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)

Case

#88948

Respondent

Citizens 4 Fire Merger

Complainant

IAFF Local 2459, and Carolyn Armanini

Description

The complaints alleged Citizens 4 Fire Merger (Committee), a 2021 ballot committee registered with the PDC, violated: (1) RCW 42.17A.255, .260 and .305 by failing to accurately and completely disclose independent expenditures and electioneering communications on Form C-6; (2) RCW 42.17A.320 by failing to include the required sponsor identification on a mailer in support of the ballot measure; and (3) RCW 42.17A.235 and .240 by failing to timely and accurately disclose contributions and expenditures.

Based on PDC staff findings, the mitigating factors concerning the Committee’s inexperience and limited spending, the fact no evidence was found of any intent to conceal true sponsorship, and the information available to the public before the election through the C-6 report, staff has determined in this instance, the Committee’s failure to: (1) accurately and completely disclose the $3,921.53 expenditure made to ASM Direct Mail in support of the merger; and (2) to include the words “Paid for” or “Sponsored by” on the political advertisement, the Committee mailing address of the Committee, and the top five contributor information as required for the sponsor of a mailer, does not amount to findings of material violations that warrants further investigation.

However, pursuant to WAC 390-37-060(1)(d), Citizens 4 Fire Merger will receive a formal written warning concerning the failure to timely file accurate reports of contribution and expenditure activities as required for a ballot committee and to include a complete sponsor identification on political advertisements sponsored by the Committee. Staff expects the Committee will, in the future, timely and accurately file PDC reports disclosing all contribution and expenditure activities as required by law, and to follow the political advertising disclosure requirements for a ballot committee in accordance with RCW 42.17A.320.

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 the two complaints in accordance with RCW 42.17A.755(1).

Disposition

Case Closed with Written Warning

Date Opened

April 14, 2021

Areas of Law

RCW 42.17A.235, RCW 42.17A.240, RCW 42.17A.255, RCW 42.17A.260, RCW 42.17A.305, RCW 42.17A.320