE JONG KARL: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80204
80203 11/13/2020 PDC Staff ETTER JODY M ETTER JODY M: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80203
80202 11/13/2020 PDC Staff GOSSETT LARRY E GOSSETT LARRY E: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80202
80201 11/13/2020 PDC Staff ELLIS DONALD A ELLIS DONALD A: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80201
80200 11/13/2020 PDC Staff HYLTON JOHN R HYLTON JOHN R: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Closed Administratively
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80200
80199 11/13/2020 PDC Staff HUCK TODD HUCK TODD: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80199
80198 11/13/2020 PDC Staff DUNCAN MARK D DUNCAN MARK D: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80198
80196 11/13/2020 PDC Staff HUGHES SCOTT HUGHES SCOTT: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80196
80195 11/13/2020 PDC Staff GEARY JILL L GEARY JILL L: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80195
80194 11/13/2020 PDC Staff ENGLE THOMAS D ENGLE THOMAS D: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80194
80193 11/13/2020 PDC Staff DUDLEY FARLEY DUDLEY FARLEY: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Closed Administratively
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80193
80192 11/13/2020 PDC Staff Dean Berkeley Dean Berkeley: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80192
80190 11/13/2020 PDC Staff DAVID M. JENKINS DAVID M. JENKINS: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Closed Administratively
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80190
80189 11/13/2020 PDC Staff Daniel P. Williams Daniel P. Williams: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission

At a February 25, 2021 enforcement hearing, the Commission found that Daniel P. Williams (the “Respondent”) violated RCW 42.17A.700 for failure to file F-1 reports (Personal Financial Affairs Statements) as an elected official who held office in 2019. The F-1 reports, disclosing financial information for 2018 & 2019, were due to be filed no later than April 15, 2019 and April 15,2020 respectively. At the hearing, the Commission ordered the Respondent to pay a $1,000 civil penalty and file the missing reports within 30 days from the date of the Initial Order, which was issued on March 11, 2021. 

https://www.pdc.wa.gov/browse/cases/80189
80188 11/13/2020 PDC Staff Dale Thornton Dale Thornton: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80188
80187 11/13/2020 PDC Staff CURTIS JAMES H CURTIS JAMES H: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80187
80186 11/13/2020 PDC Staff COVINGTON BRENDA COVINGTON BRENDA: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80186
80185 11/13/2020 PDC Staff COLEMAN JOSHUA A COLEMAN JOSHUA A: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80185
80184 11/13/2020 PDC Staff Clayton S. Whitehead Clayton S. Whitehead: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80184
80183 11/13/2020 PDC Staff CASTILLO NOE CASTILLO NOE: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80183
80182 11/13/2020 PDC Staff CARPENTER TENEILLE L CARPENTER TENEILLE L: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80182
80181 11/13/2020 PDC Staff BURROW BRIAN BURROW BRIAN: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80181
80180 11/13/2020 PDC Staff BURKETT SANDY BURKETT SANDY: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Resolved through Statement of Understanding

On November 17, 2020, the Public Disclosure Commission (PDC) notified Sandy Burkett of an alleged violation of violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for Calendar Year 2019. 

Based on 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/80180
80179 11/13/2020 PDC Staff BRETT R JONES BRETT R. JONES: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80179
80178 11/13/2020 PDC Staff BOLENEUS DERAL D BOLENEUS DERAL D: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Closed Administratively
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80178
80177 11/13/2020 PDC Staff BOERSTLER DIANE E BOERSTLER DIANE E: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80177
80176 11/13/2020 PDC Staff Beau Burkett Beau Burkett: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 & Calendar Year 2018 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation One: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
  • Allegation Two: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2018, due no later than April 15, 2019.
https://www.pdc.wa.gov/browse/cases/80176
80175 11/13/2020 PDC Staff BARKER PATRICK J BARKER PATRICK J: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Resolved through Statement of Understanding
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80175
80174 11/13/2020 PDC Staff Anthony Veliz Anthony Veliz: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80174
80173 11/13/2020 PDC Staff ANTHONY PRATT ANTHONY PRATT: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80173
80172 11/13/2020 PDC Staff Andrew J. Bickar Andrew J. Bickar: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80172
80171 11/13/2020 PDC Staff Alex Davis Alex Davis: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement for Calendar Year 2019 (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 report) for calendar year 2019, due no later than April 15, 2020.
https://www.pdc.wa.gov/browse/cases/80171
80169 11/13/2020 PDC Staff Craig Campbell Craig Campbell: Alleged violations of RCW 42.17A.205 and .700 for failure to timely file Candidate Registration and Personal Financial Affairs Statement within two weeks of becoming a candidate (Group Enforcement 2020) RCW 42.17A.205, RCW 42.17A.700 Resolved through Statement of Understanding
  • Allegation One: Violation of RCW 42.17A.205 for failure to timely file the Candidate Registration (C-1 report) within two weeks of becoming a candidate, or no later than June 1, 2020.
  • Allegation Two: 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, or no later than June 1, 2020.
https://www.pdc.wa.gov/browse/cases/80169
80168 11/13/2020 PDC Staff ROGOFF ROGER S ROGOFF ROGER S: Alleged violations of RCW 42.17A.205 for failure to timely file Candidate Registration within two weeks of becoming a candidate (Group Enforcement 2020) RCW 42.17A.205 Resolved through Statement of Understanding
  • Allegation: Violation of RCW 42.17A.205 for failure to timely file the Candidate Registration (C-1 report) within two weeks of becoming a candidate, or no later than June 1, 2020.
https://www.pdc.wa.gov/browse/cases/80168
80167 11/13/2020 PDC Staff Steve B DIXON Steve B DIXON: Alleged violations of RCW 42.17A.205 for failure to timely file Candidate Registration within two weeks of becoming a candidate (Group Enforcement 2020) RCW 42.17A.205 Resolved through Statement of Understanding
  • Allegation: Violation of RCW 42.17A.205 for failure to timely file the Candidate Registration (C-1 report) within two weeks of becoming a candidate, or no later than June 1, 2020.
https://www.pdc.wa.gov/browse/cases/80167
80166 11/13/2020 PDC Staff Charles Adkins Charles Adkins: Alleged violations of RCW 42.17A.700 for failure to timely file Personal Financial Affairs Statement within two weeks of becoming a candidate (Group Enforcement 2020) RCW 42.17A.700 Closed Administratively
  • Allegation: 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, or no later than June 1, 2020.
https://www.pdc.wa.gov/browse/cases/80166
80165 11/13/2020 PDC Staff Mario Brown Mario Brown: Alleged violations of RCW 42.17A.700 for failure to timely file Personal Financial Affairs Statement within two weeks of becoming a candidate (Group Enforcement 2020) RCW 42.17A.700 Closed Administratively
  • Allegation: 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, or no later than June 1, 2020.
https://www.pdc.wa.gov/browse/cases/80165
80164 11/13/2020 PDC Staff Justin Boneau Justin Boneau: Alleged violations of RCW 42.17A.700 for failure to timely file Personal Financial Affairs Statement within two weeks of becoming a candidate (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: 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, or no later than June 1, 2020.
https://www.pdc.wa.gov/browse/cases/80164
80163 11/13/2020 PDC Staff Clifford Cawthon Clifford Cawthon: Alleged violations of RCW 42.17A.700 for failure to timely file Personal Financial Affairs Statement within two weeks of becoming a candidate (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: 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, or no later than June 1, 2020.
https://www.pdc.wa.gov/browse/cases/80163
80162 11/13/2020 PDC Staff Paul A. Strophy Paul A. Strophy: Alleged violations of RCW 42.17A.700 for failure to timely file Personal Financial Affairs Statement within two weeks of becoming a candidate (Group Enforcement 2020) RCW 42.17A.700
  • Allegation: 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, or no later than June 1, 2020.
https://www.pdc.wa.gov/browse/cases/80162
80161 11/13/2020 PDC Staff Hank Dole Hank Dole: Alleged violations of RCW 42.17A.700 for failure to timely file Personal Financial Affairs Statement within two weeks of becoming a candidate (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: 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, or no later than June 1, 2020.
https://www.pdc.wa.gov/browse/cases/80161
80160 11/13/2020 PDC Staff Paul F. Eagle Paul F. Eagle: Alleged violations of RCW 42.17A.700 for failure to timely file Personal Financial Affairs Statement within two weeks of becoming a candidate (Group Enforcement 2020) RCW 42.17A.700 Resolved through Statement of Understanding

On November 17, 2020, the Public Disclosure Commission (PDC) notified Paul Eagle of an alleged violation of RCW 42.17A.700 for failure to timely file Personal Financial Affairs Statement (F-1 report) within two weeks of becoming a candidate.  

PDC staff have reviewed this matter and found the following: 

• You filed your F-1 on November 30, 2020 

• Your Statement of Understanding and Payment were received in the PDC office on December 10, 2020. 

Paul Eagle 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.700 for failure to timely file Personal Financial Affairs Statement. 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/80160
80159 11/13/2020 PDC Staff Ryan Vance Ryan Vance: Alleged violations of RCW 42.17A.700 for failure to timely file Personal Financial Affairs Statement within two weeks of becoming a candidate (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: 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, or no later than June 1, 2020.
https://www.pdc.wa.gov/browse/cases/80159
80158 11/13/2020 PDC Staff Learner Limbach Learner Limbach: Alleged violations of RCW 42.17A.700 for failure to timely file Personal Financial Affairs Statement within two weeks of becoming a candidate (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: 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, or no later than June 1, 2020.
https://www.pdc.wa.gov/browse/cases/80158
80157 11/13/2020 PDC Staff Mark W Christie Mark W Christie: Alleged violations of RCW 42.17A.700 for failure to timely file Personal Financial Affairs Statement within two weeks of becoming a candidate (Group Enforcement 2020) RCW 42.17A.700
  • Allegation: 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, or no later than June 1, 2020.
https://www.pdc.wa.gov/browse/cases/80157
80156 11/13/2020 PDC Staff Christopher Reed Christopher Reed: Alleged violations of RCW 42.17A.700 for failure to timely file Personal Financial Affairs Statement within two weeks of becoming a candidate (Group Enforcement 2020) RCW 42.17A.700 Closed Administratively
  • Allegation: 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, or no later than June 1, 2020.
https://www.pdc.wa.gov/browse/cases/80156
80155 11/13/2020 PDC Staff TURISSINI DANILLE A TURISSINI DANILLE A: Alleged violations of RCW 42.17A.700 for failure to timely file Personal Financial Affairs Statement within two weeks of becoming a candidate (Group Enforcement 2020) RCW 42.17A.700 Closed Administratively
  • Allegation: 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, or no later than June 1, 2020.
https://www.pdc.wa.gov/browse/cases/80155
80154 11/13/2020 PDC Staff FOGEL RAINI L FOGEL RAINI L: Alleged violations of RCW 42.17A.700 for failure to timely file Personal Financial Affairs Statement within two weeks of becoming a candidate (Group Enforcement 2020) RCW 42.17A.700 Violation Found by Commission
  • Allegation: 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, or no later than June 1, 2020.
https://www.pdc.wa.gov/browse/cases/80154
80153 11/13/2020 PDC Staff RUZUMNA DAVID RUZUMNA DAVID: Alleged violations of RCW 42.17A.700 for failure to timely file Personal Financial Affairs Statement within two weeks of becoming a candidate (Group Enforcement 2020) RCW 42.17A.700 Resolved through Statement of Understanding
  • Allegation: 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, or no later than June 1, 2020.
https://www.pdc.wa.gov/browse/cases/80153
79792 11/09/2020 Glen Morgan Kshama Solidarity Campaign Kshama Solidarity Campaign: Alleged violations of RCW 42.17A.417 for accepting a contribution from a foreign national (EY 20; Oct 20) RCW 42.17A.417 Case Closed with Reminder
  • Allegation: Violation of RCW 42.17A.417 for accepting a contribution from a foreign national.
https://www.pdc.wa.gov/browse/cases/79792
79730 11/06/2020 Salley Bull Shauna Beeman Beeman, Shauna: Alleged Violation of RCW 42.17A.235, .240 for failure to timely and accurately disclose contributions and expenditures (EY20, Nov20) RCW 42.17A.240, RCW 42.17A.235 Case Closed with Reminder
  • Allegation: Violation of RCW 42.17A.235, .240 for failure to timely and accurately disclose contributions and expenditures
https://www.pdc.wa.gov/browse/cases/79730
79721 11/06/2020 Glen Morgan Ana Ruiz Ramirez Peralta Ruiz Peralta, Ana (2): Alleged Violation of RCW 42.17A.235, .240 for failure to timely and accurately disclose expenditures (EY20, Nov20) RCW 42.17A.240, RCW 42.17A.235 Case Closed with Reminder

The complaint alleged Ana Ruiz Peralta violated RCW 42.17A.235 and .240 by failing to timely and accurately disclose expenditures. 

Based on PDC findings, and the fact Peralta was a first-time candidate, filed the original reports timely and the Campaign made a good faith efforts to comply with the reporting requirements of RCW 42.17A.240 concerning expenditures undertaken by the campaign on their C-4 reports, and the public was not deprived of critical information as the dates, amounts, and purposes of the expenditures were disclosed, staff has determined, in this instance, the failure to timely and accurately report expenditure detail does not amount a violation warranting further investigation. 

PDC staff is reminding Ana Ruiz Peralta about the importance of filing timely, accurate and complete 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/79721
79715 11/06/2020 Glen Morgan Don Welch Welch, Don: Alleged Violation of RCW 42.17A.405 for exceeding contribution limits (EY20, Nov20) RCW 42.17A.405 Case Closed with Reminder
  • Allegation: Violation of RCW 42.17A.405 for exceeding contribution limits
https://www.pdc.wa.gov/browse/cases/79715
79714 11/06/2020 Glen Morgan Clark County Is Not For Sale Clark County is Not For Sale: Alleged Violation of 42.17A RCW for failure to timely register with their sponsorship in the name; failure to timely and accurately report contributions & expenditures; and exceeding limit contributions (EY20, Nov20) RCW 42.17A.270, RCW 42.17A.405, RCW 42.17A.240, RCW 42.17A.235, RCW 42.17A.205, RCW 42.17A.260 Case Closed with Reminder
  • Allegation one: Violation of RCW 42.17A.205 for failure to timely register with their sponsorship in the name
  • Allegation two: Violation of RCW 42.17A.235, .240, .260 & .270 for failure to timely and accurately report contributions & expenditures
  • Allegation three: Violation of RCW 42.17A.405 for exceeding contribution limits
https://www.pdc.wa.gov/browse/cases/79714
79713 11/06/2020 Glen Morgan Matthew Little Little, Matthew (2): Alleged Violation of RCW 42.17A.405 for accepting over limit contributions (EY20, Nov20) RCW 42.17A.405 Case Closed with Reminder
  • Allegation: Violation of RCW 42.17A.405 for accepting over limit contributions  
https://www.pdc.wa.gov/browse/cases/79713
79694 11/06/2020 Alex Bond Bill Bruch Bruch, Bill: Alleged Violation of RCW 42.17A.405 for accepting over limit contributions (EY20, Nov20) RCW 42.17A.405 Case Closed with Reminder

The complaint alleged Bill Bruch violated RCW 42.17A.405 by accepting contributions from a county central committee that, when combined with other county central committees and a legislative district committee, exceeded contribution limits for a 2020 legislative candidate allowed in RCW 42.17A.405(4)(b).

Based on the fact Bruch refunded the contribution promptly when notified of the requirement and the funds were not used by the Campaign, staff has determined in this instance the Campaign’s acceptance of over-limit contribution does not amount a violation warranting further investigation. PDC staff is reminding Bill Bruch about the importance of compliance with RCW 42.17A.405 and expects Bruch will not accept any contributions exceeding limits in the future, as required by law. Based on 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/79694
79693 11/06/2020 Alex Bond Skagit County Republicans Skagit County Republicans (2): Alleged Violation of RCW 42.17A.405 for making over limit contributions (EY20, Nov20) RCW 42.17A.405 Case Closed with Reminder

The complaint alleged the Skagit County Republicans, a Continuing Bona-fide County Political Party Committee, violated RCW 42.17A.405 by contributing to Bill Bruch, who was a 2020 candidate for the Washington State House of Representative from the 10th District. The complaint alleged the contribution, when combined with contributions from other county central committees and a legislative district committee, exceeded contribution limits for a 2020 legislative candidate allowed in RCW 42.17A.405(4)(b).

Staff has determined in this instance, exceeding the contribution limits for a 2020 legislative candidate allowed in RCW 42.17A.405(4)(b) does not amount a violation warranting further investigation. PDC staff is reminding the Skagit County Republicans about the importance of compliance with RCW 42.17A.405 and PDC staff expects the Skagit County Republicans will not contribute in excess of contribution limits in the future, as required by law.

Based on 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/79693
79637 11/05/2020 Alex Bond House Republican Organizational Committee House Republican Organizational Committee (3): Alleged Violation of RCW 42.17A.420 for accepting an over limit contribution, during the 21-day period preceding the November 3, 2020 general election (EY20, Nov20) RCW 42.17A.420 Case Closed with No Evidence of Violations
  • Allegation: Violation of RCW 42.17A.420 for accepting an over limit contribution, during the 21-day period preceding the November 3, 2020 general election
https://www.pdc.wa.gov/browse/cases/79637
79635 11/05/2020 Alex Bond Carolyn Eslick Eslick, Carolyn (2): Alleged Violation of RCW 42.17A.205, .235 and .240 for failure to timely register and report activities for a Surplus Funds Account (EY20, Nov20) RCW 42.17A.205, RCW 42.17A.235, RCW 42.17A.240 Case Closed with Written Warning
  • Allegation one: Violation of RCW 42.17A.205 for failure to timely register Surplus Funds Account
  • Allegation two: Violation of RCW 42.17A.235 and .240 for failure to timely and accurately report activities for Surplus Funds
https://www.pdc.wa.gov/browse/cases/79635
79585 11/04/2020 Josalun Hasz Committee to Hold Elected Officials Accountable Committee to Hold Elected Officials Accountable: Alleged violations of RCW 42.17A.255, .260, and .305 for failure to accurately and completely disclose independent expenditures and electioneering communications (EY 20; Oct 20) WAC 390-16-037, wac 390-16-205, RCW 42.17A.305, RCW 42.17A.255, RCW 42.17A.260 Case Closed with Reminder

The complaint alleged the Committee to Hold Elected Officials Accountable (Committee) violated RCW 42.17A.255, .260, and .305 by failing to accurately and completely disclose independent expenditures and electioneering communications.

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

Based on PDC staff findings, and the fact the Committee filed original reports timely and made a good faith effort to comply with the reporting requirements concerning its expenditures, and the public was not deprived of critical information as the dates, amounts, and purposes of the expenditures were disclosed, staff has determined, in this instance, the failure to timely and accurately report expenditure detail does not amount a violation warranting further investigation. 

PDC staff is reminding the Committee to Hold Elected Officials Accountable about the importance of filing timely, accurate and complete reports in accordance with PDC laws and rules. PDC staff is also reminding the Committee about the importance of including complete sponsor identification in political advertising. 

Based on 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/79585
79581 11/04/2020 Judith Smriga Turn Washington Turn Washington: Alleged Violation of RCW 42.17A.320, .335 for failure to disclose full sponsor identification and false statement of incumbency in political advertising (EY20, Nov20) RCW 42.17A.320, RCW 42.17A.335 Case Closed with Reminder

The complaint alleged TURN Washington, an entity registered as a political committee in 2019 with the PDC, violated: (1) RCW 42.17A.320 by failing to include the complete sponsor identification for political advertising in support or opposition to any candidate or ballot proposition in Washington state; and (2) RCW 42.17A.335 for sponsoring political advertising that contained a false claim of incumbency in political advertising. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements;the applicable PDC reports, and the response from Kelly Payne, former Committee member of TURN Washington, to determine whether the record supports a finding of one or more violations.

Based on the findings, and the facts the advertising was clearly sponsored by the Committee and no evidence was found of any intent to conceal true sponsorship, staff has determined, in this instance, the failure to include sponsor identification does not amount a violation warranting further investigation.

PDC staff is reminding TURN Washington about the importance of identifying the sponsor's name and address on any future political advertisements in accordance with PDC laws and rules.

Based on this information, the PDC finds 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/79581
79580 11/04/2020 Judith Smriga Kevin Ballard Ballard, Kevin: Alleged Violation of RCW 42.17A.235, .240 for failure to timely and accurately disclose contributions, expenditures, loans or debts (EY20, Nov20) RCW 42.17A.240, RCW 42.17A.235 Case Closed with Reminder

The complaints alleged Kevin Ballard violated RCW 42.17A.235 and .240 by failing to timely and accurately disclose expenditures. PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements;the applicable PDC reports, and the response from Jason Michaud, treasurer for Friends of Kevin Ballard (Campaign), to determine whether the record supports a finding of one or more violations.

Based on PDC findings, and the fact the Campaign filed the original reports timely and the Campaign made a good faith efforts to comply with the reporting requirements of RCW 42.17A.240 concerning expenditures undertaken by the campaign on their C-4 reports, and the public was not deprived of critical information as the dates, amounts, and purposes of the expenditures were disclosed, staff has determined, in this instance, the failure to timely and accurately report expenditure detail does not amount a violation warranting further investigation. 

PDC staff is reminding Kevin Ballard about the importance of filing timely, accurate and complete reports in accordance with PDC laws and rules and expects in the future Ballard will timely file accurate and complete 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/79580
79577 11/04/2020 Alex Bond Equal Opportunity PAC Equal Opportunity PAC: Alleged violations of Chapter 42.17A RCW for failure to timely, accurately, and completely disclose expenditure details and report independent expenditures or electioneering communications (EY 20; Oct 20) RCW 42.17A.255, RCW 42.17A.260, RCW 42.17A.235, RCW 42.17A.240, RCW 42.17A.305 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on October 20, 2020. The complaint alleged that Equal Opportunity PAC, a political committee supporting and opposing legislative candidates in the 2020 election, may have violated: (1) RCW 42.17A.235 and RCW 42.17A.240 for failure to timely and accurately disclose expenditures for political advertising and debts; (2) RCW 42.17A.240 and WAC 390-16-037 for failure to accurately and completely disclose expenditure details, including the number of items printed; and (3) 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; 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.

It appears that, although the campaign activity reports filed by the Respondent contained a small number of errors needing correction, Equal Opportunity PAC made a good faith effort to fully disclose the PAC’s activity on both C-4 and C-6 reports in a timely manner and did not intend to keep relevant campaign activity from the public.

Based on our findings staff has determined that, in this instance, failure to include complete descriptions on a small number of expenditures does not amount to a finding of a violation that warrants further investigation.

PDC staff is reminding Equal Opportunity PAC about the importance of the timely and accurate disclosure of all campaign debts and expenditures, specifically including the detailed descriptions required on both C-4 and C-6 report 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/79577
79517 11/03/2020 Sandra Giachino Our Olympic Communities Enterprise Washington Our Olympic Communities Enterprise Washington (3): Alleged Violation of RCW 42.17A.235 & .240 for failure to timely and accurately disclose contributions, expenditures, loans and debts (EY20, Nov20) RCW 42.17A.240, WAC 390-16-042, RCW 42.17A.235 Case Closed with No Evidence of Violations

The complaint alleged Our Olympic Communities Enterprise Washington (Committee) violated RCW 42.17A.235 and .240 by failing to timely and accurately disclose contributions, expenditures, loans and debts, specifically the Committee failed to report payment of a $9,100 debt.

PDC staff reviewed the allegations, evidence you provided, applicable statutes and rules and the response provided by Tom Perry, Treasurer for Enterprise Washington, to determine whether the record supports a finding of one or more violations.

Based on the review and the fact the $9,100 was not spent by the Committee as alleged, staff has determined, in this instance, the alleged violation of RCW 42.17A.235 and .240 by failing to timely and accurately disclose contributions, expenditures, loans and debts, specifically the allegation the Committee failed to report payment of a $9,100 debt, 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/79517
79347 10/30/2020 Richard Monacelli Greg Tompkins Tompkins, Greg: Alleged violation of RCW 42.17A.555 by using public facilities to assist an election campaign (Perry Dozier). (EY '20; Oct '20) RCW 42.17A.555 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on October 22, 2020. The complaint alleged that Greg Tompkins, a current Walla Walla County Commissioner, Position 3, may have violated RCW 42.11A.555 by using public facilities (Facebook page) to assist the election campaign of 2020 State Senate candidate, Perry Dozier.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Greg Tompkins (the “Respondent”); PDC Interpretation 04-02; and the applicable PDC reports filed by the Respondent, to determine whether the record supports a finding of one or more violations.

Given the general content of information and posts, it appears that the Facebook page created “Greg Tompkins-Walla Wall County Commissioner District 3” was intended to be used primarily for Commissioner Tompkins to communicate with his constituents in his official capacity and not for personal business. Commissioner Tompkins’ response confirmed that the Walla Walla County Commissioner’s office has purposely not created social media pages for its elected officials. Staff believes, with the exception of the disclaimer stating otherwise, that a member of the public landing on this Facebook would likely interpret it as the official page for Walla Walla County Commissioner Greg Tompkins and not Mr. Tompkins’ personal page.

Based on our findings staff has determined that, in this instance, use of a Facebook page with almost every component of an official public page of an elected public official to support a candidate for public office, does not amount to a finding of a violation that warrants further investigation.

PDC staff is reminding Greg Tompkins about the importance of strictly following the prohibitions and restrictions regarding the use of public facilities in the future in accordance with PDC 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/79347
79346 10/30/2020 Richard Monacelli Perry Dozier Dozier, Perry: Alleged violation of RCW 42.17A.320 for failure to use sufficient font size to identify party preference on yard signs. (EY '20; Oct '20) 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 October 22, 2020. The complaint alleged that Perry Dozier, a candidate for State Senate, Legislative District 16, in the November 3, 2020 general election, may have violated RCW 42.17A.320 for failure to use sufficient font size to identify party preference on yard signs advertising his campaign.

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

It appears that, although the party preference on Mr. Dozier’s yard signs advertising his 2020 State Senate campaign may have been difficult for some members of the public, including the Complainant, to easily read from the road, the signs printed and distributed by Mr. Dozier, did include lettering that is compliant with PDC laws and rules.

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/79346
79301 10/29/2020 Glen Morgan Elisabeth Tutsch Tutsch, Elisabeth: Alleged Violation of RCW 42.17A.235 & .240 for failure to accurately disclose expenditures (EY20, Oct20) 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 October 29, 2020. The complaint alleged that Elisabeth Tutsch, a 2020 judicial candidate, for Yakima County Superior Court, may have violated RCW 42.17A.235 & RCW 42.17A.240 for failure to timely 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 response provided by Elisabeth Tutsch (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.

It appears that the late and inaccurate C-4 reports submitted by the Respondent were due to inexperience and general lack of knowledge regarding PDC reporting requirements and not done in an effort the conceal campaign activities from the public. Although the C-4 reports did require edits to descriptions, staff noted that the Respondent responded quickly and worked with PDC Filer Assistance staff to amend the reports, resulting in detailed disclosure of all campaign expenditures.

Based on our findings staff has determined that, in this instance, failure to timely and accurately file complete expenditure descriptions on C-4 reports for the 2020 election does not amount to a finding of a violation that warrants further investigation.

PDC staff is reminding Elisabeth Tutsch about the importance of the timely and accurate disclosure of all expenditure activities, specifically the detailed description required 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/79301
79287 10/29/2020 Glen Morgan Matthew Little Little, Matthew: Alleged Violation of RCW 42.17A.235, .240 for failure to accurately disclose expenditures; RCW 42.17A.445 for personal use of campaign funds (EY20, Oct20) RCW 42.17A.445, RCW 42.17A.240, RCW 42.17A.235 Case Closed with Reminder
  • Allegation one: Violation of RCW 42.17A.235 & .240 for failure to accurately disclose expenditures on reports (C-4)
  • Allegation two: Violation of RCW 42.17A.445 for personal use of campaign funds
https://www.pdc.wa.gov/browse/cases/79287
79164 10/28/2020 David Snell Hans Zeiger Zeiger, Hans: Alleged violation of RCW 42.17A.235, 240, WAC 390-16-037 & WAC 390-16-205 for failure to timely, accurately & sufficiently describe expenditures & report sub-vendor details. (EY '20; Oct '20) WAC 390-16-037, wac 390-16-205, RCW 42.17A.235, RCW 42.17A.240 Case Closed with Written Warning
  • Allegation: Alleged violation of RCW 42.17A.235, 240, WAC 390-16-037 & WAC 390-16-205 for failure to timely, accurately & sufficiently describe expenditures & report sub-vendor details (for Pierce Co City Council race)
https://www.pdc.wa.gov/browse/cases/79164
78972 10/26/2020 Glen Morgan Helen Price Johnson Johnson, Helen Price: Alleged violations of RCW 42.17A.235 & .240 for failure to timely and accurately report expenditures, and WAC 390-16-037 & -205 by not sufficiently describing expenditure details. (EY '20; Oct '20) RCW 42.17A.240, WAC 390-16-037, wac 390-16-205, RCW 42.17A.235 Case Closed with Reminder

The complaint alleged Helen Price Johnson, a 2020 candidate for Washington State Senate from the 10th District, may have violatedRCW 42.17A.235 and .240 by failing to timely and accurately report expenditures and expenditure detail on Summary Full Campaign Contribution and Expenditure (C-4) reports.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the applicable PDC reports, and the response from Margaret Andersen, Treasurer for the Committee to Elect Helen Price Johnson (Campaign) to determine whether the record supports a finding of one or more violations. 

Based on these findings, and the fact the advertising was sponsored by the Candidate pictured in the advertising, with no intent to conceal sponsorship, and the expenditure was reported before the election, staff has determined, in this instance, the failure to timely and accurately report the expenditure and additional detail does not amount a violation warranting further investigation. 

PDC staff is reminding Helen Price Johnson about the importance of filing timely, accurate and complete 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/78972
78962 10/26/2020 Kathleen Landel, Alex Bond South Sound Future Enterprise Washington South Sound Future Enterprise Washington: Alleged violation of WAC 390-18-040 by using the term "Re-elect" on political advertising for an appointed incumbent. (EY '20; Oct '20) WAC 390-18-040 Case Closed with Written Warning

The complaints alleged South Sound Future Enterprise Washington violated WAC 390-18-040 by using the term "Re-elect" on political advertising for an appointed incumbent, specifically Ron Muzzall.

PDC staff has determined that in this instance, the Committee using the term "Re-elect" on political advertising for an appointed incumbent does not amount to a finding of a violation that warrants further investigation

However, pursuant to WAC 390-37-060(1)(d), South Sound Future Enterprise Washington will receive a formal written warning concerning the use of re-elect as noted in this letter. The formal written warning includes staff’s expectation the Committee will, in the future, use political advertising language properly, as set forth in WAC 390-18-040. The Commission will consider the formal written warning in deciding on future 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/78962
78959 10/26/2020 Donald Britain We Want Accountability PAC We Want Accountability PAC: Alleged violation of .225, .235 & .240 for failure to timely & accurately report contributions & expenditures. (EY '20; Oct '20) RCW 42.17A.235, RCW 42.17A.240, RCW 42.17A.225 Case Closed with Reminder
  • Allegation: Alleged violation of .225, .235 & .240 for failure to timely & accurately report contributions & expenditures.
https://www.pdc.wa.gov/browse/cases/78959
78954 10/26/2020 Brian Estes, Elizabeth Hartsoch, Bill McCallum Robert Gray Gray, Robert: Alleged Violation of RCW 42.17A.320 for failure to disclose sponsor identification on political advertisement; RCW 42.17A.255 for failure to timely report Independent Expenditures (EY20, Oct20) RCW 42.17A.255, RCW 42.17A.320 Resolved through Statement of Understanding

Three complaints were filed against Resident Samish/Robert Gray alleging the following violations: (1) RCW 42.17A.205, .235 and .240 by failing to timely registered and accurately file reports disclosing contribution and expenditure activities; and (2) RCW 42.17A.320 by failing to include the require sponsor identification or using a made up or fictitious name to sponsor an independent expenditure mailer opposed to City of Bellingham Proposition 2020-14, on the November 3, 2020 general election ballot.

An Initial Hearing (Case Review Status) was held on January 6, 2021, and PDC staff opened a formal investigation against Robert Gray/Resident Samish.  

On October 14, 2020, Robert Gray presented to the public an independent expenditure mailer that listed as part of the return address that the sponsor was “Resident Samish” with the address being 2350 Newmarket Street, Suite 101-264, Bellingham, WA. The independent expenditure mailer stated “VOTE “NO” on 2020-14” but did not provide any additional contributor name or address information as required for this type of mailer, or any of the required other information concerning the sponsor.   

On October 15, 2020, PDC staff contacted Lithtex, a printing business located in Bellingham, Washington, after reviewing the Resident Samish mailer the US Postal Service Bulk Mail Permit #114, and seeking the business name that was issued the bulk permit number in order to determine the name of the sponsor.  The email from PDC staff stated that Lithtex was a commercial advertiser and based on the bulk mail permit issued to Lithtex by the US Postal Service, the PDC was requesting Lithtex provide information about the sponsor of the Resident Samish independent expenditure advertisement in accordance with RCW 42.17A.345.

On October 19, 2020, Lithtex sent an email concerning the PDC inquiry and attached an invoice dated October 7, 2020, that indicated Robert Gray placed the order and paid for the Resident Samish independent expenditure mailer on that date.  The invoice indicated that Lithtex printed 32,000 postcards and mailed them out on behalf of Mr. Gray with a total cost of $8,104.25

On October 26, 2020, after contacting Mr. Gray by telephone at the number provided to PDC staff by Lithtex, staff sent Mr. Gray an email informing him about the complaints that were filed concerning the independent expenditure mailer, and making him aware of the C-6 reporting requirement. 

On November 1, 2020 Robert Gray filed a C-6 report and listing the sponsor’s name as “Resident Samish” and disclosing that a $7,887.35 expenditure was made to Lithtex on October 7, 2020.  The expenditure was for an independent expenditure mailer presented to the public on October 14, 2020 and made in opposition to City of Bellingham Proposition 2020-14, a local transportation ballot measure on the November 3, 2020 general election ballot.  The C-6 report was filed 17 days late, and two days before the November 3, 2020 general election

Mr. Gray stated he decided to use his own personal funds to make the independent expenditure mailer in opposition to the ballot proposition, since he felt it would cause existing traffic lanes in the area to be reduced and closed in what he referred to as “road diets” if the ballot measure was ultimately approved.  He stated he did not solicit or receive any contributions in order to make the independent expenditure, and that Resident Samish was not a political committee. He stated Resident Samish was a fictitious name that he made up and selected on his own, and he felt it was a catchy phrase.

On January 14, 2021, Mr. Gray completed a Statement of Understanding (SOU) acknowledging: (1) One violation of RCW 42.17A.255 for failing to timely file a C-6 report disclosing the independent expenditure mailing in opposition to 2020-14; and (2) One violation of RCW 42.17A.320 by sponsoring independent expenditure advertising using a made up or fictitious name during the 2020 election cycle.  He paid a $650 civil penalty in accordance with the Penalty Schedule adopted by the Commission for Brief Enforcement Hearings set forth in WAC 390-37-143, with $500 of the penalty being assessed for the violation of RCW 42.17A.320 and a $150 penalty assessed for the violation of RCW 42.17A.255. 

Based on the findings, and the fact Mr. Gray competed an SOU acknowledging two violations of RCW 42.17A and paid a $650 civil penalty, staff has determined that in this instance, no further investigation is warranted, or any additional enforcement action shall be taken.  The PDC has dismissed the three complaints filed against Mr. Gray/Resident Sammish in accordance with RCW 42.17A.755(1) and WAC 390-37-070.  

https://www.pdc.wa.gov/browse/cases/78954
78947 10/26/2020 Joe Hyer Committee to Elect Gary Edwards Committee to Elect Gary Edwards: Alleged violation of RCW 42.17A.320 for failure to disclose sponsor's address on political advertising mailer. (EY '20; Oct '20) RCW 42.17A.320 Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the two complaints filed on September 18, 2020 and October 8, 2020. The complaints alleged that Gary Edwards, an incumbent Thurston County Commissioner, District 2 and candidate in the 2020 election, may have violated: (1) RCW 42.17A.320 for failure to identify the sponsor on a political advertisement video; (2) RCW 42.17A.555 by using public facilities for an election campaign; and (3) RCW 42.17A.320 for failure to disclose the sponsor's address on a political advertisement mailer.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response(s) provided by Gary Edwards (the “Respondent”); PDC Interpretation 04-02; and the applicable PDC reports filed by the Respondent, to determine whether the record supports a finding of one or more violations.

Gary Edwards is a current elected official and was re-elected in the November 3, 2020 general election. It appears that his failure to disclose a complete sponsor identification for an online political advertisement video and a mailer sponsored by his campaign, was inadvertent and not meant to conceal the sponsor from the public. Although Commissioner Edwards responded promptly to the complaint and made the necessary corrections to the online video, staff found that the limited sponsor information originally included in the online video was vague and could have been misconstrued as an independent expenditure done by a third party rather than by the Edwards Campaign.  

Staff found that the lack of an address on the mailer, although required, did not generally create confusion as to the sponsor of the advertisement. However, staff noted that the sponsor name originally used on the mailer did not match the name identified on the C-1 report until the C-1 was amended.

Finally, staff found the prompt response and remedy to remove visual images of Commissioner Edwards’ official Thurston County name plate from the video was sufficient in this instance.

Based on our findings staff has determined that, in this instance, failure to include the full required sponsor identification in an online video advertisement and mailer, and the limited use of an official name plate in a video advertisement, does not amount to a finding of a violation that warrants further investigation.

Pursuant to WAC 390-37-060(1)(d), Gary Edwards will receive a formal written warning concerning failure to disclosure the required sponsor name and address in an online video advertisement produced and distributed by his campaign. The formal written warning will include staff’s expectation that Mr. Edwards will review all future political advertisements prior to their distribution to ensure they include the required sponsor information. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

PDC staff is also reminding Mr. Edwards about the importance of including a complete and accurate sponsor identification on written political advertisements and the prohibitions against the use of public facilities to support or oppose election campaigns, 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/78947
78878 10/23/2020 Glen Morgan Carrie Hesch Hesch, Carrie: Alleged Violation of RCW 42.17A.235, .240 for failure to timely and accurately disclose contributions and expenditures (EY20, Oct20) RCW 42.17A.235, RCW 42.17A.240 Case Closed with Written Warning
  • Allegation: Violation of RCW 42.17A.235, .240 for failure to timely and accurately disclose contributions, expenditures, in-kind and debts
https://www.pdc.wa.gov/browse/cases/78878
78860 10/23/2020 Bret Uhrich Washington State Republican Party Washington State Republican Party (4): Alleged Violation of RCW 42.17A.320 for failure to disclose sponsor identification on political advertising (EY20, Oct20) 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 October 15, 2020. The complaint alleged that Washington State Republican Party (WA GOP), a bona fide state party committee, may have violated RCW 42.17A.320 and WAC 390-18-030 for failure to disclose sponsor identification on political advertising distributed by WA GOP via text message.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Executive Director, Kaitlin Vintertun on behalf of WA GOP (the “Respondent”); and written PDC guidance regarding sponsor identification alternatives for advertisements delivered via text message, to determine whether the record supports a finding of one or more violations.

Based on the response submitted by Exec. Director Vintertun, it appears that the intent of the text message was to encourage voting, specifically voting for republican backed candidates and agenda items, as part of a “get out the vote” (GOTV) effort and that the sponsor of the message was likely easy to discern by the recipient with the name “WA GOP” included.

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/78860
78848 10/23/2020 Mary Loquvam Jim Nelson Nelson, James (Jim) W.: Alleged violations of RCW 42.17A.235 for failure to timely report contributions and expenditures (EY 20; Oct 20) RCW 42.17A.235 Resolved through Statement of Understanding

The complaint alleged James W. Nelson, a 2020 candidate for Whatcom Superior Court Judge Position 4, may have violated RCW 42.17A.235 for failure to timely report contributions and expenditures on a Summary Full Campaign Contribution and Expenditure (C-4) report.

On February 10, 2021, the PDC received a completed Statement of Understanding (SOU) from James W. Nelson, acknowledging a violation of RCW 42.17A.235 for failure to timely report contributions and expenditures on a Summary Full Campaign Contribution and Expenditure (C-4) report.

James W. Nelson paid a $150 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), which resolves the issue. PDC staff found no evidence of material violations requiring additional enforcement action in this matter. 

Based on this information, the PDC has dismissed the case against James W. Nelson, in accordance with RCW 42.17A.755(1) and WAC 390-37-070. 

https://www.pdc.wa.gov/browse/cases/78848
78841 10/23/2020 Janet Thiessen Pierce County Job Creators for Economic Recovery Pierce County Job Creators for Economic Recovery: Alleged violations of RCW 42.17A.260 and .305 for failure to timely and accurately report independent expenditures and electioneering communications (EY 20; Oct 20) RCW 42.17A.305, RCW 42.17A.260 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on October 15, 2020. The complaint alleged that Pierce County Job Creators for Economic Recovery, a single year political committee registered and reporting campaign activities, including independent expenditures supporting local 2020 candidates, may have violated RCW 42.17A.260 for failure to timely and accurately report independent expenditures or RCW 42.17A.305 for failure to timely and accurately report electioneering communications within twenty-four (24) hours of presentation to the public. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by committee Director and Treasurer, Brent Ludeman on behalf of Pierce County Job Creators for Economic Recovery (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 staff’s review of the documentation submitted with the complaint, the written response provided, and the reports submitted by the Pierce County Job Creators for Economic Recovery, no evidence was found to show that the Respondent sponsored written political advertisement to specifically oppose 2020 Pierce County Council candidate Jani Hitchen, or that the C-6 report disclosing the expenditure was inaccurate or filed late. 

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/78841
78831 10/23/2020 Roger Erich Lenk Sharon Raye Brown Brown, Sharon Raye: Alleged violation of RCW 42.17A.555 by using public office or agency facilities to assist an election campaign. (EY '20; Oct '20) 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 to assist an election campaign (Benton Co. Superior Court Judge, position 1)
https://www.pdc.wa.gov/browse/cases/78831
78804 10/22/2020 Bret Uhrich Justin Raffa Raffa, Justin: Alleged Violation of RCW 42.17A.320 for failure to disclose full sponsor identification on political advertisement (EY20, Oct20) RCW 42.17A.320 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on October 17, 2020. The complaint alleged that Justin Raffa, a candidate for County Commissioner, Position 1 in Benton County in the 2020 primary and general elections, may have violated RCW 42.17A.320 for failure to disclose sponsor identification and party preference on political advertisement.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; and written guidance provided on the PDC regarding providing sponsor identification in online transmissions, to determine whether the record supports a finding of one or more violations.

Justin Raffa is a first-time candidate and has not previously been found in violation of the PDC campaign finance laws or rules. It appears that Mr. Raffa’s failure to initially include the full name and address identifying the sponsor of the political advertisements sent via text message and failure to set the party preference apart from the remainder of the ad content, was due to a general lack of knowledge and not meant to conceal this information from the public.

Based on our findings staff has determined that, in this instance, failure to include the full sponsor and clearly identify party preference on written political advertisement does not amount to a finding of a violation that warrants further investigation.

PDC staff reminded Justin Raffa about the importance of the disclosure of political advertisement sponsors and the requirement to set sponsor id and party preference apart from the text of a written ad on all future 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/78804
78803 10/22/2020 Robert Parker Jani Hitchen Hitchen, Jani: Alleged violations of RCW 42.17A.555 for misuse of public facilities to support candidate's own election campaign (EY 20; Oct 20) RCW 42.17A.555 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on October 14, 2020. The complaint alleged that Jani Hitchen, a candidate for Pierce County Council, Position 6 in the 2020 election, may have violated RCW 42.17A.555 for misuse of public facilities to support her own election campaign.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Jani Hitchen (the “Respondent”); and PDC Interpretation 01-03, to determine whether the record supports a finding of one or more violations.

It appears that Ms. Hitchen taking campaign related photos of herself and her classroom and then posting them on her campaign Facebook page, were done intentionally but with a mind towards compliance with state laws, rules and PDC Interpretation 01-03. Ms. Hitchen responded timely to the complaint and removed the posts in the interest of full compliance. Staff found that any minor misuse of public facilities by Ms. Hitchen was done because of a general misunderstanding and not a disregard for the statutory restrictions. However, it is staff’s opinion that the public areas contemplated by PDC Interpretation 01-03 are those typically used or rented by community members or organizations within the school district boundaries, and that individual classrooms would not normally be available for non-school related activities.

Based on our findings staff has determined that, in this instance, the taking and posting of two campaign related photos does not amount to a finding of a violation that warrants further investigation.

PDC staff reminded Jani Hitchen about the importance of reviewing the applicability of RCW 42.17A.555 and PDC Interpretation 01-03Guidelines for School Districts in Election Campaigns, to ensure any future campaign related activities fully comply with PDC 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/78803
78781 10/22/2020 Evelyn Fielding Lopez Javier Figueroa Figueroa, Javier: Alleged violations of RCW 42.17A.320 for failure to disclose sponsor identification on political advertising, and RCW 42.17A.240 for failure to acurrately and completely disclose expenditure details (EY 20; Oct 20) wac 390-16-205, RCW 42.17A.240, RCW 42.17A.320 Resolved through Statement of Understanding

The complaint alleged Javier Figueroa, a 2020 candidate for Pierce County Council, may have violated RCW 42.17A.320 by failing to disclose sponsor identification on paid political advertising in the Tacoma Weekly and RCW 42.17A.240 and WAC 390-16-205 for failing to accurately and completely disclose expenditure details, including sub-vendors utilized by the campaign.

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

Based on these findings, and the fact Figueroa made a good faith effort to comply with the reporting requirements concerning expenditures, staff has determined, in this instance, the failure to timely and accurately report expenditure detail does not amount a violation warranting further investigation.

The PDC reminded Javier Figueroa about the importance of accurately and timely completing PDC reports, including listing expenditure details in the proper locations on PDC reports to allow public access to complete expenditure detail. 

On January 8, 2021, the PDC received a completed Statement of Understanding (SOU) from Javier Figueroa, acknowledging violations of RCW 42.17A.320 by failing to disclose sponsor identification on paid political advertising in the Tacoma Weekly. 

Javier Figueroa paid a $150 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), which resolves the issue. PDC staff found no evidence of material violations requiring additional enforcement action in this matter. 

Based on this information, the PDC has dismissed the case against, in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/78781
78780 10/22/2020 Evelyn Fielding Lopez Jason Whalen Whalen, Jason: Violations of RCW 42.17A.320 for failure to disclose sponsor identification on political advertising with Tacoma Weekly (EY 20; Oct 20) RCW 42.17A.320 Resolved through Statement of Understanding

The complaint alleged Jason Whalen, a 2020 candidate for Pierce County Council, may have violated RCW 42.17A.320 by failing to disclose sponsor identification on paid political advertising in the Tacoma Weekly.

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

On January 11, 2021, the PDC received a completed Statement of Understanding (SOU) from Jason Whalen, acknowledging violations of RCW 42.17A.320 by failing to disclose sponsor identification on paid political advertising in the Tacoma Weekly. 

Jason Whalen paid a $150 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), which resolves the issue. PDC staff found no evidence of material violations requiring additional enforcement action in this matter. 

Based on this information, the PDC has dismissed the case against, in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/78780
78774 10/22/2020 Glen Morgan Democratic Association of Secretaries of State Democratic Association of Secretaries of State (2): Alleged violations of Chapter 42.17A RCW for failure to timely and accurately report contribution and expenditures, and for accepting foreign contributions (EY 20; Oct 20) RCW 42.17A.320, RCW 42.17A.255, RCW 42.17A.260, RCW 42.17A.270, RCW 42.17A.305, RCW 42.17A.417, RCW 42.17A.235, RCW 42.17A.240 Resolved through Statement of Understanding

A complaint was filed alleging that the Democratic Association of Secretary of States (DASS), a political committee registered with the PDC, may have violated RCW 42.17A. by: (1) failing to timely register as a political committee; (2) failing to timely and accurately file reports disclosing contribution and expenditure activities; (3) failing to timely file Independent Expenditure/Electioneering Communications Reports (C-6 reports); and (4) accepting earmarked contributions and contributions from Foreign Nationals. 

DASS is a national 527 political organization registered with the Internal Revenue Service (IRS), “whose purpose is to support the election of Democratic secretaries of state across the country. The organization was formed in 2008 under IRS laws, and regularly files disclosure reports with the IRS and with state filing agencies -- as dictated by its activities.” 

Stephen J. Kaufman, with the Kaufman Legal Group, a California law firm and legal counsel for DASS, stated that when DASS initially filed its 21-Day Pre-General C-4 report, the report only disclosed DASS’s activities in support of Washington State candidates.  He stated that “in the good faith belief that this is what the law required. DASS’ total expenditures to support Secretary of State candidate Gael Tarleton in the amount of $204,150 represent only 16.1% of DASS’ over-all expenditures to date.”

Mr. Kaufman stated the majority of DASS’ funding is from individuals making small contributions, and that for January 1 through August 31, 2020 (September 1, 2020 is the date the Registration was filed) DASS “received 16,692 contributions totaling $629,161.79 (the average contribution being $38) from individuals across the country, representing 58% of the money raised by DASS this year. Of those, 1,321 contributions totaling $28,592.57 were from Washington residents.”

On October 27, 2020, DASS filed an amended 21-Day Pre-General Election C-4 report and the 7-Day Pre-General Election disclosing DASS contribution and expenditure activities undertaken from all over the United States, rather than just expenditures in support of Gael Tarleton that were disclosed on the earlier version of the report. 

As noted by Mr. Kaufman, the expenditures made in support of Gael Tarleton only represented 16.1 percent of all expenditures made during the 2020 election cycle, and the remaining DASS expenditures included: (1) $317,400 for radio ads in support of the Democratic candidate for Missouri Secretary of State; (2) $120,000 in monetary contributions were made to Shamia Fagan, a candidate for Oregon Secretary of State; (3) $93,750 were made for digital ads in support of the Democratic candidate for Montana Secretary of State; and (4) $80,750 were made for digital ads in support of the Democratic candidate for West Virginia Secretary of State.

On October 25, 2020, DASS filed a C-6 report disclosing an $83,650 expenditure made to SKDNICKERBOCKER on October 8, 2020 for digital ads presented to the public on October 14, 2020, in support of Gael Tarleton.  DASS was required to file the C-6 report within 24 hours of the advertisements being presented to the public or no later than October 15, 2020, and the C-6 report was filed 10 days late.

On October 26, 2020, DASS filed a C-6 disclosing a total of $118,500 for three expenditures in support of Gael Tarleton, that included: (1) a $74,000 expenditure made to SKDNICKERBOCKER on October 19, 2020 for digital ads presented to the public on October 20, 2020; and (2) two expenditures totaling $44,500 made to Sadler Strategic Media, Inc. for radio ads presented to the public on October 22, 2020. DASS was required to file the C-6 report within 24 hours of the advertisements being presented to the public or no later than October 21 and October 23, 2020 respectively, and the C-6 reports were filed between three to five days late.

Concerning the remaining allegations, Mr. Kaufman stated that once again as soon as PDC staff notified DASS about the complaint, they filed amended C-4 reports providing the required expenditure details for the independent expenditures made including payments to committee sub-vendors prior to the general election.  He stated DASS has internal controls and procedures in place “to ensure that no foreign money” is received and added that when DASS processes contributions it requires contributors “to certify that they are U.S. citizens.”

Mr. Kaufman stated DASS solicits and accepts contributions from all over the United States and supports candidates all around the country, but added that the contributions solicited and received by DASS “are not earmarked for particular uses, and the organization does not solicit funds to support particular candidates.”

An Initial Hearing (Case Review Status) was held on January 6, 2021, and PDC staff opened a formal investigation against DASS.   Staff's review and investigation found the following.

On January 11, 2021, PDC staff processed a Statement of Understanding (SOU) completed by DASS acknowledging two violations of RCW 42.17A.260 for failing to timely file C-6 reports during the 2020 election cycle, and paying a $300 civil penalty in accordance with the Penalty Schedule adopted by the Commission for Brief Enforcement Hearings set forth in WAC 390-37-143.

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/78774
78620 10/20/2020 Alex Bond Ron Muzzall Muzzall, Ron (2): Alleged violations of RCW 42.17A.405 for accepting over-limit contributions from Snohomish County Republican Central Committee (EY 20; Oct 20) RCW 42.17A.405 Case Closed with Written Warning

The complaint alleged Ron Muzzall violated RCW 42.17A.405 by accepting contributions from a county central committee that, when combined with another county central committee and legislative district committee, exceeded the contribution limits for a 2020 legislative candidate allowed in RCW 42.17A.405(4)(b).

PDC staff has determined that in this instance, the Campaign accepting contributions from a county central committee that, when combined with other county central committees and a legislative district committee, exceeded the contribution limits for a 2020 legislative candidate allowed in RCW 42.17A.405(4)(b), does not amount to a finding of a violation that warrants further investigation

However, pursuant to WAC 390-37-060(1)(d), Ron Muzzall will receive a formal written warning concerning the acceptance of an over-limit contribution as noted in this letter. The formal written warning includes staff’s expectation the Campaign will adhere to the contribution limits for the remainder of the 2020 election cycle and not accept any contributions exceeding the contribution limits in the future, as required by law. The Commission will consider the formal written warning in deciding on future 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/78620
78599 10/20/2020 Alex Bond Snohomish County Republican Central Committee Snohomish County Republican Central Committee (2): Alleged violation of RCW 42.17A.405 for making over-limit contributions to Ron Muzzall (EY 20; Oct 20) RCW 42.17A.405 Case Closed with Reminder

The complaint alleged the Snohomish County Republican Central Committee, a county central committee registered with the Public Disclosure Commission, violated RCW 42.17A.405 by contributing to Ron Muzzall, who was appointed to Washington State Senate from the 10th District in October 2019 and is a candidate for the same position in 2020. The complaint alleged the contribution, when combined with contributions from another county central committee and legislative district committee, exceeded the contribution limits for a 2020 legislative candidate allowed in RCW 42.17A.405(4)(b).

Staff has determined in this instance, exceeding the contribution limits for a 2020 legislative candidate allowed in RCW 42.17A.405(4)(b) does not amount a violation warranting further investigation.

PDC staff is reminding the Snohomish County Republican Central Committee about the importance of compliance with RCW 42.17A.405 and PDC staff expects the Snohomish County Republican Central Committee will adhere to the contribution limits for the remainder of the 2020 election cycle and not contribute in excess of contribution limits in the future, as required by law.

Based on 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/78599
78517 10/19/2020 Ruby Volker Jennifer Sefzik Sefzik, Jennifer: Alleged Violation of RCW 42.17A.235 for failure to timely file the 21-day pre-General report of contributions and expenditures (EY20. Oct20) RCW 42.17A.235 Case Closed with Reminder
  • Allegation: Violation of RCW 42.17A.235 for failure to timely file the 21-day pre-General report of contributions and expenditures (C-4 report).
https://www.pdc.wa.gov/browse/cases/78517
78386 10/16/2020 Allen Dauterman Robert Clark Clark, Robert: Alleged Violation of RCW 42.17A.205, .235 & .240 for failure to timely file registration (C-1), disclose contributions and expenditures (C-3, C-4); RCW 42.17A.320 for failure to disclose sponsor identification (EY20, Oct20) RCW 42.17A.240, RCW 42.17A.320, RCW 42.17A.235, RCW 42.17A.205 Case Closed with Reminder
  • Allegation One: Violation of RCW 42.17A.205, .235 & .240 for failure to timely file registration (C-1), disclose contributions and expenditures (C-3, C-4);
  • Allegation Two: Violation of RCW 42.17A.320 for failure to disclose sponsor identification on political advertisement
https://www.pdc.wa.gov/browse/cases/78386
78205 10/14/2020 Robert Clark City of Newcastle Officials City of Newcastle Officials: Alleged violations of RCW 42.17A.555 for misuse of public facilities to support a ballot proposition RCW 42.17A.555 Case Closed with No Evidence of Violations

Two complaints were filed against the City of Newcastle alleging violations of RCW 42.17A.555 by using city facilities to produce and distribute electronically and to post on the cities website two sets of Frequently Asked Questions (FAQ) in support of Referendum 2, a City of Newcastle ballot measure concerning utility taxes on the November 3, 2020 general election ballot.

Pursuant to RCW 42.17A.555 no public facilities can be used by or authorized to be used directly or indirectly by any local elected or appointed official or public employee, to support or oppose any candidate or ballot proposition.  In addition, WAC 390-05-271(2) states that “RCW 42.17A.555 does not prevent a public office or agency from… (b) making an objective and fair presentation of facts relevant to a ballot proposition, if such action is part of the normal and regular conduct of the office or agency."

Staff reviewed the September 18, and October 1, 2020, versions of the FAQ which provided information concerning: (1) why the Newcastle City Council felt a three percent utility tax was needed at this time; (2) the cities revenue forecast projected future budget shortfalls; (3) that the City of Newcastle was one of only three municipalities in King County without a utility tax; (4) which at utilities would be subject to the utility tax and how the utility tax would be applied; and (5) the impacts of approving and rejecting the utility tax. 

The FAQ information discussed the city currently has three primary sources of revenue, property and sales taxes, and development fees, that the costs of city services, are rising especially for public safety like police and fire departments, and the existing revenues are not adequate to keep pace. The FAQ stated: (1) the three percent tax would apply to electricity and natural gas, water, sewer, garbage, cable TV and phone voice fees; (2) the average household in the City of Newcastle would pay between $8 to $14 per month in utility fees; (3) cable internet, stormwater, mobile phone text, data and non-voice fees were not subject to the utility tax; and (4) that if Referendum 2 was approved, the utility tax was estimated to generate approximately $880,000 in revenue annually, to pay for fire and police services and the projected costs increases for those contracted services in the future. 

The FAQ stated if Referendum 2 was rejected, “it is projected that the City will have an approximately $1 million shortfall in the 2021 budget alone and will need to consider cutting public safety (police and fire) and other services."

Dawn Reitan, an attorney with Inslee Best submitted the response on behalf of the City of Newcastle stating that the complainants did not discuss the "normal and regular" exemption found in the statute RCW 42.17A.555, the PDC rules and interpretation which provides the City of Newcastle with the authority to post the FAQ information about Referendum 2.  She included Attachment 6 to the response letter which listed the city’s “News Items Dealing with Utility Tax, Budget or Fiscal Sustainability” that included information dating back to March 20, 2018 to present.  

Ms. Reitan stated that the City of Newcastle was not required to provide information in the FAQ about other financial alternatives to the utility tax, as noted by the complainants who were opposed to the utility taxes, and who “preferred alternatives to addressing fiscal sustainability.”  She stated that the FAQ provided fair and objective information to citizens about the City of Newcastle proposed utility taxes, that the information was consistent with the Ordinance findings the Fiscal Sustainability Plan, and the 2020 budget adopted by the City Council which forecasted deficit spending.  

Ms. Rietan stated that the FAQ provided information related to the potential impacts to the City of Newcastle operations if the Ordinance is approved or rejected under the Referendum, and added that the information included in the FAQ was consistent with PDC Guidelines found in PDC Interpretation #04-02, and the information distributed informed residents of the City of Newcastle public safety needs and costs.

Staff found that the content of the two versions of the Frequently Asked Questions (FAQ) concerning the City of Newcastle’s Referendum 2, to be a fair and objective presentation of the facts.  The FAQ was part of the cities normal and regular conduct for communicating information about the maintenance and operations of the city to its residents.  In addition, the two versions of the FAQ were produced and distributed in accordance with PDC Interpretation #04-02 Guidelines for Local Government Agencies in Election Campaigns.

Based on these findings, PDC staff found no evidence of a violation that would require conducting a more formal investigation into the complaint or pursuing enforcement action in this instance.  The PDC has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/78205
78020 10/12/2020 Lillian "Randy" Slovic Jerome Delvin Delvin, Jerome: Alleged Violation of RCW 42.17A.320 for failure to disclose party preference (EY20, Oct20) RCW 42.17A.320 Case Closed with Reminder
  • Allegation: Violation of RCW 42.17A.320 for failure to disclose party preference
https://www.pdc.wa.gov/browse/cases/78020
78009 10/12/2020 Sean Bates Dale Wagner Wagner, Dale: Alleged Violation of RCW 42.17A.555 for misuse of public facilities to support or oppose candidates or ballot propositions (EY20, Oct20) 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 11, 2020. The complaint alleged that Dale Wagner, Adams County Sheriff, may have violated RCW 42.17A.555 by posting personal political support and opposition on the Adams County Sheriff Department’s Facebook page. 

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, the misuse of public facilities does not amount to a violation that warrants further investigation.

Pursuant to WAC 390-37-060(1)(d), however, Dale Wagner will receive a formal written warning concerning the misuse of public facilities. The formal written warning will include staff’s expectation that Dale Wagner will not use public facilities to either support or oppose candidates or ballot propositions 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/78009
77806 10/09/2020 Michael E Sternberg Howard "Howie" Hambleton Hambleton, Howard: Alleged violation of WAC 390-18-040 by using the term "Re-elect" in political advertising. (EY '20; Sep '20) WAC 390-18-040 Case Closed with Reminder
  • Allegation: Alleged violation of WAC 390-18-040 by using the term "Re-elect" in political advertising (e.g. campaign flyer & Facebook)
https://www.pdc.wa.gov/browse/cases/77806
77700 10/07/2020 Adrianna Tiesinga Evergreen Progress Evergreen Progress (Washington State Republican Party) (also known as Evergreen Progress (MC2)): Alleged violation of RCW 42.17A.335 by sponsoring political advertising containing a false statement of material fact about a candidate. (EY '20; Sep '20) RCW 42.17A.335 Case Closed with No Evidence of Violations

A complaint was filed against Evergreen Progress (Washington State Republican Party) alleging a violation of RCW 42.17A.335(1)(a) by sponsoring political advertising, specifically an independent expenditure mailer that included a false statement of material fact about Sharon Shewmake, a candidate for State Representative in the 42nd Legislative District in 2020. 

The advertisement sponsored by Evergreen Progress included a copy of a Sharon Shewmake Facebook page post which had a picture of a masked Representative Shewmake, with a group of masked protestors, and the caption stating “Keep your eye out for Young Activists of Whatcom County!  They threw an excellent march yesterday.” To the right side of that post was the statement: “The group says our police work for a violent and unjust institution built on systemic racism.”

The advertisement included the question just under that at the bottom of the first page “Why is Sharon Shewmake marching to defund the police?” Finally, the top of the second page included a picture of a pair of hands holding up a sign in all yellow highlighted capital letters stating “DEFUND THE POLICE” and just below that the advertisement stated “Sharon Shewmake (D) failed to support our local police.”

In the response from Mark Lamb, legal counsel for Evergreen Progress he stated, “The mailer is neither defamatory nor libelous and thus the PDC has no jurisdiction over the political speech contained in it.”  He stated that Representative Shewmake “called the march by Young Activists of Whatcom County “excellent” on Twitter as accurately depicted in the mail piece.” 

Based on this information, PDC staff found no evidence that would constitute a material violation or require conducting a more formal investigation into the complaint or pursuing any enforcement action in this instance. 

In order to meet the statutory definition of libel or defamation found in RCW 42.17A.335, a false statement about a candidate must be proven by clear and convincing evidence.  The question “Why is Sharon Shewmake marching to defund the police?” did not constitute a false statement that she was in favor of defunding the police, and the phrase “Sharon Shewmake (D) failed to support our local police” was a matter of opinion.

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

https://www.pdc.wa.gov/browse/cases/77700
77665 10/06/2020 Joe Hyer American Wolf 689 American Wolf: Alleged Violation of RCW 42.17A.205 for failure to timely complete committee registration; RCW 42.17A.235, .240 for failure to timely & accurately report contributions and expenditures (EY20, Oct20) RCW 42.17A.205, RCW 42.17A.235, RCW 42.17A.240 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint Joe Hyer filed on October 5, 2020. The complaint alleged that American Wolf (Respondent) may have violated RCW 42.17A.205 for failure to timely register as a political committee; 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 Peter Diaz on behalf of the Respondent; 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 committee registration does not amount to a violation that warrants further investigation.

PDC staff is reminding American Wolf, APCP and Peter Diaz about the importance of the timely filing of registration, the 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/77665
77589 10/05/2020 Joe Hyer OUR REGION PAC Our Region PAC (3): Alleged violation of RCW 42.17A.235, .240 for failure to timely and accurately report expenditures, loans and contributions (EY20, Oct20) RCW 42.17A.240, RCW 42.17A.235 Case Closed with No Evidence of Violations

A complaint was filed against Our Region PAC, a new 2020 political committee registered with the PDC, alleging that Our Region PAC may have violated RCW 42.17A.240 by failing to properly disclose committee loans and loan repayments made during the 2020 election cycle.  

On July 13, 2020, Our Region PAC (ORP) filed two Monetary Contributions reports (C-3 reports) disclosing a $10,000 contribution had been received from Responsible Economic Growth in Our Neighborhood PAC - Region PAC on July 10, 2020, and a $100 monetary loan had been received from Jon Petit.   

On July 28, 2020, ORP timely filed the 7-Day Pre-Primary Election Summary Contribution and Expenditures report (C-4 report) covering the period July 14 through 27, 2020, and disclosing no contributions had been received, and that $6,071 in total expenditures had been made during the period.  The C-4 report disclosed ORP made two $100 expenditures on July 21, 2020, with the descriptions “LOAN REPAYMENT” and “Repay Loan” and the Loan document Schedule L, Part 2 listed one $100 loan repayment made to Mr. Petit with $0 still owed.  However, Schedule L, Part 4 listed a $100 loan as the loan amount still owed to Mr. Petit.

Mr. Petit stated he made only one $100 loan, and that he received only one $100 loan repayment from ORP (check #1003). stated that he inadvertently made a duplicate entry for the loan repayment into the Online Reporting of Campaign Activity (ORCA) program, and there was no second $100 loan or loan repayment. 

On December 3, 2020, Mr. Petit filed an amended 7-Day Pre-Primary Election C-4 report, deleting the second $100 loan repayment expenditure that he had inadvertently entered into the ORCA program for ORP.

For the 2020 election cycle, Our Region PAC disclosed receiving $10,100 in total monetary contributions, $9,633.90 in total expenditures made, with a cash on hand balance of $466.10.  The $100 loan repayment that was inadvertently duplicated by Mr. Petit was not a material amount compared to the overall total committee activity, and the public was not denied of any campaign finance information since the loan repayment was actually listed twice. 

Based on this information, PDC staff found no evidence that would constitute a material violation that would require conducting a more formal investigation into the complaint or pursuing any enforcement action in this instance.  The PDC has dismissed this complaint in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/77589
77585 10/05/2020 JOE HYER OUR REGION PAC Our Region PAC (2): Alleged Violation of RCW 42.17A.205 for failure to include committee sponsor in name on registration (EY20, Oct20) RCW 42.17A.205, wac 390-16-011a Case Closed with Reminder

Two complaints (PDC Cases 74713 and 77585) were filed against Our Region PAC, a political committee registered with the PDC, the first one on July 29, 2020, and a second complaint received on October 5, 2020. The two complaints alleged that Our Region PAC violated RCW 42.17A by failing to include the required sponsor identification information for independent expenditure advertisements such as the sponsor, and the Top 5 contributor and Top 3 contributor information, as part of the disclaimer in the advertisements.

On July 2, 2020, Our Region PAC filed a Registration with the PDC disclosing that it was a Continuing Political Committee selecting the Full Reporting Option and listing Jon Petit as President and as a Ministerial Treasurer.  On July 13, 2020, Our Region PAC (ORP) filed two C-3 reports disclosing a $10,000 contribution had been received from Responsible Economic Growth in Our Neighborhood PAC - Region PAC on July 10, 2020, and that a $100 monetary loan had been received from Jon Petit.

On July 15, 2020, ORP timely filed a C-6 report checking box #2 for an independent expenditure advertisement made within 21 days of an election, disclosing a $5,120.60 expenditure for a mailing presented to the public on July 15, 2020, in support of Bud Blake a candidate for Thurston County Commission.  On August 6, 2020, ORP filed a C-6 report checking box #2 for an independent expenditure advertisement made within 21 days of an election, disclosing a $3,762.56 expenditure for a mailing presented to the public on August 6, in support of Bud Blake a candidate for Thurston County Commission.

Responsible Economic Growth in Our Neighborhood PAC - Region PAC (REGION) is a Continuing Political Committee that was formed in February of 2019, selecting the Full Reporting Option, and listing David K. Toyer as Committee Manager and Treasurer. You alleged that ORP failed to include two 2019 REGION contributors, Northpoint Development and Art by Nature, Inc. in the sponsor identification for the 2020 independent expenditures.

The complete sponsor identification in the ORP independent expenditure advertisements stated: “No candidate authorized this ad, it is paid for by Our Region PAC….Sponsored by Responsible Economic Growth in Our Neighborhood (REGION PAC) top 5 donors are  Responsible Economic Growth in Our Neighborhood (REGION PAC), top 3 individuals donors to PAC contributors are Universal Land Construction co, Gibson Traffic Consultants, and The Gordon Company, Inc.”

On October 22, 2020, ORP amended its Committee Registration to state: “Our Region PAC, Sponsored by Responsible Economic Growth in Our Neighborhood (ORPAC).”

Staff’s review found that at the time of the 2020 independent expenditure advertisements were prepared by ORP, REGION’s top three contributors for calendar year 2020 included a $2,500 monetary contribution from Gibson Traffic Consultants (June 2, 2020); a $2,500 monetary contribution from Universal Land Construction Company, Inc (June 10, 2020); and a $2,000 monetary contribution from The Gordon Company, Inc. (June 24, 2020).   The review confirmed the allegation that ORP failed to include two 2019 REGION contributors, Northpoint Development, for a $7,500 monetary contribution received by REGION on October 15, 2019; and Art by Nature, Inc., for a $5,000 monetary contribution received by REGION on November 14, 2019, in the sponsor identification.

While the independent expenditure advertisements printed and distributed by ORP did include Top five and Top three contributor information, ORP’s review only included 2020 contributors and failed to include a look back into REGION’s 2019 contributors to cover the required 12-month period referenced in the statute and rule.  However, staff did find there were several mitigating factors concerning the allegations listed in the two complaints you filed that included ORP being a first-time political committee with an inexperienced Treasurer, and that  the ORP independent expenditure advertisements  correctly identified the sponsor in the advertisements by stating in part of the sponsor identification "Sponsored by Responsible Economic Growth in Our Neighborhood PAC (REGON).”  

Based on this information, PDC staff found no evidence that would constitute a material violation that would require conducting a more formal investigation into the complaint or pursuing any enforcement action in this instance. However, staff is reminding Our Region PAC and Mr. Pettit to be aware of the sponsorship requirements in the naming of a political committee, as well as the sponsor identification requirements for independent expenditure advertising to include the Top five and Top three contributors for the previous 12 months, for any political committees he is involved with in the future. 

The PDC has dismissed these two complaints, PDC Cases 74713 and 77585, in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/77585
77415 10/01/2020 Lucas Byram and Evelyn Fielding Lopez Tacoma Weekly Tacoma Weekly: Alleged Violations of RCW 42.17A.480 for soliciting money or other property for endorsement, articles, or other communication in news media (EY 20; Sep 20) RCW 42.17A.340, RCW 42.17A.320, RCW 42.17A.480 Investigation of Possible Violation

After conducting a preliminary review and assessment of complaints filed September 14 and October 19, 2020 against Tacoma Weekly, PDC staff opened a formal investigation and held an initial hearing (also referred to as a case status review), on November 23, 2020 pursuant to RCW 42.17A.755, and WACs 390-37-060 and 390-37-071

https://www.pdc.wa.gov/browse/cases/77415
77362 09/30/2020 Allen Dauterman Newcastle Watchdogs Newcastle Watchdogs: Alleged violations of RCW 42.17A.205 for failure to timely file Campaign Registrations; and .225, .235, and .240 for failure to timely and accurately report contributions and expenditures (EY 19/20; Sep 20) RCW 42.17A.240, RCW 42.17A.235, RCW 42.17A.205, RCW 42.17A.225 Case Closed with No Evidence of Violations

A complaint was filed alleging that Newcastle Watchdogs violated RCW 42.17A.205, .235, and .240 by failing to register and report as a political committee with the PDC as a political committee in support of Referendum 2, a local ballot measure on the November 3, 2020 general election ballot concerning a utility tax in the City of Newcastle. 

Newcastle Watchdogs (NW) was founded in 2016 by Nola Coston and Bill Erxleben as a “volunteer group of concerned citizens, who came together because of a deep concern about mismanagement of city funds, deficit budgets, and a vote on a proposed new 4% utility tax. We exchanged email addresses for communication purposes, and that was the beginning of the NW email list.”  NW is not a regularly scheduled publication, there are no subscribers or members, and  she and Mr. Erxleben randomly distribute information by email as issues and/or needs arise. 

Ms. Coston stated that since June 2, 2020, “our position papers have focused on the City's budget deficit, PDC RCW violations by the City Manager, and the money behind a well-funded Newcastle PAC supporting the utility tax.”  She stated that NW’s most recent position paper is entitled “FAQ’s Not Found on Newcastle City’s Website” which was distributed on October 23, 2020. 

Ms. Coston stated NW is a group of Newcastle residents who spend and use their own personal funds and resources to promote NW.Ms. Coston stated a local resident created a NW Facebook page where people can subscribe to our email list, and in 2020 a resident assisted her in setting up an email service with MailChimp for $55 a month, which expires at the end of each month. She stated other citizens have also assisted in helping pay for the monthly email service to continue and added that is the only ongoing NW expense. She stated after the City of Newcastle’s June 2, 2020 passage of the utility tax, citizens circulated petitions and collected 1,138 signatures to force a referendum, and that NW communicated with residents and provided links to residents concerning registering to vote, voting and how to track their ballot.

Ms. Coston stated that NW informed citizens how to obtain a copy of the referendum petition, the city ordinance, and “informed citizens how to gather signatures in compliance with city requirements. Then, we informed citizens that 1665 signatures were submitted to city hall and later, we informed citizens that King County Elections placed Referendum 2 on the ballot.” 

Ms. Coston stated that the complaint filed with the PDC included “copies of fliers printed by citizens, distributed by citizens, and email communications distributed free via Gmail and social media.” .”  She stated that the complaint filed with the PDC included “copies of fliers printed by citizens, distributed by citizens, and email communications distributed free via Gmail and social media.”  She stated those activities were not undertaken by NW, that NW did not make expenditures or pool any monies with any individuals to assist in any of those activities and added NW “did not print nor distribute any petitions concerning Referendum 2.” She stated NW did not incur any expenses for the petitions, and that “As a private citizen, expressing free speech rights, I collected a few signatures, but not many, for I was busy monitoring city council meetings and answering questions from citizens.”   

Ms. Coston stated concerning the Glen Morgan/We the Governed digital publication entitled “Is the City of Newcastle on an Unsustainable Financial Path” that it was an issues-oriented publication which did not mention any candidates or ballot propositions.  Staff reviewed the August 31, 2020, publication produced and narrated by Mr. Morgan which began by stating “Newcastle Citizens are concerned about the City of Newcastle’s tax increase proposals and unsustainable spending”, and discussed he had been born and raised in Newcastle on a 20-acre parcel/farm.

The publication went on to state the following: “In Newcastle today, the bloat of bureaucracy is ascendant, and (as always) they want to raise taxes to cover their unsustainable expansion. A city like Newcastle has only one viable sustainable option – keep taxes low by restraining the bloat of bureaucracy. Don’t hire more central planners, stop hiring consultants for every whim and fancy the City Manager cooks up, and reduce the paid staff to the bare minimum.” Mr. Morgan stated that the City of Newcastle contracts with the City of Bellevue for fire and police services, and the City of Mercer Island for district court services, and added that there was “no need for a large paid staff, yet the bureaucracy from the City Manager to the feeding frenzy of consultants are always pushing for more hires, more plans, and more escalating costs.”  While critical of the City of Newcastle and its elected officials, the information did not support or oppose any candidates.

Staff also reviewed a document entitled “FAQ’s Not Found on Newcastle City’s Website” which she indicated was NW most recent position paper, and staff’s review found the document did not state, reference or infer that recipients should either vote yes or no on Referendum 2.  The FAQ began with the question of “Are Newcastle property taxes high, and then compared the property taxes on a $700,000 home in Newcastle with that of Bellevue, Renton and Issaquah, which staff noted was not a fair or balanced comparison.  The FAQ went on to discuss the City Newcastle’s taxes, the utility tax, and that the Newcastle Golf Club is the city’s largest employer, and whether or not the Golf Club was paying “...its fair share of taxes.” 

The FAQ also discussed the salary of the Newcastle City Manager and compared his salary with that of the Renton City Administrator, the Bellevue City Manager, and Governor Inslee.  The FAQ did mention that the “Friends for Newcastle PAC” were supporting the utility tax and that the committee about 30 people, that included four of the councilmembers who voted for the utility tax.  The FAQ stated one of their political advertisements stated, “that the opposition to the utility tax was from a small group of anti-tax activists” and questioned whether or not that was true.  The FAQ discussed the city’s 2021 budget, and that if the utility tax is defeated “the preliminary plan is the deplete the general fund reserve to cover the deficit rather than make any cuts.”

No evidence was found that NW solicited or accepted contributions in order to make expenditures in support of any candidate or ballot proposition, including Referendum 2 and thus did not meet the definition of a political committee in accordance with RCW 42.17A or WAC 390.  Staff’s review of the 2020 FAQ sponsored by Newcastle Watchdog and the publication “Is the City of Newcastle on an Unsustainable Financial Path” by Mr. Morgan found that the content did not indicate opposition or a “No Vote” for Referendum 2.   The NW position papers previously posted or distributed by Newcastle Watchdog while critical of some of the City of Newcastle policies, elected officials, and budgetary decisions, those papers did not directly appear to support or oppose any candidate or ballot proposition. 

Based on this information, PDC staff found no evidence that would constitute a material violation that would require conducting a more formal investigation into the complaint or pursuing any enforcement action in this instance. The PDC dismissed the complaint in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/77362
77349 09/30/2020 Charles Torelli William D McKay Jr. McKay, William D Jr.: Alleged violations of RCW 42.17A.205 for failure to timely file Candidate Registration, and .700 for failure to file Personal Financial Affairs Statement (EY 20; Sep 20) RCW 42.17A.700 Case Closed with Reminder
  • Allegation One: Violation of RCW 42.17A.205 for failure to timely file Candidate Registration within two weeks of becoming a candidate.
  • Allegation Two: Violation of RCW 42.17A.700 for failure to file a Personal Financial Affairs Statement within two weeks of becoming a candidate.
https://www.pdc.wa.gov/browse/cases/77349
77320 09/30/2020 Lisa Hitt Port Angeles School District Officials Port Angeles School District Officials: Alleged violations of RCW 42.17A.555 for misuse of public facilities to support or oppose election campaigns, and .565 for adverse employment action related to contribution activity (EY 20; Sep 20) RCW 42.17A.565, 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 September 14, 2020. The complaint alleged that the Officials of the Port Angeles School District (PASD), a public school district located in the City of Port Angeles and servicing nine public schools, may have violated: (1) RCW 42.17A.555 for failure to provide opportunities for opposing viewpoints during discussion of a local ballot measure; and (2) RCW 42.17A.565 for adverse employment action related to a public employee's contribution activity.

PDC staff reviewed the allegations; the applicable statutes and rules; the response provided by Director of Human Resources, Scott Harker, on behalf of PASD (the “Respondent”); and PDC Interpretation 01-03, to determine whether the record supports a finding of one or more violations.

Regarding the first allegation, staff found no evidence that PASD’s school board curtailed the complainant’s December 12, 2019 public comments and found that the verbal interruptions appeared to be meant to remind the speaker of the board’s written policy regarding public comments on a specific subject rather than to allow a question and answer period.

Regarding the second allegation, staff did not find that the complainant’s video project was meant to be a political contribution to PASD’s levy committee and found no evidence that PASD’s staff acted in a discriminatory manner towards the complainant regarding the absence of the levy video(s) in violation of RCW 42.17A.565(2)(c).

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/77320
77318 09/30/2020 Norman Smith Paul Mahre Mahre, Paul (3): Alleged violations of RCW 42.17A.240 and WAC 390-16-037 for failure to accurately and completely report expenditure details (EY 20; Sep 20) RCW 42.17A.240, WAC 390-16-037 Case Closed with Reminder
  • Allegation: Violations of RCW 42.17A.240 and WAC 390-16-037 for failure to accurately and completely report expenditure details, including the number of items printed.
https://www.pdc.wa.gov/browse/cases/77318
77272 09/29/2020 Joe Hyer Gary Edwards Edwards, Gary: Alleged violation of RCW 42.17A.320 and .555 for failure to identify sponsor on political advertising, and by using public facilities for an election campaign. (EY '20; Sep '20) RCW 42.17A.320, RCW 42.17A.555 Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the two complaints filed on September 18, 2020 and October 8, 2020. The complaints alleged that Gary Edwards, an incumbent Thurston County Commissioner, District 2 and candidate in the 2020 election, may have violated: (1) RCW 42.17A.320 for failure to identify the sponsor on a political advertisement video; (2) RCW 42.17A.555 by using public facilities for an election campaign; and (3) RCW 42.17A.320 for failure to disclose the sponsor's address on a political advertisement mailer.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response(s) provided by Gary Edwards (the “Respondent”); PDC Interpretation 04-02; and the applicable PDC reports filed by the Respondent, to determine whether the record supports a finding of one or more violations.

Gary Edwards is a current elected official and was re-elected in the November 3, 2020 general election. It appears that his failure to disclose a complete sponsor identification for an online political advertisement video and a mailer sponsored by his campaign, was inadvertent and not meant to conceal the sponsor from the public. Although Commissioner Edwards responded promptly to the complaint and made the necessary corrections to the online video, staff found that the limited sponsor information originally included in the online video was vague and could have been misconstrued as an independent expenditure done by a third party rather than by the Edwards Campaign.  

Staff found that the lack of an address on the mailer, although required, did not generally create confusion as to the sponsor of the advertisement. However, staff noted that the sponsor name originally used on the mailer did not match the name identified on the C-1 report until the C-1 was amended.

Finally, staff found the prompt response and remedy to remove visual images of Commissioner Edwards’ official Thurston County name plate from the video was sufficient in this instance.

Based on our findings staff has determined that, in this instance, failure to include the full required sponsor identification in an online video advertisement and mailer, and the limited use of an official name plate in a video advertisement, does not amount to a finding of a violation that warrants further investigation.

Pursuant to WAC 390-37-060(1)(d), Gary Edwards will receive a formal written warning concerning failure to disclosure the required sponsor name and address in an online video advertisement produced and distributed by his campaign. The formal written warning will include staff’s expectation that Mr. Edwards will review all future political advertisements prior to their distribution to ensure they include the required sponsor information. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

PDC staff is also reminding Mr. Edwards about the importance of including a complete and accurate sponsor identification on written political advertisements and the prohibitions against the use of public facilities to support or oppose election campaigns, 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/77272
77237 09/28/2020 Kan Qiu Washington Against Discrimination Everywhere Washington Against Discrimination Everywhere: Alleged Violation of RCW 42.17A.235, .240 for failure to disclose timely and accurately contributions and expenditures (EY20, Sept20) RCW 42.17A.235, RCW 42.17A.240 Case Closed with Written Warning

The complaint alleged Washington Against Discrimination Everywhere violated RCW 42.17A.235 and .240 by failing to timely and accurately disclose contributions and expenditures.

PDC staff reviewed the allegations; the documents you provided; the applicable statutes, rules, and reporting requirements; the applicable PDC reports; and the response from Toussaint L. Myricks, counsel for Washington Against Discrimination Everywhere, to determine whether the record supports a finding of one or more violations. 

Staff has determined in this instance, the Committee’s failure to timely and accurately disclose contributions and expenditures does not amount to a finding of a violation that warrants further investigation. 

However, pursuant to WAC 390-37-060(1)(d), Washington Against Discrimination Everywhere will receive a formal written warning concerning the failure to timely report the debt to DocuSign. The formal written warning includes staff’s expectation the Committee will, in the future, timely and accurately disclose contributions and expenditures as required by RCW 42.17A.235 and .240. The Commission will consider the formal written warning in deciding on future 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/77237
77232 09/28/2020 James Lazar Thurston County Republican Central Committee Thurston County Republican Central Committee: Alleged violations of RCW 42.17A.225, .235 & .240 by failing to timely & accurately report contributions & expenditures. (EY '20; Sep '20) RCW 42.17A.240, RCW 42.17A.235, RCW 42.17A.225 Resolved through Statement of Understanding

The complaint alleged the Thurston County Republican Central Committee may have violated RCW 42.17A.225, .235 and .240 by failing 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 during the 2020 election year.

On March 11, 2021, the PDC received a completed Statement of Understanding (SOU) from the Committee acknowledging violations of RCW 42.17A.235 for failure to timely report contributions and expenditures on C-4 reports. The Committee paid a $500 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), which resolves the issue. 

Pursuant to WAC 390-37-060(1)(d), the Committee will receive a formal written warning concerning violations of RCW 42.17A.225 and .240 by failing to timely and accurately file C-3 reports. Staff expects, in the future, the Committee will timely and accurately disclose contributions and expenditures as required by law. The Commission will consider this formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

The PDC will not be conducting a more formal investigation into these allegations or take any further enforcement action in this matter. Based on this information, the PDC has dismissed the case against Thurston County Republican Central Committee, in accordance with RCW 42.17A.755(1) and WAC 390-37-070. 

https://www.pdc.wa.gov/browse/cases/77232
77044 09/24/2020 Marsha Maguire William Armacost Armacost, William: Alleged Violation of RCW 42.17A.555 for misuse of public facilities in support or opposition of a candidate or ballot proposition (EY20, Sept20) RCW 42.17A.555 Case Closed with No Evidence of Violations https://www.pdc.wa.gov/browse/cases/77044
76914 09/21/2020 Dennis Paul Matt Larkin Larkin, Matthew: Alleged Violation of RCW 42.17A.235, .240 for failure to disclose contributions and expenditures (EY20, Sept 20) 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 on September 11, 2020 and the additional information provided on September 14, 2020. The complaint alleged that Matthew Larkin, a candidate for Washington State Attorney General in the 2020 primary and general election, may have violated 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 contributions and expenditures undertaken by the Campaign.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Mr. Larkin (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.

Staff did not find evidence showing that the campaign received over limit contributions or purposely concealed the source of a donation. Staff found that the reduction of the fair market value of items specifically affected by the current COVID restrictions was appropriate in this instance.

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/76914
76891 09/21/2020 PDC Staff WRAY GARY R WRAY GARY R: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement within two weeks of becoming a candidate (Group Enforcement 20) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement within two weeks of becoming a candidate, or no later than June 1, 2020.
https://www.pdc.wa.gov/browse/cases/76891
76890 09/21/2020 PDC Staff Tylor Grow Tylor Grow: Alleged violation of RCW 42.17A.205 for failure to timely file the Candidate Registration within two weeks of becoming a candidate (Group Enforcement 20) RCW 42.17A.205 Resolved through Statement of Understanding
  • Allegation: Violation of RCW 42.17A.205 for failure to timely file the Candidate Registration within two weeks of becoming a candidate, or no later than June 1, 2020.
https://www.pdc.wa.gov/browse/cases/76890
76889 09/21/2020 PDC Staff Thor Amundson Thor Amundson: Alleged violation of RCW 42.17A.700, .205 for failure to timely file the Personal Financial Affairs Statement & Candidate Registration within two weeks of becoming a candidate (Group Enforcement 20) RCW 42.17A.205, RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700, .205 for failure to timely file the Personal Financial Affairs Statement & Candidate Registration within two weeks of becoming a candidate 
https://www.pdc.wa.gov/browse/cases/76889
76888 09/21/2020 PDC Staff SILLIMAN PETER SILLIMAN PETER: Alleged violation of RCW 42.17A.205 for failure to timely file the Candidate Registration within two weeks of becoming a candidate (Group Enforcement 20) RCW 42.17A.205 Resolved through Statement of Understanding
  • Allegation: Violation of RCW 42.17A.205 for failure to timely file the Candidate Registration within two weeks of becoming a candidate, or no later than June 1, 2020.
https://www.pdc.wa.gov/browse/cases/76888
76887 09/21/2020 PDC Staff SHARON STEPHEN A SHARON STEPHEN A: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement within two weeks of becoming a candidate (Group Enforcement 20) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement within two weeks of becoming a candidate, or no later than June 1, 2020.
https://www.pdc.wa.gov/browse/cases/76887
76886 09/21/2020 PDC Staff Sandy Mesenbrink Sandy Mesenbrink: Alleged violation of RCW 42.17A.700, .205 for failure to timely file the Personal Financial Affairs Statement & Candidate Registration within two weeks of becoming a candidate (Group Enforcement 20) RCW 42.17A.205, RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700, .205 for failure to timely file the Personal Financial Affairs Statement & Candidate Registration within two weeks of becoming a candidate 
https://www.pdc.wa.gov/browse/cases/76886
76885 09/21/2020 PDC Staff Robert Redwine Robert Redwine: Alleged violation of RCW 42.17A.700, .205 for failure to timely file the Personal Financial Affairs Statement & Candidate Registration within two weeks of becoming a candidate (Group Enforcement 20) RCW 42.17A.700, RCW 42.17A.205 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700, .205 for failure to timely file the Personal Financial Affairs Statement & Candidate Registration within two weeks of becoming a candidate 
https://www.pdc.wa.gov/browse/cases/76885
76884 09/21/2020 PDC Staff RAZEY WILLIAM F RAZEY WILLIAM: Alleged violation of RCW 42.17A.205 for failure to timely file the Candidate Registration within two weeks of becoming a candidate (Group Enforcement 20) RCW 42.17A.205 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.205 for failure to timely file the Candidate Registration within two weeks of becoming a candidate, or no later than June 1, 2020.
https://www.pdc.wa.gov/browse/cases/76884
76883 09/21/2020 PDC Staff PIKE LIZ PIKE LIZ: Alleged violation of RCW 42.17A.700, .205 for failure to timely file the Personal Financial Affairs Statement & Candidate Registration within two weeks of becoming a candidate (Group Enforcement 20) RCW 42.17A.700, RCW 42.17A.205 Resolved through Statement of Understanding
  • Allegation: Violation of RCW 42.17A.700, .205 for failure to timely file the Personal Financial Affairs Statement & Candidate Registration within two weeks of becoming a candidate
https://www.pdc.wa.gov/browse/cases/76883
76882 09/21/2020 PDC Staff NICHOLS JAMIE L NICHOLS JAMIE: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement within two weeks of becoming a candidate (Group Enforcement 20) RCW 42.17A.700 Resolved through Statement of Understanding
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement within two weeks of becoming a candidate, or no later than June 1, 2020.
https://www.pdc.wa.gov/browse/cases/76882
76881 09/21/2020 PDC Staff Michelle Jasmer Michelle Jasmer: Alleged violation of RCW 42.17A.700, .205 for failure to timely file the Personal Financial Affairs Statement & Candidate Registration within two weeks of becoming a candidate (Group Enforcement 20) RCW 42.17A.205, RCW 42.17A.700 Violation Found by Commission

At a brief enforcement hearing (brief adjudicative proceeding) held on October 21, 2020, the Presiding Officer found Michelle Jasmer (the "Respondent") to be in violation of RCW 42.17A.205 & .700 for failure to file a Candidate Registration (C-1 report) and Personal Financial Affairs Statement (F-1 report) within two weeks of declaring candidacy or by June 1, 2020. The Respondent was assessed a civil penalty of $500 and ordered to file the missing reports within 30 days of the date of the Order, which was entered on November 25, 2020. 

The PDC received the Respondent's C-1 report and F-1 report covering 2019 financial activity on December 7, 2020.

At an enforcement hearing held on January 28, 2021, the full Commission 1) granted the Respondent's request to reconsider the Order issued October 21, 2020; and 2) affirmed the Findings of Fact, Conclusions of Law and $500 civil penalty assessed at the October 21, 2020 hearing.

https://www.pdc.wa.gov/browse/cases/76881
76880 09/21/2020 PDC Staff Megan Constable Megan Constable: Alleged violation of RCW 42.17A.700, .205 for failure to timely file the Personal Financial Affairs Statement & Candidate Registration within two weeks of becoming a candidate (Group Enforcement 20) RCW 42.17A.700, RCW 42.17A.205 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700, .205 for failure to timely file the Personal Financial Affairs Statement & Candidate Registration within two weeks of becoming a candidate 
https://www.pdc.wa.gov/browse/cases/76880
76879 09/21/2020 PDC Staff Matthew Murray Matthew Murray: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement within two weeks of becoming a candidate (Group Enforcement 20) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement within two weeks of becoming a candidate, or no later than June 1, 2020.
https://www.pdc.wa.gov/browse/cases/76879
76878 09/21/2020 PDC Staff KINSEY DANA N KINSEY DANA: Alleged violation of RCW 42.17A.700, .205 for failure to timely file the Personal Financial Affairs Statement & Candidate Registration within two weeks of becoming a candidate (Group Enforcement 20) RCW 42.17A.205, RCW 42.17A.700 Violation Found by Commission

At a brief enforcement hearing (brief adjudicative proceeding) held on October 21, 2020, the Presiding Officer found Dana Kinsey (the "Respondent") to be in violation of RCW 42.17A.205 & .700 for failure to timely file a Candidate Registration (C-1 report) and Personal Financial Affairs Statement (F-1 report) within two weeks of declaring candidacy or by June 1, 2020. The Respondent was assessed a civil penalty of $500 to be paid within 30 days of the date of the Order, which was entered on November 25, 2020. 

The PDC received the Respondent's C-1 report and F-1 report covering 2019 financial activity on September 23, 2020.

At an enforcement hearing held on January 28, 2021, the full Commission 1) granted the Respondent's request to reconsider the Order issued October 21, 2020; and 2) affirmed the Findings of Fact, Conclusions of Law and $500 civil penalty assessed at the October 21, 2020 hearing.

https://www.pdc.wa.gov/browse/cases/76878
76877 09/21/2020 PDC Staff Kelsey Reyes Kelsey Reyes: Alleged violation of RCW 42.17A.700, .205 for failure to timely file the Personal Financial Affairs Statement & Candidate Registration within two weeks of becoming a candidate (Group Enforcement 20) RCW 42.17A.205, RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700, .205 for failure to timely file the Personal Financial Affairs Statement & Candidate Registration within two weeks of becoming a candidate
https://www.pdc.wa.gov/browse/cases/76877
76876 09/21/2020 PDC Staff John Dickinson John Dickinson: Alleged violation of RCW 42.17A.700, .205 for failure to timely file the Personal Financial Affairs Statement & Candidate Registration within two weeks of becoming a candidate (Group Enforcement 20) RCW 42.17A.700, RCW 42.17A.205 Closed Administratively
  • Allegation: Violation of RCW 42.17A.700, .205 for failure to timely file the Personal Financial Affairs Statement & Candidate Registration within two weeks of becoming a candidate 
https://www.pdc.wa.gov/browse/cases/76876
76875 09/21/2020 PDC Staff Jess Mahan Jess Mahan: Alleged violation of RCW 42.17A.205 for failure to timely file the Candidate Registration within two weeks of becoming a candidate (Group Enforcement 20) RCW 42.17A.205 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.205 for failure to timely file the Candidate Registration within two weeks of becoming a candidate, or no later than June 1, 2020.
https://www.pdc.wa.gov/browse/cases/76875
76874 09/21/2020 PDC Staff Daniel Miller Daniel Miller: Alleged violation of RCW 42.17A.700, .205 for failure to timely file the Personal Financial Affairs Statement & Candidate Registration within two weeks of becoming a candidate (Group Enforcement 20) RCW 42.17A.205, RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700, .205 for failure to timely file the Personal Financial Affairs Statement & Candidate Registration within two weeks of becoming a candidate
https://www.pdc.wa.gov/browse/cases/76874
76873 09/21/2020 PDC Staff Cameron Whitney Cameron Whitney: Alleged violation of RCW 42.17A.205 for failure to timely file the Candidate Registration within two weeks of becoming a candidate (Group Enforcement 20) RCW 42.17A.205 Resolved through Statement of Understanding
  • Allegation: Violation of RCW 42.17A.205 for failure to timely file the Candidate Registration within two weeks of becoming a candidate or no later than June 1, 2020.
https://www.pdc.wa.gov/browse/cases/76873
76872 09/21/2020 PDC Staff Bridgette Fahnbulleh Bridgette Fahnbulleh: Alleged violation of RCW 42.17A.700, .205 for failure to timely file the Personal Financial Affairs Statement & Candidate Registration within two weeks of becoming a candidate (Group Enforcement 20) RCW 42.17A.205, RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700, .205 for failure to timely file the Personal Financial Affairs Statement & Candidate Registration within two weeks of becoming a candidate
https://www.pdc.wa.gov/browse/cases/76872
76615 09/15/2020 Karen Hogan William Armacost Armacost, William: Alleged Violation of RCW 42.17A.555 for misuse of public facilities in support or opposition of a candidate or ballot proposition (EY20, Sept20) RCW 42.17A.555 Unfounded or Frivolous https://www.pdc.wa.gov/browse/cases/76615
76356 09/11/2020 Barb Howard Mike Conrad Conrad, Mike: Alleged violations of RCW 42.17A.235 and .240 for failure to timely and accurately report contributions and expenditures (EY 20; Sep 20) RCW 42.17A.235, RCW 42.17A.240 Case Closed with Reminder
  • Allegation: Violations of RCW 42.17A.235 for failure to timely and accurately report contributions and expenditures.
https://www.pdc.wa.gov/browse/cases/76356
76194 09/09/2020 Shawn Anderson Tax Amazon Tax Amazon (2): Alleged violations of RCW 42.17A.240 for failure to accurately and completely disclose expenditures (EY 20; Aug 20) wac 390-16-205, RCW 42.17A.240 Case Closed with Reminder

A complaint was filed alleging that the Tax Amazon PAC, a political committee registered with the PDC, may have violated RCW 42.17A.240 by failing to timely and accurately disclose committee expenditures for payments made to committee staff during 2020.

On July 15, 2020, the PAC filed the 21-Day Pre-Primary C-4 report disclosing $39, 119 in monetary contributions received and $26,880 in expenditures made during the period that included a $4,516.61 expenditure made to surepayroll on June 1, 2020 for Payroll Taxes. 

On August 28, 2020, the PAC filed the 7-Day Pre-Primary C-4 report disclosing $745 in monetary contributions received and $13,935 in expenditures made during the period that included two expenditures to surepayroll for Payroll Taxes ($7,472.09 made on July 14, 2020, and a $2,000.16 made on July 21, 2020).  The report also disclosed a $1,702 expenditure to Rosemary Daniels on July 15, 2020 for Campaign services.

Ms. Metz stated that the correct expenditure details for the PAC expenditures made and attributed to payroll were as follows: (1) June 2020: The $4,516 expenditure made by the PAC on June 1, 2020, should have been disclosed as: $1,862.54 paid to Alycia Lewis; $1,760.00 paid to Greyson Van Arsdale, with $896.07 in payroll taxes paid through Surepayroll; (2)  July 1-13, 2020: The $7,472.09 expenditure made by the PAC on July 14, 2020, should have been disclosed as: $1,760 paid to Greyson Van Arsdale; $1,858.54 paid to Alycia Lewis; $1,605 paid to Hannah Swoboda; and $2,248.55 in payroll taxes paid through Surepayroll; and (3) July 14-31, 2020: The $2,000.16 expenditure made by the PAC on July 21, 2020, should have been disclosed as $1,618.02 paid to Joe Sugrue and $382.14 for payroll taxes paid through Surepayroll. 

On November 18, 2020, Ms. Metz filed amended 21-Day and 7-Day Pre-Primary C-4 reports correcting the expenditures made by the PAC to accurately disclose the individuals listed above as having been paid by the PAC for “Campaign Services” for June and July of 2020.

Ms. Metz stated that she was a first-time Treasurer and had no prior experience filing Campaign finance reports with the PDC through the Online Reporting of Campaign Activity (ORCA) Software.  She stated that "This error occurred when we first switched over to a direct deposit payroll system with surepayroll in June, which also coincided with an expansion of our campaign team.”   

Ms. Metz stated that prior to making the change the PAC’s employees were all paid by check, but under the new payroll system with surepayroll, some of the employees were being paid by the PAC directly by check and some PAC employees were paid electronically through direct deposits. 

PDC staff found no evidence of a violation that would require conducting a more formal investigation into the complaint or pursuing enforcement action in this instance.  Staff has determined that Tax Amazon PAC inadvertently disclosed the payments made to committee staff for services as a lump sum expenditure made to surepayroll when the committee changed to an automated direct deposit payment system for payroll expenses, rather than identifying each individual committee staff member paid by the PAC. 

PDC staff has reminded Tax Amazon PAC about the importance of campaign finance reporting for political committees, including the timely and accurate disclosure of committee expenditures for payments made to committee staff, and all other reportable committee contribution and expenditure activities, and to comply with the continuing political committee and ballot measure committee reporting requirements in the future. 

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

https://www.pdc.wa.gov/browse/cases/76194
76193 09/09/2020 Arthur David Churchman Julie Door Door, Julie (3): Alleged violation of RCW 42.17A.555 for authorizing the misuse of City Council Meeting to support or oppose election campaigns (EY 20; Aug 20) RCW 42.17A.555 Case Closed with Reminder

A complaint was filed alleging that Julie Door, the incumbent Mayor of the City of Puyallup and a candidate for State Senator in the 25th Legislative District in 2020, may have violated RCW 42.17A.555 by allowing a City of Puyallup Council member to make statements during a City Council meeting about a political committee distributing political advertising in the City of Puyallup.

During the August 18, 2020 Puyallup City Council meeting Councilmember Robin Farris made comments that political advertisements had been distributed in Puyallup by a political committee concerning the 25th Legislative District Senate race stating “that property taxes increased by 20% and a number of other things. That is absolutely false....that was sent out by a PAC or a political action committee, actually two political action committees. And if those political action committees actually believed it then they wouldn't be sending out a flyer against one candidate who is running on council and also contribute to another council member for a different race.”

In Ms. Farris's response letter to the complaint filed against her she stated that during the August 18th meeting the City Attorney “did not interrupt me, nor did any of the fellow councilmembers call a point of order, which they would not hesitate to do.”  She stated that after finishing her statement, Mayor Door requested the City Attorney provide her and the rest of the council with information “regarding speaking out about political matters during council meetings.”  She stated that while she stood by her comments at the meeting about the political committee and the mailer, “the City Attorney provided guidance on more appropriate ways of correcting the record that do not have the appearance of political speak. I have taken this approach since that time and will continue that approach from now on.”

Mayor Door stated in her response letter “As you can see from the evidence Mr. Churchman provides, I did not mention my campaign or advocate for or against any campaign during city council meeting. It appears Mr. Churchman's issue is with comments made by Councilmember Farris.

Based on these findings, PDC staff found no evidence of a violation that would require conducting a more formal investigation into the complaint or pursuing enforcement action in this instance. However, as Mayor of the City of Puyallup and Chair of the City Council meetings, Mayor Door has the responsibility to ensure that the Puyallup City council members adhere to the statutes and rules concerning open public meetings.  That responsibility includes the PDC prohibitions found in RCW 42.17A.555 for allowing comments to be made by City Councilmembers and the general public during an official open public meeting.  The prohibition includes comments made during the meeting which support or oppose any candidate for public office, including indirect references or inferences about a candidate, or any political committee that supports or opposes a candidate.

The PDC is reminding Julie Door concerning the prohibitions of using City of Puyallup facilities and resources, including during Puyallup city council meeting, to support or oppose any candidate, or any political committee that supports or opposes candidates in accordance with RCW 42.17A.555.  The PDC has dismissed this matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/76193
76192 09/09/2020 Arthur David Churchman Robin Farris Farris, Robin: Alleged violation of RCW 42.17A.555 for misuse of City Council Meeting to support or oppose election campaigns (EY 20; Aug 20) RCW 42.17A.555 Case Closed with Written Warning

A complaint was filed alleging that Robin Farris, an incumbent City of Puyallup City Councilmember, may have violated RCW 42.17A.555 by using the facilities of the City of Puyallup to make statements during a City Council meeting about a political committee distributing political advertising during the 2020 election in support or opposition of a candidate.

During the August 18, 2020 Puyallup City Council meeting, Councilmember Robin Farris made comments concerning a political committee that sponsored and distributed political advertisements in the 25th Legislative District in which she stated "property taxes increased by 20% and a number of other things. That is absolutely false, and it's one of those things where you get why people don't trust politics....that was sent out by a PAC or a political action committee, actually two political action committees. And if those political action committees actually believed it then they wouldn't be sending out a flyer against one candidate who is running on council and also contribute to another council member for a different race.”

Ms. Farris went on to state: “I don't think it's fair, I'm not bringing anyone's name into it because it's not about the candidate, it's about these PACs. But I want citizens to know that this is absolutely false, I think it is absolutely unconscionable, to bring this type of rhetoric into an election during the pandemic. And I want to assure the citizens that I have made complaints to the Public Disclosure Commission, and they have opened an enforcement case on each of these PACs. I'm not running for office, so I'm in the clear when it comes to this, I'm just trying to make sure that the truth does matter."

The comments made by Ms. Farris at the August 18th Puyallup City Council meeting did not directly mention a specific candidate or political committee or encourage support or opposition to any candidate, but Ms. Farris did file two complaints against People for Jobs Enterprise Washington, and South Sound Future Enterprise Washington on August 11, 2020.  The complaints alleged the political committees made false statements in the independent expenditures or the electioneering communications undertaken in opposition to Julie Door, a candidate for State Senator in the 25th Legislative District.  It was apparent those were the political committees and advertisements Ms. Farris was referring when she made her comments during the council meeting, and she acknowledged that her comments were focused on the political committee that had sponsored the advertisements.

Ms. Farris stated that while she stood by the comments she made at the meeting about the political committee and the mailers, after the meeting “the City Attorney provided guidance on more appropriate ways of correcting the record that do not have the appearance of political speak. I have taken this approach since that time and will continue that approach from now on.”

Based on these findings, PDC staff found no evidence of a violation that would require conducting a more formal investigation into the complaint or pursuing enforcement action in this instance. However, pursuant to WAC 390-37-060(1)(d), the PDC is issuing a formal written warning to Robin Farris concerning the prohibitions of using City of Puyallup facilities and resources, including making comments during Puyallup city council meeting, to support or oppose any candidate, or any political committee that supports or opposes candidates, either directly or indirectly, in accordance with RCW 42.17A.555.  Robin Ferris will be advised that the Commission will consider this formal written warning in deciding on further Commission action, should there be future violations of PDC laws or rules.

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

https://www.pdc.wa.gov/browse/cases/76192
75907 09/02/2020 Deborah Lippincott John Kartak Kartak, John(2): Alleged Violation of RCW 42.17A.235, .240 for failure to timely and accurately disclose contributions and expenditures (EY20, Sept20) RCW 42.17A.240, RCW 42.17A.235 Case Closed with Reminder

A complaint was filed against John Kartak, incumbent Mayor of the City of Snohomish and a candidate seeking the office of State Representative in the 44th Legislative District in 2020, alleging a violation of RCW 42.17A.240 by failing to disclose the required expenditure details for political advertising purchased by the campaign for yard signage. 

On July 14, 2020, the Vote Kartak Campaign (Campiang) timely filed the 21-Day Pre-Primary C-4 report disclosing $5,522 in monetary contributions, and $100 for in-kind contributions received, and total expenditures were $6,838 during the period of June 1 through July 13, 2020.  The 21-Day Pre-Primary C-4 report disclosed two expenditures for signage that included: (1) a $3,221.40 expenditure made to Dave’s Campaign and Business on June 30, 2020 and listing the description as “655 Campaign Signs”; and (2) a $123.20 expenditure made to Countryman Signs on June 26, 2020 and listing the description as “66 Campaign Signs.”

The amended C-4 report filed by the Campaign disclosed the purchase of 655 campaign signs from Dave’s Campaign and Business on June 30, 2020, which consisted of two different yard sign sizes as noted in the response letter stating “To be more transparent, we separated the purchase into 2 categories, one for 18” x 24” signs and the other for 8’ x 4’ signs, on the amended report.” 

The response letter added that Mr. Kartak donated 200 wire stakes to the Campaign that were already in his possession prior to the 2020, to use for the yard signs, and the Campaign conducted some online searches to determine the fair market value for the wire stakes.  The Campaign disclosed on the amended 21-Day Pre-Primary C-4 report as an estimated in-kind contribution from Mr. Kartak valued at $237.76 and stated that the “wire stakes purchased and donated were cut in half, which doubled the number of signs they could be used on. There are still signs in the campaign’s possession that are not yet staked.”

Based on these facts, and the fact that Mr. Kartak is a candidate under the Full Reporting Option for the first time, staff found that the allegations identified in your complaint and the Campaign’s filing of the amended information would not constitute a material violation that would require conducting a more formal investigation into the complaint or pursuing any enforcement action in this instance. 

The PDC has reminded the Vote Kartak Campaign about the importance of timely and accurate disclosure of contribution and expenditures activities, including the required expenditure details for political advertisements undertaken by the Campaign and the reporting of in-kind contributions from the candidate and other sources for the remainder of the 2020 election cycle.  The PDC has dismissed the complaint in accordance with RCW 42.17A.755(1).  

 

 

https://www.pdc.wa.gov/browse/cases/75907
75003 08/13/2020 Glen Morgan Committee to Recall Snohomish County Sheriff Adam Fortney Committee to Recall Snohomish County Sheriff Adam Fortney: Alleged violations of RCW 42.17A.235, .240 and WAC 390-16-207 for failure to timely & accurately report contributions & in-kind contributions. (EY '20; Aug '20) RCW 42.17A.240, RCW 42.17A.235 Violation Found by Commission
  • Allegation One: Alleged violation of RCW 42.17A.235 and .240 for failure to timely and accurately report contributions on C-3 reports 
  • Allegation Two: Alleged violation of RCW 42.17A.235, .240 and WAC 390-16-207 for failure to timely and accurately report legal expenses as in-kind contributions on C-4 reports
https://www.pdc.wa.gov/browse/cases/75003
74924 08/12/2020 Glen Morgan 33rd LD Democrats 33rd LD Democrats: Alleged Violation of RCW 42.17A.235, .240 for failure to disclose contributions on reports (EY20, Aug20) RCW 42.17A.235, RCW 42.17A.240 Case Closed with Reminder

On August 6, 2020, the Public Disclosure Commission (PDC) received a complaint alleging that 33rd Legislative District Democrats may have violated RCW 42.17A.235 and .240 for failure to disclose contributions as required by law. 

PDC staff reviewed the allegation, the applicable law/rule, the C-3 and C-4 reports filed by the 33rd Legislative, and the August 17 and September 8, 2020, responses to the complaint provided by the Committee officials. 

Staff found that the Committee failed to report a contribution received in December 2019 and issued a reminder letter to the committee regarding its failure to file an accurate contribution report. 

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

https://www.pdc.wa.gov/browse/cases/74924
74923 08/12/2020 Elliott Harvey Timothy Eyman Eyman, Timothy: Alleged violations of RCW 42.17A.205, .235 & .240 by failing to register, and report contributions & expenditures for, a political committee to recall Jenny Durkan. (Ey '20; Aug '20) RCW 42.17A.235, RCW 24.17A.205, RCW 42.17A.240 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on August 4, 2020. The complaint alleged that Timothy Eyman, a gubernatorial candidate in the August 4, 2020 primary, may have violated: (1) RCW 42.17A.205 for failing to submit a Committee Registration (C-1pc report) registering, as a political committee, his effort to recall Seattle Mayor Jenny Durkan; and (2) RCW 42.17A.235 & .240 for failing to timely & 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 recall Campaign.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the response provided by Stephen Pidgeon on behalf of Mr. Eyman (the “Respondent”), to determine whether the record supports a finding of one or more violations.

It appears that during July and August 2020, the recall effort Mr. Eyman engaged in was conducted simultaneously with his 2020 campaign for governor, and consequently any associated (possibly de minimis) expenditures were likely part of the costs connected to advertisement expenses in general. (That campaign is not the subject of this matter but is under separate review by the PDC.)

Based on our findings staff has determined that, in this instance, failure to timely register and report the limited campaign activities undertaken by the Respondent’s efforts to recall Seattle Mayor Jenny Durkan does not amount to a finding of a violation that warrants further investigation.

PDC staff remindedMr. Eyman about the importance of the timely registration and disclosure of all contribution and expenditure activities, including those specifically related to a recall effort in 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/74923
74917 08/12/2020 LaWanda Hatch Lowell Peck Peck, Lowell (3): Alleged Violation of RCW 42.17A.235, .240 for failure to disclose expenditures; RCW 42.17A.430 for improper disposal of surplus funds (EY20, Aug20) RCW 42.17A.430, 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 6, 2020. The complaint alleged that that Lowell Peck, incumbent County Commissioner in Franklin County and candidate for re-election in the 2020 primary and general elections, 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; and (2) RCW 42.17A.430 for improper disposal of surplus funds.

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.

It appears that the discrepancy between the original ending balance of the 2016 Peck Campaign and the beginning balance used for the 2020 Peck Campaign, was due to a series of minor bookkeeping errors and the previous treasurer’s general lack of knowledge of PDC laws and rules. Staff found Mr. Peck and the campaign’s current treasurer to be cooperative in making the necessary corrections to the 2016 and 2020 C-4 reports. Mr. Peck has not been found in violation of PDC laws or rules during the last five years.

Based on our findings staff has determined that, in this instance, failure to timely disclose the accurate carry forward amount from a 2016 election campaign to a 2020 election campaign does not amount to a finding of a violation that warrants further investigation.

PDC staff reminded Mr. Peck about the importance of the timely disclosure of all campaign activities, including the ending and beginning balances for each election, 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/74917
74882 08/11/2020 Robin Farris People for Jobs Enterprise Washington People for Jobs Enterprise Washington: Alleged Violation of RCW 42.17A.320 for improper sponsor identification on political advertisement; RCW 42.17A.335 for false statements in political advertising (EY20, Aug20) RCW 42.17A.335, RCW 42.17A.320 Case Closed with No Evidence of Violations

The complaints alleged People for Jobs Enterprise Washington and South Sound Future Enterprise Washington (Committees) each violated RCW 42.17A.335(1)(a) by sponsoring political advertising, specifically mailers, that included a false statement of material fact about a candidate for public office, stating Julie Door, a 2020 candidate for State Senate from the 25th Legislative District (Candidate), voted to increase sales taxes.

PDC staff reviewed the allegations, evidence provided, applicable statutes and rules and the response provided by Dan Brady, Attorney for Enterprise Washington, to determine whether the record supports a finding of one or more violations.

While it appears Resolution No. 2395 did not increase sales taxes or authorize the collection of additional sales taxes, in light of Door’s support for Resolution No. 2395, and support for an ordinance laying the foundation for the collection of tax monies, there is not clear and convincing evidence that the statement made by People for Jobs Enterprise Washington and South Sound Future Enterprise Washington was made with actual malice.

Based on these findings staff has determined, in this instance, the alleged violation of RCW 42.17A.335(1)(a) 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/74882
74881 08/11/2020 Robin Farris South Sound Future Enterprise Washington South Sound Future Enterprise Washington: Alleged Violation of RCW 42.17A.320 for improper sponsor identification on political advertisement; RCW 42.17A.335 for false statements in political advertising (EY20, Aug20) RCW 42.17A.335, RCW 42.17A.320 Case Closed with No Evidence of Violations

The complaints alleged People for Jobs Enterprise Washington and South Sound Future Enterprise Washington (Committees) each violated RCW 42.17A.335(1)(a) by sponsoring political advertising, specifically mailers, that included a false statement of material fact about a candidate for public office, stating Julie Door, a 2020 candidate for State Senate from the 25th Legislative District (Candidate), voted to increase sales taxes.

PDC staff reviewed the allegations, evidence provided, applicable statutes and rules and the response provided by Dan Brady, Attorney for Enterprise Washington, to determine whether the record supports a finding of one or more violations.

While it appears Resolution No. 2395 did not increase sales taxes or authorize the collection of additional sales taxes, in light of Door’s support for Resolution No. 2395, and support for an ordinance laying the foundation for the collection of tax monies, there is not clear and convincing evidence that the statement made by People for Jobs Enterprise Washington and South Sound Future Enterprise Washington was made with actual malice.

Based on these findings staff has determined, in this instance, the alleged violation of RCW 42.17A.335(1)(a) 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/74881
74718 08/07/2020 LaWanda J Hatch Lowell (Brad) Peck Peck, Lowell (Brad)(2): Alleged violation of RCW 42.17A.335 for sponsoring false statements of endorsement in political advertising (EY 20; July 20) RCW 42.17A.335 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on July 29, 2020. The complaint alleged that Lowell Peck, incumbent County Commissioner in Franklin County and candidate for re-election in the 2020 primary and general elections, may have violated RCW 42.17A.335 for sponsoring false statements of endorsement in 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.

It appears that Mr. Peck believed the endorsement was made by the Tri-Cities Tea Party and that the manner of communication and documentation he received did not lead him to believe the endorsement was false or being sent by unauthorized individuals.

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/74718
74713 08/07/2020 Joe Hyer Our Region PAC Our Region PAC: Alleged violations of RCW 42.17A.320 for failure to accurately and completely disclose Top 3 Donors to PAC Contributors (EY 20; Aug 20) RCW 42.17A.320 Case Closed with Reminder

Two complaints (PDC Cases 74713 and 77585) were filed against Our Region PAC, a political committee registered with the PDC, the first one on July 29, 2020, and a second complaint received on October 5, 2020. The two complaints alleged that Our Region PAC violated RCW 42.17A by failing to include the required sponsor identification information for independent expenditure advertisements such as the sponsor, and the Top 5 contributor and Top 3 contributor information, as part of the disclaimer in the advertisements.

On July 2, 2020, Our Region PAC filed a Registration with the PDC disclosing that it was a Continuing Political Committee selecting the Full Reporting Option and listing Jon Petit as President and as a Ministerial Treasurer.  On July 13, 2020, Our Region PAC (ORP) filed two C-3 reports disclosing a $10,000 contribution had been received from Responsible Economic Growth in Our Neighborhood PAC - Region PAC on July 10, 2020, and that a $100 monetary loan had been received from Jon Petit.

On July 15, 2020, ORP timely filed a C-6 report checking box #2 for an independent expenditure advertisement made within 21 days of an election, disclosing a $5,120.60 expenditure for a mailing presented to the public on July 15, 2020, in support of Bud Blake a candidate for Thurston County Commission.  On August 6, 2020, ORP filed a C-6 report checking box #2 for an independent expenditure advertisement made within 21 days of an election, disclosing a $3,762.56 expenditure for a mailing presented to the public on August 6, in support of Bud Blake a candidate for Thurston County Commission.

Responsible Economic Growth in Our Neighborhood PAC - Region PAC (REGION) is a Continuing Political Committee that was formed in February of 2019, selecting the Full Reporting Option, and listing David K. Toyer as Committee Manager and Treasurer. You alleged that ORP failed to include two 2019 REGION contributors, Northpoint Development and Art by Nature, Inc. in the sponsor identification for the 2020 independent expenditures.

The complete sponsor identification in the ORP independent expenditure advertisements stated: “No candidate authorized this ad, it is paid for by Our Region PAC….Sponsored by Responsible Economic Growth in Our Neighborhood (REGION PAC) top 5 donors are  Responsible Economic Growth in Our Neighborhood (REGION PAC), top 3 individuals donors to PAC contributors are Universal Land Construction co, Gibson Traffic Consultants, and The Gordon Company, Inc.”

On October 22, 2020, ORP amended its Committee Registration to state: “Our Region PAC, Sponsored by Responsible Economic Growth in Our Neighborhood (ORPAC).” 

Staff’s review found that at the time of the 2020 independent expenditure advertisements were prepared by ORP, REGION’s top three contributors for calendar year 2020 included a $2,500 monetary contribution from Gibson Traffic Consultants (June 2, 2020); a $2,500 monetary contribution from Universal Land Construction Company, Inc (June 10, 2020); and a $2,000 monetary contribution from The Gordon Company, Inc. (June 24, 2020).   The review confirmed the allegation that ORP failed to include two 2019 REGION contributors, Northpoint Development, for a $7,500 monetary contribution received by REGION on October 15, 2019; and Art by Nature, Inc., for a $5,000 monetary contribution received by REGION on November 14, 2019, in the sponsor identification.

While the independent expenditure advertisements printed and distributed by ORP did include Top five and Top three contributor information, ORP’s review only included 2020 contributors and failed to include a look back into REGION’s 2019 contributors to cover the required 12-month period referenced in the statute and rule.  However, staff did find there were several mitigating factors concerning the allegations listed in the two complaints you filed that included ORP being a first-time political committee with an inexperienced Treasurer, and that  the ORP independent expenditure advertisements  correctly identified the sponsor in the advertisements by stating in part of the sponsor identification "Sponsored by Responsible Economic Growth in Our Neighborhood PAC (REGON).”  

Based on this information, PDC staff found no evidence that would constitute a material violation that would require conducting a more formal investigation into the complaint or pursuing any enforcement action in this instance. However, staff is reminding Our Region PAC and Mr. Pettit to be aware of the sponsorship requirements in the naming of a political committee, as well as the sponsor identification requirements for independent expenditure advertising to include the Top five and Top three contributors for the previous 12 months, for any political committees he is involved with in the future. 

The PDC has dismissed these two complaints, PDC Cases 74713 and 77585, in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/74713
74700 08/07/2020 Steven Lydolph COMMUNITY PROGRESS (MC2) Community Progress MC2: Alleged Violation of RCW 42.17A.235, .240, .255, .260 & .305 for failure to report expenditures (EY20, Aug20) RCW 42.17A.235, RCW 42.17A.240, RCW 42.17A.255, RCW 42.17A.260, RCW 42.17A.305 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint Steven Lydolph filed on August 5, 2020. The complaint alleged that Community Progress (MC2) (Respondent), a political committee, may have violated RCW 42.17A.235, .240, .255, .260 & .305 for failure to timely and accurately file Monetary Contribution reports (C-3 reports), Summary Full Campaign Contribution and Expenditure reports (C-4 reports), and Independent Expenditure or Electioneering Communication reports (C-6 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, 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/74700
74699 08/07/2020 Steven Lydolph Evergreen Progress 2020 Evergreen Progress 2020: Alleged Violation of RCW 42.17A.235, .240, .255, .260 & .305 for failure to report expenditures (EY20, Aug20) RCW 42.17A.305, RCW 42.17A.235, RCW 42.17A.240, RCW 42.17A.255, RCW 42.17A.260 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint Steven Lydolph filed on August 5, 2020. The complaint alleged that “Evergreen Progress 2020” (Respondent), a political committee, may have violated RCW 42.17A.235, .240, .255, .260, and .305 for failure to timely and accurately file Monetary Contribution reports (C-3 reports), Summary Full Campaign Contribution and Expenditure reports (C-4 reports), and Independent Expenditure or Electioneering Communication reports (C-6 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, 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/74699
74691 08/07/2020 Michael Bell Steven Parker Parker, Steven: Alleged Violation of RCW 42.17A.235, .240 for failure to timely and accurately disclose contributions and expenditures on reports (C-3 & C-4) (EY20, Aug20) RCW 42.17A.235, RCW 42.17A.240 Case Closed with Written Warning

On August 2, 2020, the Public Disclosure Commission (PDC) received a complaint alleging that Steven Parker, a 2020 candidate for County Commissioner in Stevens County, may have violated RCW 42.17A.235 and .240 for failure to timely and accurately report Monetary Contributions (C-3) and Summary Campaign Contribution and Expenditure (C-4) reports. 

Staff reviewed the applicable statute, rules, and the reporting requirements, including the 2020 C-4 reports filed by the Steven L. Parker Campaign and the September 10, 2020 response to the complaint provided by Steven Parker. 

Staff found the Campaign's reporting deficient, however, Mr. Parker qualified for Mini Reporting although he did not request to switch from Full to Mini reporting. Staff also found that Mr. Parker did not receive any monetary contributions from the public and placed third in the primary election and therefore did not qualify for the general election.

Based on these findings, the staff issued a formal written warning to Mr. Parker's campaign for failure to timely report C-4 reports and dismissed the matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/74691
74623 08/06/2020 James Russell Douglass Jeannine Tater Tater, Jeannine: Alleged violation of RCW 42.17A.335 for sponsoring political advertising that falsely claims the 42nd Leg. Dist. Democrats endorses six candidates. (EY '20; Aug '20) RCW 42.17A.335 Case Closed with No Evidence of Violations

A complaint was filed against Jeannine Tater, a Precinct Committee Officer (PCO) for the 42nd Legislative District Democrats (Committee), alleging violations of RCW 42.17A when Ms. Tater reproduced a slate card political advertisement originally produced by the Committee endorsing candidates for the 2020 primary election, that included additional candidate endorsements that had not been approved by the Committee.

Staff's review found that Ms. Tater reproduced the Committees original slate card adding candidate endorsements that were not included in the original flyer, and she included her name as an endorser of the candidates listed as well as the sponsor of the advertisement at the bottom of the flyer.  The added information stated: “Endorsement by 42nd LD Democrats &/or Your PCO Jeannine Tater”  and “Printing and Distribution Paid By Jeannine Tater, Precinct Committee Officer #210.”

Ms. Tater stated “There was never any malice on my part. I only wanted to provide my constituents in the 42nd LD Precinct 201 a complete slate of Democratic candidates.  She stated that she spent several hours revising her flyer which needed to be re-designed after conversations she had with other party members. The revised flyer included the Committee’s logo, and two columns that stated “Official 42nd LD Endorsements” and “PCO Tater Recommends” followed by the lists of candidates endorsed by the Committee and Ms. Tater.  The flyer included the sponsor identification listed above and added the following clarifying statement “Endorsements and Recommendations Included in Precinct 201 ballot order. When candidates are dual endorsed, or no endorsement on race, PCO #201 Jeannine Tater from LD#42 PCO Tater selected the best electable Democratic Party candidate without 42nd LD Endorsement. The 42nd LD Never Endorses PCO Candidates. Voters make that determination!”

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

https://www.pdc.wa.gov/browse/cases/74623
74589 08/05/2020 Jonathan Alvarado John Ley Ley, John (2): Alleged violations of RCW 42.17A.235 & .240 for failure to timely and accurately report contributions & expenditures, and sufficiently describe expenditures. (EY '20; Jul '20) RCW 42.17A.235, RCW 42.17A.240 Case Closed with Written Warning

On July 30, 2020, the Public Disclosure Commission (PDC) received a complaint alleging that John Ley may have violated RCW 42.17A.235 for failure to timely and accurately report contribution and expenditure reports and RCW 42.17A.240 for failure to properly break down and describe expenditure details, as required in WAC 390-16-047 and WAC 390-16-205. 

Staff reviewed the allegation; the applicable statutes, rules, and the reporting requirements, including the Contribution (C-3) and Summary Campaign Contribution and Expenditure report (C-4 report) filed by the Friends to Elect John Ley, and the June 28, 2020, and August 6, 2020, responses to the complaints provided by John Ley on behalf of his Campaign.   

Staff found that Mr. Ley did not timely and accurately report contributions and expenditures made by his campaign. His expenditures also lacked the proper description(s) and break down required by law/rule. 

Based on these findings, the staff issue a formal written warning to Mr. Ley regarding the failure to timely and accurately reports C-3 and C-4 reports and failure to properly break down and describe expenditure details, as required in WAC 390-16-047 and WAC 390-16-205. 

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

https://www.pdc.wa.gov/browse/cases/74589
74588 08/05/2020 Terry Peterson Mason County Auditor's Office Officials Mason County Auditor's Office Officials (2): Alleged Violation of RCW 42.17A.555 for misuse of public facilities (EY20, Aug20) RCW 42.17A.555 Case Closed with No Evidence of Violations

A complaint was filed alleging that the Mason County Auditor’s Office may have violated RCW 42.17A.555 by sharing a League of Women Voter's of Washington Facebook post on the Mason County Auditor’s Office Facebook page concerning voter registration efforts.

On July 11, 2020, the Mason County Auditor’s Office Facebook post stated: “You can update your voter registration online at VoteWA.gov if you have a valid Washington Driver’s License or WAID card.  If not, go to out website masoncountyelections.us to download a registration form or contact us.  #BeVoteReady.” 

Below the post from the Mason County Auditor was a July 3, 2020 repost from the League of Women Voter's (LWV) of Washington Facebook page, featuring a picture of a woman in an orange Hazmat suit holding a clipboard stating “Are you registered to vote at your current address?”  followed by the statement “Nothing stops the LWV from registering citizens to vote.” The repost included a hyperlink to the LWV Facebook homepage. 

Paddy McGuire, Mason County Auditor stated in his response to the complaint: “The League of Women Voters is a non-partisan organization dedicated to expanding participation in the electoral process. What was linked to from our official Facebook page was not election advocacy. None of the issues that the complainant was able to find by searching the website of the League of Women Voters is a matter of a Washington State ballot measure.”

The Facebook information posted on the LWV site and reviewed by PDC staff provided information about registering to vote, the importance of registering and voting, the suffrage movement that provided women the opportunity to vote, and recognizing individuals that have worked on behalf of voting rights and included Congressman John Lewis, Fannie Lou Hammer, and Alice Dunbar Nelson.  Staff’s review, found no information was posted on the LWV Facebook site that supported or opposed any 2020 candidates dating back to July 11, 2020. 

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

https://www.pdc.wa.gov/browse/cases/74588
74524 08/04/2020 PDC Staff Jodi Wilke Jodi Wilke: Alleged violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement within two weeks of becoming a candidate (Group Enforcement 20) RCW 42.17A.700 Violation Found by Commission
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement within two weeks of becoming a candidate, or no later than June 1, 2020.
https://www.pdc.wa.gov/browse/cases/74524
74490 08/03/2020 Johnny Alvarado Portland Vancouver Junction Railroad Portland Vancouver Junction Railroad: Alleged violations of RCW 42.17A.255 for failure to report independent expenditures, and RCW 42.17A.320 for failure to disclose sponsor identificaiton (EY 20; August 20) RCW 42.17A.320, RCW 42.17A.255 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on August 2, 2020. The complaint alleged that Portland Vancouver Junction Railroad (PVJR), a lobbyist employer during calendar year 2020, may have violated: (1) RCW 42.17A.255 for failure to report the value of independent expenditures for political advertising; and (2) 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 President Eric Temple, on behalf of PVJR (the “Respondent); and the applicable PDC reports filed by the Respondent, to determine whether the record supports a finding of one or more violations.

It appears that the posts referenced in the complaint did not meet the statutory definition of political advertisement and therefore did not require PVJR to include sponsor identification. In addition, staff did not find evidence that the posts were independent expenditures reportable under RCW 42.17A.255.

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/74490
74473 08/03/2020 Rachael Berg Mike Vaska Vaska, Mike: Alleged violation of RCW 42.17A.235 & .240 for failure to timely & accurately report TV ads & sufficiently describe expenditures on C-4 reports. (EY '20; Jul '20) RCW 42.17A.240, RCW 42.17A.235 Case Closed with Written Warning

A complaint was filed against Mike Vaska, a candidate for Washington State Attorney General in 2020.  The complaint alleged that the Mike Vaska for AG Campaign (Campaign) violated RCW 42.17A.240 by failing to timely and accurately disclose expenditures or orders placed for political advertisements undertaken by the Campaign for the August 4, 2020 primary election on the 21-Day and 7-Day Pre-Primary Summary Full Campaign Contributions and Expenditures reports (C-4 reports).  The expenditures or orders placed included more than $40,000 in expenditures for a television political advertising media buy for “advertisements that started running on July 13 on cable across multiple media market in Washington” and a mailed political advertisement paid for by the Campaign that was received on July 16, 2020. 

Supplemental complaint information alleged the Campaign also violated RCW 42.17A.405 for spending contributions solicited and/or received for the 2020 general election on 2020 primary election activites. 

Dan Brady, legal counsel for the Campaign stated that TV “order contracts with Comcast are booked with a Sunday to Monday run date regardless of the date the advertising is actually ordered, paid, and/or begins.” He stated that while the “Run date” stated July 13, 2020 on the “Order Contract” line of the invoice, the detailed summary of the media buy made “it clear that no advertising ran before July 15, 2020.”   

Mr. Brady stated the Campaign did not place a final order with Comcast until July 14, 2020, reiterated the Campaign’s TV political advertisements did not begin running on Comcast until July 15, 2020, and added the Campaign timely disclosed the expenditure to Comcast for advertising on the 7-day Pre-Primary C-4 report filed on July 28, 2020 as having been made on July 14, 2020.

Mr. Brady stated that the Campaign expenditure for the mailer was initially disclosed on the 7-day Pre-Primary C-4 report as an expenditure made on July 14, 2020 to Sermo Digital, but noted that after reviewing the allegation the Campaign received updated billing information regarding the mailing indicating an order placed should have been disclosed on a prior C-4 report.   He added the postage expense had been timely disclosed.

The Campaign filed an amended 21-day Pre-Primary C-4 report disclosing a total of $38,130 in outstanding debts and liabilities owed to Sermo Digital that included a $27,000 order placed on July 10, 2020, through Print NW for printing an estimated 164,754 mail pieces. 

On August 17, 2020 the Campaign filed an amended 7-Day Pre-Primary C-4 report disclosing the same monetary contributions received and expenditures made during the period, but added $37,857 in new debts and total liabilities, the majority of which were orders placed with  Sermo Digital that included $12,500 for online advertising for the period July 15 through August 4, 2020; $10,000 for online advertising with Pandora for the period July 27 through August 4, 2020; $3,000 for Digital Consulting; and $1,833 for email political advertising.

Staff reviewed the allegation that the Campaign spent general election contributions on 2020 primary election activites, and found: (1) the Campaign received a total of seven contributions designated for the 2020 general election totaling $10,750; and (2) as of  August 31, 2020, the Campaign had $35,067 cash on hand balance that included the $10,750 in general election contributions, verifying the general election contributions received by the Campaign had not been spent.  Mr. Vaska stated that the Campaign “always maintained a cash balance exceeding the total balance of sequestered General Election contributions.”

On October 1, 2020, the Campaign submitted an email stating all of the general election contributions that had been received were refunded, and that the Campaign reattributed one contribution made by joint check between the two spouses.

Mr. Vaska stated he retained two very experienced consultants for his Campaign and an experienced Campaign Treasurer to file the PDC reports, that he met weekly via Zoom with the team to discuss the Campaign which included PDC filing deadlines, and that PDC reporting requirements were also discussed by email.  He stated that due to “COVlD—19, our entire team never had the opportunity to meet in person after the campaign was launched. As a result, the campaign did not have the normal, in-person communications structure that would have provided me with a better opportunity to ensure full and timely disclosure by the campaign team, especially during the rigorous reporting deadlines in the three weeks before the Primary.”

Staff noted Mr. Vaska was seeking election to a high-profile office, and the typical campaign practices and procedures a Statewide candidate would engage in, including the communication and interactions with consultants, vendors and Campaign Officers and Treasurers were impacted due to Covid-19.  The late-disclosed orders placed were for a statewide mailing and digital campaign that was largely conducted remotely.  In addition, no evidence was found by staff that the Campaign exceeded contribution limits for the 2020 election or spent 2020 general election contributions on primary election activities.

However, pursuant to WAC 390-37-060(1)(d), the PDC issued a formal written warning to the Mike Vaska for AG Campaign concerning the failure to timely disclose orders placed with Sermo Digital on both the 21-Day and 7-Day Pre-Primary C-4 reports as required by RCW 42.17A.240.  The PDC dismissed the complaint in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/cases/74473
74410 07/31/2020 LaWanda Hatch Ana Ruiz Peralta Ruiz Peralta, Ana: Alleged Violation of RCW 42.17A.320 for failure to disclose party preference on political advertising (EY20, July20) WAC 390-18-020, RCW 42.17A.320 Case Closed with Reminder

The complaint alleged Ana Ruiz Peralta, a 2020 candidate for Franklin County Commissioner, position 2, may have violated RCW 42.17A.320 and WAC 390-18-020 by failing to identify a party preference on political advertising, specifically political signs. PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the applicable PDC reports, and the response fromAna Ruiz Peralta, to determine whether the record supports a finding of one or more violations. 

Ana Ruiz Peralta responded to the PDC on August 19, 2020 stating “Our campaign is aware of the need to include our political affiliation on our campaign banners and signs. We have purchased stickers with the (D) clearly printed on them and we are currently in the process of putting those stickers on all of our signs so that they are all in compliance.”

Based on these findings, and the fact Peralta is a first-time candidate and updated the signs when notified of the requirement, staff has determined in this instance the failure to include party identification does not amount a violation warranting further investigation.

PDC staff is reminding Ana Ruiz Peralta about the importance of identifying the party preference on all 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/74410
74390 07/31/2020 Kess Smith Sharlett Mena Mena, Sharlett: Alleged Violation of RCW 42.17A.235, .240 for failure to timely and accurately disclose expenditures (EY20, July20) 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 July 28, 2020. The complaint alleged that Sharlett Mena, a candidate for State Representative in Legislative District 29, in the August 4, 2020 primary election, may have violated RCW 42.17A.235 and .240 for failure to timely 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 response provided by Dorian Waller, Campaign Consultant with Archway Consulting, on behalf of 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.

Sharlett Mena is a first-time candidate, with a volunteer treasurer, and has not previously been found in violation of the PDC campaign finance laws or rules. Although Ms. Mena employed the services of a consulting firm, Mr. Waller was not involved in the campaign reporting obligations. It appears that the reporting discrepancies were caused by a general lack of knowledge regarding the requirements for the disclosure of campaign expenses and not meant to conceal campaign activity from the public.

Based on our findings staff has determined that, in this instance, failure to timely and accurately report a small number of expenditures, does not amount to a finding of a violation that warrants further investigation.

PDC staff reminded Sharlett Mena about the importance of the timely and accurate filing of campaign expenditures, specifically the detailed descriptions required for expenses, 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/74390
74277 07/29/2020 Alex Bond The Leadership Council The Leadership Council (2): Alleged Violation of RCW 42.17A.405 for making over-limit contributions (EY20, July20) RCW 42.17A.405 Resolved through Statement of Understanding

The complaints alleged The Leadership Council and WA Forward (The Leadership Council), two continuing political committees registered with the PDC, violated RCW 42.17A.405 by making over-limit contributions from affiliated entities to five 2020 legislative candidates, which exceeded the $2,000 contribution limit. 

On November 12, 2020, the PDC received a completed Statements of Understanding (SOU) for both The Leadership Council and WA Forward (the Leadership Council), acknowledging violations of RCW 42.17A.405 by making over-limit contributions to five candidates for the Washington State Legislature in 2020 from two affiliated entities. The Leadership Council and WA Forward (the Leadership Council) each paid a $750 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), which resolves the issues of making over-limit contributions from affiliated entities to five 2020 Legislative candidates. 

PDC staff found no evidence of material violations requiring additional enforcement action in this matter, especially since the affiliated contributions made by WA Forward (The Leadership Council) to the five 2020 candidates were mitigated by the fact the candidates timely refunded the over-limit contributions and none of the candidates appeared to have spent any of the over-limit contributions. 

Based on this information, the PDC has dismissed these two cases against the Leadership Council (PDC Case 74277) and WA Forward - The Leadership Council (PDC Case 74270), in accordance with RCW 42.17A.755(1).  

https://www.pdc.wa.gov/browse/cases/74277
74270 07/29/2020 Alex Bond WA Forward (The Leadership Council) WA Forward (The Leadership Council) (2): Alleged Violation of RCW 42.17A.405 for making over-limit contributions (EY20, July20) RCW 42.17A.405 Resolved through Statement of Understanding

The complaints alleged The Leadership Council and WA Forward (The Leadership Council), two continuing political committees registered with the PDC, violated RCW 42.17A.405 by making over-limit contributions from affiliated entities to five 2020 legislative candidates, which exceeded the $2,000 contribution limit. 

On November 12, 2020, the PDC received a completed Statements of Understanding (SOU) for both The Leadership Council and WA Forward (the Leadership Council), acknowledging violations of RCW 42.17A.405 by making over-limit contributions to five candidates for the Washington State Legislature in 2020 from two affiliated entities. The Leadership Council and WA Forward (the Leadership Council) each paid a $750 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), which resolves the issues of making over-limit contributions from affiliated entities to five 2020 Legislative candidates. 

PDC staff found no evidence of material violations requiring additional enforcement action in this matter, especially since the affiliated contributions made by WA Forward (The Leadership Council) to the five 2020 candidates were mitigated by the fact the candidates timely refunded the over-limit contributions and none of the candidates appeared to have spent any of the over-limit contributions. 

Based on this information, the PDC has dismissed these two cases against the Leadership Council (PDC Case 74277) and WA Forward - The Leadership Council (PDC Case 74270), in accordance with RCW 42.17A.755(1).  

https://www.pdc.wa.gov/browse/cases/74270
74254 07/29/2020 Dorothy Luzzo Gilmour Rodney "Rocky" Mullen Mullen, Rodney "Rocky": Alleged Violation of RCW 42.17A.320 for failure to disclose sponsor identification on political advertising (EY20, July20) RCW 42.17A.320 Case Closed with Reminder

On July 22, 2020, the Public Disclosure Commission (PDC) received a complaint alleging that Rodney Mullen, a first-time candidate for the County Commissioner (Position 2) in Franklin County, may have violated RCW 42.17A.320 for failure to include sponsor identification (paid-for-by information) on a political advertisement. 

PDC staff reviewed the applicable statute(s), rule(s), and the reporting requirement(s) pertinent to the sponsor identification. 

Staff found that Mr. Mullen failed to include sponsor identification (paid-for-by information, followed by his name and complete address) on his political advertisement for the postcard/mailer that was sent to voters on or about the second week of July 2020. 

Staff reminded Mr. Mullen about the importance of including sponsor identification information on political advertisement for all future mailers and reiterated its expectation that Mr. Mullen will review all political advertisements in the future that, he and his campaign sponsors, to ensure they contain required sponsor identification information ("Paid for or Sponsored by" followed by the candidate's name and full address), as required by law. 

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

https://www.pdc.wa.gov/browse/cases/74254
74253 07/29/2020 Alex Bond Chris Gildon Gildon, Chris: Alleged Violation of RCW 42.17A.405 for accepting over limit contributions (EY20, July20) RCW 42.17A.405 Case Closed with Reminder

The complaint alleged Chris Gildon, who was first elected to the Washington State House of Representatives from the 25th District in 2018 and is a candidate for the Washington State Senate in 2020, violated RCW 42.17A.405 by accepting contributions from an affiliated entity, when aggregated, exceeded the contributions limits for a 2020 legislative candidate of $1,000 each for the primary and general elections.

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

Staff has determined that in this instance, the Campaign’s acceptance of over-limit contribution from an affiliated entity does not amount to a finding of a violation that warrants further investigation based on the facts that as of July 14, 2020: (1) the campaign had received contributions totaling $101,155.39 and had $20,456.45 as a cash on hand balance; and (2) the $1,000 contribution received from Washington Forward had not been spent by the Campaign. 

Based on these findings, and the fact Gildon refunded the contribution promptly when notified of the requirement, staff has determined in this instance the failure to include party identification does not amount a violation warranting further investigation.

PDC staff is reminding Chris Gildon about the importance of acceptance of an over-limit contribution from an affiliated entity in accordance with PDC laws and rules and staff expects the Campaign will adhere to the contribution limits for the remainder of the 2020 election cycle and not accept any contributions exceeding the contribution limits in the future, as required by law.

Based on 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/74253
74225 07/28/2020 Alex Bond Steve O'Ban O'Ban, Steven (2): Alleged Violation of RCW 42.17A.405 for accepting over limit contributions (EY20, July20) RCW 42.17A.405 Case Closed with Written Warning

The complaint alleged Steve O’Ban, a State Senator and a 2020 candidate for re-election to the office from the 28th District, violated RCW 42.17A.405 by accepting contributions from an affiliated entity, when aggregated, exceeded the contributions limits for a 2020 legislative candidate of $1,000 each for the primary and general elections.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements and the response from Mark Lamb, attorney for Steve O’Ban, to determine whether the record supports a finding of one or more violations.

Staff has determined that in this instance, the Campaign’s acceptance of over-limit contribution from an affiliated entity does not amount to a finding of a violation that warrants further investigation based on the facts that as of July 14, 2020: (1) the campaign had received contributions totaling $366,200.85 and had $124,190.58 as a cash on hand balance; and (2) the $1,000 contribution received from Washington Forward had not been spent by the Campaign. 

However, pursuant to WAC 390-37-060(1)(d), Steve O’Ban will receive a formal written warning concerning the acceptance of an over-limit contribution from an affiliated entity as noted in this letter. The formal written warning includes staff’s expectation the Campaign will adhere to the contribution limits for the remainder of the 2020 election cycle and not accept any contributions exceeding the contribution limits in the future, as required by law. 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/74225
74205 07/28/2020 Norman J Smith Devin D Beach Beach, Devin: Alleged violation of RCW 42.17A.235 by failing to provide digital access to candidate's books of account within 48 hours of request. (EY '20; Jul '20) RCW 42.17A.235 Case Closed with No Evidence of Violations

On July 27, 2020, the Public Disclosure Commission (PDC) received a complaint alleging that Devin Beach, a first-time candidate for the County Commissioner (Position 1) in Pend Oreille County, may have violated RCW 42.17A.235 for failure to provide digital access to books of account within 48 hours of the request. 

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, rule, and the July 28, 2020 response from Mr. Beach.

Staff's review found no evidence to support a finding of a violation warranting further investigation or enforcement action. 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/74205
74189 07/28/2020 Joseph Colombo Kelly Chambers Chambers, Kelly: Alleged Violation of RCW 42.17A.320 & WAC 390-18-010 for failure to disclose sponsor information on political advertising (EY20, July20) WAC 390-18-010, RCW 42.17A.320 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on July 20, 2020. The complaint alleged that Kelly Chambers, incumbent State Representative in Legislative District 25, Position 1 and candidate for re-election in the 2020 general election, may have violated RCW 42.17A.320 and WAC 390-18-010 for failure to disclose sponsor identification on written political advertisement.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the response provided by campaign consultant Alex Hays of AB Hays, LLC, on behalf of Rep. Chambers (“the Respondent”), to determine whether the record supports a finding of one or more violations.

Although Rep. Chambers is not a first-time candidate and her campaign consultant, AB Hays, LLC, has general knowledge of PDC laws and rules regarding written political advertisement and sponsor identification, it appears that the creation and mailing of this specific ad was mistakenly viewed by the campaign as something different than the more traditional type of mailers done in the past. Furthermore, the response to the complaint shows that the campaign is fully aware of the sponsor identification requirements as they used this knowledge in a subsequent mailing.

Based on our findings staff has determined that, in this instance, failure to include sponsor identification on one piece of political advertisement, does not amount to a finding of a violation that warrants further investigation.

PDC staff reminded Rep. Chambers about the importance of including the proper and full disclosure of the sponsor on all future written political advertisement in accordance with PDC 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/74189
74124 07/27/2020 Laurie Euler, Sarah Zarrow, and Glen Morgan David Blomstrom Blomstrom, David: Alleged violation of RCW 42.17A.320 for failure to disclose sponsor identification on political advertising (EY 20; July 20) RCW 42.17A.235, RCW 42.17A.240, WAC 390-16-125, RCW 42.17A.320 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaints filed by Laurie Euler on July 23, 2020, Sarah Zarrow on July 24, 2020 and Glen Morgan on July 29, 2020. As all three complaints included allegations concerning the same mailer, PDC staff combined the complaints and investigated the allegations under PDC Case 74124. The complaints alleged that David Blomstrom, a gubernatorial candidate in the 2020 election, may have violated: (1) RCW 42.17A.320 and WAC 390-18-010 for failure to disclose sponsor identification on written political advertisement; (2) RCW 42.17A.320(1) for failure to include party preference on written political advertisement; and (3) RCW 42.17A.235 and .240, and WAC 390-16-125 for exceeding mini-reporting limitations without prior authorization from the PDC.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by David Blomstrom (“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 the documentation provided by Mr. Blomstrom detailing his 2020 gubernatorial campaign expenses, staff found no evidence that the campaign exceeded the Mini Reporting dollar amount thresholds.

Although Mr. Blomstrom is not a first-time candidate, it appears that the creation and mailing of this specific postcard was mistakenly viewed by him as advertisement for his book only and not as a comprehensive political advertisement. Furthermore, Mr. Blomstrom’s campaign history shows that he has not engaged in this type of advertising in the past and had little knowledge about the requirements at the time he chose the ad language.

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

PDC staff reminded Mr. Blomstrom about the importance of including the full sponsor on all future written political advertisement and party preference on all political ads in accordance with PDC 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/74124
74122 07/27/2020 Robert Parker, Rick Offner Michelle Caldier Caldier, Michelle: Alleged violation of RCW 42.17A.320 by failing to identify sponsor on political advertising mailer. (EY '20; Jul '20) RCW 42.17A.320 Case Closed with Reminder

On July 13 and July 25, 2020, the Public Disclosure Commission (PDC) received two complaints alleging that Ms. Caldier, a 2020 candidate for State Representative in the 26th District (Position 2), may have violated RCW 42.17A.320 for failure to include sponsor identification ("Paid for or Sponsored by" followed by the candidate's name and complete address) on a political advertisement. 

PDC staff reviewed the applicable statute/rule, the two exhibits attached to the complaint(s), and the reporting requirement(s) pertinent to the sponsor identification statute/rule. 

PDC staff found that Ms. Caldier failed to include sponsor identification on her political advertisement for the mailer that was sent to the voters on or about the week of July 20, 2020. Staff reminded Ms. Caldier about the importance of including sponsor identification on political advertisements for all future mailers. 

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/74122
74102 07/27/2020 Alex Bond Lynda Wilson Wilson, Lynda: Alleged violation of RCW 42.17A.405 by accepting over-limit contribution from an affiliated entity. (EY '20; Jul '20) RCW 42.17A.405 Case Closed with Written Warning

The complaint alleged Lynda Wilson, a State Senator and a 2020 candidate for re-election to that office from the 17th District, violated RCW 42.17A.405 by accepting contributions from an affiliated entity, when aggregated, exceeded the contributions limits for a 2020 legislative candidate of $1,000 each for the primary and general elections.

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

Staff has determined that in this instance, the Campaign’s acceptance of over-limit contribution from an affiliated entity does not amount to a finding of a violation that warrants further investigation based on the facts that as of July 27, 2020: (1) the campaign had received contributions totaling $263,594, and had $75,267 as a cash on hand balance; and (2) the $1,000 contribution received from Washington Forward had not been spent by the Campaign. 

However, pursuant to WAC 390-37-060(1)(d), Lynda Wilson will receive a formal written warning concerning the acceptance of an over-limit contribution from an affiliated entity as noted in this letter. The formal written warning will include staff’s expectation the Campaign will adhere to the contribution limits for the remainder of the 2020 election cycle and not accept any contributions exceeding the contribution limits in the future, as required by law. 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/74102
74003 07/23/2020 Alex Bond Ron Muzzall Muzzall, Ron: Alleged violation of RCW 42.17A.405 by accepting over-limit contribution from an affiliated entity. (EY '20; Jul '20) RCW 42.17A.405 Case Closed with Reminder

The complaint alleged Ron Muzzall, who was appointed to Washington State Senate from the 10th District in October 2019 and is a candidate for the same position in 2020, violated RCW 42.17A.405 by accepting contributions from an affiliated entity, when aggregated, exceeded the contributions limits for a 2020 legislative candidate of $1,000 each for the primary and general elections.

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

Staff has determined in this instance, the Campaign’s acceptance of over-limit contribution from an affiliated entity does not amount to a finding of a violation that warrants further investigation based on the facts that as of July 14, 2020: (1) the campaign had received contributions totaling $189,539.94 and had $20,588.09 as a cash on hand balance; and (2) the $1,000 contribution received from Washington Forward had not been spent by the Campaign. 

Based on these findings, and the fact Muzzall is a first-time candidate and refunded the contribution promptly when notified of the requirement, staff has determined in this instance the failure to include party identification does not amount a violation warranting further investigation.

PDC staff is reminding Ron Muzzall about the importance of acceptance of an over-limit contribution from an affiliated entity in accordance with PDC laws and rules and PDC staff expects the Campaign will adhere to contribution limits for the remainder of the 2020 election cycle and not accept any contributions exceeding the contribution limits in the future, as required by law.

Based on 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/74003
74002 07/23/2020 Alex Bond Connie Beauvais Beauvais, Connie: Alleged violation of RCW 42.17A.405 by accepting over-limit contribution from an affiliated entity. (EY '20; Jul '20) RCW 42.17A.405 Case Closed with Reminder

The complaint alleged Connie Beauvais, a Port of Port Angeles Port Commissioner, and a 2020 candidate for election to the Washington State Senate from the 24th District, violated RCW 42.17A.405 by accepting contributions from an affiliated entity, when aggregated, exceeded the contributions limits for a 2020 legislative candidate of $1,000 each for the primary and general elections.

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

Staff has determined that in this instance, the Campaign’s acceptance of over-limit contribution from an affiliated entity does not amount to a finding of a violation that warrants further investigation based on the facts that as of July 14, 2020: (1) the campaign had received contributions totaling $47,660.01 and had $11,472.25 as a cash on hand balance; and (2) the $1,000 contribution received from Washington Forward had not been spent by the Campaign. 

Based on these findings, and the fact Beauvais is a first-time candidate for Legislative office and refunded the contribution promptly when notified of the requirement, staff has determined in this instance the failure to include party identification does not amount a violation warranting further investigation.

PDC staff is reminding Connie Beauvais about the importance of acceptance of an over-limit contribution from an affiliated entity in accordance with PDC laws and rules and staff expects the Campaign will adhere to the contribution limits for the remainder of the 2020 election cycle and not accept any contributions exceeding the contribution limits in the future, as required by law. 

Based on 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/74002
73978 07/23/2020 Glen Morgan Navarra Carr Carr, Navarra: Alleged violation of RCW 42.17A.700 for failure to timely file a Personal Financial Affairs Statement (EY 20; July 20) RCW 42.17A.700 Case Closed with Reminder

On July 13, 2020, the Public Disclosure Commission (PDC) received a complaint alleging that Navarra Carr may have violated RCW 42.17A.700 for failure to timely file a Personal Financial Affairs Statement report (F-1) by April 15, 2020.   

Staff reviewed the applicable statute(s), rule(s), and the reporting requirements, including the response submitted by Navarra Carr.    

Staff found that Ms. Carr failed to file her F-1 report by April 15, 2020, as required by law. However, she did file the F-1 report on July 14, 2020.  

Based on these findings, the staff reminded Ms. Carr. about the importance of filing an F-1 report in a timely manner in the future.     

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

https://www.pdc.wa.gov/browse/cases/73978
73973 07/23/2020 Glen Morgan Olympia Citizens for Schools Olympia Citizens for Schools: Alleged violations of RCW 42.17A.220, .235, and .240 for failure to accurately and completely disclose contributions and expenditures (EY 20; July 20) RCW 42.17A.240, RCW 42.17A.220, RCW 42.17A.235, WAC 390-16-037 Case Closed with Reminder

On July 13, 2020, the Public Disclosure Commission (PDC) received a complaint alleging violations of RCW 42.17A.235 for failure to accurately and completely disclose contribution and expenditures report and RCW 42.17A.240 for failure to properly breakdown and describe expenditure details, as required in WAC 390-16-037 and WAC 390-16-205. 

Staff reviewed the allegations, the applicable law(s), rule(s), and reporting requirements, the C-3 and C-4 reports filed by the Committee, and the July 29 and August 12, 2020 responses. 

Staff found that the Committee failed to breakdown and describe expenditure details, as required in WAC 390-16-037 and WAC 390-16-205. Based on this finding, the staff issued a reminder letter regarding the importance of properly breaking down and describing expenditures in the future. 

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

https://www.pdc.wa.gov/browse/cases/73973
73962 07/23/2020 Glen Morgan Lorna Dale Smith Smith, Lorna Dale: Alleged violation of RCW 42.17A.240 for failure to sufficiently describe expenditures on C-4 reports. (EY '20; Jul '20) RCW 42.17A.240 Case Closed with Reminder

On July 21, 2020, the Public Disclosure Commission (PDC) received a complaint alleging that Lorna Smith violated RCW 42.17A.240 for failure to properly break down and describe expenditure details, as required in WAC 390-16-047 and WAC 390-16-205. 

Staff reviewed the allegation; the applicable statutes, rules, and the reporting requirements, including the May 2020 Summary Campaign Contribution and Expenditure report (C-4 report) filed by the Committee to Lorna Smith.  

Staff found that the expenditures made by Ms. Smith's campaign lacked proper description(s) and break down required by law/rule. 

Based on these findings, the staff reminded Ms. Smith about the importance of properly breaking down and describing expenditures in the future as required by law/rule.    

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

https://www.pdc.wa.gov/browse/cases/73962
73934 07/22/2020 Glen Morgan Mark Lundsten Lundsten, Mark: Alleged Violation of RCW 42.17A.240 for failure to accurately disclose expenditures on reports (EY 20, July 20) RCW 42.17A.240 Case Closed with Reminder

The complaint alleged Mark Lundsten, a 2020 candidate for Skagit County Commissioner, may have violatedRCW 42.17A.240 by failing to timely and accurately report expenditure detail on Summary Full Campaign Contribution and Expenditure (C-4) reports.

Based on PDC findings, and the fact Lundsten is a first-time candidate, staff has determined in this instance the failure to timely and accurately report expenditure detail does not amount a violation warranting further investigation. PDC staff is reminding about the importance of filing timely, accurate and complete 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/73934
73884 07/22/2020 Glen Morgan Eastside Democratic Dinner Committee PAC Eastside Democratic Dinner Committee (2): Alleged Violation of RCW 42.17A.235 for failure to timely and fully disclose contributions on reports (C-3 & C-4) (EY20, July20) RCW 42.17A.235 Case Closed with No Evidence of Violations

A complaint was filed alleging that the Eastside Democratic Dinner Committee (Committee), a political committee registered with the PDC may have violated: (1) RCW 42.17A.235 and .240 by failing to disclose a $500 contribution received from the King County Democratic Central Committee; and (2) RCW 42.17A.430 by accepting a $1,000 contribution from the Tana Senn Surplus Funds Account and not being eligible to receive a contribution since they are not a political party organization.

The Registration filed by the Committee listed its Officers as Steve Kasner, Chair of the 41st District Democrats; K.C. Shankland, Chair of the 5th District Democrats; James Terwilliger, Chair of the 48th District Democrats; David Williams, Chair of the 45th District Democrats.

The Committee acknowledged receiving a $500 contribution from the King County Democratic Central Committee on June 23, 2020.  However, they noted the Committee “erroneously reported the contribution as coming from Ms. Shasti Conrad. Ms. Conrad is the chair of the King County Democratic Central Committee.” The Committee stated on June 23, 2020, Ms. Conrad made an online contribution as Chair of the King County Democratic Central Committee using the party’s debit card, but that “when the ActBlue confirmation came through to our treasurer only Ms. Conrad’s name was shown on the confirmation.” The Committee included a June 23, 2020, email from ActBlue and stating on the Subject line “(ActBlue) Shasti Conrad $500 to Eastside Democrats.

On July 22, 2020, the Committee filed an amended C-3 report disclosing “the King County Democratic Central Committee as the donor and removing Shasti Conrad’s personal name” as the contributor.  The contribution had been deposited on June 24, 2020, and the original C-3 report was timely filed by the Committee on June 28, 2020.

Concerning the contribution received from the Tana Senn Surplus Funds account, the Committee acknowledged receiving the contribution from the Tana Senn Surplus Account, but that the Committee “relied on the Senn team with regards to the appropriate account from which the donation could be made. Upon learning of this error, we immediately refunded the donation of $1,000 to the Tana Senn Surplus Account.” The Committees refund check was received by the Tana Senn Surplus Funds account and deposited into the surplus fund bank account on July 23, 2020, per the Committee bank records.

Staff found that the $500 contribution received by the Eastside Democratic Dinner Committee from the King County Democratic Central Committee was timely received and deposited.  However, due to processing issue on the part of the vendor the contributor information provided to the Committee inadvertently attributed the contribution to Ms. Conrad, the Chair of the King County Democratic Central Committee. Once notified of the discrepancy, the Eastside Democratic Dinner Committee promptly filed an amended report disclosing  the King County Democratic Central Committee as the contributor.   In addition, while the surplus fund expenditure was improperly made by Tana Senn using surplus funds to a political committee, the Eastside Democratic Dinner Committee did not violate RCW 42.17.430 by receiving and depositing the $1,000 contribution from the Tana Senn Surplus Funds Account.

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

https://www.pdc.wa.gov/browse/cases/73884
73852 07/21/2020 Glen Morgan Tana Senn (Surplus Account) Senn, Tana: Alleged Violation of RCW 42.17A.430 for improper transfer of surplus funds (EY20, July 20) RCW 42.17A.430 Case Closed with Reminder

A complaint was filed alleging that Tana Senn, an incumbent Washington State Representative for the 41st Legislative District and a candidate seeking re-election to that office in 2020, may have violated RCW 42.17A.430 by making a $1,000 prohibited expenditure from the Tana Senn Surplus Funds Account to the Eastside Democratic Dinner Committee.

On July 9, 2020, the Tana Senn Surplus Funds account filed a C-4 report for June of 2020, disclosing $1,524.50 in surplus funds expenditures were made during June that included a $1,000 contribution made to the Eastside Democratic Dinner Committee on June 11, 2020.

According to its website, the Eastside Democratic Dinner Committee (Committee) is made up of regional Democratic Party organizations that supports “Democratic party building efforts” for four legislative district organizations in East King County. The Committee works collaboratively with the 5th, 41st, 45th and 48th Legislative District Democratic organizations, and the Committee’s leadership consists of each of the four Chairs of those East King County Legislative District Democratic organizations.

Representative Senn and her Treasurer both “mistakenly believed it was a political party and not a PAC (and therefore a permissible use of the funds). It was not until reading the complaint that we realized our mistake, and a request was immediately made for the refund of the donation.”

The $1,000 contribution made using surplus funds was refunded by the Committee and received and deposited by the Tana Senn Surplus funds account on July 23, 2020.  A C-3 report was filed by the Tana Senn Surplus funds account on July 24, 2020, disclosing the receipt and deposit of the $1,000 refund of contribution from the Committee as July 23, 2020.  

Staff found that while the Eastside Democratic Dinner Committeehas a direct nexus to the 5th, 41st, 45th and 48th Legislative District Democratic organizations since the Chairs are its Officers, the surplus fund expenditure was not made to a bona fide political party committee.  The $1,000 contribution was timely refunded by the Eastside Democratic Dinner Committee, and staff’s review indicated the contribution had not been spent prior to being refunded. 

PDC staff found no evidence of a material violation that would require conducting a more formal investigation into the complaint or pursuing enforcement action in this instance. Staff is reminding Representative Senn concerning the importance of carefully reviewing expenditures made from the surplus funds account to make sure all expenditures are permissible in accordance with RCW 42.17A.430, especially contributions made to political party organizations.  The PDC has dismissed the complaint in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/73852
73839 07/21/2020 Carol Ham Dan Driscoll Driscoll, Dan: Alleged violation of RCW 42.17A.320(1) by failing to include party preference on campaign yard signs. (EY '20l Jul '20) RCW 42.17A.320 Case Closed with No Evidence of Violations

The complaint alleged Dan Driscoll, a 2020 candidate for Pacific County Commissioner, position 2, may have violated RCW 42.17A.320 by failing to identify a party preference on political advertising, specifically political signs. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the applicable PDC reports, and the response from Linda Engelsiepen, Secretary for Vote for Driscoll (Campaign), to determine whether the record supports a finding of one or more violations. 

Engelsiepen responded to the PDC on July 21, 2020, stating “We did consult the PDC guidelines and “L” is listed as a proper notice of libertarian party affiliation, which is included on the campaign signs for Dan Driscoll’s campaign.”

In the sign you included with the complaint, the L is listed, as noted by Engelsiepen. 

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1). If you have questions, you may contact Alice Fiman toll-free at 1-877-601-2828, or by email at pdc@pdc.wa.gov.

https://www.pdc.wa.gov/browse/cases/73839
73829 07/21/2020 Glen Morgan George Bridges Bridges, George: Alleged violation of RCW 42.17A.700 for failure to timely file a personal financial affairs statement by April 15, 2020. (EY '20; Jul '20) RCW 42.17A.700 Case Closed with Written Warning

On July 17, 2020, the Public Disclosure Commission (PDC) received a complaint alleging that George Bridges violated RCW 42.17A.700(2) and .710 for failure to timely file a Personal Financial Affairs Statement report (F-1) by April 15, 2020.   

Staff reviewed the applicable statute(s), rule(s), and the reporting requirements, including the response submitted by George Bridges.  

Staff found that Mr. Bridges failed to file his F-1 report by April 15, 2020, as required by law. However, he did file the F-1 report on July 16, 2020.  

Based on these findings, the staff formally warned Mr. Bridges for failure to timely file a Personal Statement of Financial Affairs (F-1) report.    

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

https://www.pdc.wa.gov/browse/cases/73829
73828 07/21/2020 Glen Morgan Jeff Winmill Winmill, Jeff: Alleged violation of RCW 42.17A.700 and .710 for failure to timely & accurately file a personal financial affairs statement within two weeks of becoming a candidate. (EY '20; Jul '20) RCW 42.17A.710, RCW 42.17A.700 Case Closed with Reminder

On July 17, 2020, the Public Disclosure Commission (PDC) received a complaint alleging that Jeff Winmill may have violated RCW 42.17A.700 for failure to timely file a Personal Financial Affairs Statement report (F-1) by April 15, 2020.   

Staff reviewed the applicable statute(s), rule(s), and the reporting requirements, including the response submitted by Jeff Winmill.   

Staff found that Mr. Winmill failed to file his F-1 report by April 15, 2020, as required by law. However, he did file the F-1 report on August 12, 2020.  

Based on these findings, the staff reminded Mr. Winmill about the importance of filing an F-1 report in a timely manner in the future.     

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

https://www.pdc.wa.gov/browse/cases/73828
73826 07/21/2020 Glen Morgan Lorena Gonzalez Gonzalez, Lorena: Alleged violation of RCW 42.17A.700 and .710 for failure to timely & accurately file a personal financial affairs statement by April 15, 2020 or within two weeks of becoming a candidate, whichever occurred first. (EY '20; Jul '20) RCW 42.17A.700, RCW 42.17A.710 Case Closed with Written Warning

The complaint alleged Lorena Gonzalez, a 2020 candidate for Washington State Attorney General, violated 42.17A.700 and RCW 42.17A.710 by failing to timely and accurately file a financial affairs statement within two weeks of becoming a candidate.

It was determined Gonzalez is a current member of the Seattle City Council, and PDC staff updated the allegation to “by failing to timely and accurately file a financial affairs statement by April 15, 2020 or within two weeks of becoming a candidate, whichever occurred first.”

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

Staff has determined that in this instance, the failure to timely and accurately file financial affairs statement does not amount to a finding of a violation that warrants further investigation. 

However, pursuant to WAC 390-37-060(1)(d), Lorena Gonzalez will receive a formal written warning concerning the failure to comply with PDC requirements as noted in this letter.

The formal written warning will include staff’s expectation that Lorena Gonzalez timely file all future required financial affairs reports as required by law. 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/73826
73822 07/21/2020 Glen Morgan Frank Wallbrown Wallbrown, Frank: Alleged Violation of RCW 42.17A.700 for failure to timely file Personal Financial Affairs Statement (F-1) (EY 20, July 20) RCW 42.17A.700 Case Closed with Reminder

On July 22, 2020, the Public Disclosure Commission (PDC) received a complaint alleging that Frank Wallbrown, a first-time candidate for Washington State Public Lands Commissioner in 2020, may have violated RCW 42.17A.235 for failure to file contribution (C-3) and expenditure (C-4) reports and RCW 42.17A.700 for failure to timely file a Financial Statement of Financial Affairs (F-1) report.  

PDC staff reviewed the applicable statute(s) and rule(s), and reporting requirements related to the annual Personal Financial information and found that Mr. Wallbrown failed to timely file a Personal Statement of Financial Affairs that was due no later than April 15, 2020, including failure to file the 21-day and 7-day pre-primary reports that were due on July 14 and July 28, 2020, respectively. 

Staff issued a reminder letter reminding Mr. Wallbrown about the importance of filing the F-1 report and the required contribution and expenditure reports in a timely number in the future, as required by the law. 

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/73822
73816 07/21/2020 Glen Morgan Auburn Citizens for Schools (ACS) Auburn Citizens for Schools (ACS): Alleged violations of RCW 42.17A.235 & .240 for failure to timely & accurately report expenditures and carry forward cash & in-kind contributions for election years 2016 & 2020. (Jul '20) 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 July 15, 2020. The complaint alleged that Auburn Citizens for Schools (ACS), a political committee registered with the PDC in 2016 to support a bond and in 2020 to support a levy, may have violated: (1) RCW 42.17A.235 and .240 for failure to timely and accurately file Summary Full Campaign Contribution and Expenditure reports (C-4 reports) disclosing expenditures for election years 2016 & 2020; and (2) RCW 42.17A.235 and .240 for failure to timely and accurately report carry forward cash for election years 2016 & 2020.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the responses provided by committee president, Cari Manry, and committee treasurer, Margaret Keller, for ACS (“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.

It appears that the late and incomplete reporting was due to a general lack of knowledge with PDC laws, rules and reporting software, and not done to conceal the campaign activities of ACS. The committee has not been the subject of enforcement matters before the Commission and cooperated with staff to make the corrections referenced above.

As noted in the complaint, staff believes that the way ACS registered each election was partly to blame for the allegations related to the carry forward balances.

Based on our findings staff has determined that, in this instance, failure to timely and accurately file C-4 reports disclosing the campaign activities of ACS during election years 2016 & 2020, does not amount to a finding of a violation that warrants further investigation.

PDC staff is reminding ACS about the importance of the timely and accurate disclosure of all contribution and expenditure activities, including the carry forward balances and expenditure details when required, 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/73816
73784 07/20/2020 Glen Morgan Hollie Huthman Huthman, Hollie: Alleged Violation of RCW 42.17A.700, .710 for failure to timely file Personal Financial Affairs Statement (F-1) (EY20, July 20) RCW 42.17A.710, RCW 42.17A.700 Case Closed with Written Warning

On July 13, 2020, the Public Disclosure Commission (PDC) received a complaint alleging that Hollie Huthman may have violated RCW 42.17A.700(2) for failure to timely file a Personal Financial Affairs Statement report (F-1) by April 15, 2020.   

Staff reviewed the applicable statute(s), rule(s), and the reporting requirements, including the response submitted by Hollie Huthman.   

Staff found that Ms. Huthman failed to file his F-1 report by April 15, 2020, as required by law. However, she did file the F-1 report on August 10, 2020, six days after the 2020 Primary Election.   

Based on these findings, the staff issued a formal written warning to Ms.Huthman for failure to timely file a Personal Statement of Financial Affairs (F-1) report.    

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

https://www.pdc.wa.gov/browse/cases/73784
73589 07/16/2020 Glen Morgan Christian McLachlan McLachlan, Christian: Alleged violations of Chapter 42.17A RCW for failure to file Candidate Registration and Personal Financial Affairs Statement (EY 20; July 20) RCW 42.17A.205, RCW 42.17A.710, RCW 42.17A.700, RCW 42.17A.235, RCW 42.17A.215, RCW 42.17A.210 Case Closed with Reminder

On July 10, 2020, the Public Disclosure Commission (PDC) received a complaint alleging that Christian McLachlan, a 2020 first-time candidate for State Representative in the 6th Legislative District, Position 2, may have violated RCW.24.17A.700 for failure to timely file a Personal Financial Statement Report (F-1) and RCW 42.17A.205 for failure to timely file a Candidate Registration (C-1) report. 

PDC staff reviewed the applicable statute(s), rules(s), and the reporting requirements related to the annual Personal Financial Affairs Statement and Candidate Registration. 

Staff found Mr. McLachlan failed to timely file a Personal Statement of Financial Affairs (F-1) report that was due no later than April 1, 2020. Staff also found that Mr. McLachlan failed to file a Candidate Registration report timely. 

Staff issued a reminder letter since Mr. McLachlan has no prior PDC violations and dismissed the matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/cases/73589
73588 07/16/2020 Glen Morgan Columbia Voice PAC, sponsored by Washington Realtors PAC Columbia Voice PAC: Alleged violations of RCW 42.17A.320(1), (5), .350 & .255(5)(b) by failing to identify sponsor's name, city, state, Top 5 & Top 3 contributors & party preference on radio ad & fully describe expenditures on C-6 reports. (Jul '20) RCW 42.17A.350, RCW 42.17A.255, RCW 42.17A.320 Case Closed with No Evidence of Violations

The complaint alleged Columbia Voice PAC violated RCW 42.17A.320(1), (5) and 42.17A.350 for failing to disclose who authorized/paid for a radio advertisement, the sponsor's name, city, state, Top 5 contributors and Top 3 donors, and the party preference of the candidate identified and RCW 42.17A.255(5)(b) for failure fully describe independent expenditure details on C-6 reports.

PDC staff reviewed the recording, which included all information required by law. 

Based on 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/73588
73582 07/16/2020 Martin Buckley Cyrus Krohn Krohn, Cyrus: Alleged violations of RCW 42.17A.320 for failure to disclose party preference on political advertising (EY 20; July 20) RCW 42.17A.320 Case Closed with No Evidence of Violations

The complaint alleged Cyrus Krohn, a 2020 candidate for House of Representatives, Legislative District 5, Position 1, may have violated may have violated RCW 42.17A.320 by failing to identify a party preference on political advertising, specifically political signs.

The signs did include the party preference text, however PDC staff has noted the confusion when Krohn added the word “for” on the signs and encouraged the candidate to remove the word in future campaigns to improve clarity and transparency. 

Based on 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/73582
73573 07/16/2020 Glen Morgan Jimmy Matta Matta, Jimmy (3): Alleged Violation of RCW 42.17A.700, .710 for failure to timely and accurately file Personal Financial Affairs Statement (F-1) (EY20, July20) RCW 42.17A.710, RCW 42.17A.700 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on July 13, 2020. The complaint alleged that Jimmy Matta, a current City Council Member of the City of Burien, may have violated RCW 42.17A.710 for failure to timely file the Personal Financial Affairs Statement (F-1 report) due by April 15, 2020 and covering calendar year 2019. 

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

Although it appears that Mr. Matta experienced extraordinary difficulties this year due to the restrictions of the COVID pandemic, and that he did not intentionally attempt to deprive the public of the disclosure of his finances as described in statute, the F-1 report covering financial activities for calendar year 2019 was submitted late. However, Mr. Matta has not been found in violation of late filing of the F-1 reports during his time as an elected official and cooperated with staff to complete his missing report.

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. Matta about the importance of timely filing a Personal Financial Affairs Statement with the PDC no later than April 15th each year as an elected official, and the timely filing of all future PDC F-1 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/73573
73564 07/16/2020 Carol Ham Jon Lind Lind, Jon: Alleged violation of RCW 42.17A.320(1) by failing to include party preference in campaign yard signs. (EY '20l Jul '20) RCW 42.17A.320 Case Closed with Reminder

The complaint alleged Jon A. Lind, a 2020 candidate for Pacific County Commissioner, position 2, may have violated RCW 42.17A.320 by failing to identify a party preference on political advertising, specifically political signs. 

Lind responded to the PDC on July 21, 2020, stating “I appreciate the notification of the failure to disclose my party preference on the yard signs. I have updated all yards signs to include my party preference using the abbreviation “Ind”. I’m also including a picture of the sign that Carol Ham identified as reference. Please be assured that I have included that same “Ind” party preference on all signs.”

Based on these findings, and the fact Lind is a first-time candidate and updated the signs as soon as notified of the requirement, staff has determined that, in this instance, the failure to include party identification does not amount a violation warranting further investigation.

PDC staff is reminding Lind about the importance of identifying the party preference on all 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/73564
73552 07/16/2020 Glen Morgan Daniel Smith Smith, Daniel: Alleged violation of RCW 42.17A.235 for failure to sufficiently describe expenditures on C-4 reports. (EY '20; Jul '20) RCW 42.17A.235 Case Closed with Reminder

On July 7, 2020, the Public Disclosure Commission (PDC) received a complaint alleging that Daniel Smith violated RCW 42.17A.240 for failure to properly break down and describe expenditure details, as required in WAC 390-16-047 and WAC 390-16-205. 

Staff reviewed the allegation; the applicable statutes, rules, and the reporting requirements, including the May 2020 Summary Campaign Contribution and Expenditure report (C-4 report) filed by the Committee to Elect Daniel Smith.  

Staff found that the expenditures made by Mr. Smith's campaign lacked proper description(s) and break down required by law/rule. 

Based on these findings, the staff reminded Mr. Smith about the importance of properly breaking down and describing expenditures in the future as required by law/rule.    

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

https://www.pdc.wa.gov/browse/cases/73552
73519 07/15/2020 W Shawn Minton Dale England England, Dale: Alleged Violation of RCW 42.17A.700 for failure to timely file Personal Financial Affairs Statement (F-1) (EY20, July 20) RCW 42.17A.700 Case Closed with Reminder
  • Allegation: Violation of RCW 42.17A.700 for failure to file Personal Financial Affairs Statement (F-1) without two weeks of becoming a candidate
https://www.pdc.wa.gov/browse/cases/73519
73338 07/13/2020 Glen Morgan Cydney Moore Moore, Cydney: Alleged violation of RCW 42.17A.700 for failure to timely file personal statement of financial affairs by April 15, 2020. (Jul '20) RCW 42.17A.700 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on July 13, 2020. The complaint alleged that Cydney Moore, a current City Council Member of the City of Burien, Position 2, may have violated RCW 42.17A.710 for failure to timely file the Personal Financial Affairs Statement (F-1 report) due by April 15, 2020 and covering calendar year 2019.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Cydney Moore (“the Respondent”); and the F-1 report filed by the Respondent, to determine whether the record supports a finding of one or more violations.

Although the F-1 report was submitted late, the report was not required to disclose any business, lobbying or income pertaining to the City of Burien as Ms. Moore did not take office until January 2020 and the late F-1 report covered activity during calendar year 2019. In addition, the report contained little change from the one Ms. Moore submitted as a candidate in the 2019 election.

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 Ms. Moore about the importance of timely filing a Personal Financial Affairs Statement with the PDC no later than April 15th each year as an elected official, and the timely filing of all future PDC F-1 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/73338
73030 07/08/2020 Glen Morgan Heidi Eisenhour Eisenhour, Heidi: Alleged Violation of RCW 42.17A.240 for failure to accurately disclose expenditures on reports (EY 20, July 20) RCW 42.17A.240, WAC 390-16-037 Case Closed with Reminder

On July 7, 2020, the Public Disclosure Commission (PDC) received a complaint alleging that Heidi Eisenhour violated RCW 42.17A.240 for failure to properly break down and describe expenditure details, as required in WAC 390-16-047 and WAC 390-16-205. 

Staff reviewed the allegation; the applicable statutes, rules, and the reporting requirements, including the May 2020 Summary Campaign Contribution and Expenditure report (C-4 report) filed by the Committee to Elect Heidi Eisenhour. 

Staff found that the expenditures made by Ms. Einsenhour's campaign lacked the proper description(s) and break down required by law/rule. 

Based on these findings, the staff reminded Ms. Eisenhour about the importance of properly breaking down and describing expenditures in the future as required by law/rule.    

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

https://www.pdc.wa.gov/browse/cases/73030
73018 07/08/2020 Glen Morgan Washingtonians Win in the 19th PAC Sponsored by Maverick Gaming Washingtonians Win in the 19th: Alleged Violation of RCW 42.17A.235, .240 for failure to properly disclose expenditures on reports; RCW 42.17A.320 for failure to properly disclose required sponsor, disclaimer and party information (EY20, July20) WAC 390-18-020, WAC 390-18-025, RCW 42.17A.320, RCW 42.17A.235, RCW 42.17A.240 Case Closed with Written Warning

A complaint was filed alleging that Washingtonians Win in the 19th, a political committee registered and reporting with the PDC, violated RCW 42.17A by failing to accurately disclose expenditure details on Summary Full Campaign Contribution and Expenditure reports (C-4 reports), and provide the required sponsor identification information including independent expenditure language, top contributor information, and the party preference of the candidates featured in the advertisements.

Washingtonians Win – sponsored by Maverick Gaming is a continuing political committee that registered and reported in CY 2019 and 2020.  On March 1, 2020, Washingtonians Win in the 19th– sponsored by Maverick Gaming (WW19) filed a Registration disclosing that it was a Continuing Political Committee sponsored by Maverick Gaming and selecting the Full Reporting Option.  

In 2020, WW19 has received $190,000 in monetary contributions, plus an additional $1,500 for in-kind contributions received from Washingtonians Win – sponsored by Maverick Gaming.  In addition, WW19 disclosed receiving a total of $5,000 for in-kind contributions from Maverick Gaming for the costs associated with operating the political committee. 

WW 19 timely filed the monthly C-4 reports covering the period March 1 through May 31, 2020, as well as the 21-Day and 7-Day Pre-Primary C-4 reports disclosing $155,449 in itemized expenditures that included 24 expenditures to Levy Online totaling $107,219 for billboard production and independent advertising, creative design and management fees, and a $37,100 expenditure made to EMC Research for survey work. 

On June 22, 2020, WW19 filed an Independent Expenditure Report (C-6 report) checking box 2 as an Independent Expenditure of more than $1,000 and disclosing $23,528 for independent expenditures made in opposition to Representative Jim Walsh in the 19th Legislative District.  The independent expenditures included six expenditures that were all made on March 10, 2020 to Levy Online for Billboard Media for $8,568, $8,175, and $2,385, and Billboard Production and Installation for $1,450 listed three times.  The C-6 report disclosed that the billboards were presented to the public on May 25, June 1, and June 22, 2020.

The Committee stated the first billboards for WW19 went up on April 27, 2020, but did not support or oppose any candidate or even contain a message about any candidates, instead the billboards content only included information about coronavirus safety reminders.  The first billboards to present a message regarding Rep. Walsh did not go up until June 1, 2020.

The Committee acknowledged the sponsor identification on the billboards failed to include the phrase “No candidate paid for this ad,” in addition to the top 5 and top 3 contributor information, and that the billboards have been corrected.  The Committee stated Maverick Gaming was the only contributor required to have been listed in the disclaimer, and added WW19 “was not hiding the identity of its contributors, and there could be no confusion on the part of the public about who paid for the ad.”  The Committee also acknowledged that billboards initially failed to identify Representative Walsh’s party preference, but the billboards have been corrected to properly identify Representative Walsh’s party preference as “Republican.” 

Pursuant to WAC 390-37-060(1)(d), the PDC issued a formal written warning to Washingtonians Win in the 19th, and Maverick Gaming, concerning the requirement to provide the party preference for any partisan candidates, along with the Notice to Voter and Top contributor language, on all independent expenditures, and electioneering communications undertaken for the remainder of the 2020 election.  Washingtonians Win in the 19th, and Maverick Gaming will be advised that the Commission will consider this formal written warning in deciding on further Commission action, should there be future violations of PDC laws or rules.

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

https://www.pdc.wa.gov/browse/cases/73018
73017 07/08/2020 John Harland Trumbo; and Lillian "Randy" Slovic Sharon Raye Brown: Brown, Sharon Raye: Alleged violations of RCW 42.17A.710 for failure to fully report assets and debt on Personal Statement of Financial Affairs for reporting years 2015-2019. (Jul 20) RCW 42.17A.710 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaints filed by John Trumbo on July 2, 2020 and by Lillian “Randy” Slovic on July 15, 2020. As both complaints alleged violations of RCW 42.17A.710, PDC staff combined the complaints and investigated the allegations under PDC Case 73017. The complaints alleged that Sharon Raye Brown, a Senator in Legislative District 8, may have violated: (1) RCW 42.17A.710 for failure to fully report assets on Personal Statement of Financial Affairs (F-1 reports) for calendar years 2015 to 2019; and (2) RCW 42.17A.710 for failure to report debt on F-1 reports for calendar years 2015 to 2018.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response(s) provided by Mark Lamb, Attorney with The North Creek Law Firm on behalf of Sharon Raye Brown (the “Respondent”); the applicable PDC reports filed by the Respondent; and the Order issued by the Commission granting the Respondent’s request for a retroactive reporting modification, to determine whether the record supports a finding of one or more violations.

During the review of Ms. Slovic’s complaint, staff referred to the requirements in RCW 42.17A.710(1)(c), the definition of the term “debt” in WAC 390-24-110, and the response provided by the Respondent. Based on this review. staff did not find that Sen. Brown was required to disclose the debt on her previously submitted F-1 reports.

Although Sen. Brown was required to either include reportable financial interests of her former spouse’s business or timely request a modification to these reporting requirements, the Commission granted her retroactive reporting modification request, therefore relieving her of the obligation of full disclosure under chapter 42.17A RCW.

Based on our findings staff has determined that, in this instance, failure to accurately file F-1 report covering calendar years 2015, 2016 and 2017 or timely submit a request to modify the required filing obligations, does not amount to a finding of a violation that warrants further investigation.

PDC staff reminded Sen. Brown about the importance of the timely and complete disclosure of all personal financial information and the timely filings of all future PDC F-1 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/73017
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 20; July 20) RCW 42.17A.235, RCW 42.17A.700, RCW 42.17A.710, 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 Omari Tahir-Garrett on September 28, 2020, a brief adjudicative proceeding was held on October 21, 2020, remotely from Olympia, WA by live audio and online transmission, 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 2020 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 2020 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 June 1, 2020. 

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.

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

FINDINGS OF FACT 

1. The Respondent is a candidate for Washington State Governor.  
2. As a gubernatorial candidate appearing on the August 4, 2020 primary election ballot, the Respondent was required to file the C-1 report and F-1 report, within two weeks of declaring candidacy or no later than June 1, 2020. 
3. The Respondent did not file the missing C-1 or F-1 reports 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.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 June 1, 2020. 

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, with $300 of the penalty suspended, in accordance with the C-1 and F-1 report 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 $200 non-suspended portion of the civil penalty within 30 days of the date of this Order. 
2. File the missing C-1 and F-1 reports within 30 days of the date of this Order.  
3. Commit no further violations of Chapter 42.17A RCW or Title 390 WAC, for a period of 4 years from the date of this order, or the suspended $300 will become payable. 
 

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) RCW 42.17A.240, WAC 390-16-105 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on June 30, 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.240 and WAC 390-16-115 failure to collect and maintain contributor information.

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.

Mr. Mahre’s response confirmed that his campaign has a process for obtaining all required contact information from donors who utilize the donate option on his campaign website. In addition, the evidence shows that the Mahre Campaign had the required information from your $25.01 online donation within two days of you making the contribution. Staff noted that the complainant, Norm Smith, sent supplemental information to the PDC regarding your complaint against Mr. Mahre in which he stated “[g]oing forward, I have no doubt that Mr. Mahre will diligently attempt to comply with all PDC Regulations.  Please take that into consideration that [sic] making your determination.”

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/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 Case Closed with No Evidence of Violations

The complaint alleged Krystal Marx, a 2021 candidate for Burien City Council, may have violated RCWs 42.17A.235 and .240 by failing to timely and completely disclose contributions and expenditures on Monetary Contributions (C-3) reports and Summary Full Campaign Contribution and Expenditure (C-4) reports and RCW 42.17A.555 by using public resources to promote a political campaign, specifically using her city-sponsored e-mail address on a Financial Affairs Statement (F-1). 

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/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 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on June 19, 2020. The complaint alleged that John Lovick, incumbent State Representative in Legislative District 44 and candidate for re-election in the 2020 primary election, may have violated PDC statute RCW 42.17A.555 or legislative ethics statute RCW 42.52.180 by collaborating with Everett Public Schools in sharing a virtual event originating on Representative Lovick’s 2020 Campaign Facebook page.

PDC staff reviewed the allegations; the applicable statutes and rules; the response provided by Rep. Lovick; and the response provided by Everett Public Schools in related PDC Case 72467, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, as concerns the Lovick 2020 
Campaign, 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/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 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on June 19, 2020. The complaint alleged that Everett Public Schools, a public school district in Snohomish County serving the cities of Everett, Bothell and Mill Creek, may have violated RCW 42.17A.555 by misusing the district’s official Facebook page to share a virtual event originating on Representative John Lovick’s 2020 Campaign Facebook page.

PDC staff reviewed the allegations; the applicable statutes and rules; PDC Interpretation 01-03; the response provided by Sarah S. Mack, General Counsel for Everett Public Schools (the “Respondent”); and the response provided by Representative John Lovick in related PDC Case 72472, to determine whether the record supports a finding of one or more violations.

Staff’s review of the Respondent’s written response shows that they have a general understanding of RCW 42.17A.555 and PDC Interpretation 01-03, Guidelines for School Districts in Election Campaigns and acted in a good faith manner they believed to be permissible as well as consistent with similar activities. However, staff noted that the district was aware that the virtual invitation included a web address for Rep. Lovick’s 2020 Re-election Campaign but did not flag this as problematic.

Based on our findings staff has determined that, in this instance, the act of the Respondent sharing a post from a current legislator’s Facebook page despite the fact that the invitation language included a campaign web address, does not amount to a violation that warrants further investigation.

PDC staff reminded Everett Public Schools about the importance of following the prohibitions described in RCW 42.17A.555 and PDC Interpretation 01-03 closely and to review all future events shared on the district’s official Facebook page with more scrutiny to ensure that they are free of any campaign related language. 

Based on 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/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 Case Closed with No Evidence of Violations

The complaint alleged may have violated RCW 42.17A.555 by misusing public facilities, specifically wearing a city council pin in political advertising. 

Alvarez stated the pins do not identify him as a city council member and added “Anyone who wants one can get one if they ask, and that is probably how the person who gave me one got theirs.” 

Based on this information, the PDC finds 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/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) RCW 42.17A.240, WAC 390-16-115 Case Closed with No Evidence of Violations

On June 22, 2020, the Public Disclosure Commission (PDC) received a complaint from Norm Smith alleging that Mr. Beach failed to maintain contributor address records in violation of RCW 42.17A.240 and WAC 390-16-115. 

PDC staff reviewed the allegation listed in the complaint in the complaint to determine whether a formal investigation or enforcement action is warranted. Staff reviewed all attachments submitted with the complaint, the statute, rule, and the July 6, 2020, and July 22, 2020 responses from Mr. Beach and attorney Martin Rowland on behalf of Mr. Beach, respectively. 

Staff found no evidence to support a finding of a violation warranting further investigation or enforcement action and dismissed the matter in accordance with RCW 42.17A.755(1). 

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.235, RCW 42.17A.240, RCW 42.17A.555 Case Closed with Reminder

On June 16, 2020, the Public Disclosure Commission received a complaint alleging that Sarah Blossom violated RCW 42.17A.235 and .240 for failure to timely and accurately report contributions and expenditures, and RCW 42.17A.555 for using public facilities to assist an election campaign in the 2019 election year. 

Staff reviewed the allegation listed in the complaint to determine whether a formal investigation or enforcement action is warranted. Staff reviewed all attachments submitted with the complaint, the statutes, rules, and PDC Interpretation 04-02 "Guidelines for Local Government Agencies in Election Campaigns," and the July 6, 2020, response from Ms. Blossom. 

Staff found Ms. Blossom failed to report a $250 contribution she received prior to amending her C-1 report. Ms. Blosson did not formally file an amended C-1 report until June 25, 2020. Staff reminded Ms. Blossom about the importance of timely amending the Candidate Registration (C-1) report in the future so that the public has access to the most current C-1 report on file with the PDC. 

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

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.235, RCW 42.17A.240 Case Closed with Written Warning

On June 12, 2020, the Public Disclosure Commission (PDC) received a complaint alleging that John Ley may have violated RCW 42.17A.235 for failure to timely and accurately report contribution and expenditure reports and RCW 42.17A.240 for failure to properly break down and describe expenditure details, as required in WAC 390-16-047 and WAC 390-16-205. 

Staff reviewed the allegation; the applicable statutes, rules, and the reporting requirements, including the Contribution (C-3) and Summary Campaign Contribution and Expenditure report (C-4 report) filed by the Friends to Elect John Ley, and the June 28, 2020, and August 6, 2020, responses to the complaints provided by John Ley on behalf of his Campaign.   

Staff found that Mr. Ley did not timely and accurately report contributions and expenditures made by his campaign. His expenditures also lacked the proper description(s) and break down required by law/rule. 

Based on these findings, the staff issue a formal written warning to Mr. Ley regarding the failure to timely and accurately reports C-3 and C-4 reports and failure to properly break down and describe expenditure details, as required in WAC 390-16-047 and WAC 390-16-205. 

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

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 Case Closed with Reminder

The complaint alleged Daniel P. Evans, a 2020 candidate for Island County Commissioner, position 2, may have violated RCW 42.17A.320 by failing to identify a party preference on political advertising, specifically political signs. 

Based on its findings, and the fact Evans is a first-time candidate, the political signs were purchased by the Campaign with no apparent intent to conceal party preference, and the expenditures for signs were reported timely and accurately on publicly-available PDC reports, staff has determined that, in this instance, the failure to include party identification does not amount a violation warranting further investigation.

PDC staff is reminding Daniel P. Evans about the importance of identifying the party preference on all 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/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.700, RCW 42.17A.205, 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 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on May 28, 2020. The complaint alleged that Robert J. Thompson, a current City Council Member for the City of Richland, Position 1, may have violated RCW 42.17A.710 for failure to accurately file the Personal Financial Affairs Statement (F-1 report) covering calendar year 2019 by not including all sources of income.

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

Although Mr. Thompson was the subject of a previous complaint filed with the PDC, the complaint was not related to the submission of the F-1 report. In addition, during a review of his F-1 report filing history, staff found that Mr. Thompson appears to have a good understanding of the F-1 filing requirements.

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

PDC staff is reminding Mr. Thompson about the importance of the timely and accurate disclosure of all sources of income on F-1 reports, and the timely and accurate filing of all future F-1 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/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 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on May 28, 2020. The complaint alleged that Terry Christensen, a current City Council Member for the City of Richland, Position 6, may have violated RCW 42.17A.710 for failure to accurately file the Personal Financial Affairs Statement (F-1 report) covering calendar year 2019 by not including all sources of income.

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

The Respondent has not previously been found in violation of PDC laws or rules and responded promptly to the complaint.

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

PDC staff reminded Mr. Christensen about the importance of the timely and accurate disclosure of all sources of income on F-1 reports, and the timely and accurate filing of all future F-1 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/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) WAC 390-18-020, RCW 42.17A.320 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 Case Closed with Written Warning

A complaint was filed against Matt Shea, an incumbent Washington State Representative in the 4th Legislative District and a candidate seeking re-election to that office in 2020, alleging violations of RCW 42.17A.445 by making a personal prohibited expenditure using campaign funds.

On May 11, 2020, the 2020 Matt Shea for State Representative Campaign (Campaign) filed the April 2020 C-4 report disclosing contribution and expenditure information undertaken during the month, that included a $65.32 expenditure made to Matt Shea on April 11, 2020 and listing the description as a reimbursement for “home goods security curtain

PDC staff's review found that Representative Shea made a decision to not seek re-election, and is no longer a candidate for State Representative in 2020.  In addition, the $65.32 expenditure made to Matt Shea reimbursing him for the purchase of a “security curtain” was a very small expenditure of campaign funds, both in the amount of the expenditure and concerning the percentage of the $65.32 reimbursement to the overall campaign expenditures made.

Based on these facts, staff found that the expenditure identified in your complaint would not constitute a material violation that would require conducting a more formal investigation into the complaint or pursuing enforcement action in this instance.  Pursuant to WAC 390-37-060(1)(d), the PDC is issuing a formal written warning to the Matt Shea Campaign concerning the prohibition of making expenditures using campaign funds that may also have a personal use component, would likely constitute a violation.  Representative Shea will be advised that the Commission will consider this formal written warning in deciding on further Commission action, should there be future violations of PDC laws or rules.

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

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 24.17A.205, RCW 42.17A.405, 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 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 Case Closed with Written Warning
  • 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.240, RCW 42.17A.235 Case Closed with No Evidence of Violations

The PDC received a complaint alleging that Retired Firefighters of Washington (the “Respondent”) may have violated RCW 42.17A.205 by failing to timely register as a political committee, and RCW 42.17A.235 & .240 by not reporting contribution and expenditure activities undertaken in calendar years 2015-2020 on C-3 & C-4 reports. 

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

According to PDC Interpretation 07-02, Primary Purpose Test Guidelines, an entity becomes a political committee if they become a “receiver of contributions” to support or oppose candidates or ballot propositions, or if spending funds to support or oppose candidates or ballot propositions become one of its primary purposes. Under the “maker of expenditures” prong, an organization may be required to register as a political committee if one of its primary purposes includes political campaign activity, but an organization would not be required to register solely because one of its primary purposes was to attempt to influence state or local legislation (lobbying).

PDC staff found that the Respondent’s primary purpose is not to make contributions, but rather to keep its members informed about legislative activities that would impact their retirement benefits and pensions. The Respondent indicated that it receives its funding from 1) membership dues and 2) unsolicited voluntary donations from members, which are held in separate accounts. The membership dues are primarily used for educational and member outreach purposes. Members’ voluntary donations are used to finance lobbying activities and make a relatively small amount of contributions to candidates. PDC records indicate that the Respondent spends between 10-20% of its money on lobbying, as well as member communication and other issues. The majority of the Respondent’s activities do not appear to involve making contributions to candidates for public office or electoral political activity. The portion of overall spending attributed to lobbying and candidate contributions is relatively small. 

While the Respondent did make expenditures in the form of monetary contributions to candidates, the above findings suggest that it did not meet the primary purpose test and the activity was insufficient to trigger the registration requirements as a political committee. PDC staff determined that, in this instance, failure to register and report as a political committee does not amount to a violation that warrants further investigation and dismissed this matter in accordance with RCW 42.17A.755(1). 

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.240, WAC 390-16-034, RCW 42.17A.235, RCW 42.17A.145 Case Closed with Reminder

The complaint alleged Joshua Freed, a 2020 candidate for Governor, may have violatedRCW 42.17A.145, .235 and .240 by failing to timely and accurately report expenditure detail, and failing to have both the candidate and treasurer certify reports as complete and also may have violated WAC 390-16-034 by failing to disclose contributor employer and occupation for contributions over $100.

In response to the complaint, the Campaign amended the Monetary Contributions (C-3) reports and Summary Full Campaign Contribution and Expenditure (C-4) reports noted in the complaint. During its investigation, PDC staff noted missing expenditure detail on C-4 reports, and the campaign amended additional reports, adding required details.

Staff has determined in this instance the failure to timely and accurately report expenditure detail, and have both the candidate and treasurer certify reports as complete and failing to disclose contributor employer and occupation for contributions over $100 does not amount a violation warranting further investigation.

PDC staff is reminding about the importance of filing timely, accurate and complete 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/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 Violation Found by Commission

At its September 24, 2020 meeting, the Commission found Joshua Freed in violation of RCW 42.17A.145, RCW 42.17A.235(9), RCW 42.17A.235, RCW 42.17A.240, RCW 42.17A.445 and WAC 390-16-226(1) and assessed a total civil penalty of $50,000 of which $25,000 is suspended on the following conditions: (1) The Respondent is not found to have committed any further violations of Chapter 42.17A RCW or Title 390 WAC within four years of the date of this Final Order. 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 Respondent remains in full compliance with all PDC reporting requirements and; (3) The non-suspended portion of the penalty ($25,000) is paid by the Respondent within 30 days of the date of this Final Order.

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 Case Closed with Written Warning
  • 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
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
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 Resolved through Deferred Enforcement
  • 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.640, RCW 42.17A.240, RCW 42.17A.205 Case Closed with Written Warning

On February 11, 2020, the Public Disclosure Commission (PDC) received a complaint alleging that the Tax Amazon 2020 may have violated RCW 42.17A.205 for failure to timely file a Committee Registration (C-1pc) and RCW 42.17A.235 for failure to file timely C-3 and C-4 reports.    

Staff reviewed the applicable statute(s), rule(s), and the reporting requirements, including the response submitted by the Committee.   

Staff found that the Committee failed to timely register and report contributions and expenditures report in a timely manner, as required by law.   

Based on these findings, the staff formally warned the Committee for failure to register and file statutory contributions and expenditure reports timely.     

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

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.320, RCW 42.17A.260, RCW 42.17A.255 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.235, RCW 42.17A.240 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
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.210, RCW 42.17A.240, RCW 42.17A.235, RCW 42.17A.205, RCW 42.17A.225, RCW 42.17A.215 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.255, RCW 42.17A.320 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 Resolved through Statement of Understanding

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on December 30, 2019. The complaint alleged that 34th Legislative District Democrats, a bona fide legislative district party 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) during calendar year 2019.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements;  the applicable PDC reports filed by Kelly Skahan on behalf of her client; 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 July 16, 2020, the PDC received a completed Statement of Understanding (SOU) that was signed by Benjamin M. Reilly, Committee Treasurer. 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 34th Legislative District Democrats for failing to timely file C-3 and C-4 reports during calendar year 2019.

Based on the resolution of this matter through an SOU, PDC staff is dismissing this matter in accordance with WAC 390-37-070.

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 390-16-037, WAC 390-16-034 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 initial hearing, on 2/20/20, pursuant to RCW 42.17.755 and WACs 390-37-060 and  390-37-071.

On May 19, 2020, the staff issued a warning letter after our investigation found that Mr. Searls failed to timely file a C-1 report for the 2019  election. Mr. Searls filed a C-1 report for 2019 on May 8, 2020. \

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/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

The PDC received a complaint alleging that Dan Chaplik (the “Respondent”), the Superintendent of Sultan School District (the “District”), may have violated RCW 42.17A.555 by using public office or agency facilities (e.g. the school district’s Facebook page) to assist an election campaign for write-in candidate Heidi Dawson. 

PDC staff reviewed the allegations and evidence; the applicable statutes and rules; and the response provided by the Respondent to determine whether they support a finding of one or more violations. Staff’s review found the following:

As the District’s superintendent, the Respondent is subject to .555, which prohibits elected officials and employees of public offices and agencies from directly or indirectly using or authorizing the use of public facilities to assist an election campaign. Activities that are “part of the normal and regular conduct of the office or agency” are exempted from this prohibition.

Following some comments made by School Board Director, Ed Husmann – who was also a candidate for re-election in the 2019 General Election – at an October 28, 2019 board meeting, the Respondent distributed a statement to District parents, students and community members on November 1, 2019 stating that “comments made by a Sultan School District Board Director…do not reflect the Sultan School District’s Mission, Vision, Goals and Guiding Beliefs for and about our students.” The school board member was not mentioned by name in the statement – which was distributed via the District’s Facebook page and website – nor did it contain any references to the upcoming election or any participating candidates. 

Ed Husmann (the “Complainant”) stated his belief that the small community of Sultan would know to whom the Respondent referred, despite not being named in the statement, which he believes was politically motivated, “influenced voters,” and assisted the election campaign of his opponent, Heidi Dawson, who filed as a write-in candidate the same day the Respondent’s statement was released to the public.

The Respondent denied attempting to influence the General Election and said his November 1, 2019 statement was made in direct response to “intense negative press coverage and public reaction” following the Complainant’s October 28, 2019 comments. He also stated that communicating with the Sultan community regarding the District’s programs and policies and responding to press coverage were part of his job. The District and the Respondent routinely share information with parents, students and community members by posting messages via the District’s website and Facebook page. 

The evidence provided fails to conclusively show how the Respondent’s statement, which did not mention candidates or the upcoming election, assisted an election campaign. Furthermore, absent any evidence to the contrary, the statement made by the Respondent appears to constitute normal & regular conduct for the District and would therefore be exempt from the prohibition on use of facilities set forth in .555. 

Based on these findings, staff determined that, in this instance, no evidence supports a finding of a violation that warrants further investigation. The PDC dismissed this matter in accordance with RCW 42.17A.755(1). 

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.555, RCW 42.17A.495 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.255, 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 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.240, RCW 42.17A.235 Case Closed with Written Warning

The PDC received a complaint alleging that Peter Swant (the “Respondent”) may have violated RCW 42.17A.205 by failing to timely register as a candidate within two weeks of declaring candidacy, and RCW 42.17A.235 & .240 by failing to disclosing expenditure activities undertaken by the campaign on C-4 reports and sufficiently describe expenditures and in-kind contributions on C-4 reports. 

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

PDC staff found that the Respondent filed a Candidate Registration (C-1 report) with the PDC 20 days late and selected the Full Reporting Option, which triggers the periodic disclosure of contributions and expenditures on C-3 & C-4 reports. Between late May and December 10, 2019, six of the Respondent’s C-4 reports were received between 3-180 days late, two of which lacked details regarding in-kind contributions for yard signs and Facebook advertising.

The Respondent quickly replied to the complaint, stated his belief that his reports were both timely and accurate, and cited technical difficulties filing PDC reports. He indicated a willingness to amend reports to resolve noncompliance and subsequently filed eight amended reports disclosing his candidate filing fee (which was paid with personal funds), expenditures made for banners and consulting services, and additional details regarding in-kind contributions. The amended reports were received 24-159 days late.

Based on the aggravating and mitigating factors in this case, PDC staff issued the Respondent a formal written Warning concerning his failure to timely register as a candidate and timely & accurately report expenditures & in-kind contributions. PDC staff expect the Respondent to file all required contribution & expenditure reports in the future, and the Commission will consider the formal written Warning when deciding on further Commission action if there are future violations of PDC laws or rules. 

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/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 42.17A.255, RCW 42.17A.305, RCW 42.17A.260, RCW 24.17A.235 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.235, RCW 42.17A.320, RCW 42.17A.240, RCW 42.17A.205 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.235, RCW 42.17A.240, RCW 42.17A.205 Case Closed with Written Warning

The PDC received a complaint alleging that Andrew Hooper (the “Respondent”) may have violated RCW 42.17A.205, .235 & .240 by failing to timely register as a candidate within two weeks of declaring candidacy & timely disclose contributions and expenditures undertaken by the campaign on C-3 & C-4 reports.

PDC staff reviewed the allegations and evidence provided; the applicable statutes, rules and reporting requirements; the response provided by the Respondent; and the Respondent’s reporting history to determine whether they support a finding of one or more violations. Staff’s review found the following:

The Respondent declared candidacy with Elections officials on May 14, 2019 and was due to file a Candidate Registration (C-1 report) with the PDC no later than May 29, 2019. The Respondent filed a C-1 report on December 10, 2019, after the general election and 195 days late. 

On his C-1, the Respondent selected the mini-reporting option whereby a candidate’s campaign is not required to file C-3 & C-4 reports with the PDC if they raise & spend no more than $5,000 and receive no more than $500 from any one contributor. 

The Respondent indicated his failure to timely file a Candidate Registration was based on a misunderstanding that he was not required to file a C-1 report if his campaign did not receive any contributions. 

Based on these findings, staff determined that, in this instance, the Respondent’s failure to timely register as a candidate does not amount to a violation that warrants further investigation. However, the PDC issued the Respondent a formal written Warning, including PDC staff's expectation that the Respondent will timely register as a candidate 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. The PDC has dismissed this matter in accordance with RCW 42.17A.755(1). 

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.210, RCW 42.17A.205, RCW 42.17A.215 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.235, RCW 42.17A.240 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.210, RCW 42.17A.700, 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.255, RCW 42.17A.305, RCW 42.17A.260 Case Closed with Reminder

The PDC received a complaint alleging that North Snohomish County Union Firefighters Local 4033 (the “Respondent”) may have violated RCW 42.17A.255, .260 or .305 by failing to timely & accurately report, and provide sufficient expenditure details for, independent expenditures supporting candidate Jeff Sinker (campaign mailers and postage).

PDC staff reviewed the allegations; the applicable statutes, rules and reporting requirements; the response provided by the Respondent; and the Respondent’s reporting history to determine whether they support a finding of one or more violations. Staff’s review found the following:

In mid-October of 2019, the Respondent made two independent expenditures to Woodinville Print totaling $2,907 for a postcard mailer that supported candidate Jeff Sinker and related postage. The postcard mailer was first presented to the public on October 17, 2019, within 19 days of an election. Due to its proximity to the election, the postcard expenditures were due to be reported to the PDC within 24 hours or by October 18, 2019. 

The Respondent reported the independent expenditure for postage on a C-6 report filed October 26, 2019, which was eight (8) days late; the postage was described as a “print shop” expenditure on the C-6 report. Upon being notified that the expenditure for the postcard mailer had not been reported and the postage expenditure needed further description, the Respondent amended its C-6 report within five days, making the reporting of the mailer 33 days late. Noncompliance appeared to be the result of a good-faith omission. 

Based on these findings, staff determined that, in this instance, the Respondent’s failure to timely & accurately report and sufficiently describe independent expenditures does not amount to a violation that warrants further investigation. However, the PDC reminded the Respondent about the importance of timely & accurately reporting independent expenditures and providing detailed expenditure descriptions on reports. The PDC has dismissed this matter in accordance with RCW 42.17A.755(1). 

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.235, RCW 42.17A.240 Case Closed with Written Warning

The PDC received a complaint alleging that Bob Thompson (the “Respondent”) may have violated RCW 42.17A.235 & .240 by failing to timely & accurately disclose 2019 contributions and expenditures undertaken by the campaign on C-3 & C-4 reports.

PDC staff reviewed the allegations and evidence provided; the applicable statutes, rules and reporting requirements; the response provided by the Respondent; and the Respondent’s reporting history to determine whether they support a finding of one or more violations. Staff’s review found the following:

On the Candidate Registration (C-1 report) the Respondent filed with the PDC, he selected the Full Reporting option, obligating the campaign to file periodic C-3 & C-4 reports based on the election cycle. 

Upon being notified of this complaint, the Respondent indicated his erroneous belief that he had selected the Mini-Reporting option on his C-1 report. If selected, the Mini-Reporting option relieves a candidate’s campaign of the need to file C-3 & C-4 reports with the PDC if they raise & spend no more than $5,000 and receive no more than $500 from any one contributor. The Respondent indicated noncompliance was due to the retirement of his long-time legal assistant, who managed election campaign reporting. The new assistant was not fully aware of the reporting requirements for the Respondent’s campaign.

The Respondent filed a total of six C-4 reports, which were received after the election and 31-122 days late, and were later amended to include additional expenditure and in-kind contribution details.

Based on these findings, staff determined that, in this instance, the Respondent’s failure to timely file C-4 reports does not amount to a violation that warrants further investigation. However, the PDC issued the Respondent a formal written Warning, including PDC staff's expectation that the Respondent will timely file all required reports 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. The PDC has dismissed this matter in accordance with RCW 42.17A.755(1). 

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.205, RCW 24.17A.235 Case Closed with Written Warning

The PDC received a complaint alleging that Melissa Smith (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 disclose contributions and expenditures undertaken by the campaign on C-3 & C-4 reports for election year 2019.

PDC staff reviewed the allegations and evidence provided; the applicable statutes, rules and reporting requirements; the response provided by the Respondent; and the Respondent’s reporting history to determine whether they support a finding of one or more violations. Staff’s review found the following:

The Respondent publicly declared as a (write-in) candidate on or about October 9, 2019 and was therefore required to file a Candidate Registration (C-1 report) with the PDC within two weeks, or no later than October 23, 2019. The Respondent successfully filed a C-1 report with the PDC on December 13, 2019, after the election and 51 days late.

On her C-1 report, the Respondent selected the Mini-reporting Option, whereby a candidate’s campaign is not required to file C-3 & C-4 reports with the PDC if they raise & spend no more than $5,000 and receive no more than $500 from any one contributor. 

In her response to the complaint, the Respondent indicated that a medical procedure & subsequent recovery contributed to noncompliance. 

Based on these findings, staff determined that, in this instance, the Respondent’s failure to timely register as a candidate does not amount to a violation that warrants further investigation. However, the PDC issued the Respondent a formal written Warning, including PDC staff's expectation that the Respondent will timely file all required reports 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. The PDC has dismissed this matter in accordance with RCW 42.17A.755(1). 

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 24.17A.205, RCW 42.17A.700, RCW 24.17A.235 Case Closed with Reminder

The PDC received a complaint alleging that Tim Larson (the “Respondent”) may have violated RCW 42.17A.205, .235 & .700 by failing to timely register as a candidate and file a statement of financial affairs within two weeks of becoming a candidate, and timely report contributions & expenditures on C-3 & C-4 reports.

PDC staff reviewed the allegations; the applicable statutes, rules and reporting requirements; the responses provided by the Respondent; and the Respondent’s reporting history to determine whether they support a finding of one or more violations. Staff’s review found the following:

The Respondent is a first-time candidate who filed with Elections on May 14, 2019 and was therefore required to file a Candidate Registration (C-1 report) and Personal Financial Affairs Statement (F-1 report) with the PDC within two weeks, or no later than May 28, 2019. The Respondent filed a C-1 and F-1 report with the PDC on December 10, 2019, which is 196 days late. 

On his C-1 report, the Respondent selected the Mini-reporting Option, whereby a candidate’s campaign is not required to file C-3 & C-4 reports with the PDC if they raise & spend no more than $5,000 and receive no more than $500 from any one contributor. 

In his response to the complaint, the Respondent indicated he withdrew from the election because he moved out of the district. He reached out the Chelan County Auditor’s Office and was assured his name would not appear on the ballot. Based on this conversation, the Respondent thought he had ceased being a candidate and did not raise or spend any money on his campaign. The Respondent later learned that his name did appear on the ballot and he had won the election. However, due to his move out of the district, the Respondent formally declined to accept the position.

Based on these findings, staff determined that, in this instance, the Respondent’s failure to timely register as a candidate and file a statement of financial affairs does not amount to a violation that warrants further investigation. However, the PDC reminded the Respondent about the importance of timely filing all future PDC reports. The PDC has dismissed this matter in accordance with RCW 42.17A.755(1). 

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.235, RCW 42.17A.320, 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.205, RCW 42.17A.215, RCW 42.17A.700, RCW 42.17A.210 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.235, RCW 42.17A.240 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) WAC 390-16-037, RCW 42.17A.240 Case Closed with Reminder

The PDC received a complaint alleging that Yes for Homes Coalition of San Juan County (the “Respondent”) may have violated RCW 42.17A.240 and WAC 390-16-037 by failing to provide sufficient expenditure details on C-4 reports during election year 2018. PDC staff reviewed the allegations; the applicable statutes, rules and reporting requirements; the response provided by the Respondent; and the Respondent’s reporting history to determine whether they support a finding of one or more violations. 

Staff’s review found the following:

RCW 42.17A.240(6) requires committees to report the name & address of each person to whom an expenditure is made in the aggregate amount of more than $50 during the period covered by the report, including the amount, date and purpose of each expenditure. Pursuant to WAC 390-16-037, expenditures disclosed on the C-4 report should be described “in detail,” including how the recipient of the expenditure (e.g. vendor) will use the goods and/or services purchased, and numerical descriptions (e.g. the number of items printed). WAC 390-16-205 further requires each committee to report any expenditures, paid to a sub-vendor or other third party, by a vendor it employs or retains. 

The Respondent filed five C-4 reports in 2018 that appeared to lack sub-vendor breakdowns and/or expenditure details regarding signs, digital ads, printing, mailer, and advertising. The Respondent amended five C-4 reports from 2018 to include the missing information on December 11 and 13, 2019.

Based on these findings, staff determined that, in this instance, the Respondent’s failure to report sub-vendor breakdowns and complete expenditure descriptions on C-4 reports does not amount to a violation that warrants further investigation. However, the PDC reminded the Respondent about the importance of providing sub-vendor breakdowns and detailed expenditure descriptions on C-4 reports. 

The Respondent made minor or ministerial errors on required reports, which did not materially impact the public interest. Upon being notified of the errors, the Respondent amended its reports, making the necessary technical corrections as requested by staff. The PDC has dismissed this matter in accordance with RCW 42.17A.755(1). 

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.210, RCW 42.17A.205, RCW 42.17A.215 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) WAC 390-05-210, RCW 42.17A.260, RCW 42.17A.255, RCW 42.17A.405, RCW 42.17A.240, RCW 42.17A.235, RCW 42.17A.305 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.240, RCW 42.17A.235 Case Closed with Written Warning

The PDC received a complaint alleging that NARAL Pro-Choice Washington (the “Respondent”) may have violated RCW 42.17A.235 & .240 by failing to timely & accurately disclose expenditures (e.g. contributions to candidates) made by the campaign during election year 2019 on C-4 reports. 

PDC staff reviewed the allegations; the applicable statutes, rules and reporting requirements; the response provided by the Respondent; and the Respondent’s reporting history to determine whether they support a finding of one or more violations. Staff’s review found the following:

During calendar year 2019, the Respondent substantially complied with C-3 reporting requirements but failed to timely file nine C-4 reports that were received between 2-107 days late, five of which were due immediately preceding or following the Primary and General Elections. The Respondent also amended seven C-4 reports and two C-3 reports. The late filed reports disclosed that the Respondent contributed a total of $1,600 to seven 2019 local candidates and made two $1,000 monetary contributions to the 2020 campaigns of Jay Inslee and Bob Ferguson respectively. 

The Respondent indicated the late reports were the result of the early 2019 resignation of its office manager and a lack of “trained staff to handle reporting.” The Respondent’s new office manager filed the required C-4 reports with the PDC, bringing it into compliance five days before the General Election and four days before being notified that a complaint had been filed with the PDC. 

Based on these findings, staff determined that, in this instance, the Respondent’s failure to timely & accurately disclose expenditures & contributions does not amount to a violation that warrants further investigation. However, the PDC issued the Respondent a formal written Warning concerning its failure to timely & accurately disclose expenditures & contributions. PDC staff expect the Respondent to timely & accurately file all required reports 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. The PDC has dismissed this matter in accordance with RCW 42.17A.755(1). 

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.235, RCW 42.17A.240, 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.235, RCW 42.17A.240 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.240, RCW 42.17A.350, 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.235, RCW 42.17A.240 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.205, RCW 42.17A.235 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 Case Closed with Reminder

The complaint alleged Partnering for Spokane's Future PAC (Committee) a 2018 election-year only committee formed to support Proposition No. 1, the City of Spokane Public Library General Obligation Bond measure, may have violated RCW 42.17A.240 by failing to timely and accurately report expenditure detail on Summary Full Campaign Contribution and Expenditure (C-4) reports.

Based on PDC findings, and the fact the Committee made good faith efforts to comply with the reporting requirements of RCW 42.17A.240 concerning expenditures undertaken by the campaign on their C-4 reports, the public was not deprived of critical information as the dates, amounts, and purposes of the expenditures were disclosed, staff has determined, in this instance, the failure to timely and accurately report expenditure detail does not amount a violation warranting further investigation. PDC staff is reminding Partnering for Spokane's Future PAC about the importance of filingtimely, accurate and complete 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/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) RCW 42.17A.240, WAC 390-16-037 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.

The PDC resolved this matter with a Statement of Understanding which received on April 16, 2020, along with a check of $300 for penalty payment. 

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

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 Resolved by Attorney General – Violation

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 Referred to Attorney General by Commission
  • 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. At the 8/27/2020 Commission meeting, the Commission referred this matter to the Attorney General for further action.
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.320, RCW 42.17A.430, RCW 42.17A.255 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

The PDC received a complaint alleging that Jeff Sinker (the “Respondent”) may have violated RCW 42.17A.235 & .240 by failing to timely & accurately report deposits, contributions & expenditures on C-3 & C-4 reports.

PDC staff reviewed the allegations and evidence provided; the applicable statutes, rules and reporting requirements; the response provided by the Respondent; and the Respondent’s reporting history to determine whether they support a finding of one or more violations. Staff’s review found the following:

The Respondent is a candidate for election who did not participate in the Primary Election. He registered as a candidate with the PDC on September 4, 2019 by filing a C-1 report and selected the Full Reporting Option, which triggers the requirement to file periodic C-3 & C-4 reports with the PDC based on the election cycle. 

Upon being notified of the complaint, the Respondent indicated that his campaign did not solicit or collect contributions but had received in-kind contributions, which he previously attempted to report. The Respondent indicated that technical issues with the online filing system had frustrated compliance. He quickly took corrective action to disclose campaign activity for September & October and worked with the PDC to amend minor or ministerial errors on previously submitted reports. 

Based on these findings, staff determined that, in this instance, the Respondent’s failure to timely & accurately file two C-4 reports does not amount to a violation that warrants further investigation. However, the PDC reminded the Respondent about the importance of timely disclosing all contribution & expenditure activity, including in-kind donations, and timely filing all future PDC reports. The PDC has dismissed this matter in accordance with RCW 42.17A.755(1). 

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.205, wac 390-16-011a, RCW 42.17A.240 Case Closed with Reminder

The PDC received a complaint alleging that Citizens for Lopez Solid Waste Levy (the “Respondent”) may have violated RCW 42.17A.205(5) and .240(11) by failing to include its sponsor’s name in the registered committee’s name on C-1PC and C-3 reports filed during election years 2016 and 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 they support a finding of one or more violations. 

Staff’s review found the following:

RCW 42.17A.205(5) and WAC 390-16-011A(1) require a sponsored committee to include the name of its sponsor “in the committee’s name” on the C-1PC (Committee Registration) form it files with the PDC. RCW 42.17A.005(46)(b)(i) defines a “sponsor” to include a source from which a committee receives 80% or more of its contributions. Contributions received in the previous twelve months should be considered to determine whether a contributor meets the definition of a committee sponsor.

The Respondent reported receiving $1,900 in contributions from Solid Waste Alternative Program (SWAP) during 2016, which represented 100% of the contributions received by the Respondent during the preceding twelve months. The Respondent also reported receiving $3,000 in contributions from SWAP in 2019, which represented 100% of the contributions received by the Respondent during the preceding twelve months.

SWAP’s name was omitted from the committee name the Respondent reported on its C-1PC reports for election years 2016 and 2019.

After being notified of the complaint, the Respondent made a good-faith effort to comply by amending its C-1PC reports for election years 2016 and 2019 within five days. On these amended reports, the committee’s name was changed to “Citizens for Lopez Solid Waste Levy sponsored by Solid Waste Alternative(s) Program (SWAP).” 

PDC laws and rules do not require a committee to retroactively amend its C-3 reports to reflect a registered name change.

Based on these findings, staff determined that, in this instance, failure to include the sponsor’s name in the committee’s registered name does not amount to a violation that warrants further investigation. PDC staff reminded the Respondent about the importance of including its sponsor in the committee name, when required. 

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 their reports, making the necessary technical corrections requested by PDC staff. 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/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.235, RCW 42.17A.240 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 390-16-037, wac 390-16-205, 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 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) RCW 42.17A.320, wac 390-16-011a, RCW 42.17A.205, 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 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) RCW 42.17A.205, RCW 42.17A.240, RCW 42.17A.320, WAC 390-16-037, wac 390-16-205, wac 390-16-011a 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.205, RCW 42.17A.320 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.205, wac 390-16-011a, RCW 42.17A.240 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

The PDC received a complaint alleging that Kelly Geiger (the “Respondent”) may have violated RCW 42.17A.240 by failing to provide sufficient expenditure details on C-4 reports during election year 2017. PDC staff reviewed the allegations; the applicable statutes, rules and reporting requirements; the response provided by the Respondent; and the Respondent’s reporting history to determine whether they support a finding of one or more violations. 

Staff’s review found the following:

RCW 42.17A.240(6) requires candidates to report the name & address of each person to whom an expenditure is made in the aggregate amount of more than $50 during the period covered by the report, including the amount, date and purpose of each expenditure. Pursuant to WAC 390-16-037, expenditures disclosed on the C-4 report should be described “in detail,” including how the recipient of the expenditure (e.g. vendor) will use the goods and/or services purchased, and numerical descriptions (e.g. the number of items printed). 

The Respondent filed four C-4 reports in 2017 that appeared to lack expenditure details regarding signs, political flyers, and handout/flyers. The Respondent amended the four C-4 reports to include the missing information on October 15, 2019.

Based on these findings, staff determined that, in this instance, the Respondent’s failure to provide complete expenditure descriptions on C-4 reports does not amount to a violation that warrants further investigation. However, the PDC reminded the Respondent about the importance of providing detailed expenditure descriptions on C-4 reports. 

The Respondent made minor or ministerial errors on required reports, which did not materially impact the public interest. Upon being notified of the errors, the Respondent quickly amended its reports, making the necessary technical corrections as requested by staff. The PDC has dismissed this matter in accordance with RCW 42.17A.755(1). 

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, WAC 390-16-037, RCW 42.17A.320, 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) RCW 42.17A.240, RCW 42.17A.220, 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 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.235, RCW 42.17A.205, RCW 42.17A.240, RCW 42.17A.320 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.420, 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 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.320, RCW 42.17A.555 Violation Found by Commission
  • 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.

The Public Disclosure Commission will hold an enforcement hearing on Thursday, July 23, 2020 at 10:15 am concerning allegations that Steve Hall, former City Manager for the City of Olympia, violated RCW 42.17A.555 by authorizing the use of City of Olympia resources to produce and distribute a mailer providing information about I-976.  A copy of the Report of Investigation with exhibits is attached below.

Concerning the allegations listed in the complaints against the City of Olympia Mayor Cheryl Selby, and all of the City Council members, PDC staff determined that in this instance, no evidence supports a finding of a violation of RCW 42.17A.555 or the taking of any enforcement action, and staff dismissed those allegations with a Reminder cover letter on July 22, 2020.  See attached complaint return letters below.  

A proposed Stipulation has been agreed to by the Respondent Steve Hall, and PDC staff and will be presented to the Commission at the enforcement hearing to be conducted at the July 23, 2020 Commission meeting.  The Stipulation (which is posted below) may be accepted, modified, or rejected by the Commission at the meeting today.

At the July 23, 2020 Commission meeting, the Commission accepted the proposed Stipulation and found that Steve Hall, former City of Olympia City Manager, violated RCW 42.17A.555 by authorizing the use of City of Olympia resources to produce and distribute a mailer that provided information about I-976, including encouraging recipients to "Vote No" in three separate areas of the mailer.  

The Commission further accepted the proposed penalty of $10,000 be assessed against Mr. Hall, with $5,000 of the penalty suspended on the condition that he commits no further violations of RCW 42.17A for a period of four years from the date of the Order, and the $5,000 non-suspended portion of the penalty is paid within 30 days. 

 

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.240, RCW 42.17A.430, RCW 42.17A.490, WAC 390-16-037, 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/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

The PDC received a complaint alleging that Steven. C Fox (the “Respondent”) may have violated RCW 42.17A.240 by failing to provide sufficient expenditure details on C-4 reports filed with the PDC. PDC staff reviewed the allegations; the applicable statutes, rules and reporting requirements; the response provided by the Respondent; and the Respondent’s reporting history to determine whether they support a finding of one or more violations. 

Staff’s review found the following:

RCW 42.17A.240(6) requires candidates to report the name & address of each person to whom an expenditure is made in the aggregate amount of more than $50 during the period covered by the report, including the amount, date and purpose of each expenditure. Pursuant to WAC 390-16-037, expenditures disclosed on the C-4 report should be described “in detail,” including how the recipient of the expenditure (e.g. vendor) will use the goods and/or services purchased, and numerical descriptions (e.g. the number of items printed). 

The Respondent filed two C-4 reports in 2019 that appeared to lack expenditure details regarding signs, mailings, and a reimbursed Visa card purchase. Upon being notified of the complaint, the Respondent immediately responded and indicated that he was unable to find a statutory requirement to report the number of signs purchased and had followed the PDC’s instructions for reporting an expenditure made with a personal credit card. The Respondent explained that his campaign had entered expenditure details into the ORCA filing system that, due to field length limitations, were truncated and did not appear on the reports that were publicly available on the PDC’s website.

The Respondent amended his C-4 reports on October 22, 2019 to include the number of signs and mailers purchased. The expenditure details for the credit card purchase were also updated, although a portion of the description still truncates due to ORCA field length limits. 

Based on these findings, staff determined that, in this instance, the Respondent’s failure to provide detailed expenditure descriptions on C-4 reports does not amount to a violation that warrants further investigation. 

The Respondent made minor or ministerial errors on required reports, which did not materially impact the public interest. Upon being notified of the errors, the Respondent timely amended his reports, making the necessary technical corrections requested by PDC staff. The PDC has dismissed this matter in accordance with RCW 42.17A.755(1). 

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) RCW 42.17A.205, RCW 42.17A.255, RCW 42.17A.260, RCW 42.17A.240, wac 390-16-205, wac 390-16-011a, RCW 42.17A.305 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.240, RCW 42.17A.235, 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
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.235, RCW 42.17A.240 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

The PDC received a complaint alleging that Peter Miller (the “Respondent”) may have violated RCW 42.17A.320 by failing to identify the sponsor on political advertising (e.g. billboard). PDC staff reviewed the allegations; the applicable statutes, rules and reporting requirements; and the response provided by the Respondent to determine whether they support a finding of one or more violations. 

Staff’s review found the following:

RCW 42.17A.320 requires political advertising to include the sponsor’s name and address.

During the 2019 election, the Respondent and fellow candidate Malia Hollowell co-sponsored advertising that appeared on a billboard in Maple Valley, Washington. The billboard did not include the names & addresses of the billboard’s sponsors.

The Respondent is a first-time candidate who said he was unaware of the sponsor identification requirements for political advertising. He indicated his erroneous belief that sponsor identification is not required for advertising that candidates pay for themselves. Upon being notified of the complaint on October 16, 2019, the Respondent immediately took steps to resolve non-compliance by contacting the billboard company the same day and instructing them to reprint the advertising. The revised billboard, including sponsor identification, was posted on October 25, 2019.

Based on these findings, staff determined that, in this instance, the Respondent’s failure to identify the sponsors of political advertising does not amount to a violation that warrants further investigation. PDC staff reminded the Respondent about the importance of identifying the sponsor’s name and address on political advertising, including billboards. The PDC finds that no further actions is warranted. and has dismissed this matter in accordance with RCW 42.17A.755(1).

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

The PDC received a complaint alleging that Malia Hollowell (the “Respondent”) may have violated RCW 42.17A.320 by failing to identify the sponsor on political advertising (e.g. billboard). PDC staff reviewed the allegations; the applicable statutes, rules and reporting requirements; and the response provided by the Respondent to determine whether they support a finding of one or more violations. 

Staff’s review found the following:

RCW 42.17A.320 requires political advertising to include the sponsor’s name and address.

During the 2019 election, the Respondent and fellow candidate Peter Miller co-sponsored advertising that appeared on a billboard in Maple Valley, Washington. The billboard did not include the names & addresses of the billboard’s sponsors.

The Respondent is a first-time candidate who said she was unaware of the sponsor identification requirements for political advertising. Upon being notified of the complaint on October 16, 2019, the Respondent immediately took steps to resolve non-compliance by contacting the billboard company the same day and instructing them to reprint the advertising. The revised billboard, including sponsor identification, was posted on October 25, 2019.

Based on these findings, staff determined that, in this instance, the Respondent’s failure to identify the sponsors of political advertising does not amount to a violation that warrants further investigation. PDC staff reminded the Respondent about the importance of identifying the sponsor’s name and address on political advertising, including billboards. The PDC finds that no further actions is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

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.235, RCW 42.17A.240, 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

The PDC received a complaint alleging that Mark Michel (the “Respondent”) may have violated RCW 42.17A.335 and WAC 390-18-040 by using the term “reelect” in political advertising. PDC staff reviewed the allegation; the applicable statutes, rules and reporting requirements; and the response provided by the Respondent to determine whether they support a finding of one or more violations. 

Staff’s review found the following:

RCW 42.17A.335(1(b) prohibits political advertising that includes a false statement of incumbency about a candidate who is not an incumbent that is made with actual malice. However, subsection (3) of .335 states that it is not a violation for a candidate or their agent to make such a statement about themselves because a person cannot defame themselves. 

WAC 390-18-040(1) states that the term “reelect” can be used when “the candidate is presently holding the office being sought, was elected to it, and is seeking another term in that same office in the same district or political subdivision.” The rule is silent concerning what term(s) could be used by incumbents holding multiple positions within the same office. 

The Respondent, who is an incumbent Key Peninsula Parks & Recreation Commissioner in position 1, as well as a candidate for position 3, distributed campaign signs and other political advertising containing the term “reelect” during election year 2019.

Upon being notified of the allegation, the Respondent reached out to the PDC for guidance and immediately and voluntarily altered his campaign signs to omit the term “reelect” to alleviate any concerns about their use. The Respondent also explained that the Key Peninsula Parks & Recreation Commission positions are not defined by geographical limits within the district. As a result, it appears these Commissioner positions are for offices within the same district or political subdivision for the purposes of WAC 390-18-040(1).

Based on these findings, staff determined that, in this instance, the use of the term “reelect” by a position 1 incumbent candidate seeking election to position 3 of the same office does not amount to 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/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
SC 19-2-04952-34 10/08/2019 State of Washington Evergreen Freedom Foundation SC 19-2-04952-34 Evergreen Freedom Foundation d/b/a Freedom Foundation (Thurston County Superior Court)

For case information visit: https://www.atg.wa.gov/enforcement-campaign-finance-laws

https://www.pdc.wa.gov/browse/cases/SC 19-2-04952-34
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.205, RCW 42.17A.235, RCW 42.17A.240 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.240, RCW 42.17A.235, RCW 42.17A.700, RCW 42.17A.710 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, WAC 390-16-125, RCW 42.17A.205 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.235, WAC 390-16-125, RCW 42.17A.205, RCW 42.17A.240 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

The PDC received a complaint alleging that Daniel Hammill (the “Respondent”) may have violated RCW 42.17A.240 by failing to provide sufficient expenditure details & report his candidate filing fee. PDC staff reviewed the allegations; the applicable statutes, rules and reporting requirements; the response provided by the Respondent; and the Respondent’s reporting history to determine whether they support a finding of one or more violations.  

Staff’s review found the following: 

The Respondent registered as a candidate with the PDC by filing a C-1 report on March 21, 2019. On the C-1 report, the Respondent selected the Full Reporting Option. As a result, the Respondent is required to file periodic C-3 & C-4 reports, based on the election cycle, disclosing the campaign’s contribution and expenditure activities. Pursuant to WAC 390-16-037, expenditures disclosed on the C-4 report should be described “in detail,” including how the recipient of the expenditure (e.g. vendor) will use the goods and/or services purchased, and numerical descriptions (e.g. the number of items printed).    

The Respondent did not timely report his candidate filing fee on a May C-4 report or sufficient describe an expenditure made to AMS Print & Mail Specialist on the campaign's 7-day pre-primary C-4 report. Upon being notified of the missing information, the Respondent took corrective action and made a good-faith effort to comply by amending the necessary reports. The Respondent indicated that noncompliance was the result of a misunderstanding. 

Based on these findings, staff determined that, in this instance, the Respondent’s failure to timely & accurately report his candidate filing fee and sufficiently describe an expenditure does not amount to a violation that warrants further investigation. However, the PDC reminded the Respondent about the importance of timely disclosing all expenditures, including the candidate filing fee and any in-kind loans or contributions from the candidate to his campaign.  

The Respondent made minor or ministerial errors on his reports, which did not materially impact the public interest. Upon notification of the error, the Respondent timely amended his reports, making the necessary technical corrections. The PDC has dismissed this matter in accordance with RCW 42.17A.755(1).  
 

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.235, RCW 42.17A.205, RCW 42.17A.210, RCW 42.17A.215 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.445, 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 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.635, RCW 42.17A.640 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.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 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.635, RCW 42.17A.640 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.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 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.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 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.205, RCW 42.17A.215, RCW 42.17A.210, RCW 42.17A.700 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 o