Republican Women of Clallam County: Alleged violation of RCW 42.17A.205 & .225 by failing to register as a political committee, and report contributions & expenditures. (EY '21; Aug '21)

Case

#97535

Respondent

Republican Women of Clallam County

Complainant

Lisa Ann Dekker

Description

The complaint alleged the Republican Women of Clallam County violated RCW 42.17A.205 by failing to register as a committee for the 2018 and 2020 elections.

Washington law defines a political committee as any person, group, club, organization, or collection of individuals (except a candidate or individual dealing with his or her own funds) expecting to receive contributions or make expenditures in support of or in opposition to any candidate or ballot proposition. While an organization may be a civic, social, or professional organization primarily, it also may be a political committee if it solicits or receives contributions for the purpose of use in election campaigns or otherwise meets the primary purpose tests outlined in PDC Interpretation 07-02.

The Commission adopted PDC Interpretation 07-02 to provide guidance concerning how the PDC applies the “primary purpose test” for determining a political committee as set forth by court decisions. The Interpretation provides guidance in determining whether an entity that participates in elections by making campaign contributions, but whose campaign activities are only one prong or aspect of an organization’s overall work, is required to register and file reports with the PDC as a “political committee.”

Based on staff findings, PDC staff has determined that, in this instance, the failure to register as a committee and report contributions and expenditures during calendar years 2018 and 2020, does not amount to a violation warranting further investigation. 

Staff is reminding the RWCC to review PDC Interpretation 07-02 and evaluate if ongoing election activity meets the primary purpose test to register as a political committee.

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).

Disposition

Case Closed with Reminder

Date Opened

August 20, 2021

Areas of Law

RCW 42.17A.205, RCW 42.17A.225

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