Cunningham, Alecia: Alleged violation of RCW 42.17A.240 for failure to accurately disclose expenditure descriptions on C-4 reports. (EY '21; Jul '21)

Case

#95996

Respondent

Alecia Cunningham

Complainant

Glen Morgan

Description

A complaint was filed against Alecia Cunningham, a candidate for University Place School Director in 2021 alleging that the 2021Alecia Cunningham Campaign (Campaign) may have violated RCW 42.17A.240 by failing to accurately disclose the complete expenditure description for political advertising purchased by the Campaign. 

On May 31, 2021, the Campaign timely filed the May 2021 C-4 report disclosing no contributions had been received and that $294.21 in expenditures were made.  The two expenditures included a $203.44 expenditure to the Washington State Democratic Central Committee for a vote building effort, and a $79.27 expenditure made to Argo Strategies for Invoice #5492.

On June 10, 2021, the Campaign timely filed an amended May 2021 C-4 report disclosing newly amended information that included listing Code “M” for Management for the Argo Strategies expenditure, and disclosing a new $1,200 expenditure that was made by the Campaign on May 27, 2021, to Johnson-Cox Printing, Inc., with the description stating “Doorbeller estimate for order.”

On July 26, 2021, after being made aware of the complaint allegations, the Campaign promptly filed a second amended May 2021 C-4 report disclosing the same $250 in monetary contributions received and $1,494.21 in expenditures made during the period, but amended the Johnson-Cox Printing, Inc. expenditure description to state “3,000 door hangers printed."

Based on these findings staff has determined, in this instance, the allegation of failing to accurately disclose the proper description for one Campaign expenditure that was otherwise, timely disclosed, does not amount to a violation warranting further investigation. RCW 42.17A.005(52) defines "Technical correction" to mean “the correction of a minor or ministerial error in a required report that does not materially harm the public interest and needs to be corrected for the report to be in full compliance with the requirements of this chapter.” 

Alecia Cunningham is a first-time candidate with a first-time Treasurer, and the Campaign made a minor or ministerial error on the May 2021 C-4 report, which did not materially impact the public. Upon notification of the error, the Campaign timely filed an amended May 2021 C-4 report making the necessary technical corrections as requested by staff to bring the Campaign back into compliance. The PDC has dismissed this matter as a technical correction in accordance with RCW 42.17A.755(1)

Disposition

Resolved with Technical Correction

Date Opened

July 21, 2021

Areas of Law

RCW 42.17A.240

Documents

• Cunningham, Alecia Complaint Return Letter (Morgan) PDC Case 95196.pdf
• 95996 Cunningham Alecia Complaint.pdf
• Email responses received from Alecia Cunningham.pdf