Dhingra, Manka (8): Alleged violation of RCW 42.17A.445 for personal use of campaign funds, RCW 42.17A.265 for failure to timely report last minute contributions, and RCW 42.17A.235 for failure to report expenditures (EY 17; Aug 17)

Case

#24233

Respondent

Manka Dhingra

Complainant

Glen Morgan

Description

A total of ten complaints were filed against Manka Dhingra, a candidate for State Senator in the 45th Legislative District in 2017, with the first two complaints having already been resolved.  The remaining eight complaints contained numerous allegations of violations of RCW 42.17A. for hundreds of campaign contribution and expenditure activities as disclosed on Candidate Registrations (C-1 reports), Monetary Contributions reports (C-3 reports), and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), filed by the Friends of Manka Dhingra Campaign (Campaign).  

 

The eight complaints were combined into one letter for the following cases: (1) Complaint #3 (PDC Case 15366); (2) Complaint #4 (PDC Case 18600); (3) Complaint #5 (PDC Case 21175); (4) Complaint #6 (PDC Case 21336); (5) Complaint #7 (PDC Case 23120); (6) Complaint #8 (PDC Case 24233); (7) Complaint #9 (PDC Case 25507); and (8) Complaint #10 (PDC Case 27088).  

 

PDC staff found no evidence of a material violation that would require conducting a more formal investigation into the eight complaints filed against Senator Dhingra or pursuing enforcement action in this instance, which was also noted in the Attorney General’s letter to Mr. Morgan and Senator Dhingra (and cc:d to the PDC) concerning these complaints.  

 

PDC staff would note that Ms. Dhingra was a first-time candidate for public office in 2017, and her Campaign filed a total of 692 campaign finance reports with the PDC for the 2017 election cycle that included 46 amended C-4 reports and 31 amended C-3 reports.  A number of the allegations listed in the eight complaints concerned information disclosed on amended C-3 and C-4 reports filed by the Campaign.  The Campaign stated the amendments were filed “to correct the record and the C-4 reports were filed as soon as the error was discovered. All reports filed were as accurate as the campaign was aware of at the time, and no concealment was intended.”

 

Staff’s review of the amended C-3 and C-4 reports filed by the Campaign, Mr. Lo’s frequent communications with PDC staff concerning filing questions both by telephone and by email, and the timeliness in which the Campaign filed amended C-3 and C-4 reports indicated the Campaign made a good faith effort to comply with the reporting requirements.  The Campaign did everything requested by PDC staff to facilitate transparency in one the most expensive legislative elections in Washington State history.  Based on this information, the PDC dismissed the allegations listed in the eight complaints concerning amended reports in accordance with RCW 42.17A.755(1).  

 

The PDC also dismissed the allegations listed in the eight complaints that were based “on information and belief” in accordance with RCW 42.17A.755(1), since the complainant failed to provide any evidence to support or substantiate those allegations. 

 

Finally, PDC staff dismissed the remaining allegations in the eight complaints filed against Senator Dhingra as referenced in the attached complaint return letter in accordance with RCW 42.17A.755(1). 

Disposition

Case Closed with No Evidence of Violations

Date Opened

August 24, 2017

Areas of Law

RCW 42.17A.235, RCW 42.17A.265, RCW 42.17A.445, WAC 390-16-283

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