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)

Case

#58919

Respondent

Steven C Fox

Complainant

Kelly Geiger

Description

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). 

Disposition

Resolved with Technical Correction

Date Opened

October 21, 2019

Areas of Law

RCW 42.17A.240

Documents

• 58919 Fox Steven Technical Correction Ltr.pdf
• 58919 Fox Steven C Response.pdf
• 58919 Fox Steven C Complaint.pdf