Included here are cases from October 2015 to the present. You can search across all fields by using the search box below. Click "Advanced search" to reveal a menu for more detailed filtering. You can download the results of your search by using the "csv" and "copy" buttons at the bottom of the list. To see case documents, click the case number. Or search across all case documents using the compliance case document search

For more information about how the PDC handles complaints alleging violations of RCW 42.17A and what the different case statuses mean, see our enforcement guide. For a glimpse at how long it is taking to close cases, see the case resolution chart


Case # Opened Complainant Respondent Subject Areas of Law Status Description Url
56380 08/19/2019 Glen Morgan Approve Prop 1 – Our Public Hospital Approve Prop 1 - Our Public Hospital: Alleged violations of RCW 42.17A.240 for failure to accurately report and describe expenditures & contributions. (EY '19) (Aug '19) RCW 42.17A.240 Assessment of Facts
  • Allegation: Alleged violations of RCW 42.17A.240 for failure to accurately report and describe expenditures & contributions
https://www.pdc.wa.gov/browse/enforcement-cases/56380
56287 08/16/2019 Robert Parker Kristen Deskin Deskin, Kristen: Alleged Violation of RCW 42.17A.205, .210, .215, .235 for failure to file Candidate Registration, designate Treasurer information, disclose Depositories, and failure to file Contribution or Expenditure reports. (EY 2019, AUG 2019) RCW 42.17A.235, RCW 42.17A.215, RCW 42.17A.205, RCW 42.17A.210 Assessment of Facts

Allegation One: Violation of RCW 42.17A.205 for failure to file Candidate Registration.

Allegation Two: Violation of RCW 42.17A.210 for failure to designate Treasurer information.

Allegation Three: Violation of RCW 42.17A.215 for failure to disclose depositories.

Allegation Four: Violation of RCW 42.17A.235 for failure to disclose contributions or expenditures.

https://www.pdc.wa.gov/browse/enforcement-cases/56287
56286 08/16/2019 Robert Parker Michael Christophersen, Candidate for Seattle School District #1 Christophersen, Michael: Alleged Violation of RCW 42.17A.205, .210, .215 for failure to file Candidate Registration, designate Treasurer information, and disclose Depositories. (EY 2019, AUG 2019) RCW 42.17A.215, RCW 42.17A.205, RCW 42.17A.210

Allegation One: Violation of RCW 42.17A.205 for failure to file Candidate Registration.

Allegation Two: Violation of RCW 42.17A.210 for failure to designate Treasurer information.

Allegation Three: Violation of RCW 42.17A.215 for failure to disclose depositories.

https://www.pdc.wa.gov/browse/enforcement-cases/56286
56285 08/16/2019 Robert Parker Darcie Kline Kline, Darcie: Alleged Violation of RCW 42.17A.205, .210, .215 for failure to file Candidate Registration, designate Treasurer information, and disclose Depositories. (EY 2019, AUG 2019) Assessment of Facts

Allegation One: Violation of RCW 42.17A.205 for failure to file Candidate Registration.

Allegation Two: Violation of RCW 42.17A.210 for failure to designate Treasurer information.

Allegation Three: Violation of RCW 42.17A.215 for failure to disclose depositories.

https://www.pdc.wa.gov/browse/enforcement-cases/56285
56284 08/16/2019 Robert Parker Justin Johnson Johnson, Justin: Alleged Violation of RCW 42.17A.205, .210, .215 for failure to file Candidate Registration, designate Treasurer information, and disclose Depositories. (EY 2019, AUG 2019) Assessment of Facts

Allegation One: Violation of RCW 42.17A.205 for failure to file Candidate Registration.

Allegation Two: Violation of RCW 42.17A.210 for failure to designate Treasurer information.

Allegation Three: Violation of RCW 42.17A.215 for failure to disclose depositories.

https://www.pdc.wa.gov/browse/enforcement-cases/56284
56252 08/15/2019 Glen Morgan EvergreenHealth Foundation EvergreenHealth Foundation: Alleged violations of Chapter 42.17A RCW for failure to timely register and report as an incidental committee, to disclose sponsor ID on political advertising, and to report independent expenditures (EY 19; Aug 19) RCW 42.17A.235, RCW 42.17A.207, RCW 42.17A.240, RCW 42.17A.255, RCW 42.17A.320 Assessment of Facts
  • Allegation One: Violation of RCW 42.17A.207 for failure to timely file an Incidental Committee Registration (C-1ic report) within two weeks of the expectation of making contributions or expenditures aggregating at least $25,000 in a calendar year in any election campaign, or to a political committee; and receiving payments from a single source, which in the aggregate total at least $10,000 from that source, in the current calendar year.
  • Allegation Two: Violations of RCW 42.17A.235 and .240 for failure to timely file Incidental Committee Payments and Political Expenditures reports (C-8 reports) disclosing the top ten sources of payments of $10,000 or more during the calendar yer; and monetary or in-kind contributions to candidates or political committees.
  • Allegation Three: Violation of RCW 42.17A.320 for failure to disclose sponsor identification on mailed political advertising, including the top 5 contributors to the advertising.
  • Allegation Four: Violation of RCW 42.17A.235 and .240 for failure to report expenditures for political advertising made in coordination with related or affiliated political committees; or RCW 42.17A.255 for failure to report independent expenditures in support of ballot propositions on Independent Expenditure and Electioneering Communication reports (C-6 reports).
https://www.pdc.wa.gov/browse/enforcement-cases/56252
56147 08/13/2019 Kendra Shirley Eliana Macias Macias, Eliana: Alleged violations of RCW 42.17A.320 for failure to disclose sponsor ID on political advertising, and .335 for false statements of material fact in political advertising (EY 19; Aug 19) RCW 42.17A.320, RCW 42.17A.335 Assessment of Facts
  • Allegation One: Violation of RCW 42.17A.320 for failure to disclose the sponsor's name and address on political advertising.
  • Allegation Two: Violation of RCW 42.17A.335 for sponsoring with actual malice, false statements of material fact meant to cause injury to candidate Gartrell.
https://www.pdc.wa.gov/browse/enforcement-cases/56147
56012 08/12/2019 Thomas Fancher Steven D Verhey Verhey, Steven: Alleged Violation of RCW 42.17A.235, .240 for failure to file accurate contribution reports. (AUG 2019) Assessment of Facts
  • Allegation: Violation of RCW 42.17A.235, .240 for failure to file accurate contribution reports. 
https://www.pdc.wa.gov/browse/enforcement-cases/56012
56009 08/12/2019 Nancy Jean Majors Fa'izah Bradford Bradford, Fa'izah: Alleged Violation of WAC 390-18-040 for inaccurate use of the term "reelect" in political advertising. (AUG 2019) Assessment of Facts

Allegation: Violation of WAC 390-18-040 for misuse of the term "reelect" in political advertising. 

https://www.pdc.wa.gov/browse/enforcement-cases/56009
56008 08/12/2019 Tarn Ohana Western Consultants LLC and/or Kevin Topping Moms for Seattle: Alleged Violation of RCW 42.17A.255, .305 for failure to file a C-6 report that meets electioneering communication requirements. (AUG 2019) RCW 42.17A.305 Assessment of Facts

Allegation: Violation of RCW 42.17A.305 for failure to file a C-6 report that meets electioneering communication requirements. 

https://www.pdc.wa.gov/browse/enforcement-cases/56008
55901 08/09/2019 James Lazar The City of Olympia, a municipal corporation, and Steve Hall in his capacity as City Manager, City of Olympia City of Olympia: Alleged Violation of RCW 42.17A.555, .575 for using public facilities to support a political campaign and for distributing a Public Service Announcement in which a municipal officer in the PSA is a political candidate. (AUG 2019, EY 2019) RCW 42.17A.575, RCW 42.17A.555 Assessment of Facts

Allegation One: Violation of RCW 42.17A.555 for using public facilities to support a political campaign.

Allegation Two: Violation of RCW 42.17A.572 for distributing a Public Service Announcement in which a municipal officer in the PSA is a political candidate.

https://www.pdc.wa.gov/browse/enforcement-cases/55901
55739 08/06/2019 Heidi Whaley Deborah “Sunny” Hemphill Hemphill, Deborah "Sunny": Alleged violation of RCW 42.17A.205 by failing to timely register as a candidate w/the PDC within two weeks of candidacy. (EY '19) (Jul '19) RCW 42.17A.205 Assessment of Facts
  • Allegation: Alleged violation of RCW 42.17A.205 by failing to timely register as a candidate w/the PDC within two weeks of candidacy 
https://www.pdc.wa.gov/browse/enforcement-cases/55739
55726 08/06/2019 Kristjan K Gorshkov Tiger Budbill Budbill, Tiger: Alleged violation of RCW 42.17A.205 & .700 by failing to timely register as a candidate w/the PDC & file statement of financial affairs within two weeks of candidacy. (EY '19) (Jul '19) RCW 42.17A.700, RCW 42.17A.205 Assessment of Facts
  • Allegation: Alleged violation of RCW 42.17A.205 & .700 by failing to timely register as a candidate w/the PDC within two weeks of candidacy & timely file a financial affairs statement.
https://www.pdc.wa.gov/browse/enforcement-cases/55726
55723 08/06/2019 Robert Parker Mark D. Emerson Emerson, Mark: Alleged violation of RCW 42.17A.205 by failing to timely register as a candidate w/the PDC within two weeks of candidacy and disclose Treasurer, depository. (EY '19) (Jul '19) RCW 42.17A.205 Assessment of Facts
  • Alleged violation of RCW 42.17A.205 by failing to timely register as a candidate w/the PDC within two weeks of candidacy and disclose Treasurer, depository. 
https://www.pdc.wa.gov/browse/enforcement-cases/55723
55719 08/06/2019 Robert Parker Drayton Jackson Jackson, Drayton: Alleged violation of RCW 42.17A.205 by failing to register as a candidate w/the PDC within two weeks of candidacy and disclose Treasurer, depository. (EY '19) (Jul '19) RCW 42.17A.205 Assessment of Facts
  • Alleged violation of RCW 42.17A.205 by failing to timely register as a candidate w/the PDC within two weeks of candidacy and disclose Treasurer, depository. 
https://www.pdc.wa.gov/browse/enforcement-cases/55719
55714 08/06/2019 David Lee Sandretto Michelle McLeod McLeod Michelle: Alleged Violation of WAC 390-18-040 for inaccurate of use of reelection terms in political advertising. (JULY 2019, EY 2019) Assessment of Facts

Allegation: Violation of WAC 390-18-040 for inaccurate use of reelection terminology in political advertising.

https://www.pdc.wa.gov/browse/enforcement-cases/55714
55704 08/05/2019 Jason Ritchie Layna Crofts Crofts, Layna: Alleged violations of RCW 42.17A.205, .235, and .700 for failure to register as a candidate and report contributions, expenditures, and financial affairs (EY 19; Jul 19) RCW 42.17A.235, RCW 42.17A.205, RCW 42.17A.700 Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Jason Ritchie on July 28, 2019. The complaint alleged that Layna Crofts (Respondent), a 2019 candidate for Issaquah School Director, may have violated RCW 42.17A.205 for failure to timely file a Candidate Registration (C-1 report) within two weeks of becoming a candidate; RCW 42.17A.235 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign; and RCW 42.17A.700 for failure to file a Personal Financial Affairs Statement (F-1 report), certifying financial affairs for twelve calendar months prior to becoming a candidate, within two weeks of becoming a candidate.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to timely register as a candidate and disclose personal financial affairs do not amount to violations that warrants further investigation.

Pursuant to WAC 390-37-060(1)(d), Layna Crofts will receive a formal written warning concerning failure to timely register as a candidate and to disclose personal financial affairs for twelve calendar months prior to becoming a candidate, within two weeks of becoming a candidate. The formal written warning will include staff’s expectation that Layna Crofts timely files all future required reports. The Commission will consider the formal written warning in deciding on further 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 this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/55704
55701 08/05/2019 Andrew Saturn People for Seattle People for Seattle: Alleged violations of RCW 42.17A.240 for failure to disclose value of mailing lists, and RCW 42.17A.260 for failure to timely report independent expenditures for political advertising (EY 19; Jul 19) RCW 42.17A.260, RCW 42.17A.240 Assessment of Facts
  • Allegation One: Violation of RCW 42.17A.240 for failure to report expenditures or in-kind contribution for the value of mailing lists.
  • Allegation Two: Violation of RCW 42.17A.260 for failure to report independent expenditures for political advertising appearing within 21 days of an election, within 24 hours of presentation to the public.
https://www.pdc.wa.gov/browse/enforcement-cases/55701
55700 08/05/2019 Freedom Foundation (Maxford Nelsen) Temp-Control Mechanical Corporation Temp-Control Mechanical Corporation (2): Alleged violations of RCW 42.17A.495 and WAC 390-17-100 by failing to obtain written authorization from employees before deducting wages or salaries for political contributions (July 19) WAC 390-17-100, RCW 42.17A.495 Assessment of Facts

Allegation: Violations of RCW 42.17A.495 & WAC 390-17-100 by failing to obtain written authorization from employees before deducting wages or salaries for political contributions

https://www.pdc.wa.gov/browse/enforcement-cases/55700
55699 08/05/2019 Andrew Saturn John Weidenfeller Weidenfeller, John: Alleged violation of RCW 42.17A.555 by authorizing use of public office or agency facilities to assist an election campaign. (EY 2018) (Jun 2019) RCW 42.17A 555 Assessment of Facts
  • Alleged violation of RCW 42.17A.555 by authorizing use of public office or agency facilities to assist an election campaign (e.g. using PUD facilities to pay for a candidate to attend 10/10/18 Candidate Forum)
https://www.pdc.wa.gov/browse/enforcement-cases/55699
55698 08/05/2019 Freedom Foundation (Maxford Nelsen) Waste Treatment Completion Company Waste Treatment Completion Company, LLC (3): Alleged violations of RCW 42.17A.495 and WAC 390-17-100 by failing to obtain written authorization from employees before deducting wages or salaries for political contributions (July 19) RCW 42.17A.495, WAC 390-17-110 Assessment of Facts

Allegation: Violations of RCW 42.17A.495 & WAC 390-17-100 by failing to obtain written authorization from employees before deducting wages or salaries for political contributions

https://www.pdc.wa.gov/browse/enforcement-cases/55698
55606 08/02/2019 Marylou Eckart, Charles Eakins, Glen Morgan Naz Lashgari Lashgari, Naz: Alleged violation of RCW 42.17A.320 for failure to identify sponsor on campaign website (EY '19) (Jul '19) RCW 42.17A.320 Assessment of Facts
  • Alleged violation of RCW 42.17A.320 for failure to identify sponsor on Lynnwood Forward slate campaign website
https://www.pdc.wa.gov/browse/enforcement-cases/55606
55605 08/02/2019 Marylou Eckart, Charles Eakins, Glen Morgan Ashkan Amouzegar Amouzegar, Ashkan: Alleged violation of RCW 42.17A.320 for failure to identify sponsor on campaign website (EY '19) (Jul '19) RCW 42.17A.320 Assessment of Facts
  • Alleged violation of RCW 42.17A.320 for failure to identify sponsor on Lynnwood Forward slate campaign website
https://www.pdc.wa.gov/browse/enforcement-cases/55605
55603 08/02/2019 Marylou Eckart, Charles Eakins & Glen Morgan Nicholas Coelho Coelho, Nicholas: Alleged violation of RCW 42.17A.320 for failure to identify sponsor on campaign website. (EY '19) (Jul '19) RCW 42.17A.320 Assessment of Facts
  • Alleged violation of RCW 42.17A.320 for failure to identify sponsor on Lynnwood Forward slate campaign website
https://www.pdc.wa.gov/browse/enforcement-cases/55603
55601 08/02/2019 Robert Parker Sanjay Pal Pal, Sanjay: Alleged Violation of RCW 42.17A.205, .210, .215 for failure to file Candidate Registration (C-1 Report), failure to disclose designated Treasurer, and failure to disclose depositories. (JULY 2019, EY 2019) RCW 42.17A.205 Assessment of Facts
  • Allegation One: Violation of RCW 42.17A.205 for failure to file Candidate Registration (C-1 Report)
  • Allegation Two: Violation of RCW 42.17A.210 for failure to disclose designated Treasurer
  • Allegation Three: Violation of RCW 42.17A.215 for failure to disclose depositories.
https://www.pdc.wa.gov/browse/enforcement-cases/55601
55599 08/02/2019 Robert Parker Breane Martinez Martinez, Breane: Alleged Violation of RCW 42.17A.205, .210, .215 for failure to file Candidate Registration (C-1 Report), failure to disclose designated Treasurer, and failure to disclose depositories. (JULY 2019, EY 2019) RCW 42.17A.205 Assessment of Facts
  • Allegation One: Violation of RCW 42.17A.205 for failure to file Candidate Registration (C-1 Report).
  • Allegation Two: Violation of RCW 42.17A.210 for failure to disclose designated Treasurer. 
  • Allegation Three: Violation of RCW 42.17A.215 for failure to disclose depositories. 
https://www.pdc.wa.gov/browse/enforcement-cases/55599
55598 08/02/2019 Robert Parker Mike Desmond Desmond, Mike: Alleged Violation of RCW 42.17A.205, .210, .215 for failure to file the Candidate Registration (C-1 Report), failure to disclose designated Treasurer, and failure to disclose depositories. (JULY 2019, EY 2019) Assessment of Facts
  • Allegation One: Violation of RCW 42.17A.205 for failure to file Candidate Registration (C-1 Report).
  • Allegation Two: Violation of RCW 42.17A.210 for failure to disclose designated Treasurer. 
  • Allegation Three: Violation of RCW 42.17A.215 for failure to disclose depositories.
https://www.pdc.wa.gov/browse/enforcement-cases/55598
55594 08/02/2019 Robert Parker Jonee Dubos Dubos, Jonee: Alleged Violation of RCW 42.17A.205, .210, .215 for failure to file Candidate Registration (C-1 Report), failure to disclose designated Treasurer, and failure to disclose depositories. (JULY 2019, EY 2019) RCW 42.17A.205 Assessment of Facts
  • Allegation One : Violation of RCW 42.17A.205 for failure to file Candidate Registration (C-1 Report).
  • Allegation Two: Violation of RCW 42.17A.210 for failure to disclose a designated Treasurer.
  • Allegation Three: Violation of RCW 42.17A.215 for failure to disclose depositories. 
https://www.pdc.wa.gov/browse/enforcement-cases/55594
55593 08/02/2019 Glen Morgan Tony Anderson Anderson, Anthony D.: Alleged Violation of RCW 42.17A.700, .710 for failure to disclose financial entities on the F-1 Statement of Personal Financial Affairs (JULY 2019, EY 2019). RCW42.17A.700, RCW 42.17A.710 Assessment of Facts

Allegation: Violation of RCW 42.17A.700 for failure to disclose financial entities on the Statement of Personal Financial Affairs (F-1 Report).

https://www.pdc.wa.gov/browse/enforcement-cases/55593
55589 08/02/2019 Robert Parker Rob MacDermid MacDermid, Robert: Alleged Violation of RCW 42.17A.205 for failure to file the C-1 Candidate Registration) (JULY 2019) (EY 2019) RCW 42.17A.205 Assessment of Facts
  • Allegation: Violation of RCW 42.17A.205 for failure to file the candidate registration (C-1 Report)
https://www.pdc.wa.gov/browse/enforcement-cases/55589
55534 08/01/2019 Ron Anderson Tom Sund Sund, Thomas: Alleged violation of RCW 42.17A.205, .235 & .240 for failure to timely register as a candidate with the PDC, and timely & accurately report contributions & expenditures. (EY '19) (July '19) RCW 42.17A.235, RCW 42.17A.240, RCW 42.17A.205 Assessment of Facts
  • Allegation One: Alleged violation of RCW 42.17A.205 for failure to timely register as a candidate with the PDC within two weeks of declaring candidacy.
  • Allegation Two: Alleged violation of RCW 42.17A.235 & .240 for failure to timely & accurately report contributions & expenditures.
https://www.pdc.wa.gov/browse/enforcement-cases/55534
55529 08/01/2019 Whatcom County Democratic Central Committee (Andrew Reding) Whatcom County Republican Party Whatcom County Republican Party (3): Alleged violations of RCW 42.17A.220, .235, and .240 for failure to accurately and timely deposit and report contributions and expenditures (EY 19; Aug 19) RCW 42.17A.240, RCW 42.17A.235, RCW 42.17A.220 Assessment of Facts
  • Allegation One: Violations of RCW 42.17A.220 for failure to timely deposit contributions within five business days of receipt.
  • Allegation Two: Violation of RCW 42.17A.235 for failure to timely report contributions and deposits.
  • Allegation Three: Violations of RCW 42.17A.240 and WAC 390-16-205 for failure to accurately and completely disclose contributions from auctions, and expenditures made to sub-vendors, with the amounts attributable to each.
https://www.pdc.wa.gov/browse/enforcement-cases/55529
55460 07/31/2019 Glen Morgan People for Moon PAC People for Moon PAC: Alleged Violation of RCW 42.17A.240 for failure to accurately describe expenditure. Assessment of Facts
  • Allegation: Violation of RCW 42.17A.240 fore failure to accurately describe expenditure.
https://www.pdc.wa.gov/browse/enforcement-cases/55460
55351 07/29/2019 Tallman Trask Facebook, Inc. Facebook, Inc. (5): Alleged violations of RCW 42.17A.345 and WAC 390-18-050 for failure to maintain and provide documents and books of account as a commercial advertiser, promptly upon request from any person (EY 19; Jul 19) WAC 390-18-050, RCW 42.17A.345 Assessment of Facts

Allegation: Violations of RCW 42.17A.345 and WAC 390-18-050 for failure to maintain and provide documents and books of account as a commercial advertiser, promptly upon request from any person.

https://www.pdc.wa.gov/browse/enforcement-cases/55351
55345 07/29/2019 Tallman Trask UniteHere Local 8 PAC UniteHere Local 8 PAC: Alleged violations of Chapter 42.17A RCW for failure to register as a political committee, report expenditure activities, and disclose sponsor identification (EY 19; July 19) RCW 42.17A.235, RCW 42.17A.260, RCW 42.17A.240, RCW 42.17A.305, RCW 42.17A.255, RCW 42.17A.320 Assessment of Facts
  • Allegation One: Violations of RCW 42.17A.320 for failure to completely and accurately disclose sponsor identification on digital political advertising.
  • Allegation Two: Violations of RCW 42.17A.235 and .240 for failure to timely, accurately, and completely report contributions and expenditures.
  • Allegation Three: Violations of RCW 42.17A.255, .260, and .305 for failure to timely, accurately, and completely disclose independent expenditures and electioneering communications.
https://www.pdc.wa.gov/browse/enforcement-cases/55345
55344 07/29/2019 Tallman Trask Unite Here Unite Here: Alleged violations of Chapter 42.17A RCW for failure to register as an out-of-state committee, to report expenditure activity, and to disclose sponsor identification (EY 19; July 19) RCW 42.17A.255, RCW 42.17A.305, RCW 42.17A.320, RCW 42.17A.260, RCW 42.17A.250 Assessment of Facts
  • Allegation One: Violations of RCW 42.17A.320 for failure to completely and accurately disclose sponsor identification on digital political advertising.
  • Allegation Two: Violations of RCW 42.17A.250 for failure to register as an out-of-state political committee and to report contributions and expenditures.
  • Allegation Three: Violations of RCW 42.17A.255, .260, and .305 for failure to timely, accurately, and completely disclose independent expenditures and electioneering communications.
https://www.pdc.wa.gov/browse/enforcement-cases/55344
55341 07/29/2019 Glen Morgan Natalie McClendon McClendon, Natalie: Alleged violations of RCW 42.17A.240 for failure to accurately and completely disclose expenditures (EY 19; July 19) RCW 42.17A.240, WAC 390-16-037 Assessment of Facts
  • Allegation: Violations of RCW 42.17A.240 and WAC 390-16-037 for failure to completely and accurately disclose details of expenditures undertaken by the Campaign.
https://www.pdc.wa.gov/browse/enforcement-cases/55341
55339 07/29/2019 Glen Morgan Sofia Aragon Aragon, Sofia: Alleged violations of RCW 42.17A.240 for failure to accurately report expenditures, and .320 for failure to disclose sponsor identification on political advertising (EY 19; Jul 19) RCW 42.17A.320, WAC 390-16-037, RCW 42.17A.240 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Glen Morgan on July 21, 2019. The complaint alleged that Sofia Aragon (Respondent), a 2019 candidate for Burien City Council, may have violated RCW 42.17A.240 and WAC 390-16-037 for failure to accurately and completely disclose in-kind contributions or expenditures undertaken by the Campaign; and RCW 42.17A.320 for failure to accurately and completely disclose sponsor identification on digital political advertising.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the responses provided by the Respondent; the applicable PDC reports filed by the Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, minor and ministerial errors on required reports that did not materially impact the public interest, and failure to include complete and accurate sponsor identification on digital political advertising, do not amount to violations that warrant further investigation.

PDC staff is reminding Sofia Aragon about the importance of the complete and accurate disclosure of in-kind contributions and expenditures, including the number of items printed for political advertising, and the complete and accurate disclosure of sponsor identification on political advertising in the future.

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).

https://www.pdc.wa.gov/browse/enforcement-cases/55339
55287 07/26/2019 Tallman Trask Chistopher Rufo Rufo, Christopher: Alleged violation of RCW 42.17A.430 by donating surplus funds to an unregistered charity. (EY '19) (Jul '19) RCW 42.17A.430 Assessment of Facts
  • Allegation: Alleged violation of RCW 42.17A.430 by donating surplus funds to a charity that is not registered pursuant to RCW 19.09
https://www.pdc.wa.gov/browse/enforcement-cases/55287
55284 07/26/2019 Philip L. Johnson Shauna Walters Walters, Shauna: Alleged violations of WAC 390-16-105 & .125 and RCW 42.17A.220 by accepting a contribution greater than $500, failure to change from mini to full reporting, and exceeding $300 in anonymous donations. (EY '19) (Jul '19). WAC 390-16-105, RCW 42.17A.220, WAC 390-16-125 Assessment of Facts
  • Allegation One: Alleged violation of WAC 390-16-105 by accepting a contribution exceeding $500 from a single source
  • Allegation Two: Alleged violation of WAC 390-16-125 for failure to apply for a change from mini to full reporting prior to exceeding contribution limit
  • Allegation Three: Alleged violation of RCW 42.17A.220 by exceeding $300 in anonymous donations
https://www.pdc.wa.gov/browse/enforcement-cases/55284
55283 07/26/2019 Glen Morgan Ricky Moon Moon, Ricky: Alleged Violation of RCW 42.17A.205, .235, .240, .700 for failure to timely or accurately file Candidate Registration, Financial Affairs Statement, and Contribution or Expenditure Reports (JULY 2019, EY 2019). RCW 42.17A.205, RCW.42.17A.240, RCW 42.17A.235, RCW 42.17A.700 Assessment of Facts
  • Allegation One: Violation of RCW 42.17A.205 for failure to timely file the Candidate Registration (C-1 report).
  • Allegation Two: Violation of RCW 42.17A.700 for failure to timely file the Financial Affairs Statement (F-1 report).
  • Allegation Three: Violation of RCW 42.17A.235 for failure to timely disclose Contributions or Expenditures (C-3 or C-4 Reports).
  • Allegation Four: Violation of RCW 42.17A.240 for failure to accurately describe expenditures..

 

https://www.pdc.wa.gov/browse/enforcement-cases/55283
55282 07/26/2019 Glen Morgan Debbie Bertlin Bertlin, Debbie (2): Alleged violations of RCW 42.17A.555 for misuse of public facilities to support candidate's own election campaign (EY 19; Jul 19) RCW 42.17A.555 Assessment of Facts
  • Allegation: Violations of RCW 42.17A.555 for misuse of phones, computers, servers, and other public facilities owned and operated by the City of Mercer Island to support the candidate's own election campaign.
https://www.pdc.wa.gov/browse/enforcement-cases/55282
55276 07/26/2019 Glen Morgan Lillian (Randy) Slovic Slovic, Lillian (Randy): Alleged violations of RCW 42.17A.235 for failure to report contributions and expenditures (EY 19; Jul 19) RCW 42.17A.235 Assessment of Facts

Allegation: Violations of RCW 42.17A.235 for failure to report contributions and expenditures on Summary Full Campaign Contribution and Expenditure reports (C-4 reports)

https://www.pdc.wa.gov/browse/enforcement-cases/55276
55267 07/26/2019 Glen Morgan Darcy Burner Burner, Darcy: Alleged Violation of RCW 42.17A.220 for accepting anonymous over-limit contributions during the 2016 campaign. (JULY 2019, EY 2016) RCW 42.17A.220 Assessment of Facts
  • Allegation: Alleged violation of RCW 42.17A.220 for accepting over-limit anonymous contributions.
https://www.pdc.wa.gov/browse/enforcement-cases/55267
55265 07/26/2019 Michael Kelly Preserve Reasonable Shoreline Management Preserve Reasonable Shoreline Management: Alleged violations of Chapter 42.17A RCW for failure to register as a political committee, report contributions and expenditures, and disclose sponsor identification on political advertising (EY 19; July 19) RCW 42.17A.205, RCW 42.17A.207, RCW 42.17A.235, RCW 42.17A.320 Assessment of Facts
  • Allegation One: Violation of RCW 42.17A.205 or .207 for failure to register as a political or incidental committee.
  • Allegation Two: Violations of RCW 42.17A.235 for failure to report contributions and expenditures.
  • Allegation Three: Violation of RCW 42.17A.320 for failure to disclose sponsor identification on political advertising.
https://www.pdc.wa.gov/browse/enforcement-cases/55265
55221 07/25/2019 Guy Thompson Washington Association of Realtors Washington Association of Realtors: Alleged violations of RCW 42.17A.320 for failure to disclose sponsor identification on digital political advertising (EY 19; Jul 19) RCW 42.17A.320 Assessment of Facts

Allegation: Violations of RCW 42.17A.320 for failure to include sponsor identification on digital political advertising in support of candidate Nadine Woodward

https://www.pdc.wa.gov/browse/enforcement-cases/55221
55220 07/25/2019 Guy Thompson Concerned Taxpayers of Washington State Concerned Taxpayers of Washington State: Alleged violations of RCW 42.17A.320 for failure to disclose sponsor identification on digital political advertising (EY 19; Jul 19) RCW 42.17A.320 Assessment of Facts

Allegation: Violations of RCW 42.17A.320 for failure to include sponsor identification on digital political advertising in support of candidate Nadine Woodward

https://www.pdc.wa.gov/browse/enforcement-cases/55220
55219 07/25/2019 Guy Thompson Spokane Good Government Alliance Spokane Good Government Alliance: Alleged violations of RCW 42.17A.320 for failure to disclose sponsor identification on digital political advertising (EY 19; Jul 19) RCW 42.17A.320 Assessment of Facts

Allegation: Violations of RCW 42.17A.320 for failure to disclose sponsor identification on digital political advertising in support of candidate Nadine Woodward

https://www.pdc.wa.gov/browse/enforcement-cases/55219
55218 07/25/2019 Guy Thompson Washington Realtors Political Action Committee Washington Realtors Political Action Committee (2): Alleged violations of RCW 42.17A.320 for failure to disclose sponsor identification on digital political advertising (EY 19; July 19) RCW 42.17A.320 Assessment of Facts

Allegation: Violations of RCW 42.17A.320 for failure to include sponsor identification on digital political advertising in support of candidate Nadine Woodward

https://www.pdc.wa.gov/browse/enforcement-cases/55218
55217 07/25/2019 Guy Thompson Nadine Woodward Woodward, Nadine: Alleged violations of RCW 42.17A.320 for failure to disclose sponsor identification on digital political advertising (EY 19; July 19) RCW 42.17A.320 Assessment of Facts

Allegation: Violations of RCW 42.17A.320 for failure to disclose sponsor identification on digital political advertising.

https://www.pdc.wa.gov/browse/enforcement-cases/55217
55069 07/22/2019 Glen Morgan Thurston County Democratic Central Committee Thurston County Democratic Central Committee: Alleged violation of RCW 42.17A.220 by accepting over-limit anonymous contributions. (EY '16) (July '19) RCW 42.17A.220 Assessment of Facts
  • Allegation: Alleged violation of RCW 42.17A.220 by accepting over-limit anonymous contributions
https://www.pdc.wa.gov/browse/enforcement-cases/55069
55065 07/22/2019 Glen Morgan Ben Stuckart Stuckart, Ben: Alleged violation of RCW 42.17A.220 by accepting over-limit anonymous contributions. (EY '19) (July '19) RCW 42.17A.220 Assessment of Facts
  • Allegation: Alleged violation of RCW 42.17A.220 by accepting over-limit anonymous contributions
https://www.pdc.wa.gov/browse/enforcement-cases/55065
55057 07/22/2019 Glen Morgan Yes for Libraries! Yes for Libraries!: Alleged violation of RCW 42.17A.220 by accepting over-limit anonymous contributions. (EY '18) (July '19) RCW 42.17A.220 Assessment of Facts
  • Allegation: Alleged violation of RCW 42.17A.220 by accepting over-limit anonymous contributions
https://www.pdc.wa.gov/browse/enforcement-cases/55057
55052 07/22/2019 Glen Morgan Fire Services Fund of Washington Fire Services Fund of Washington: Alleged violation of RCW 42.17A.220 by accepting over-limit anonymous contributions. (EY '18) (July '19) RCW 42.17A.220 Assessment of Facts
  • Allegation: Alleged violation of RCW 42.17A.220 by accepting over-limit anonymous contributions
https://www.pdc.wa.gov/browse/enforcement-cases/55052
55049 07/22/2019 Glen Morgan Debra Entenman Entenman, Debra: Alleged violation of RCW 42.17A.220 by accepting over-limit anonymous contributions. (EY '18) (July '19) RCW 42.17A.220 Assessment of Facts
  • Allegation: Alleged violation of RCW 42.17A.220 by accepting over-limit anonymous contributions
https://www.pdc.wa.gov/browse/enforcement-cases/55049
55044 07/22/2019 Glen Morgan Victoria Mena Mena, Victoria: Alleged violation of RCW 42.17A.220 by accepting over-limit anonymous contributions. (EY '18) (July '19) RCW 42.17A.220 Assessment of Facts
  • Allegation: Alleged violation of RCW 42.17A.220 by accepting over-limit anonymous contributions
https://www.pdc.wa.gov/browse/enforcement-cases/55044
55043 07/22/2019 Glen Morgan Debra Lekanoff Lekanoff, Debra: Alleged violation of RCW 42.17A.220 by accepting over-limit anonymous contributions. (EY '18) (July '19) RCW 42.17A.220 Assessment of Facts
  • Allegation: Alleged violation of RCW 42.17A.220 by accepting over-limit anonymous contributions
https://www.pdc.wa.gov/browse/enforcement-cases/55043
55041 07/22/2019 Glen Morgan Pinky Vargas Vargas Pinky: Alleged violation of RCW 42.17A.220 by accepting over-limit anonymous contributions. (EY '18) (July '19) RCW 42.17A.220 Assessment of Facts
  • Allegation: Alleged violation of RCW 42.17A.220 by accepting over-limit anonymous contributions
https://www.pdc.wa.gov/browse/enforcement-cases/55041
55035 07/22/2019 Glen Morgan Clean Air Clean Energy Washington Clean Air Clean Energy Washington: Alleged violation of RCW 42.17A.220 by accepting over-limit anonymous contributions. (EY '18) (July '19) RCW 42.17A.220 Assessment of Facts
  • Allegation: Alleged violation of RCW 42.17A.220 by accepting over-limit anonymous contributions
https://www.pdc.wa.gov/browse/enforcement-cases/55035
54991 07/19/2019 Glen Morgan Martha Cunningham Cunningham, Martha: Alleged violations of RCW 42.17A.205 & .700 for failure to timely register as a candidate & file financial affairs statement within 2 weeks of declaring candidacy. (EY '19) (Jul '19) RCW 42.17A.700, RCW 42.17A.205 Case Closed with Reminder
  • Allegation One: Alleged violation of RCW 42.17A.205 for failure to timely register as a candidate with PDC within two weeks of declaring candidacy.  
  • Allegation Two:  Alleged violation of RCW 42.17A.700 for failure to timely file a statement of financial affairs with PDC within two weeks of declaring candidacy. 
https://www.pdc.wa.gov/browse/enforcement-cases/54991
54984 07/19/2019 Glen Morgan Alliance for Gun Responsiblity (ERP Committee) PAC Alliance for Gun Responsibility ERP Committee: Alleged Violation of RCW 42.17A.220 for accepting over-limit anonymous contributions. (JULY 2019) RCW 42.17A.220 Assessment of Facts

Allegation: Violation of RCW 42.17A.220 for exceeding anonymous contribution limits.

https://www.pdc.wa.gov/browse/enforcement-cases/54984
54979 07/19/2019 Michele Levenite Matthew J Bishop Bishop, Matthew: Alleged Violation of RCW 42.17A.700 for failure to file the Statement of Personal Financial Affairs (F-1 report) (JULY 2019, EY 2019) 235

Allegation: Violation of RCW 42.17A.700 for failing to file the Statement of Personal Financial Affairs (F-1)

https://www.pdc.wa.gov/browse/enforcement-cases/54979
54975 07/19/2019 Kevin Mendez Mason Thompson Thompson, Mason: Alleged violation of RCW 42.17A.320 for failure to accurately disclose complete sponsor ID on political advertising. (EY '19) (Jul '19)) RCW 42.17A.320 Assessment of Facts
  • Allegation: Violation of RCW 42.17A.320 for failure to accurately disclose complete sponsor ID on political advertising (flyers).
https://www.pdc.wa.gov/browse/enforcement-cases/54975
54972 07/19/2019 Glen Morgan Richard Robinson Robinson Richard: Alleged violations of RCW 42.17A.205, .700 & .235 for failure to timely register as a candidate & file financial affairs statement within 2 weeks of declaring candidacy & timely report contributions & expenditures. (EY '19) (Jul '19) RCW 42.17A.205, RCW 42.17A.700, RCW 42.17A.235 Assessment of Facts
  • Allegation One: Alleged violation of RCW 42.17A.205 for failure to register as a candidate with PDC within two weeks of declaring candidacy.  
  • Allegation Two:  Alleged violation of RCW 42.17A.700 for failure to timely file a statement of financial affairs with PDC within two weeks of declaring candidacy.  
  • Allegation Three:  Alleged violation of RCW 42.17A.235 for failure to timely report contributions & expenditures.
https://www.pdc.wa.gov/browse/enforcement-cases/54972
54968 07/19/2019 Glen Morgan Jared Hofer Hofer, Jared: Alleged violations of RCW 42.17A.205 & .235 for failure to register as a candidate within 2 weeks of declaring candidacy & timely report contributions & expenditures. (EY '19) (Jul '19) RCW 42.17A.205, RCW 42.17A.235 Case Closed with Reminder
  • Allegation One: Alleged violation of RCW 42.17A.205 for failure to register as a candidate with PDC within two weeks of declaring candidacy  
  • Allegation Two:  Alleged violation of RCW 42.17A.235 for failure to timely report contributions & expenditures
https://www.pdc.wa.gov/browse/enforcement-cases/54968
54966 07/19/2019 Michele Levenite Lisa Thomas Thomas, Lisa: Alleged violations of RCW 42.17A.700 & .240 for failure to timely & accurately file statement of financial affairs (F-1 report) & accurately report expenditures (EY '19) (Jul '19) RCW 42.17A.710, RCW 42.17A.240, 42.17A.700 Assessment of Facts
  • Allegation One: Alleged violation of RCW 42.17A.700 & .710 for failure to timely & accurately file the Statement of Personal Financial Affairs (F-1 report) within two weeks of becoming a candidate
  • Allegation Two: Alleged violation of RCW 42.17A.240 for failure to accurately disclose expenditures on the C-4 report
https://www.pdc.wa.gov/browse/enforcement-cases/54966
54934 07/18/2019 Michael Eckart Nicola Smith Nicola Smith: Alleged violation of RCW 42.17A.555 by allowing the use of public facilities to assist an election campaign. (EY '19) (Jul '19) RCW 42.17A.555 Case Closed with No Evidence of Violations
  • Alleged violation of RCW 42.17A.555 by allowing the use of public facilities (City of Lynnwood website) to assist an election campaign (Lynnwood Forward slate campaign website endorsements)
https://www.pdc.wa.gov/browse/enforcement-cases/54934
54918 07/18/2019 Glen Morgan Erinn Howell Howell, Erinn: Alleged violations of RCW 42.17A.205, .700 & .235 for failure to register as a candidate & file financial affairs statement within 2 weeks of declaring candidacy & timely report contributions & expenditures. (EY '19) (Jul '19) RCW 42.17A.700, RCW 42.17A.235, RCW 42.17A.205 Assessment of Facts
  • Allegation One: Alleged violation of RCW 42.17A.205 for failure to register as a candidate with PDC within two weeks of declaring candidacy.  
  • Allegation Two:  Alleged violation of RCW 42.17A.700 for failure to file a statement of financial affairs with PDC within two weeks of declaring candidacy.  
  • Allegation Three:  Alleged violation of RCW 42.17A.235 for failure to timely report contributions & expenditures.
https://www.pdc.wa.gov/browse/enforcement-cases/54918
54873 07/17/2019 Marylou Eckart, Charles Eakins, Glen Morgan Lynnwood Forward PAC Lynnwood Forward: Alleged violations of RCW 42.17A.205, .235, .240, .255 & .320 for failure to register as a political committee, report contributions & expenditures, disclose independent expenditures or electioneering communication, and identify sponsor RCW 42.17A.240, RCW 42.17A.235, RCW 42.17A.255, RCW 42.17A.205, RCW 42.17A.320 Assessment of Facts
  • Allegation One: Alleged violations of RCW 42.17A.205, .235 & .240 for failure to register as a political committee and timely & accurately report contributions and expenditures
  • Allegation Two: Alleged violation of RCW 42.17A.255, .260 & .305 for failure to disclose independent expenditures or electioneering communications (Lynnwood Forward website)
  • Allegation Three: Alleged violation of RCW 42.17A.320 by failing to identify sponsor on political advertising (Lynnwood Forward website)
https://www.pdc.wa.gov/browse/enforcement-cases/54873
54867 07/17/2019 Sean McGee Patrick Guettner Guettner, Patrick: Alleged violations of RCW 42.17A.205 for failure to timely register as a candidate, and RCW 42.17A.700 for failure to timely disclose personal financial affairs (EY 19; July 19) RCW 42.17A.700, RCW 42.17A.205 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Sean McGee on July 15, 2019. The complaint alleged that Patrick Guettner (Respondent), a 2019 candidate for Pasco City Council may have violated RCW 42.17A.205 for failure to timely file a Candidate Registration (C-1 report), and .700 for failure to timely file a Personal Financial Affairs Statement (F-1 report), both due within two weeks of declaring candidacy, or not later than June 3, 2019.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the applicable PDC reports filed by the Respondent, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to timely file the C-1 and F-1 reports do not amount to violations that warrant further investigation.

PDC staff is reminding Patrick Guettner about the importance of timely registering as a candidate in an election campaign, and timely disclosing financial affairs for twelve calendar months prior to declaring candidacy. PDC staff expects the timely filing of all future reports as required by statute and rule.

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).

https://www.pdc.wa.gov/browse/enforcement-cases/54867
54865 07/17/2019 Glen Morgan 37th LD Democrats 37th Legislative District Democrats (2): Alleged violations of RCW 42.17A.220 for accepting and retaining over-limit anonymous contributions (EY 16; Jul 19) RCW 42.17A.220 Assessment of Facts
  • Allegation: Violations of RCW 42.17A.220 for accepting and retaining anonymous contributions over the limit of 1% of contributions received in the calendar year, or $300, whichever is greater.
https://www.pdc.wa.gov/browse/enforcement-cases/54865
54863 07/17/2019 Glen Morgan Washington State Democratic Party Committee Washington State Democratic Central Committee (5): Alleged violations of RCW 42.17A.220 for accepting and retaining over-limit anonymous contributions (EY 16; Jul 19) RCW 42.17A.220 Assessment of Facts
  • Allegation: Violations of RCW 42.17A.220 for accepting and retaining anonymous contributions over the limit of 1% of contributions received in the calendar year, or $300, whichever is greater.
https://www.pdc.wa.gov/browse/enforcement-cases/54863
54861 07/17/2019 Glen Morgan Citizens for Sequim Schools Bond 4 Citizens for Sequim Schools Bond 4: Alleged violations of RCW 42.17A.220 for accepting and retaining over-limit anonymous contributions (EY 16; Jul 19) RCW 42.17A.220 Assessment of Facts
  • Allegation: Violations of RCW 42.17A.220 for accepting and retaining anonymous contributions over the limit of 1% of contributions received in the calendar year, or $300, whichever is greater.
https://www.pdc.wa.gov/browse/enforcement-cases/54861
54859 07/17/2019 Andrew Saturn Linda Oosterman Oosterman, Linda (9): Alleged violation of RCW 42.17A.555 by using public facilities to assist an election campaign. (EY '18 ) (Jul '19) RCW 42.17A.555 Assessment of Facts
  • Allegation: Alleged violation of RCW 42.17A.555 by using public facilities (e.g. training certification purchased by Public Utility Dist.) to assist a re-election campaign
https://www.pdc.wa.gov/browse/enforcement-cases/54859
54858 07/17/2019 Glen Morgan Citizens for Ridgefield Schools Citizens for Ridgefield Schools: Alleged violations of RCW 42.17A.220 for accepting and retaining over-limit anonymous contributions (EY 16; Jul 19) RCW 42.17A.220 Assessment of Facts
  • Allegation: Violations of RCW 42.17A.220 for accepting and retaining anonymous contributions over the limit of 1% of total contributions received in the calendar year, or $300, whichever is greater.
https://www.pdc.wa.gov/browse/enforcement-cases/54858
54857 07/17/2019 Glen Morgan Jay Inslee Inslee, Jay (3): Alleged violations of RCW 42.17A.220 for accepting and retaining over-limit anonymous contributions (EY 16; Jul 19) RCW 42.17A.220 Assessment of Facts
  • Allegation: Violations of RCW 42.17A.220 for accepting and retaining anonymous contributions over the limit of 1% of contributions received in the calendar year, or $300, whichever is greater.
https://www.pdc.wa.gov/browse/enforcement-cases/54857
54856 07/17/2019 Andrew Saturn Linda Oosterman Oosterman, Linda (8): Alleged violations of RCW 42.17A.235 & .240 by failing to timely & accurately report in-kind contributions, expenditures & proceeds from Champagne Brunch. (EY '18) (Jul '19) RCW 42.17A.240, RCW 42.17A.235 Assessment of Facts
  • Allegation: Alleged violations of RCW 42.17A.235 & .240 for failure to timely and accurately report in-kind contributions and proceeds from, and  expenditures for, Champagne Brunch event.
https://www.pdc.wa.gov/browse/enforcement-cases/54856
54855 07/17/2019 Glen Morgan Don Orange Orange, Don: Violations of RCW 42.17A.220 for accepting and retaining over-limit anonymous contributions (EY 17; July 17) RCW 42.17A.220 Assessment of Facts
  • Allegation: Violations of RCW 42.17A.220 for accepting and retaining anonymous contributions over the limit of 1% of contributions received in the calendar year, or $300, whichever is greater.
https://www.pdc.wa.gov/browse/enforcement-cases/54855
54852 07/17/2019 Glen Morgan Kshama Sawant Sawant, Kshama (2): Alleged violations of RCW 42.17A.220 for accepting and retaining over-limit anonymous contributions (EY 19; Jul 19) RCW 42.17A.220 Assessment of Facts
  • Allegation: Violations of RCW 42.17A.220 for accepting and retaining anonymous contributions over the limit of 1% of contributions received in the calendar year, or $300, whichever is greater.
https://www.pdc.wa.gov/browse/enforcement-cases/54852
54849 07/17/2019 Andrew Saturn Linda Oosterman Oosterman, Linda (7): Alleged violations of Chapter 42.17A RCW and WAC 390-32, the Fair Campaign Practices Code (EY 18; July 18) WAC 390-32-010 Resolved through Complaint Publication Process

On July 15, 2019, the Public Disclosure Commission (PDC) received a complaint from Andrew Saturn, alleging a violation of one or more specific provisions of WAC 390-32-010, the Fair Campaign Practices Code (FCPC).  The complaint concerned Linda Oosterman, a 2018 candidate for Thurston County Public Utility Commissioner.

The Campaign Fair Practices Code requires the PDC to forward the complaint to the party alleged to have violated the FCPC, request a response within five days, and then send the complaint and the response, if one is received, to news media.  Linda Oosterman supplied a response to the complaint's allegations on July 24, 2019. WAC 390-32-030 prevents the Commission and staff from commenting on the complaint or the response. 

On July 25, 2019, a copy of the complaint and response were sent to news media.

https://www.pdc.wa.gov/browse/enforcement-cases/54849
54841 07/17/2019 Glen Morgan Whatcom County Democratic Central Commitee Whatcom County Democratic Central Committee (2): Alleged violations of RCW 42.17A.220 for accepting and retaining over-limit contributions (EY 18; Jul 19) RCW 42.17A.220 Assessment of Facts
  • Allegation: Violations of RCW 42.17A.220 for accepting and retaining anonymous contributions over the limit of 1% of contributions received in the calendar year, or $300, whichever is greater.
https://www.pdc.wa.gov/browse/enforcement-cases/54841
54840 07/17/2019 Glen Morgan Washington Association of Nurse Anesthetists PAC (WANA PAC) Washington Association of Nurse Anesthetists PAC (WANA PAC): Alleged violations of RCW 42.17A.220 for accepting and retaining over-limit anonymous contributions (EY 19; Jul 19) RCW 42.17A.220 Assessment of Facts
  • Allegation: Violations of RCW 42.17A.220 for accepting and retaining anonymous contributions over the limit of 1% of contributions received in the calendar year, or $300, whichever is greater.
https://www.pdc.wa.gov/browse/enforcement-cases/54840
54839 07/17/2019 Glen Morgan My-Linh Thai Thai, My-Linh (2): Alleged violations of RCW 42.17A.220 for accepting and retaining over-limit anonymous contributions (EY 18; July 19) RCW 42.17A.220 Assessment of Facts
  • Allegation: Violations of RCW 42.17A.220 for accepting and retaining anonymous contributions over the limit of 1% of contributions received in the calendar year, or $300, whichever is greater.
https://www.pdc.wa.gov/browse/enforcement-cases/54839
54838 07/17/2019 Glen Morgan Jennifer Tyler Tyler, Jennifer (2): Alleged violations of RCW 42.17A.220 for accepting and retaining over-limit anonymous contributions (EY 18; Jul 18) RCW 42.17A.220 Assessment of Facts
  • Allegation: Violations of RCW 42.17A.220 for accepting and retaining anonymous contributions over the limit of 1% of contributions received in the calendar year, or $300, whichever is greater.
https://www.pdc.wa.gov/browse/enforcement-cases/54838
54830 07/17/2019 Glen Morgan Matthew Stroe Stroe, Matthew: Alleged violations of RCW 42.17A.220 for accepting and retaining over-limit anonymous contributions (EY 18; July 19) RCW 42.17A.220 Assessment of Facts
  • Allegation: Violations of RCW 42.17A.220 for accepting and retaining anonymous contributions exceeding the limit of 1% of total contributions received in the calendar year, or $300, whichever is more.
https://www.pdc.wa.gov/browse/enforcement-cases/54830
54827 07/17/2019 Glen Morgan Dan Satterberg Satterberg, Dan: Alleged violations of RCW 42.17A.220 for accepting and retaining over-limit anonymous contributions (EY 18; July 19) RCW 42.17A.220 Assessment of Facts
  • Allegation: Violations of RCW 42.17A.220 for accepting anonymous contributions over the limit of 1% of total contributions received in the calendar year, or $300, whichever is greater.
https://www.pdc.wa.gov/browse/enforcement-cases/54827
54826 07/17/2019 Glen Morgan Charlie McCaughan McCaughan, Charlie: Alleged violations of RCW 42.17A.205 and .235 for failure to register as a candidate, and report contributions and expenditures (EY 19; July 19) RCW 42.17A.235, RCW 42.17A.205 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Glen Morgan on July 15, 2019. The complaint alleged that Charlie McCaughan (Respondent), a 2019 candidate for Pasco City Council may have violated RCW 42.17A.205 for failure to timely file a Candidate Registration (C-1 report); and RCW 42.17A.235 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the applicable PDC reports filed by the Respondent, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to timely file the C-1 report does not amount to a violation that warrants further investigation.

PDC staff is reminding Charlie McCaughan about the importance of timely registering as a candidate in an election campaign. PDC staff expects the timely filing of all future reports as required by statute and rule.

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).

https://www.pdc.wa.gov/browse/enforcement-cases/54826
54823 07/17/2019 Glen Morgan Artur Wojnowski Wojnowski, Artur: Alleged violations of RCW 42.17A.205, .235, and .700 for failure to timely register as a candidate and report contributions, expenditures, and financial affairs (EY 19; July 19) RCW 42.17A.205, RCW 42.17A.700, RCW 42.17A.235 Assessment of Facts
  • Allegation One: Violation of RCW 42.17A.205 for failure to file a Candidate Registration (C-1 report)
  • Allegation Two: Violation of RCW 42.17A.235 for failure to report contributions and expenditures (C-3 and C-4 reports)
  • Allegation Three: Violation of RCW 42.17A.700 for failure to timely file Personal Financial Affairs Statement (F-1 report)
https://www.pdc.wa.gov/browse/enforcement-cases/54823
54818 07/17/2019 Freedom Foundation (Maxford Nelsen) Intermech, Inc. Intermech, Inc. (3): Alleged violations of RCW 42.17A.495 and WAC 390-17-100 by failing to obtain written authorization from employees before deducting wages or salaries for political contributions (July 19) RCW 42.17A.495, WAC 390-17-100 Assessment of Facts
  • Allegation: Violations of RCW 42.17A.495 & WAC 390-17-100 by failing to obtain written authorization from employees before deducting wages or salaries for political contributions 
https://www.pdc.wa.gov/browse/enforcement-cases/54818
54751 07/16/2019 Michele Levenite Radona Devereaux Devereaux, Radona: Alleged violations of RCW 42.17A.235 and .700 for failure to timely report contributions, expenditures, and financial affairs (EY 19; July 19) RCW 42.17A.235, RCW 42.17A.700 Scheduled for Brief Hearing
  • Allegation One: Violations of RCW 42.17A.235 for failure to report contribution and expenditure activity on C-3 and C-4 reports.
  • Allegation Two: Violation of RCW 42.17A.700 for failure to report financial activity for 12 months prior to declaring candidacy on the F-1 report.
https://www.pdc.wa.gov/browse/enforcement-cases/54751
54746 07/16/2019 Freedom Foundation (Maxford Nelsen) Apollo Mechanical Contractors Apollo Mechanical Contractors (3): Alleged violations of RCW 42.17A.495 and WAC 390-17-100 by failing to obtain written authorization from employees before deducting wages or salaries for political contributions (July 19) RCW 42.17A.495, WAC 390-17-110 Assessment of Facts

Allegation: Violations of RCW 42.17A.495 & WAC 390-17-100 by failing to obtain written authorization from employees before deducting wages or salaries for political contributions

https://www.pdc.wa.gov/browse/enforcement-cases/54746
54633 07/15/2019 Debra Omaha Sternberg Lucy Krakowiak Krakowiak, Lucy: Alleged Violation of RCW 42.17A.205 for failure to timely file Candidate Registration (C-1 report). RCW 24.17A.205

Allegation: Violation of RCW 42.17A.205 for failure to timely file the Candidate Registration (C-1 report).

https://www.pdc.wa.gov/browse/enforcement-cases/54633
54487 07/12/2019 Michael Fertakis Larry Gossett Gossett, Larry: Alleged violation of RCW 42.17A.555 by using public facilities to assist an election campaign. (EY '19) (Jul '19) RCW 42.17A.555 Assessment of Facts
  • Allegation: Alleged violation of RCW 42.17A.555 by using public facilities (e.g. city council office) to assist an election campaign (e.g. to take a photograph used on campaign Facebook page)
https://www.pdc.wa.gov/browse/enforcement-cases/54487
54348 07/11/2019 William Miano James Barnfather Barnfather, James: Alleged violation of RCW 42.17A.205 & .235 for failure to timely register as a candidate within two weeks of declaring candidacy & timely report contributions & expenditures. (EY '19) (Jul '19) RCW 42.17A.205, RCW 42.17A.235 Case Closed with Reminder
  • Allegation: Alleged violation of RCW 42.17A.205 & .235 for failure to timely register as a candidate within two weeks of declaring candidacy & timely report contributions & expenditures.
https://www.pdc.wa.gov/browse/enforcement-cases/54348
54324 07/10/2019 Freedom Foundation (Maxford Nelsen) JH Kelly, LLC JH Kelly, LLC (3): Alleged violations of RCW 42.17A.495 & WAC 390-17-100 by failing to obtain written authorization from employees before deducting wages or salaries for political contributions. (EY '19) (Jul '19) WAC 390-17-100, RCW 42.17A.495 Assessment of Facts
  • Alleged violations of RCW 42.17A.495 & WAC 390-17-100 by failing to obtain written authorization from employees before deducting wages or salaries for political contributions
https://www.pdc.wa.gov/browse/enforcement-cases/54324
54177 07/08/2019 CLAUD WILHITE ROBERT SAMSON Samson, Robert: Alleged Violation of RCW 42.17A.335 for political advertising that contains false statements about a candidate constituting libel or defamation. Assessment of Facts

Allegation: Violation of RCW 42.17A.335 for political advertising that contains false statements about a candidate constituting libel or defamation. 

https://www.pdc.wa.gov/browse/enforcement-cases/54177
54170 07/08/2019 Dori Luzzo Gilmour Wendi Warner Wendi Warner: Alleged Violation of RCW 42.17A.205 for failure to timely file the Candidate Registration (C-1 report) Assessment of Facts

Allegation: Violation of RCW 42.17A.205 for failure to timely file the Candidate Registration (C-1 report).

https://www.pdc.wa.gov/browse/enforcement-cases/54170
54145 07/08/2019 Freedom Foundation (Maxford Nelsen) American Federation of State, County and Municipal Employees Special Account American Federation of State, County and Municipal Employees Special Account: Alleged violations of Chapter 42.17A RCW for failure to accurately and completely report as an out-of-state political committee, and to report independent expenditures/electioneering communications (July 19) RCW 42.17A.255, RCW 42.17A.305, RCW 42.17A.250, RCW 42.17A.260 Assessment of Facts

A complaint was filed against American Federation of State, County and Municipal Employees Special Account (AFSCME) alleging violations of: (1) RCW 42.17A.250 for failing to timely and accurately file reports disclosing contributions and expenditures as an out-of-state political committee on the C-5 reports; and (2) RCW 42.17A.255, .260, and .305 for failure to timely, accurately, and completely report independent expenditures and/or electioneering communications.

https://www.pdc.wa.gov/browse/enforcement-cases/54145
53838 06/28/2019 Andrew Saturn Linda Oosterman Oosterman, Linda (6): Alleged violation of RCW 42.17A.555 by using public office or agency facilities to assist an election campaign. (EY 2018) (Jun 2019) RCW 42.17A 555 Assessment of Facts
  • Alleged violation of RCW 42.17A.555 by using public office or agency facilities to assist an election campaign (using PUD facilities for 10/10/18 candidate forum).
https://www.pdc.wa.gov/browse/enforcement-cases/53838
53596 06/24/2019 Sheri Connor Julieta Altamirano-Crosby Altamirano-Crosby, Julieta: Alleged violation of RCW 42.17A.235 for failure to timely report contributions & expenditures. (EY '19) (Jun '19) RCW 42.17A.235 Case Closed with Reminder

Allegation: Alleged violation of RCW 42.17A.235 for failure to timely report contributions & expenditures.

https://www.pdc.wa.gov/browse/enforcement-cases/53596
53590 06/24/2019 Sheri Connor Maggie Mae Mae, Maggie: Alleged violations of RCW 42.17A.205, .700 & .235 for failure to register as a candidate & file financial affairs statement within 2 weeks of declaring candidacy & timely report contributions & expenditures. (EY '19) (Jun '19) RCW 42.17A.700, RCW 42.17A.235, RCW 42.17A.205 Case Closed with Reminder
  • Allegation One: Alleged violation of RCW 42.17A.205 for failure to register as a candidate with PDC within two weeks of declaring candidacy.  
  • Allegation Two:  Alleged violation of RCW 42.17A.700 for failure to file a statement of financial affairs with PDC within two weeks of declaring candidacy.  
  • Allegation Three:  Alleged violation of RCW 42.17A.235 for failure to timely report contributions & expenditures.
https://www.pdc.wa.gov/browse/enforcement-cases/53590
53461 06/21/2019 Amanda Zimmerman Ramon Llanos Llanos, Ramon: Alleged violation of RCW 42.17A.205, .700 & .235 for failure to register as a candidate & file financial affairs statement within 2 weeks of declaring candidacy & timely report contributions & expenditures. (EY '19) (Jun '19) RCW 42.17A 700, RCW 42.17A.205, RCW 42.17A.235 Case Closed with Reminder
  • Allegation One: Alleged violation of RCW 42.17A.205 for failure to register as a candidate with PDC within two weeks of declaring candidacy. 
  • Allegation Two:  Alleged violation of RCW 42.17A.700 for failure to file a statement of financial affairs with PDC within two weeks of declaring candidacy. 
  • Allegation Three:  Alleged violation of RCW 42.17A.235 for failure to timely report contributions & expenditures.
https://www.pdc.wa.gov/browse/enforcement-cases/53461
53456 06/21/2019 Elizabeth Hallock Soneya Lund Lund, Soneya (2): Alleged violations of RCW 42.17A.240 for failure to accurately and completely report expenditures and in-kind contributions, and .710 for failure to disclose board membership (EY 19; June 19) RCW 42.17A.710, RCW 42.17A.240 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Elizabeth Hallock on June 21, 2019. The complaint alleged that Soneya Lund (Respondent), a 2019 candidate for Yakima City Council, may have violated RCW 42.17A.240 for failure to accurately and completely disclose in-kind contributions and expenditures undertaken by the Campaign; and RCW 42.17A.710 for failure to disclose officership or directorship on the board of directors for Rod’s House, a non-profit organization, on the Personal Financial Affairs Statement (F-1 report).

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the responses provided by the Respondent; the applicable PDC reports filed by the Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to accurately and completely disclose an officership on a non-profit board of directors, and to accurately and completely disclose in-kind contributions, do not amount to violations that warrant further investigation.

PDC staff is reminding Soneya Lund about the importance of accurately and completely disclosing financial affairs and in-kind contributions. PDC staff expects the timely, accurate, and complete disclosure filing of future reports in accordance with statutes and rules.

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).

https://www.pdc.wa.gov/browse/enforcement-cases/53456
53454 06/21/2019 Glen Morgan One Washington Equality Campaign One Washington Equality Campaign: Alleged violations of RCW 42.17A.235, .240, and .255 for failure to report expenditures or in-kind contributions for legal services, and independent expenditures in support or opposition to ballot propositions (EY 19; June 19) RCW 42.17A.255, RCW 42.17A.240 Assessment of Facts
  • Allegation One: Violations of RCW 42.17A.240 for failure to report expenditures or in-kind contributions for legal services in support of 2018 State Initiative 1000, and in opposition to 2019 State Referendum 88.
  • Allegation Two: Violations of RCW 42.17A.255 for failure to report independent expenditures for legal services in support of 2018 State Initiative 1000, and in opposition to 2019 State Referendum 88.
https://www.pdc.wa.gov/browse/enforcement-cases/53454
53443 06/21/2019 Arthur David Churchman Shelly Schlumpf Schlumpf, Shelly: Alleged violation of RCW 42.17A.700 for failure to file statement of financial affairs (F-1 report) with the PDC within two weeks of candidacy. (EY 2019) (Jun '19) RCW 42.17A.700 Case Closed with Reminder
  • Allegation: Alleged violation of RCW 42.17A.700 for failure to file statement of financial affairs (F-1 report) with the PDC within two weeks of candidacy. 
https://www.pdc.wa.gov/browse/enforcement-cases/53443
53400 06/20/2019 Amanda Zimmerman, Mike Olson, and Bill Pate Daniel Sydney Hevenor Sydney Hevenor, Daniel: Alleged violations of RCW 42.17A.205, .235, and .700 for failure to register and report contributions, expenditures, and financial affairs as a candidate (EY 19; June 19) RCW 42.17A.235, RCW 42.17A.205, RCW 42.17A.700 Scheduled for Brief Hearing
  • Allegation One: Violation of RCW 42.17A.205 for failure to file a Candidate Registration (C-1 report) within two weeks of declaring candidacy.
  • Allegation Two: Violation of RCW 42.17A.235 for failure to report contributions and expenditures (C-3 and C-4 reports)
  • Allegation Three: Violation of RCW 42.17A.700 for failure to file a Personal Statement of Financial Affairs (F-1 report), disclosing financial activities for twelve calendar months prior to declaring candidacy, within two weeks of declaring candidacy.
https://www.pdc.wa.gov/browse/enforcement-cases/53400
53381 06/20/2019 William White Dorel Singeorzan Singeorzan, Dorel: Alleged violation of RCW 42.17A.205 for failure to register as a candidate with PDC within two weeks of declaring candidacy. (EY 2019) (Jun ’19) RCW 42.17A.205 Case Closed with Reminder
  • Allegation: Alleged violation of RCW 42.17A.205 for failure to file a Candidate Registration (C-1 report) with the PDC within two weeks of declaring candidacy
https://www.pdc.wa.gov/browse/enforcement-cases/53381
53342 06/19/2019 Michelle Kaplan Patrick M. Shanahan Shanahan, Patrick: Alleged violations of RCW 42.17A.710 for failure to accurately and completely disclose personal financial affairs (June 19) RCW 42.17A.710 Assessment of Facts
  • Allegation: Violations of RCW 42.17A.710 for failure to accurately and completely disclose real property, creditors, and intangible personal property on the Personal Statement of Financial Affairs (F-1 report) for the reporting periods of calendar year 2014, 2015, and 2016.
https://www.pdc.wa.gov/browse/enforcement-cases/53342
53323 06/18/2019 Glen Morgan Debbie Bertlin Bertlin, Debbie: Alleged violations of RCW 42.17A.205 and .235 for failure to register and report contributions and expenditures as a candidate (EY 19; Jun 19) RCW 42.17A.235, RCW 42.17A.205 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Glen Morgan on June 18, 2019. The complaint alleged that Debbie Bertlin (Respondent), a 2019 candidate for Mercer Island City Council, may have violated RCW 42.17A.205 for failure to timely file a Candidate Registration (C-1 report) within two weeks of becoming a candidate; and RCW 42.17A.235 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Respondent.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Respondent; the applicable PDC reports filed by the Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to timely register as a candidate and report contributions do not amount to violations that warrant further investigation.

PDC staff is reminding Debbie Bertlin about the importance of timely candidate registration, and subsequent timely disclosure of all contribution and expenditure activities, and the timely filings of all future PDC reports in accordance with the statutes and rules.

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).

https://www.pdc.wa.gov/browse/enforcement-cases/53323
53320 06/18/2019 Elizabeth Hallock Soneya Lund Lund, Soneya: Alleged violations of RCW 42.17A.235 for failure to timely report contributions and expenditures (EY 19; June 19) RCW 42.17A.235 Request for Technical Correction

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Elizabeth Hallock on June 12, 2019. The complaint alleged that Soneya Lund, a 2019 candidate for Yakima City Council, may have violated RCW 42.17A.235 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; correspondence provided by Soneya Lund; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, filing reports under the wrong Filer ID does not amount to a violation warranting further investigation.

Soneya Lund made minor or ministerial errors on required reports, which did not materially impact the public interest. Upon notification of these errors, PDC staff migrated the data to the correct Filer ID, and Soneya Lund timely amended their ORCA records for the correct campaign, making the necessary technical corrections as requested by staff.

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).

https://www.pdc.wa.gov/browse/enforcement-cases/53320
53230 06/17/2019 Lynda Gerpheide Daniel R. Miller Miller, Daniel R.: Alleged violations of RCW 42.17A.205 & .700 for failure to timely register as a candidate & file statement of financial affairs. (EY '19) (Jun '19) RCW 42.17A.205, RCW 42.17A.700 Case Closed with Reminder

Alleged violations of RCW 42.17A.205 & .700 for failure to timely register as a candidate & file statement of financial affairs for election year 2019

https://www.pdc.wa.gov/browse/enforcement-cases/53230
53227 06/17/2019 Dori Luzzo Gilmour Brad Anderson Anderson Brad: Alleged violation of RCW 42.17A.205 for failure to timely register as a candidate with PDC for election year 2019. (Jun 19) RCW 42.17A.205 Case Closed with Reminder
  • Allegation: Alleged violation of RCW 42.17A.205 for failure to timely register as a candidate with PDC for election year 2019
https://www.pdc.wa.gov/browse/enforcement-cases/53227
52905 06/13/2019 Carrie L. Barrow Robert (Rocky) Samson III Samson, Robert (Rocky) III: Alleged violations of Chapter 42.17A RCW for failure to timely register and report contributions, expenditures, and financial affairs as a candidate; and for false statements in political advertising (EY 19; June 19) RCW 42.17A.205, RCW 42.17A.335, RCW 42.17A.700, RCW 42.17A.235 Assessment of Facts
  • Allegation One: Violation of RCW 42.17A.205 for failure to file a Candidate Registration (C-1 report) within two weeks of declaring candidacy.
  • Allegation Two: Violation of RCW 42.17A.235 for failure to report contributions and expenditures as a candidate.
  • Allegation Three: Violation of RCW 42.17A.700 for failure to timely file the Personal Statement of Financial Affairs (F-1 report) within two weeks of declaring candidacy.
  • Allegation Four: Violation of RCW 42.17A.335 for sponsoring false statements of material fact about a candidate in political advertising.
https://www.pdc.wa.gov/browse/enforcement-cases/52905
52903 06/13/2019 Donald Sorensen Jr. Jim Hill Hill, James (Jim): Alleged violations of RCW 42.17A.205, 235, and .700 for failure to register and report contributions, expenditures, and financial affairs as a candidate (EY 19; June 19) RCW 42.17A.700, RCW 42.17A.205, RCW 42.17A.235 Request for Technical Correction

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Donald Sorensen Jr. on June 5, 2019. The complaint alleged that James (Jim) Hill may have violated RCW 42.17A.205 for failure to timely file a Candidate Registration (C-1 report) with the PDC, within two weeks of declaring candidacy. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; correspondence provided by Jim Hill; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, selecting the wrong office and jurisdiction on the C-1 report does not amount to a violation warranting further investigation. 

James (Jim) Hill made minor or ministerial errors on required reports, which did not materially impact the public interest. Upon notification of these errors, Jim Hill timely amended their reports, making the necessary technical corrections as requested by staff. 
 
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). 
 

https://www.pdc.wa.gov/browse/enforcement-cases/52903
52901 06/13/2019 Glen Morgan Kathryn Campbell Campbell, Kathryn (2): Alleged violation of RCW 42.17A.700 for failure to timely disclose personal financial affairs in calendar year 2017 (EY 19; June 19) RCW 42.17A.700 Scheduled for Brief Hearing
  • Allegation: Violation of RCW 42.17A.700 for failure to timely file the Personal Statement of Financial Affairs (F-1 report), due not later than April 16, 2018, disclosing financial activities in calendar year 2017.
https://www.pdc.wa.gov/browse/enforcement-cases/52901
52807 06/12/2019 Avi Neal Elliott Shapiro Preeti Shridhar Shridhar, Preeti: Alleged Violation of RCW 42.17A.320 for failure to include sponsor identification in political advertising. RCW 42.17A.320 Case Closed with Reminder

Allegation: Violation of RCW 42.17A.320 for failure to include sponsor identification in political advertising 

https://www.pdc.wa.gov/browse/enforcement-cases/52807
52387 06/05/2019 Glen Morgan Kate Kruller Kruller, Kate: Alleged violations of RCW 42.17A.205, .235 & .240 for failure to timely register as a candidate and timely & accurately report contributions & expenditures. (EY '18 & '19) (Jun 2019) RCW 42.17A.205 Case Closed with Reminder

The complaint alleged Kate Kruller, a candidate for Tukwila City Council Member, Pos. 6 may have violated RCW 42.17A.205 for failure to timely register as a candidate and RCW 42.17A .235 and .240 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the responses provided by Kate Kruller; the applicable PDC reports filed by Kruller; and reviewed Kruller’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign does not amount to a violation warranting further investigation. 

Kate Kruller made minor or ministerial errors on her required C-1 report, which did not materially impact the public interest. Upon notification of these errors, Kruller timely re-filed the report, making the necessary technical corrections as requested by staff. 

Kate Kruller also made minor or ministerial errors on her initial C-4 report, which did not materially impact the public interest. Upon notification of these errors, Kruller timely re-filed the report, making the necessary technical corrections as requested by staff. 

PDC staff is also reminding Kate Kruller about the importance of timely disclosure of all contribution and expenditure activities, including personal property used for campaign purposes, and the timely filings of all future PDC reports in accordance with the statutes and rules. 

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). 

https://www.pdc.wa.gov/browse/enforcement-cases/52387
52310 06/04/2019 Nikolas Battle & Tiffany Chang Diana White White, Diana K.: Alleged violations of RCW 42.17A.235 & .240 for failure to timely & accurately report contributions and expenditures. (Jun 2019) RCW 42.17A.240, RCW 42.17A.235 Case Closed with Reminder
  • Allegation: Alleged violations of RCW 42.17A.235 and .240 for failure to timely and accurately report contributions and expenditures
https://www.pdc.wa.gov/browse/enforcement-cases/52310
51819 05/24/2019 Freedom Foundation (Maxford Nelsen) Williams Plant Services Williams Plant Services (2): Alleged violations of RCW 42.17A.495 & WAC 390-17-100 for failure to obtain proper employee authorization forms for political contribution payroll deductions and maintain for public inspection. (May 19) WAC 390-17-100, RCW 42.17A.495 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by the Freedom Foundation on May 20, 2019. The complaint alleged that the 19 named respondents may have violated RCW 42.17A.495 and WAC 390-17-100 for failure to maintain copies of payroll deduction authorizations for public inspection, deducting employee wages for contributions to political committees without first obtaining proper employee authorization forms, and for failure to allow employees to determine the amount of their wages to deduct for contributions to political committees on employee authorization forms. 
PDC staff reviewed the allegations; the applicable statutes and rules; and a response provided by Wayne Gold Jr. on behalf of Doubl-Kold to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.  The PDC’s action was taken because Freedom Foundation did not submit evidence of violations obtained from individual employers/contractors. 

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).  The PDC’s action does not preclude Freedom Foundation from contacting individual employers/contractors and refiling a complaint based on evidence obtained from individual employers/contractors. 

https://www.pdc.wa.gov/browse/enforcement-cases/51819
51818 05/24/2019 Freedom Foundation (Maxford Nelsen) Washington Building Trades Washington Building Trades (2): Alleged violations of RCW 42.17A.495 & WAC 390-17-100 for failure to obtain employee authorization forms for political contribution payroll deductions. (May 19) RCW 42.17A.495, WAC 390-17-100 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by the Freedom Foundation on May 20, 2019. The complaint alleged that the 19 named respondents may have violated RCW 42.17A.495 and WAC 390-17-100 for failure to maintain copies of payroll deduction authorizations for public inspection, deducting employee wages for contributions to political committees without first obtaining proper employee authorization forms, and for failure to allow employees to determine the amount of their wages to deduct for contributions to political committees on employee authorization forms. 
PDC staff reviewed the allegations; the applicable statutes and rules; and a response provided by Wayne Gold Jr. on behalf of Doubl-Kold to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.  The PDC’s action was taken because Freedom Foundation did not submit evidence of violations obtained from individual employers/contractors. 

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).  The PDC’s action does not preclude Freedom Foundation from contacting individual employers/contractors and refiling a complaint based on evidence obtained from individual employers/contractors. 

https://www.pdc.wa.gov/browse/enforcement-cases/51818
51817 05/24/2019 Freedom Foundation (Maxford Nelsen) Waste Treatment Completion Company, LLC Waste Treatment Completion Company, LLC (2): Alleged violations of RCW 42.17A.495 & WAC 390-17-100 for failure to obtain employee authorization forms for political contribution payroll deductions. (May 19) WAC 390-17-100, RCW 42.17A.495 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by the Freedom Foundation on May 20, 2019. The complaint alleged that the 19 named respondents may have violated RCW 42.17A.495 and WAC 390-17-100 for failure to maintain copies of payroll deduction authorizations for public inspection, deducting employee wages for contributions to political committees without first obtaining proper employee authorization forms, and for failure to allow employees to determine the amount of their wages to deduct for contributions to political committees on employee authorization forms. 
PDC staff reviewed the allegations; the applicable statutes and rules; and a response provided by Wayne Gold Jr. on behalf of Doubl-Kold to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.  The PDC’s action was taken because Freedom Foundation did not submit evidence of violations obtained from individual employers/contractors. 

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).  The PDC’s action does not preclude Freedom Foundation from contacting individual employers/contractors and refiling a complaint based on evidence obtained from individual employers/contractors. 

https://www.pdc.wa.gov/browse/enforcement-cases/51817
51816 05/24/2019 Freedom Foundation (Maxford Nelsen) S2 Industrial, Inc. S2 Industrial, Inc: Alleged violations of RCW 42.17A.495 & WAC 390-17-100 for failure to obtain proper employee authorization forms for political contribution payroll deductions and maintain for public inspection. (May 19) RCW 42.17A.495, WAC 390-17-100 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by the Freedom Foundation on May 20, 2019. The complaint alleged that the 19 named respondents may have violated RCW 42.17A.495 and WAC 390-17-100 for failure to maintain copies of payroll deduction authorizations for public inspection, deducting employee wages for contributions to political committees without first obtaining proper employee authorization forms, and for failure to allow employees to determine the amount of their wages to deduct for contributions to political committees on employee authorization forms. 
PDC staff reviewed the allegations; the applicable statutes and rules; and a response provided by Wayne Gold Jr. on behalf of Doubl-Kold to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.  The PDC’s action was taken because Freedom Foundation did not submit evidence of violations obtained from individual employers/contractors. 

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).  The PDC’s action does not preclude Freedom Foundation from contacting individual employers/contractors and refiling a complaint based on evidence obtained from individual employers/contractors. 

https://www.pdc.wa.gov/browse/enforcement-cases/51816
51815 05/24/2019 Freedom Foundation (Maxford Nelsen) McKinstry Company, LLC McKinstry Company, LLC (2): Alleged violations of RCW 42.17A.495 & WAC 390-17-100 for failure to obtain proper employee authorization forms for political contribution payroll deductions and maintain for public inspection. (May 19) WAC 390-17-100, RCW 42.17A.495 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by the Freedom Foundation on May 20, 2019. The complaint alleged that the 19 named respondents may have violated RCW 42.17A.495 and WAC 390-17-100 for failure to maintain copies of payroll deduction authorizations for public inspection, deducting employee wages for contributions to political committees without first obtaining proper employee authorization forms, and for failure to allow employees to determine the amount of their wages to deduct for contributions to political committees on employee authorization forms. 
PDC staff reviewed the allegations; the applicable statutes and rules; and a response provided by Wayne Gold Jr. on behalf of Doubl-Kold to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.  The PDC’s action was taken because Freedom Foundation did not submit evidence of violations obtained from individual employers/contractors. 

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).  The PDC’s action does not preclude Freedom Foundation from contacting individual employers/contractors and refiling a complaint based on evidence obtained from individual employers/contractors. 

https://www.pdc.wa.gov/browse/enforcement-cases/51815
51814 05/24/2019 Freedom Foundation (Maxford Nelsen) JH Kelly, LLC JH Kelly, LLC (2): Alleged violations of RCW 42.17A.495 & WAC 390-17-100 for failure to obtain proper employee authorization forms for political contribution payroll deductions and maintain for public inspection. (May 19) WAC 390-17-100, RCW 42.17A.495 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by the Freedom Foundation on May 20, 2019. The complaint alleged that the 19 named respondents may have violated RCW 42.17A.495 and WAC 390-17-100 for failure to maintain copies of payroll deduction authorizations for public inspection, deducting employee wages for contributions to political committees without first obtaining proper employee authorization forms, and for failure to allow employees to determine the amount of their wages to deduct for contributions to political committees on employee authorization forms. 
PDC staff reviewed the allegations; the applicable statutes and rules; and a response provided by Wayne Gold Jr. on behalf of Doubl-Kold to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.  The PDC’s action was taken because Freedom Foundation did not submit evidence of violations obtained from individual employers/contractors. 

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).  The PDC’s action does not preclude Freedom Foundation from contacting individual employers/contractors and refiling a complaint based on evidence obtained from individual employers/contractors. 

https://www.pdc.wa.gov/browse/enforcement-cases/51814
51813 05/24/2019 Freedom Foundation (Maxford Nelsen) Joint Apprenticeship and Training Committee Joint Apprenticeship and Training Committee (2): Alleged violations of RCW 42.17A.495 & WAC 390-17-100 for failure to obtain proper employee authorization forms for political contribution payroll deductions and maintain for public inspection. (May 19) WAC 390-17-100, RCW 42.17A.495 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by the Freedom Foundation on May 20, 2019. The complaint alleged that the 19 named respondents may have violated RCW 42.17A.495 and WAC 390-17-100 for failure to maintain copies of payroll deduction authorizations for public inspection, deducting employee wages for contributions to political committees without first obtaining proper employee authorization forms, and for failure to allow employees to determine the amount of their wages to deduct for contributions to political committees on employee authorization forms. 
PDC staff reviewed the allegations; the applicable statutes and rules; and a response provided by Wayne Gold Jr. on behalf of Doubl-Kold to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.  The PDC’s action was taken because Freedom Foundation did not submit evidence of violations obtained from individual employers/contractors. 

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).  The PDC’s action does not preclude Freedom Foundation from contacting individual employers/contractors and refiling a complaint based on evidence obtained from individual employers/contractors. 

https://www.pdc.wa.gov/browse/enforcement-cases/51813
51812 05/24/2019 Freedom Foundation (Maxford Nelsen) Iron Mountain Management Iron Mountain Management (2): Alleged violations of RCW 42.17A.495 & WAC 390-17-100 for failure to obtain proper employee authorization forms for political contribution payroll deductions and maintain for public inspection. (May 19) WAC 390-17-100, RCW 42.17A.495 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by the Freedom Foundation on May 20, 2019. The complaint alleged that the 19 named respondents may have violated RCW 42.17A.495 and WAC 390-17-100 for failure to maintain copies of payroll deduction authorizations for public inspection, deducting employee wages for contributions to political committees without first obtaining proper employee authorization forms, and for failure to allow employees to determine the amount of their wages to deduct for contributions to political committees on employee authorization forms. 
PDC staff reviewed the allegations; the applicable statutes and rules; and a response provided by Wayne Gold Jr. on behalf of Doubl-Kold to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.  The PDC’s action was taken because Freedom Foundation did not submit evidence of violations obtained from individual employers/contractors. 

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).  The PDC’s action does not preclude Freedom Foundation from contacting individual employers/contractors and refiling a complaint based on evidence obtained from individual employers/contractors. 

https://www.pdc.wa.gov/browse/enforcement-cases/51812
51811 05/24/2019 Freedom Foundation (Maxford Nelsen) Intermech, Inc. Intermech, Inc. (2):Alleged violations of RCW 42.17A.495 & WAC 390-17-100 for failure to obtain proper employee authorization forms for political contribution payroll deductions and maintain for public inspection. (May 19) WAC 390-17-100, RCW 42.17A.495 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by the Freedom Foundation on May 20, 2019. The complaint alleged that the 19 named respondents may have violated RCW 42.17A.495 and WAC 390-17-100 for failure to maintain copies of payroll deduction authorizations for public inspection, deducting employee wages for contributions to political committees without first obtaining proper employee authorization forms, and for failure to allow employees to determine the amount of their wages to deduct for contributions to political committees on employee authorization forms. 
PDC staff reviewed the allegations; the applicable statutes and rules; and a response provided by Wayne Gold Jr. on behalf of Doubl-Kold to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.  The PDC’s action was taken because Freedom Foundation did not submit evidence of violations obtained from individual employers/contractors. 

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).  The PDC’s action does not preclude Freedom Foundation from contacting individual employers/contractors and refiling a complaint based on evidence obtained from individual employers/contractors. 

https://www.pdc.wa.gov/browse/enforcement-cases/51811
51810 05/24/2019 Freedom Foundation (Maxford Nelsen) Infrasource Services, LLC Infrasource Services, LLC (2): Alleged violations of RCW 42.17A.495 & WAC 390-17-100 for failure to obtain proper employee authorization forms for political contribution payroll deductions and maintain for public inspection. (May 19) WAC 390-17-100, RCW 42.17A.495 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by the Freedom Foundation on May 20, 2019. The complaint alleged that the 19 named respondents may have violated RCW 42.17A.495 and WAC 390-17-100 for failure to maintain copies of payroll deduction authorizations for public inspection, deducting employee wages for contributions to political committees without first obtaining proper employee authorization forms, and for failure to allow employees to determine the amount of their wages to deduct for contributions to political committees on employee authorization forms. 
PDC staff reviewed the allegations; the applicable statutes and rules; and a response provided by Wayne Gold Jr. on behalf of Doubl-Kold to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.  The PDC’s action was taken because Freedom Foundation did not submit evidence of violations obtained from individual employers/contractors. 

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).  The PDC’s action does not preclude Freedom Foundation from contacting individual employers/contractors and refiling a complaint based on evidence obtained from individual employers/contractors. 

https://www.pdc.wa.gov/browse/enforcement-cases/51810
51809 05/24/2019 Freedom Foundation (Maxford Nelsen) Indian Eyes, LLC Indian Eyes, LLC (2): Alleged violations of RCW 42.17A.495 & WAC 390-17-100 for failure to obtain proper employee authorization forms for political contribution payroll deductions and maintain for public inspection. (May 19) WAC 390-17-100, RCW 42.17A.495 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by the Freedom Foundation on May 20, 2019. The complaint alleged that the 19 named respondents may have violated RCW 42.17A.495 and WAC 390-17-100 for failure to maintain copies of payroll deduction authorizations for public inspection, deducting employee wages for contributions to political committees without first obtaining proper employee authorization forms, and for failure to allow employees to determine the amount of their wages to deduct for contributions to political committees on employee authorization forms. 
PDC staff reviewed the allegations; the applicable statutes and rules; and a response provided by Wayne Gold Jr. on behalf of Doubl-Kold to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.  The PDC’s action was taken because Freedom Foundation did not submit evidence of violations obtained from individual employers/contractors. 

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).  The PDC’s action does not preclude Freedom Foundation from contacting individual employers/contractors and refiling a complaint based on evidence obtained from individual employers/contractors. 

https://www.pdc.wa.gov/browse/enforcement-cases/51809
51808 05/24/2019 Freedom Foundation (Maxford Nelsen) Doubl-Kold Doubl-Kold (2): Alleged violations of RCW 42.17A.495 & WAC 390-17-100 for failure to obtain employee authorization forms for political contribution payroll deductions. (May 19) RCW 42.17A.495, WAC 390-17-100 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by the Freedom Foundation on May 20, 2019. The complaint alleged that the 19 named respondents may have violated RCW 42.17A.495 and WAC 390-17-100 for failure to maintain copies of payroll deduction authorizations for public inspection, deducting employee wages for contributions to political committees without first obtaining proper employee authorization forms, and for failure to allow employees to determine the amount of their wages to deduct for contributions to political committees on employee authorization forms. 
PDC staff reviewed the allegations; the applicable statutes and rules; and a response provided by Wayne Gold Jr. on behalf of Doubl-Kold to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.  The PDC’s action was taken because Freedom Foundation did not submit evidence of violations obtained from individual employers/contractors. 

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).  The PDC’s action does not preclude Freedom Foundation from contacting individual employers/contractors and refiling a complaint based on evidence obtained from individual employers/contractors. 

https://www.pdc.wa.gov/browse/enforcement-cases/51808
51807 05/24/2019 Freedom Foundation (Maxford Nelsen) Day & Zimmerman NPS Day & Zimmerman NPS (2): Alleged violations of RCW 42.17A.495 & WAC 390-17-100 for failure to obtain proper employee authorization forms for political contribution payroll deductions and maintain for public inspection. (May 19) RCW 42.17A.495, WAC 390-17-100 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by the Freedom Foundation on May 20, 2019. The complaint alleged that the 19 named respondents may have violated RCW 42.17A.495 and WAC 390-17-100 for failure to maintain copies of payroll deduction authorizations for public inspection, deducting employee wages for contributions to political committees without first obtaining proper employee authorization forms, and for failure to allow employees to determine the amount of their wages to deduct for contributions to political committees on employee authorization forms. 
PDC staff reviewed the allegations; the applicable statutes and rules; and a response provided by Wayne Gold Jr. on behalf of Doubl-Kold to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.  The PDC’s action was taken because Freedom Foundation did not submit evidence of violations obtained from individual employers/contractors. 

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).  The PDC’s action does not preclude Freedom Foundation from contacting individual employers/contractors and refiling a complaint based on evidence obtained from individual employers/contractors. 

https://www.pdc.wa.gov/browse/enforcement-cases/51807
51806 05/24/2019 Freedom Foundation (Maxford Nelsen) Cogen Cleaning Technology Cogen Cleaning Technology: Alleged violations of RCW 42.17A.495 & WAC 390-17-100 for failure to obtain proper employee authorization forms for political contribution payroll deductions and maintain for public inspection. (May 19) WAC 390-17-100, RCW 42.17A.495 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by the Freedom Foundation on May 20, 2019. The complaint alleged that the 19 named respondents may have violated RCW 42.17A.495 and WAC 390-17-100 for failure to maintain copies of payroll deduction authorizations for public inspection, deducting employee wages for contributions to political committees without first obtaining proper employee authorization forms, and for failure to allow employees to determine the amount of their wages to deduct for contributions to political committees on employee authorization forms. 
PDC staff reviewed the allegations; the applicable statutes and rules; and a response provided by Wayne Gold Jr. on behalf of Doubl-Kold to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.  The PDC’s action was taken because Freedom Foundation did not submit evidence of violations obtained from individual employers/contractors. 

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).  The PDC’s action does not preclude Freedom Foundation from contacting individual employers/contractors and refiling a complaint based on evidence obtained from individual employers/contractors. 

https://www.pdc.wa.gov/browse/enforcement-cases/51806
51805 05/24/2019 Freedom Foundation (Maxford Nelsen) Central Washington Refrigeration Central Washington Refrigeration (2): Alleged violations of RCW 42.17A.495 & WAC 390-17-100 for failure to obtain proper employee authorization forms for political contribution payroll deductions and maintain for public inspection. (May 19) WAC 390-17-100, RCW 42.17A.495 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by the Freedom Foundation on May 20, 2019. The complaint alleged that the 19 named respondents may have violated RCW 42.17A.495 and WAC 390-17-100 for failure to maintain copies of payroll deduction authorizations for public inspection, deducting employee wages for contributions to political committees without first obtaining proper employee authorization forms, and for failure to allow employees to determine the amount of their wages to deduct for contributions to political committees on employee authorization forms. 
PDC staff reviewed the allegations; the applicable statutes and rules; and a response provided by Wayne Gold Jr. on behalf of Doubl-Kold to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.  The PDC’s action was taken because Freedom Foundation did not submit evidence of violations obtained from individual employers/contractors. 

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).  The PDC’s action does not preclude Freedom Foundation from contacting individual employers/contractors and refiling a complaint based on evidence obtained from individual employers/contractors. 

https://www.pdc.wa.gov/browse/enforcement-cases/51805
51804 05/24/2019 Freedom Foundation (Maxford Nelsen) BNB Mechanical, LLC BNB Mechanical, LLC (2): Alleged violations of RCW 42.17A.495 & WAC 390-17-100 for failure to obtain proper employee authorization forms for political contribution payroll deductions and maintain for public inspection. (May 19) WAC 390-17-100, RCW 42.17A.495 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by the Freedom Foundation on May 20, 2019. The complaint alleged that the 19 named respondents may have violated RCW 42.17A.495 and WAC 390-17-100 for failure to maintain copies of payroll deduction authorizations for public inspection, deducting employee wages for contributions to political committees without first obtaining proper employee authorization forms, and for failure to allow employees to determine the amount of their wages to deduct for contributions to political committees on employee authorization forms. 
PDC staff reviewed the allegations; the applicable statutes and rules; and a response provided by Wayne Gold Jr. on behalf of Doubl-Kold to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.  The PDC’s action was taken because Freedom Foundation did not submit evidence of violations obtained from individual employers/contractors. 

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).  The PDC’s action does not preclude Freedom Foundation from contacting individual employers/contractors and refiling a complaint based on evidence obtained from individual employers/contractors. 

https://www.pdc.wa.gov/browse/enforcement-cases/51804
51803 05/24/2019 Freedom Foundation (Maxford Nelsen) Apollo Mechanical Contractors Apollo Mechanical Contractors (2): Alleged violations of RCW 42.17A.495 & WAC 390-17-100 for failure to obtain proper employee authorization forms for political contribution payroll deductions and maintain for public inspection. (May 19) RCW 42.17A.495, WAC 390-17-100 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by the Freedom Foundation on May 20, 2019. The complaint alleged that the 19 named respondents may have violated RCW 42.17A.495 and WAC 390-17-100 for failure to maintain copies of payroll deduction authorizations for public inspection, deducting employee wages for contributions to political committees without first obtaining proper employee authorization forms, and for failure to allow employees to determine the amount of their wages to deduct for contributions to political committees on employee authorization forms. 
PDC staff reviewed the allegations; the applicable statutes and rules; and a response provided by Wayne Gold Jr. on behalf of Doubl-Kold to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.  The PDC’s action was taken because Freedom Foundation did not submit evidence of violations obtained from individual employers/contractors. 

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).  The PDC’s action does not preclude Freedom Foundation from contacting individual employers/contractors and refiling a complaint based on evidence obtained from individual employers/contractors. 

https://www.pdc.wa.gov/browse/enforcement-cases/51803
51802 05/24/2019 Freedom Foundation (Maxford Nelsen) American Electric, Inc American Electric, Inc. (2): Alleged violations of RCW 42.17A.495 & WAC 390-17-100 for failure to obtain proper employee authorization forms for political contribution payroll deductions and maintain for public inspection. (May 19) RCW 42.17A.495, WAC 390-17-100 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by the Freedom Foundation on May 20, 2019. The complaint alleged that the 19 named respondents may have violated RCW 42.17A.495 and WAC 390-17-100 for failure to maintain copies of payroll deduction authorizations for public inspection, deducting employee wages for contributions to political committees without first obtaining proper employee authorization forms, and for failure to allow employees to determine the amount of their wages to deduct for contributions to political committees on employee authorization forms. 
PDC staff reviewed the allegations; the applicable statutes and rules; and a response provided by Wayne Gold Jr. on behalf of Doubl-Kold to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, no evidence supports a finding of a violation warranting further investigation.  The PDC’s action was taken because Freedom Foundation did not submit evidence of violations obtained from individual employers/contractors. 

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).  The PDC’s action does not preclude Freedom Foundation from contacting individual employers/contractors and refiling a complaint based on evidence obtained from individual employers/contractors. 

https://www.pdc.wa.gov/browse/enforcement-cases/51802
51796 05/24/2019 Carly Coburn Lisa Thomas Thomas, Lisa: Alleged Violation of RCW 42.17A.205 for failure to file C-1 Candidate Registration Report within two weeks of declaring candidacy. Case Closed with Reminder

Allegation: Violation of RCW 42.17A.205 for failure to file C-1 Candidate Registration within two weeks of declaring candidacy.

https://www.pdc.wa.gov/browse/enforcement-cases/51796
51330 05/15/2019 Andrew Saturn Linda Oosterman Oosterman, Linda (5): Alleged violation of Chapter 42.17A RCW for receiving and failing to report over-limit contributions reported as independent expenditures by Up for Thurston County (EY 18; May 19) WAC 390-05-210, RCW 42.17A.205, RCW 42.17A.235, RCW 42.17A.240, RCW 42.17A.310, RCW 42.17A.265, RCW 42.17A.270 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Andrew Saturn on April 23, 2019. The complaint alleged that Linda Oosterman, a 2018 candidate for Public Utility Commissioner for Thurston County, may have violated RCW 42.17A.205 for failure to report Paul Berendt as a committee officer; RCW 42.17A.235, .240, .310, and WAC 390-05-210 for failure to accurately and timely report in-kind contributions from expenditures coordinated with Up for Thurston County (Sponsored by Puget Sound Energy); RCW 42.17A.265 for failure to timely report last minute in-kind contributions from coordinated expenditures with Up for Thurston County (Sponsored by Puget Sound Energy) within 48 hours of receipt; and RCW 42.17A.270 for failure to timely and accurately report contributions made by Puget Sound Energy to Up for Thurston County (Sponsored by Puget Sound Energy), allegedly earmarked for coordinated expenditures with Linda Oosterman; and RCW 42.17A.420 for accepting contributions from coordinated expenditures made by Up for Thurston County exceeding $5,000 within 21 days of the general election.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the responses provided by the Re-Elect Linda Oosterman Campaign (Campaign); the minutes from the Thurston County Democratic Party Endorsement Meeting; the applicable PDC reports filed by the Campaign and Up for Thurston County (Sponsored by Puget Sound Energy); and queried the Campaign and Up for Thurston County (Sponsored by Puget Sound Energy)’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

The complaint alleged the Committee failed to disclose Paul Berendt as a Committee officer based on: (1) a letter Paul Berendt allegedly distributed at a meeting of the Thurston County Democratic Party in coordination with the Oosterman Campaign; and (2) a $16.39 in-kind contribution made from Paul Berendt to the Committee for a high-resolution copy of a photograph of Linda Oosterman was taken from a photo-sharing website and used to facilitate the electioneering communication mailer.

The evidence provided, which staff reviewed, does not support a finding that Paul Berendt served as an officer for the Oosterman Campaign in the capacity to “make, direct, or authorize contributions, expenditure, strategic or policy decisions on behalf of the committee.” 

The complaint alleged that the electioneering communication sponsored and mailed by the Committee totaling $9,952 in support of Linda Oosterman, was made in cooperation and coordination with the Campaign, and should have been reported as an in-kind contribution in accordance with RCW 42.17A.240 and WAC 390-05-210, based on the same facts concerning officer status as noted in the letters dismissing this case.  In addition, the complaint alleged that the factors listed in WAC 390-05-210 of presumptive coordination were met by the ‘Dear Friends’ letter, and the quality of a photograph used on a mailer printed by Capitol City Press, stating “[g]eneral members of the public would have no way to know about this letter or receive a copy unless they were working in close coordination with the Linda Oosterman campaign as a member of the executive committee” citing an email from the Campaign’s consultant Joe Hyer, which states “I don’t remember any significant quantity of that letter being produced- I was given a copy to review, but the candidate didn’t have much of a mailing list that would work with this letter.

No evidence was provided that the Committee expenditures were made in “cooperation, concert or collaboration with, or at the request or suggestion” of a Linda Oosterman, authorized campaign, or an agent of the campaign.

The remaining alleged violations of failure to timely report last minute in-kind contributions, failure to timely and accurately report earmarked in-kind contributions, and accepting contributions exceeding $5,000 within 21 days of the general election rely upon a finding that the expenditures undertaken by Up for Thurston County (Sponsored by Puget Sound Energy) constituted in-kind contributions to the Campaign, which the evidence does not support.

Based on our findings staff has determined that, in this instance, the evidence does not support a finding of a violation warranting further investigation.

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).

https://www.pdc.wa.gov/browse/enforcement-cases/51330
51097 05/10/2019 Darrell Lambert Fuzzy Fletcher Fletcher Fuzzy: Alleged violations of RCW 42.17A.205 & .700 for failure to timely register candidate committee & file a Personal Financial Affairs Statement within two weeks of publicly declaring candidacy. (May 19) RCW 42.17A.205, RCW 42.17A.700 Case Closed with Reminder

This case alleged that Fuzzy Fletcher (the "Respondent") may have violated RCW 42.17A.205 and .700 by failing to timely register as a candidate and file a statement of financial affairs within two weeks of publicly declaring candidacy. 

PDC staff reviewed the allegations, applicable statutes, rules and reporting requirements, the response provided by the Respondent, and the applicable PDC reports filed by the Respondent to determine whether they supported a finding of one or more violations.

Based on staff's review, the PDC found that the Respondent publicly announced his candidacy for Snoqualmie City Council position #4 at a Snoqualmie City Council Meeting on April 8, 2019. Pursuant to RCW 42.17A.205 and .700, the Respondent was required to file a Candidate Registration (C-1 report) and a Personal Financial Affairs Statement (F-1 report) with the PDC within two weeks of becoming a candidate (e.g. publicly announcing candidacy). The Respondent indicated that the late reports were the result of his erroneous belief that they were not due until after a candidate officially files with the appropriate Elections office.

Upon being notified of the missing reports, the Respondent quickly contacted the PDC and made a good-faith effort to resolve the matter by filing the required reports. The PDC received the Respondent's F-1 report on 5/14/19 and C-1 report on 5/16/19. 

The Respondent's noncompliance was the result of a good-faith error or omission, the impact to the public was minimal, the oversight did not occur during a critical election period, and the Respondent quickly took corrective action.  PDC reminded the Respondent about the importance of timely registering as a candidate and submitting a statement of financial affairs with the PDC within two weeks of becoming a candidate, and timely filing all future PDC reports. Based on this information, the PDC found that no further action was warranted and dismissed the matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/51097
51086 05/10/2019 Freedom Foundation (Maxford Nelsen) Washington State Council of County and City Employees Washington State Council of County and City Employees (WSCCCE): Alleged violation of RCW 42.17A.235, .240 for failure to timely and accurately report in-kind contributions, and timely report contributions and expenditures, for 2014-2019. (May 19) RCW 42.17A.240, RCW 42.17A.235 Case Closed with Written Warning

A complaint was filed against the Washington State Council of County and City Employees PAC (Committee), a continuing political committee registered with the PDC, alleging violations of RCW 42.17A.235 and .240 by failing to timely file Campaign Full Summary Contributions and Expenditures reports (C-4 reports) disclosing contribution and expenditure activities, including staff time and the overhead costs to operate and maintain the committee for calendar years 2014 through 2018.

PDC staff's review found  the Committee failed to timely report $3,843.78 for in-kind contributions received from Washington State Council of County and City Employees (WSCCE) for calendar years 2014 through 2018, and that information was not disclosed until July 23, 2019, when the amended C-4 reports were filed. 

However, based on staff's findings and the information listed below, PDC staff has determined that the facts in this instance do not amount to a finding of a violation warranting further investigation.  Staff considered several mitigating factors that included: (1) the $3,843.78 in late disclosed in-kind contributions received by the Committee from WSCCE for staffing and overhead costs of running the PAC was not material in amount and had no impact on the public; (2) the Committee timely disclosed the majority of the C-3 and C-4 reports for calendar years 2014 through 2018; and (3) neither the WSCCE nor the Committee has any prior PDC violations.

Pursuant to WAC 390-37-060(1)(d), PDC staff formally warned the Committee concerning the importance of timely and accurately filing C-3 and C-4 reports disclosing contribution and expenditure activities undertaken by a continuing political committee, in accordance with PDC laws, rules and reporting requirements.  This formal written warning conveys staff’s expectation that the Committee will fully comply with the reporting requirements for a continuing political committee in the future, including the timely disclosure of the WSCCE staffing and overhead costs of running the PAC. The Commission will consider this formal written warning if there are any future PDC law or rule violations by Committee.

Based on this information, PDC staff is dismissing the remaining allegations in this matter against the Washington State Council of County and City Employees PAC in accordance with RCW 42.17A.755(1).  

https://www.pdc.wa.gov/browse/enforcement-cases/51086
50825 05/02/2019 Reece A. Williams Dale Ragan Ragan, Dale: Alleged violation of RCW 42.17A.255 by failing to report independent expenditure for political advertising. (Apr 2019) RCW 42.17A.255 Case Closed with Reminder

This case alleged that the Respondent may have violated RCW 42.17A.255 by failing to report independent expenditure(s) for political advertising (e.g. No on Fire Bond signs). PDC staff reviewed the allegations, applicable statutes, rules and reporting requirements, the response provided by the Respondent, and the applicable PDC reports filed by the Respondent to determine whether they support a finding of one or more violations.

Based on staff's review, the PDC found that the Respondent purchased 50 signs from SignRocket on March 20, 2019 for $253.50. The signs contained an opposition ad concerning a fire bond and were distributed in Mt. Vernon in late March/early April of 2019. The signs were purchased and paid for by the Respondent using his own funds. 

Pursuant to RCW 42.17A.255, a person who makes an independent expenditure equaling $100 or more (aggregate, per election campaign) in support or opposition to a candidate or ballot proposition is required to file a C-6 report with the PDC within 5 days. The Respondent indicated he was unaware of the need to report independent expenditures but quickly took corrective action upon being notified of his registration requirements.

PDC staff reminded the Respondent about the importance of timely disclosing any independent expenditures for political advertising and timely filing all future PDC reports, as applicable. The PDC found that no further action was warranted and dismissed the matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/50825
50704 04/29/2019 Susan Wilkins Lake Washington School District Officials (Jane Stavem, Superintendent) Lake Washington School District Officials: Alleged violations of RCW 42.17A.555 for misuse of public facilities to support levy measure (EY 19; Apr 19) RCW 42.17A 555 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Susan Wilkins on April 23, 2019. The complaint alleged that Officials and Public Employees of the Lake Washington School District may have violated RCW 42.17A.555 for misuse of public facilities to support a levy measure.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by the Lake Washington School District (District); the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, the evidence does not support a finding of a violation warranting further investigation.

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).

https://www.pdc.wa.gov/browse/enforcement-cases/50704
50698 04/29/2019 Nikita Minkin Ginny Scantlebury Scantlebury, Ginny: Alleged violation of RCW 42.17A.320 for failure to include sponsor identification in political advertising. (Apr 2019) RCW 42.17A.320 Case Closed with Reminder

This case alleged that the Respondent may have violated RCW 42.17A.320 by failing to include sponsor identification in political advertising (e.g. brochures, website). PDC staff reviewed the allegations, applicable statutes, rules and reporting requirements, and the responses provided by the Respondent to determine whether they support a finding of one or more violations.

Based on staff's review, the PDC found that the Respondent's campaign created and distributed brochures in approximately April of 2019 that lacked the sponsor's name and address. This sponsor ID information was also omitted from the Respondent's website, which was created on April 8, 2019.

Upon being notified of the missing sponsor ID information, the Respondent ceased using its brochures and quickly resolved the matter by updating its website and adding stickers containing sponsor name and address to its existing brochures.

PDC staff reminded the Respondent about the importance of including sponsor ID on all future political advertising. Based on the information, the PDC found that no further action was warranted and dismissed the matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/50698
50640 04/26/2019 David Churchman Paul M Herrera Herrera, Paul: Alleged Violation of RCW 42.17A.700 for failure to timely file the Personal Financial Affairs Statement (F-1 Report) within two weeks of becoming a candidate. (APR 2019, EY 2019) Case Closed with Reminder

Allegation: Violation of RCW 42.17A.700 for failure to timely file the F-1 Personal Financial Affairs Statement within two weeks of becoming a candidate. 

https://www.pdc.wa.gov/browse/enforcement-cases/50640
50639 04/26/2019 Nick Minkin Ginny Scantleburry Scantlebury, Virginia: Alleged Violation of RCW 42.17A.320 for failure to disclose complete sponsorship information. (APR 2019, EY 2019) RCW 42.17A.320 Closed Administratively

This case was closed administratively because the PDC received two, substantially similar complaints from a single Complainant alleging potential violations of the same statute by a single Respondent. The Respondent's use of a nickname also made it appear that the complaints concerned two, different individuals. 

For clarity and the convenience of the parties involved, the PDC consolidated the complaints, evidence and response in a single case, which is retained as PDC Case 50698. Conversely, PDC Case 50639 is now closed.

https://www.pdc.wa.gov/browse/enforcement-cases/50639
50329 04/18/2019 Andrew Saturn Jay Rodne Rodne, Jay: Alleged violations of RCW 42.17A.600 and WAC 390-20-143 for failure to register PacRim Bridges as a lobbyist firm, and Jay Rodne as a lobbyist agent (EY 19; Apr 19) RCW 42.17A.600, WAC 390-20-143 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Andrew Saturn on April 10, 2019. The complaint alleged that Jay Rodne may have violated: (1) RCW 42.17A.600 and WAC 390-20-143 for failure to register Pac Rim Bridges, LLC as a lobbyist firm; and (2) RCW 42.17A.600 for failure to register himself as a lobbyist with Pac Rim Bridges, LLC.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the response(s) provided by Jay Rodne and Senator Doug Ericksen in a related case (PDC Case 50328), to determine whether the record supports a finding of one or more violations.

The written responses from Jay Rodne and Senator Doug Ericksen, confirm that Pac Rim Bridges, LLC and its two named governors, do not meet the statutory definition of a lobbyist and that neither Pac Rim nor Mr. Rodne have engaged in lobbying activities that would require registration with the PDC.

Based on these findings staff has determined that, in this instance, no evidence supports a finding of an actual violation warranting further investigation.

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).

https://www.pdc.wa.gov/browse/enforcement-cases/50329
50328 04/18/2019 Andrew Saturn Doug Ericksen Ericksen, Doug: Alleged violations of RCW 42.17A.600 and WAC 390-20-143 for failure to register PacRim Bridges as a lobbyist firm, and Doug Ericksen as a lobbyist agent (EY 19; Apr 19) RCW 42.17A.600, WAC 390-20-143 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Andrew Saturn on April 10, 2019. The complaint alleged that Doug Ericksen, a Senator in Legislative District 42, may have violated: (1) RCW 42.17A.600 and WAC 390-20-143 for failure to register Pac Rim Bridges, LLC as a lobbyist firm; and (2) RCW 42.17A.600 for failure to register himself as a lobbyist with Pac Rim Bridges, LLC.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the response(s) provided by Senator Ericksen and Jay Rodne in a related case (PDC Case 50329), to determine whether the record supports a finding of one or more violations.

The written responses from Senator Ericksen and Jay Rodne, confirm that Pac Rim Bridges, LLC and its two named governors, do not meet the statutory definition of a lobbyist and that neither Pac Rim nor Senator Ericksen have engaged in lobbying activities that would require registration with the PDC.

Based on these findings staff has determined that, in this instance, no evidence supports a finding of an actual violation warranting further investigation.

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).

https://www.pdc.wa.gov/browse/enforcement-cases/50328
50297 04/18/2019 Robert L Fiedler, Glenn Ash International Association of Firefighters Local 1983 International Association of Firefighters Local 1983: Alleged violation of RCW 42.17A.555 by using public facilities to promote a ballot measure. (Apr 2019) RCW 42.17A.555 Case Closed with No Evidence of Violations

This case alleged that International Association of Firefighters Local 1983 (the "Respondent") may have violated RCW 42.17A.555 by using public facilities (Mt. Vernon Fire Department's address) to promote a ballot measure (advertisement supporting Prop 1 fire bond).

PDC staff reviewed the allegations, applicable statutes, rules and reporting requirements, and the responses provided by the Respondent to determine whether they supported a finding of one or more violations. Staff's review found the following: 

The Respondent sponsored a political ad supporting Prop 1 fire bond that included an address of "1901 N LaVenture, ATTN Union Mail Box, Mount Vernon, WA 98273," the address used by the City of Mt. Vernon Fire Dept., its administrative staff, and Fire Station 2. The mailer clearly identified the Respondent as its sponsor, as required under RCW 42.17A.320, and included a specific reference to the union's mailbox. The Respondent timely filed the necessary C-6 reports with the PDC, disclosing its independent expenditures pertaining to Prop 1. 

RCW 42.17A.555 prohibits elected officials and employees of public offices and agencies from using or authorizing the use of public office/agency facilities to promote or oppose any ballot proposition. Activities exempted from this prohibition include, but are not limited to, activities that are "part of the normal and regular conduct of the office or agency." However, whereas a union is not an elected official or public employee, it cannot violate RCW 42.17A.555.

 The Respondent stated it has maintained a mailbox at 1901 N LaVenture Rd Mt. Vernon, WA 98273 for approximately 20 years and such access is a prevailing right under its collective bargaining agreement with the City of Mt. Vernon. The Respondent indicated that the mailer was created by union members during non-work hours on personal, home computers and sent to a printer via personal email. The Respondent also indicated that "no materials were created or distributed at or from any facility at any time and no campaign activity took place outside of regularly scheduled union meetings." 

As a public agency, the City of Mt. Vernon is subject to RCW 42.17A.555. However, the city's practice of allowing the Respondent to use a mailbox located at its fire station appears to be normal and regular conduct for the city under WAC 390-05-273 because the activity is lawful, authorized by the city, and usual (not extraordinary) given the fact that the Respondent has received correspondence of all kinds via the mailbox for several years. 

Based on these findings, PDC staff determined that the Respondent's use of a mailbox located on city property - and the disclosure of this address in political advertising - does not amount to a violation warranting further investigation. The PDC found that no further action was warranted and dismissed the matter in accordance with RCW 42.17A.755(1).

 

 

 

https://www.pdc.wa.gov/browse/enforcement-cases/50297
50292 04/18/2019 Kaidi Williams Evergreen Yes (Randy Pepple) Evergeen Yes: Alleged Violation of RCW 42.17A.320 for failure to include complete sponsor identification on political advertising. RCW 42.17A.320 Case Closed with Reminder

Allegation: Violation of RCW 42.17A.320 for failure to include complete sponsor identification on political advertising. 

https://www.pdc.wa.gov/browse/enforcement-cases/50292
50178 04/15/2019 James Busey Barry DePaoli DePaoli, Barry: Alleged violations of RCW 42.17A.555 for use of school district resources to distribute political advertising from Citizens Campaign Committee (EY 19; April 19) RCW 42.17A 555 Resolved through Statement of Understanding

Allegation: Violation of RCW 42.17A.555 for misuse of school district emails to distribute political advertising sponsored by the Citizens Campaign Committee, a political committee in favor of a bond measure for the Lake Chelan School District.

https://www.pdc.wa.gov/browse/enforcement-cases/50178
49906 04/11/2019 Tony Guzman Juan Eddie Orozco (aka) John Edward Orozco Orozco, Juan: Alleged Violation of RCW 42.17A.555 for use of public facilities to support political campaign expenditures. RCW 42.17A 555 Case Closed with No Evidence of Violations

Allegation: Violation of RCW 42.17A.555 for use of public facilities to support political campaign expenditures.

https://www.pdc.wa.gov/browse/enforcement-cases/49906
49439 04/03/2019 Andrew Saturn VerifyMore VerifyMore: Alleged Violation of RCW 42.17A.207 for failure to register as an incidental committee as required by SB 5991 which took effect on January 1, 2019. (MARCH 2019) Case Closed with No Evidence of Violations

Allegation: Violation of RCW 42.17A.207 for failure to register as an incidental committee following the creation of the Washington State DISCLOSE Act (SB 5991), which took effect on January 1, 2019.  

https://www.pdc.wa.gov/browse/enforcement-cases/49439
49254 03/29/2019 Andrew Saturn Linda Oosterman Oosterman, Linda (2): Alleged violations of RCW 42.17A.305, .235 & .310 for failure to report electioneering communications & in-kind contributions, and fully describe advertising expenditures. (Mar 2019) RCW 42.17A.305, RCW 42.17A.235, RCW 42.17A.310 Case Closed with Reminder

This case alleged that Linda Oosterman (the “Respondent”) may have violated RCW 42.17A.305, .235 & .310 by failing to report electioneering communications and in-kind contributions, and fully disclose advertising expenditures for a “Dear Friends” letter and “Vote Linda” color copy & cardstock “strips.” 

PDC staff reviewed the allegations, the applicable statutes, rules and reporting requirements, the responses provided by the Respondent, and the applicable PDC reports filed by the Respondent to determine whether the record supports a finding of one or more violations. 

Based on its findings, staff determined that, in this instance, the Respondent’s failure to fully describe expenditures reported on C-4 reports does not amount to an actual violation warranting further investigation. PDC staff reminded Linda Oosterman about the importance of fully describing advertising and other expenditure details on C-4 reports pursuant to RCW 42.17A.235. 

The Respondent made minor or ministerial errors on required reports, which did not materially impact the public interest. Upon notification of these errors, the Respondent timely amended her reports, making the necessary technical corrections. The PDC found that no further action was warranted and dismissed the matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/enforcement-cases/49254
48963 03/25/2019 Andrew Saturn Linda Oosterman Oosterman, Linda: Alleged violations of RCW 42.17A.330, .240 & .555 for failure use a recent photo in political advertising, report in-kind contribution; and by using public facilities to assist an election campaign. (Mar 2019) RCW 42.17A.555, RCW 42.17A.240, RCW 42.17A.330 Case Closed with No Evidence of Violations

This case alleged violations of RCW 42.17A.330, .240 & .555 1) for failure to use at least one photo, taken within the last 5 years, in all political advertising (e.g. 2012 photo used for profile image on campaign Facebook page), 2) failure to report use of the photograph as an in-kind contribution to the current campaign; and 3) by using public facilities (e.g. an agency photo) to assist an election campaign. PDC staff reviewed the allegations, applicable statutes, rules, and reporting requirements, the response provided by the Respondent, and the applicable PDC reports filed by the Respondent to determine if they support a finding of one or more violations. Staff’s review found the following:

The Respondent is an elected Commissioner for the Thurston County Public Utility District (PUD) and was a candidate for this office & jurisdiction during election year 2018. As a result, the Respondent is subject to RCW 42.17A.330 and .240, which require 1) at least one photograph used in any political advertising to have been taken within the last five years; and 2) the monetary value of any contributions to be reported. The Respondent is also subject to .555, which prohibits elected officials from using a public office or agency facilities to assist an election campaign. 

The evidence provided by the Complainant included four photos that appeared on the Respondent's campaign Facebook account and a 2012 photo that appears on the PUD's official website, the website of the non-profit organization Pro Truth Pledge, and was published in a county voter's pamphlet. Of the photographic evidence provided, only the Facebook photo(s) appear to constitute political advertising. 

The photos used on the Respondent's campaign Facebook page were taken in 2017 & 2018 by volunteer supporters, who are not professional photographers, using cell phones; the photos were provided to the Respondent at no cost. Subsequently, the photos comply with the age requirements of .330. Per WAC 390-17-405, photos taken by unpaid persons who do not normally charge a fee are "volunteer services" that do not need to be reported as contributions. The value of the photos themselves appear to be de minimis in nature. 

The 2012 photo was taken by Vento Photography and the expenditure was reported by the Respondent to the PDC in April, 2012; this professional photo was gifted by the Respondent to the PUD in 2013, was not used for campaign purposes, and need not be reported as an in-kind contribution to the Respondent under .240. Pro Truth Pledge obtained the 2012 photo from another source & re-posted it without the Respondent's knowledge. The evidence provided by the Complainant was insufficient to demonstrate the 2012 photo was used for political advertising during the Respondent's 2018 election campaign. Furthermore, the professional photo paid for by the Respondent in 2012 was not produced by a public office or agency and therefore does not constitute use of public facilities under .555.

https://www.pdc.wa.gov/browse/enforcement-cases/48963
48709 03/18/2019 Dave Churchman David Prutzman Prutzman, David: Alleged violations of Chapter 42.17A RCW for failure to register and report as a political committee, and failure to disclose sponsor ID on political advertising (EY 19; Mar 19) RCW 42.17A.205, RCW 42.17A.235, RCW 42.17A.320 Case Closed with Reminder

The complaint alleged David Prutzman violated RCW 42.17A.205 for failing to timely register a political committee, RCW 42.17A.235 for failing to report contributions and expenditures as a political committee and RCW 42.17A.320 for failing to disclose true sponsors. All allegations relate to the of Strong Mayor initiative in Puyallup.

Staff has determined that in this instance, the failure to report expenditures of $108.63 does not amount to an actual violation warranting further investigation. PDC staff is reminding David Prutzman about the importance of the requirements regarding filing accurately and timely in future years in accordance with PDC laws and rules. 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). 

https://www.pdc.wa.gov/browse/enforcement-cases/48709
48521 03/14/2019 Andrew Saturn Up for Thurston County Up for Thurston County (3): Alleged violations of RCW 42.17A.205 for failure to disclose committee officers, .320 for failure to include officer name in on political advertising, .750 for filing false documents with the Commission (EY 18; Mar 19) rcw 42.17a.750, RCW 42.17A.205, RCW 42.17A.320 Case Closed with Written Warning
  • Allegation One: Violation of RCW 42.17A.205 for failure to disclose any full committee officers on the Committee Registration (C-1pc) at time of initial registration, amending the registration to attest that Jason Bennett provided more than ministerial services, then amending the registration again to attest that no person served as a full committee officer.
  • Allegation Two: Violation of RCW 42.17A.750 for knowingly filing false C-1pc reports with the Commission.
  • Allegation Three: Violation of RCW 42.17A.320 for failure to list Jason Bennett in sponsor identification on political advertising as the sole controlling individual for Up for Thurston County.
https://www.pdc.wa.gov/browse/enforcement-cases/48521
48424 03/13/2019 Eli Sanders Google, LLC. Google, LLC (2): Alleged violation of RCW 42.17A.345 and WAC 390-18-050 for failure to promptly provide documents and books of account concerning political advertising, upon request from any person (EY 19; Mar 19) WAC 390-18-050, RCW 42.17A.345 Investigation of Possible Violation
Allegation: Violation of RCW 42.17A.345 and WAC 390-18-050 for failure to provide documents and books of account detailing the exact nature and extend of political advertising services rendered, within 24 hours of request from any person.
https://www.pdc.wa.gov/browse/enforcement-cases/48424
48311 03/11/2019 Edward Horejs III Jennifer Robertson Robertson, Jennifer: Alleged violations of RCW 42.17A.240 and WAC 390-16-205 for failure to accurately report expenditures (EY 15; Mar 19) wac 390-16-205, WAC 390-16-207, RCW 42.17A.240 Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Edward Horejs on March 5, 2019. The complaint alleged that Jennifer Robertson, a 2015 candidate for Bellevue City Council may have violated RCW 42.17A.240 for failure to accurately and completely disclose in-kind contributions and debts on Summary Full Campaign Contribution and Expenditure reports (C-4 reports), and WAC 390-16-037 and WAC 390-16-205 for failure to accurately disclose sub-vendor breakdowns for expenditures undertaken by the campaign. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Jennifer Robertson; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to accurately and completely break down expenditure details does not amount to a violation warranting further investigation.

Pursuant to WAC 390-37-060(1)(d), Jennifer Robertson will receive a formal written warning concerning failure to accurately and completely disclose expenditure details, including the number of items and sub-vendors actually providing the goods and services for the campaign. The formal written warning will include staff’s expectation that Jennifer Robertson provides detailed descriptions of expenditure details on all future required reports. The Commission will consider the formal written warning in deciding on further 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 this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/48311
48307 03/11/2019 Andrew Saturn Facebook, Inc. Facebook, Inc. (4): Alleged violations of RCW 42.17A.345 and WAC 390-18-050 for failure to maintain and provide documents and books of account for public inspection (EY 19; Mar 19) WAC 390-18-050, RCW 42.17A.345 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Andrew Saturn on March 1, 2019. The complaint alleged that Facebook Inc., a commercial advertiser, may have violated RCW 42.17A.345 for failure to promptly provide documents and books of account regarding political advertising upon request.

PDC staff reviewed the allegations; the applicable statutes and rules; and the response provided by Facebook Inc. to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, no evidence supports a finding that the complainant made a request for commercial advertiser records relating to political advertising, or that Facebook Inc. denied the complainant access to these records.

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).

https://www.pdc.wa.gov/browse/enforcement-cases/48307
48011 03/06/2019 Roger Lenk Brian Brooks Brooks, Brian & Kennewick SD #17 Board of Directors: Alleged violation of RCW 42.17A.555 by failing to provide required notice of a Prop. 1 bond-related topic & allow the public to express opposing views at its Jan. 9, 2019 Board Meeting. (Mar 19) RCW 42.17A.555 Case Closed with Reminder

This case alleged that Kennewick School District No. 17 Board of Directors Dawn Adams, Brian Brooks, Heather Kintzley, Ron Mabry & Ben Messinger (collectively “the Respondents”) may have violated RCW 42.17A.555 by failing to provide notice of – and give the public an opportunity to express opposing views about – action taken at its January 9, 2019 Board Meeting that supported a ballot proposition.

PDC staff reviewed the allegations and evidence, the applicable statutes, rules and reporting requirements, and the response provided by the Respondents to determine whether they support a finding of one or more violations. 

Based on its findings, staff determined that, in this instance, the Respondent’s January 9, 2019 approved motions to move, adopt, and later rescind a suggestion to send a letter to the newspaper supporting Prop. 1 does not amount to an actual violation warranting further investigation. PDC staff reminded Kennewick School District No. 17 Board of Directors about the importance of 1) not using public facilities to directly or indirectly promote or oppose any ballot propositions; and 2) ensuring the public is provided with adequate notice and an opportunity to express opposing views when the Board takes any action at a public meeting that concerns a ballot proposition. The PDC found that no further action was warranted and dismissed the matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/enforcement-cases/48011
48010 03/06/2019 Roger Lenk Ron Mabry Mabry, Ron & Kennewick SD #17 Board of Directors: Alleged violation of RCW 42.17A.555 by failing to provide required notice of a Prop. 1 bond-related topic & allow the public to express opposing views at its Jan. 9, 2019 Board Meeting. (Mar 19) RCW 42.17A.555 Case Closed with Reminder

This case alleged that Kennewick School District No. 17 Board of Directors Dawn Adams, Brian Brooks, Heather Kintzley, Ron Mabry & Ben Messinger (collectively “the Respondents”) may have violated RCW 42.17A.555 by failing to provide notice of – and give the public an opportunity to express opposing views about – action taken at its January 9, 2019 Board Meeting that supported a ballot proposition.

PDC staff reviewed the allegations and evidence, the applicable statutes, rules and reporting requirements, and the response provided by the Respondents to determine whether they support a finding of one or more violations. 

Based on its findings, staff determined that, in this instance, the Respondent’s January 9, 2019 approved motions to move, adopt, and later rescind a suggestion to send a letter to the newspaper supporting Prop. 1 does not amount to an actual violation warranting further investigation. PDC staff reminded Kennewick School District No. 17 Board of Directors about the importance of 1) not using public facilities to directly or indirectly promote or oppose any ballot propositions; and 2) ensuring the public is provided with adequate notice and an opportunity to express opposing views when the Board takes any action at a public meeting that concerns a ballot proposition. The PDC found that no further action was warranted and dismissed the matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/enforcement-cases/48010
48009 03/06/2019 Roger Lenk Ben Messinger Messinger, Ben & Kennewick SD #17 Board of Directors: Alleged violation of RCW 42.17A.555 by failing to provide required notice of a Prop. 1 bond-related topic & allow the public to express opposing views at its Jan. 9, 2019 Board Meeting. (Mar 19) RCW 42.17A.555 Case Closed with Reminder

This case alleged that Kennewick School District No. 17 Board of Directors Dawn Adams, Brian Brooks, Heather Kintzley, Ron Mabry & Ben Messinger (collectively “the Respondents”) may have violated RCW 42.17A.555 by failing to provide notice of – and give the public an opportunity to express opposing views about – action taken at its January 9, 2019 Board Meeting that supported a ballot proposition.

PDC staff reviewed the allegations and evidence, the applicable statutes, rules and reporting requirements, and the response provided by the Respondents to determine whether they support a finding of one or more violations. 

Based on its findings, staff determined that, in this instance, the Respondent’s January 9, 2019 approved motions to move, adopt, and later rescind a suggestion to send a letter to the newspaper supporting Prop. 1 does not amount to an actual violation warranting further investigation. PDC staff reminded Kennewick School District No. 17 Board of Directors about the importance of 1) not using public facilities to directly or indirectly promote or oppose any ballot propositions; and 2) ensuring the public is provided with adequate notice and an opportunity to express opposing views when the Board takes any action at a public meeting that concerns a ballot proposition. The PDC found that no further action was warranted and dismissed the matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/enforcement-cases/48009
48008 03/06/2019 Roger Lenk Heather Kintzley Kintzley, Heather & Kennewick SD #17 Board of Directors: Alleged violation of RCW 42.17A.555 by failing to provide required notice of a Prop. 1 bond-related topic & allow the public to express opposing views at its Jan. 9, 2019 Board Meeting. (Mar 19) RCW 42.17A.555 Case Closed with Reminder

This case alleged that Kennewick School District No. 17 Board of Directors Dawn Adams, Brian Brooks, Heather Kintzley, Ron Mabry & Ben Messinger (collectively “the Respondents”) may have violated RCW 42.17A.555 by failing to provide notice of – and give the public an opportunity to express opposing views about – action taken at its January 9, 2019 Board Meeting that supported a ballot proposition.

PDC staff reviewed the allegations and evidence, the applicable statutes, rules and reporting requirements, and the response provided by the Respondents to determine whether they support a finding of one or more violations. 

Based on its findings, staff determined that, in this instance, the Respondent’s January 9, 2019 approved motions to move, adopt, and later rescind a suggestion to send a letter to the newspaper supporting Prop. 1 does not amount to an actual violation warranting further investigation. PDC staff reminded Kennewick School District No. 17 Board of Directors about the importance of 1) not using public facilities to directly or indirectly promote or oppose any ballot propositions; and 2) ensuring the public is provided with adequate notice and an opportunity to express opposing views when the Board takes any action at a public meeting that concerns a ballot proposition. The PDC found that no further action was warranted and dismissed the matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/enforcement-cases/48008
48006 03/06/2019 Roger Lenk Dawn Adams Adams, Dawn & Kennewick SD #17 Board of Directors: Alleged violation of RCW 42.17A.555 by failing to provide required notice of a Prop. 1 bond-related topic & allow the public to express opposing views at its Jan. 9, 2019 Board Meeting. (Mar 19) RCW 42.17A.555 Case Closed with Reminder

This case alleged that Kennewick School District No. 17 Board of Directors Dawn Adams, Brian Brooks, Heather Kintzley, Ron Mabry & Ben Messinger (collectively “the Respondents”) may have violated RCW 42.17A.555 by failing to provide notice of – and give the public an opportunity to express opposing views about – action taken at its January 9, 2019 Board Meeting that supported a ballot proposition.

PDC staff reviewed the allegations and evidence, the applicable statutes, rules and reporting requirements, and the response provided by the Respondents to determine whether they support a finding of one or more violations. 

Based on its findings, staff determined that, in this instance, the Respondent’s January 9, 2019 approved motions to move, adopt, and later rescind a suggestion to send a letter to the newspaper supporting Prop. 1 does not amount to an actual violation warranting further investigation. PDC staff reminded Kennewick School District No. 17 Board of Directors about the importance of 1) not using public facilities to directly or indirectly promote or oppose any ballot propositions; and 2) ensuring the public is provided with adequate notice and an opportunity to express opposing views when the Board takes any action at a public meeting that concerns a ballot proposition. The PDC found that no further action was warranted and dismissed the matter in accordance with RCW 42.17A.755(1). 

https://www.pdc.wa.gov/browse/enforcement-cases/48006
47998 03/06/2019 Jeanne Martin Our Olympic Communities Enterprise Washington Our Olympic Communities Enterprise Washington: Alleged violations of RCW 42.17A.320 & .335 by failing to identify Top Five Contributors & including false statements of material fact in political adverting (Mar 2019) RCW 42.17A.320, RCW 42.17A.335, WAC 390-18, RCW 42.17A.255, RCW 42.17A.305, RCW 42.17A.240, RCW 42.17A.260 Investigation of Possible Violation

A complaint was filed with the PDC against Our Olympic Communities Enterprise Washington alleging the committee may have violated RCW 42.17A.320 for failing to fully identify the top five contributors on political advertising; RCW 42.17A.335 by making a false statement of material fact in opposition ads; RCW 42.17A.335 by sponsoring an ad that falsely represents Irene Bowling as an incumbent; RCW 42.17A.320 and WAC 390-18 by failing to clearly identify sponsor identification on political advertising; and RCW 42.17A.260 by failing to timely file Independent Spending and Electioneering Communications (C-6) reports., alleging the Committee may have violated RCW 42.17A.220 by failing to timely deposit contributions within five business days of receipt and RCW 42.17A.235 by failing to timely file Monetary Contribution reports (C-3 reports) and Campaign Summary Receipts and Expenditure reports (C-4 reports). 

After PDC staff conducted a preliminary review and assessment of the facts, PDC staff opened a formal investigation and held an Initial Hearing (Case Status Review Hearing) Olympic Communities Enterprise Washington on May 21, 2019, pursuant to RCW 42.17A.755, and WACs 390-37-060 and 390-37-071. 

https://www.pdc.wa.gov/browse/enforcement-cases/47998
47572 02/26/2019 Eli Sanders Facebook, Inc. Facebook, Inc. (3): Alleged violations of RCW 42.17A.345 and WAC 390-18-050 for failure to provide documents and books of account for public inspection as a commercial advertiser (EY 19; Feb 19) WAC 390-18-050, RCW 42.17A.345 Investigation of Possible Violation
Allegation: Violation of RCW 42.17A.345 and WAC 390-18-050 for failure to maintain and provide documents and books of account as a commercial advertiser, promptly upon request from any person.
https://www.pdc.wa.gov/browse/enforcement-cases/47572
47514 02/25/2019 Andrew Saturn The Olympian The Olympian: Alleged violations of RCW 42.17A for failure to allow public inspection of commercial advertiser records & disclose sponsor ID on ads, and by publishing false statements about a candidate. (Feb 19) RCW 42.17A.335, RCW 42.17A.345, RCW 42.17A.240, RCW 42.17A.320 Case Closed with Reminder

This case alleged that The Olympian (the "Respondent") violated RCW 42.17A.345 by failing to allow public inspection of commercial advertiser records, .335 by publishing false statements re: a candidate (e.g. editorials), and .320 for failure to disclose sponsor information on political ads. 

PDC staff reviewed the allegations, applicable statutes, rules, and the response provided by the Respondent to determine whether it supported a finding of one or more violations. Staff's review showed that the Respondent is a commercial advertiser required to make its documents & books of accounts concerning political advertising & electioneering communications available for public inspection in-person during normal business hours or, if requested electronically, by email or online publication. 

The Respondent published two advertisements for Linda Oosterman's campaign in October, 2018, both of which included sponsor identification as required under RCW 42.17A.320. Between October 19, 2018 and February 12, 2019, the Complainant sent three emails to the Respondent's employees and a message via its website portal requesting commercial advertiser records related to the Oosterman campaign ads, but never received a response. The Complainant indicated he visited the Respondent in-person on February 14, 2019 but was denied access to records, a charge the Respondent denied.

The Complainant failed to fully identify the records sought prior to February 12, 2019 and requested some information outside the scope of RCW 42.17A.345. However, the Respondent failed to respond to the requests, ask for missing information and timely fulfill the portion of the request that fell within the scope of .345 and WAC 390-18-050. The Respondent indicated its belief the such requests were required to be made in-person. However, PDC laws and rules do not specify how requests for commercial advertiser records must be made and WAC 390-18-050 allows the public to request records electronically, which can be satisfied by email or online publication. The Respondent provided the requested records to the Complainant by email on April 22, 2019. 

This complaint also alleged that three editorial articles published by the Respondent between October 27 and November 9, 2018 contained false statements about him, in violation of RCW 42.17A.335, which prohibits a person from sponsoring, with actual malice, a false statement of material fact about a candidate for public office in political advertising or electioneering communications. However, WAC 390-05-290(4) and RCW 42.17A.005(22)(b)(iii) define political advertising and electioneering communications to exclude editorial content in a regularly scheduled new medium that is not controlled by a candidate or committee where payment for the space or time is not normally required. Subsequently, the editorials did not meet the criteria for libel and defamation set forth in .335. 

Based on the information, the PDC found that no further action was warranted and dismissed the matter in accordance with RCW 42.17A.755(1). 

PDC staff reminded the Respondent about the importance of making commercial advertiser documents and books of account open for public inspection during normal business hours for three years following the election to which they pertain. PDC staff clarified that this information can be requested electronically or in-person & conveyed its expectation that the Respondent make such information available to the public in future years in accordance with PDC laws and rules. 



 

https://www.pdc.wa.gov/browse/enforcement-cases/47514
47381 02/21/2019 Glen Morgan Eric Newman Newman, Eric: Alleged violations of RCW 42.17A.235 & .240 & WAC 390-16-037 for failure to timely report contributions & expenditures and fully describe expenditures in election year 2016. (Feb 2019) RCW 42.17A.240, RCW 42.17A.235, WAC 390-16-037 Case Closed with Reminder
  • Allegation One: Alleged violations of RCW 42.17A.235 & .240 for failure to timely report contributions & expenditures in election year 2016. 
  • Allegation Two: Alleged violations of RCW 42.17A.240 & WAC 390-16-037 by not fully describing expenditures in election year 2016.
https://www.pdc.wa.gov/browse/enforcement-cases/47381
47303 02/19/2019 Freedom Foundation (Maxford Nelsen) Gerald Hudson SEIU Political Education and Action Fund: Alleged Violation of RCW 42.17A.250, .405, .442 for failure to timely file Out-of-State Poltiical Committee Reports (C-5) and for failure to meet WA registered voter requirements. (FEB 2019) RCW 42.17A.205, RCW 42.17A.405, RCW 42.17A.442 Case Closed with Written Warning

A complaint was filed against Service Employees International Union Political Education & Action Fund (SEIU PEAF), a federal political committee, alleging violations of: (1) RCW 42.17A.250 by failing to timely and accurately file Out-of State Political Committee reports (C-5 reports) as an out-of-state committee: (2) RCW 42.17A.405 by failing to receive $10 from ten registered voters in Washington State prior to making contributions to candidates; and (3) RCW 42.17A.442 by failing to received $10 from ten registered voters in Washington State prior to making contributions to another political committee.

As noted in the complaint return letter, SEIU PEAF failed to timely report $1,534,947 in contributions received from SEIU in Washington, DC for the 2018 elections, and that information was not disclosed until March 12, 2019 when the amended C-5 reports were filed.  While the amount of late reported contributions was significant, there were several mitigating factors considered by staff that included SEIU PEAF: 

(1) disclosed no additional expenditures as having been made in 2018 on the amended C-5 reports; 

(2) timely disclosed the $747,983 in expenditures made as contributions to political committees in Washington state and registered with the PDC on the initial C-5 reports; 

(3) did not spend any of the $1,534,947 in late reported contributions received from SEIU in Washington state; and 

(4) received a total of $8,128,222 in aggregate contributions from SEIU in Washington, DC, so the $747,983 spent in Washington state in 2018 by SEIU PEAF, represented 9.2% of total expenditure activities.

Based on these findings, PDC staff has determined that the facts in this instance do not amount to a finding of an actual violation warranting further investigation.  However, pursuant to WAC 390-37-060(1)(b), PDC staff will be formally warning SEIU PEAF concerning the importance of timely and accurately filing C-5 reports disclosing contribution and expenditure activities undertaken by an out-of-state political committee as required by PDC laws and rules. 

This formal written warning conveys staff’s expectation that SEIU PEAF will fully comply with the C-5 reporting requirements in the future, should the committee make additional contributions to candidates or political committees registered with the PDC in Washington State. The Commission will consider this formal written warning if there are any future PDC law or rule violations by SEIU PEAF.

Based on this information, PDC staff is dismissing the remaining allegations in this matter against the Service Employees International Union Political Education & Action Fund PAC in accordance with RCW 42.17A.755(1).  

 

https://www.pdc.wa.gov/browse/enforcement-cases/47303
47265 02/19/2019 Delina Cline Don Bradshaw Bradshaw, Don: Alleged violations of RCW 42.17A.320 for failure to disclose sponsor ID on political advertising (EY 17; Feb 19) RCW 42.17A.320 Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Delina Cline on February 14, 2019. The complaint alleged that Don Bradshaw, write-in candidate for Winlock City Council, may have violated RCW 42.17A.320 for failure to disclose sponsor identification on political advertising.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Don Bradshaw; the applicable PDC reports filed by Respondent; and a commercial advertiser disclosure from the Town Crier Community Newspaper, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, failure to disclose sponsor identification on political advertising does not amount to an actual violation warranting further investigation.

Pursuant to WAC 390-37-060(1)(b), Don Bradshaw will receive a formal written warning concerning failure to disclose sponsor identification on political advertising sponsored by the candidate. The formal written warning will include staff’s expectation that Don Bradshaw accurately and completely discloses sponsor identification on any future political advertising. The Commission will consider the formal written warning in deciding on further 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 this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/47265
47250 02/19/2019 Northwest Accountability Project We the Governed We the Governed: Alleged violations of Chapter 42.17A RCW for failure to report contributions and expenditures, failure to disclose sponsor ID, and failure to report independent expenditures/electioneering communications (Feb 19) RCW 42.17A.235, RCW 42.17A.255, RCW 42.17A.260, RCW 42.17A.305, RCW 42.17A.320 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by the Northwest Accountability Project on March 29, 2019. The complaint alleged that We the Governed, a 2016 political committee, may have violated RCW 42.17A.235 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign; RCW 42.17A.255, .260, and .305 for failure to timely and accurately file Independent Spending and Electioneering Communication reports (C-6 reports), disclosing independent expenditures and electioneering communications; and RCW 42.17A.320 for failure to include sponsor identification and top five contributors on political advertising. 

The complaint also alleged that We the Governed, LLC, may have violated RCW 42.17A.205 for failure to file a Political Committee Registration report (C-1pc report); RCW 42.17A.235 for failure to timely and accurately file C-3 reports and C-4 reports, disclosing contributions and expenditures undertaken by the Campaign; RCW 42.17A.255, .260, and .305 for failure to timely and accurately file C-6 reports, disclosing independent expenditures and electioneering communications; and RCW 42.17A.320 for failure to include sponsor identification and top five contributors on political advertising.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the responses provided by We the Governed; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, insufficient evidence has been provided to support a finding of a violation warranting further investigation.

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).

https://www.pdc.wa.gov/browse/enforcement-cases/47250
47222 02/18/2019 Andrew Saturn Thurston County Democratic Women Thurston County Democratic Women: Alleged violations of Chapter 42.17A RCW for failure to re-register as mini-reporting, exceeding mini-reporting limits, and failure to timely report contributions and expenditures (Feb 19) RCW 42.17A.205, RCW 42.17A.235, RCW 42.17A.240, WAC 390-16-125 Case Closed with Reminder
  • Allegation One: Violation of RCW 42.17A.205 for failure to re-register as mini-reporting in 2019.
  • Allegation Two: Violation of WAC 390-16-125 for exceeding mini-reporting limitations without written approval from PDC in 2018.
  • Allegation Three: Violations of RCW 42.17A.235 for failure to timely report contributions and expenditures after exceeding mini-reporting limitations in 2018.
https://www.pdc.wa.gov/browse/enforcement-cases/47222
47219 02/18/2019 Freedom Foundation (Maxford Nelsen) Washington State Labor Council AFL-CIO PPP Committee Washington State Labor Council AFL-CIO PPP Cmte: Alleged violations of RCW 42.17A.235, RCW 42.17A.235, RCW 42.17A.240, RCW 42.17A.435 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Maxford Nelsen on behalf of the Freedom Foundation on February 14, 2019. The complaint alleged that Washington State Labor Council AFL-CIO PPP Committee (WSLC AFL-CIO PPP), a Continuing Political Committee may have violated: (1) RCW 42.17A.235 and 42.17A.240 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports) disclosing campaign activities and for failure to disclose contributions from individuals identified as “President’s Club” members for calendar years 2014, 2015, 2016 and 2017; and (2) RCW 42.17A.435 for failure to accurately disclose the true source of contributions from “President’s Club” members on C-3 reports. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Dmitri Iglitzin, on behalf of his client WSLC AFL-CIO PPP; and the applicable PDC reports filed by Respondent, to determine whether the record supports a finding of one or more violations.

Although staff’s review of the C-3 and C-4 reports filed by WSLC AFL-CIO PPP for calendar years 2014, 2015, 2016 and 2017, and the committee’s response did not warrant further investigation, staff’s general review of the committee’s campaign activity reports did find instances during 2014, 2015, 2016 and 2017 of late reporting and reports requiring amendments in order to accurately disclose receipts and expenditures. 

Based on these findings staff has determined that, in this instance, failure to timely and accurately disclose WSLC AFL-CIO PPP’s campaign activity for calendar years 2014, 2015, 2016 and 2017 does not amount to an actual violation warranting further investigation or enforcement action.

PDC staff reminded WSLC AFL-CIO PPP about the importance of the timely disclosure of all contribution and expenditure activities, specifically those occurring during the accelerated reporting schedule prior to and after any election in which WSLC AFL-CIO PPP is participating, and the timely filings of all future PDC reports in accordance with the statutes and rules.

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).

https://www.pdc.wa.gov/browse/enforcement-cases/47219
47218 02/18/2019 Glen Morgan Laurie Dolan Dolan, Laurie: Alleged violation of RCW 42.17A.435 for failure to identify source of contribution (EY 16; Feb 19) RCW 42.17A.435 Request for Technical Correction
Allegation: Violation of RCW 42.17A.435 for failure to identify source of refunded contribution from Chris Marr as coming from Regence.
https://www.pdc.wa.gov/browse/enforcement-cases/47218
47130 02/14/2019 Glen Morgan Laurie Jinkins Jinkins, Laurie: Alleged Violation of RCW 42.17A.700, 710 for failing to disclose a corporation, association, or entity in which an office, ownership, partnership, or financial interest is held. (FEB 2019) RCW 42.17A.710, RCW 42.17A.700 Case Closed with No Evidence of Violations

The complaint alleged Laurie Jinkins may have violated RCW 42.17A.700 and RCW 42.17A.710 by “failing to disclose a corporation, association, or entity on the F-1 Personal Financial Affairs Statement in which an office, ownership, partnership, or financial interest is held.” Specifically, it alleged Jinkins failed to report her controlling interest in LM PAC. 

PDC staff reviewed the allegations listed in the complaint you filed, the statutes, rules and reporting requirements, and the response to the complaint provided by Taki V. Flevaris, attorney representing Laurie Jinkins. 

Based on staff’s review, we found RCW 42.17A.710(1)(g) does not include “political committee” in the list of entities required to be reported on the F-1 Supplement, and historically, PDC staff has not advised F-1 filers to include political committees on the F-1 Supplement when the filer holds a position of committee officer in a political committee. 

Based on these findings staff has determined that, in this instance, the failure to list LM PAC on an F-1 Supplement does not appear to be an actual violation warranting further investigation.

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). 

https://www.pdc.wa.gov/browse/enforcement-cases/47130
47128 02/14/2019 Glen Morgan Matthew Randazzo Randazzo, Matthew: Alleged Violation of RCW 42.17A.605 for failure to submit recent photograph at time of lobbyist registration. (FEB 2019) RCW 42.17A.605 Case Closed with No Evidence of Violations
Allegation: Violation of RCW 42.17A.605 for failure to submit recent photograph at time of registration.
https://www.pdc.wa.gov/browse/enforcement-cases/47128
47080 02/13/2019 Glen Morgan Kittitas County Democratic Central Committee Kittitas County Democratic Central Committee: Alleged violations of RCW 42.17A.235 & .240 for failure to timely & accurately report debt and accurately report expenditures. (Feb 2019) RCW 42.17A.240, RCW 42.17A.235 Case Closed with Reminder
  • Allegation One: Alleged violation of RCW 42.17A.235 & .240 for failure to timely & accurately report debt resulting from March 2, 2018 Stipulation & Judgment with State of WA including $7,912.50 non-suspended portion of civil penalty, $6,740 in fees & costs, and the unpaid portion of $5,217.17 forfeited for over-limit contributions.
  • Allegation Two: Alleged violation of RCW 42.17A.240 by failing to accurately report settlement payments made to State of WA (e.g. recipient name & description of expense fields for 6/21/18 & 12/21/18 payments)
https://www.pdc.wa.gov/browse/enforcement-cases/47080
47065 02/13/2019 Glen Morgan Pierce County Democratic Central Committee Pierce County Democratic Central Committee (5): Alleged violations of RCW 42.17A.240 for failure to report debt for settlement judgment (Feb 19) RCW 42.17A.240 Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the complaints filed by Glen Morgan on February 3, 2019 and February 5, 2019. Your complaints alleged that the Pierce County Democratic Central Committee (PCDCC), a bona fide political party committee may have violated: (1) RCW 42.17A.235 and .240 by failing to timely and accurately file Monetary Contribution reports (C-3 reports) disclosing proceeds from a low-cost fundraiser; and (2) RCW 42.17A.240 by failing to accurately disclose the unsuspended portion of a penalty as a debt.

PDC staff reviewed the allegations listed in the two complaints filed; the applicable statutes, rules, and reporting requirements; the response provided by Rick Offner, Treasurer for Pierce County Democratic Central Committee; and the applicable PDC reports filed by Respondent, to determine whether the record supports a finding of one or more violations.

Based on staff’s review, the late filed C-3 report cited in PDC Case 46474 was the result of an internal audit conducted by the PCDCC. The Commission encourages the practice of internal review and the submittal of missing or incorrect reports of campaign activities.

Based on these findings staff has determined that, in this instance, failure to timely file one C-3 report disclosing proceeds from a low-cost fundraiser and failure to disclose the October 27, 2017 unsuspended penalty owed to the AGO as a debt, does not warrant further investigation or enforcement action.

Pursuant to WAC 390-37-060(1)(d), the PCDCC received a formal written warning concerning failure to timely and accurately file Summary Full Campaign Contribution and Expenditure reports (C-4 reports) disclosing debt. The formal written warning included staff’s expectation that the PCDCC timely file accurate and complete C-4 reports in future years in accordance with PDC laws and rules. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

In addition, PDC staff reminded the PCDCC about the importance of timely filing all Monetary Contributions reports (C-3 reports) disclosing deposits made, no matter the source of contributions or the amount. The reminder included staff’s expectation that the PCDCC continue utilizing internal controls and audits to ensure timely and accurate reporting of all campaign activities in the future. 

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).

https://www.pdc.wa.gov/browse/enforcement-cases/47065
46701 02/07/2019 Glen Morgan Campaign to Prevent Fraud and Protect Seniors Campaign to Prevent Fraud and Protect Seniors: Alleged violation of RCW 42.17A.235 & .240 for failure to timely and accurately report contributions & expenditures. (Feb 2019) RCW 42.17A.235, RCW 42.17A.240 Case Closed with Reminder

This complaint alleged that Campaign to Prevent Fraud and Protect Seniors (the "Respondent" violated RCW 42.17A.235 & .240 by failing to timely & accurately report contributions & expenditures. PDC staff reviewed the allegations, statutes, rules and reporting requirements, and the Respondent's registrations, and found that it submitted its post-general C-4 report disclosing November, 2018 contribution & expenditure activities 30 days late. All other C-4 reports for 2018 were timely filed by the Respondent and the vast majority of the expenditures reported were for legal/compliance and accounting purposes, as opposed to electoral activity. The late-reported contributions & expenditures represented less than 1% of the Respondent's total contributions & expenditures for 2018. 

The Respondent made a good-faith effort to remedy its omission by filing the missing report for November on January 9, 2019. The Respondent indicated that it is a 2016 ballot committee so the financial activity disclosed on the late report did not pertain to an upcoming election or deprive the public of critical information. Based on the findings, PDC staff determined that, in this instance, failure to timely & accurately report contributions & expenditures for November, 2018 does not amount to an actual violation warranting further investigation. 

PDC staff reminded the Respondent about the importance of timely disclosing all contribution & expenditure activities and the timely filing of all future PDC reports, including the C-4 report. The PDC dismissed the matter and did not conduct a more formal investigation into the complaint or pursue further enforcement action in this case. 

https://www.pdc.wa.gov/browse/enforcement-cases/46701
46694 02/07/2019 Glen Morgan Walla Walla County Demo Central Committee Walla Walla County Demo Central Committee: Alleged violations of RCW 42.17A.235 & .240 for failure to timely and accurately file contributions & expenditures. (Feb 2019) RCW 42.17A.240, RCW 42.17A.235 Case Closed with Written Warning
  • Allegation: Walla Walla County Demo Central Committee: Alleged violations of RCW 42.17A.235 & .240 for failure to timely and accurately file contributions & expenditures
https://www.pdc.wa.gov/browse/enforcement-cases/46694
46655 02/06/2019 Glen Morgan Matthew Haney Haney, Matthew: Alleged violation of RCW 42.17A.605 by failing to submit a recent photograph for lobbyist registration. (Feb 2019) RCW 42.17A.605 Case Closed with Reminder
  • Alleged violation of RCW 42.17A.605 by failing to submit a recent photograph for lobbyist registration
https://www.pdc.wa.gov/browse/enforcement-cases/46655
46650 02/06/2019 Glen Morgan Paula Swedeen Swedeen, Paula: Alleged violation of RCW 42.17A.605 by failing to submit a recent photograph for lobbyist registration. (Feb 2019) RCW 42.17A.605 Case Closed with Reminder
  • Alleged violation of RCW 42.17A.605 by failing to submit a recent photograph for lobbyist registration
https://www.pdc.wa.gov/browse/enforcement-cases/46650
46645 02/06/2019 Glen Morgan Melanie Smith Smith, Melanie: Alleged violation of RCW 42.17A.605 by failing to submit a recent photograph for lobbyist registration. (Feb 2019) RCW 42.17A.605 Case Closed with Reminder
  • Allegation: Alleged violation of RCW 42.17A.605 by failing to submit a recent photograph for lobbyist registration
https://www.pdc.wa.gov/browse/enforcement-cases/46645
46642 02/06/2019 Glen Morgan Nonemacher, Darcy Nonemacher, Darcy: Alleged violation of RCW 42.17A.605 by failing to submit a recent photograph for lobbyist registration. (Feb 2019) RCW 42.17A.605 Case Closed with Reminder
  • Alleged violation of RCW 42.17A.605 by failing to submit a recent photograph for lobbyist registration
https://www.pdc.wa.gov/browse/enforcement-cases/46642
46636 02/06/2019 Glen Morgan Abbie Zulock Zulock, Abbie: Alleged violation of RCW 42.17A.605 by failing to submit a recent photograph for lobbyist registration. (Feb 2019) RCW 42.17A.605 Case Closed with Reminder

The Respondent is a registered lobbyist, employed by WA Public Employees Association, who failed to submit a recent photograph to the PDC as required per RCW 42.17A.605. The Respondent took corrective action and uploaded the missing photograph on March 25, 2019. Prior attempts to upload the photo were unsuccessful due to technical and account access issues. 

Based on its findings, PDC staff determined that, in this instance, failure to submit a photograph for a lobbyist registration does not amount to an actual violation warranting further investigation. PDC staff reminded the Respondent about the importance of submitting a recent photograph when registering as a lobbyist, maintaining current contact and lobbyist information with the PDC, and the timely filing of all future required lobbyist registration information. The PDC dismissed the matter and did not conduct a more formal investigation into the complaint or pursue further enforcement action in this case.

https://www.pdc.wa.gov/browse/enforcement-cases/46636
46514 02/05/2019 Glen Morgan Yes for Public Safety Yes for Public Safety: Alleged violation of RCW 42.17A.320 for failure to accurately disclose Top 5 contributors on political advertising. (Jan 2019) RCW 42.17A.320 Case Closed with Reminder

The Respondent sponsored an advertisement supporting Proposition 1 that was mailed out on January 25, 2019. The cost of the mailer was $5,200 and was timely & accurately reported by the Respondent to the PDC. The Respondent disclosed two organizations as the Top 5 Contributors on the mailer. McDaniel Projects made an in-kind contribution of $1,000 to the Respondent on January 16, 2019 and the Respondent failed to include this third contributor in its Top 5 disclosure. When it became aware of the omission, the Respondent made a good-faith effort to remedy the error by updating subsequent ads, including another mailer that was sent to a broader, overlapping audience. Based on these findings, PDC staff has determined that, in this instance, failure to include the third contributor in its Top 5 disclosure did not amount to an actual violation warranting further investigation. 

PDC reminded the Respondent about the importance of timely & accurately disclosing the Top 5 Contributors on all political advertising. The PDC dismissed the matter and did not conduct a more formal investigation into the complaint or pursue further enforcement in this case. 

https://www.pdc.wa.gov/browse/enforcement-cases/46514
46509 02/05/2019 Glen Morgan Ben Stuckart Stuckart, Ben: Alleged violations of RCW 42.17A.240 and .405 by not accurately reporting in-kind contribution & accepting an over limit in-kind contribution. (Jan 2019) RCW 42.17A.405, RCW 42.17A.240 Case Closed with No Evidence of Violations

A photo of, and quote from, the Respondent appeared in a advertisement supporting Proposition 1 that was sponsored by Yes for Public Safety and mailed on January 25, 2019. The Respondent was President of the Spokane City Council & a mayoral candidate at the time of the mailing. The mailer did not identify the Respondent as a mayoral candidate, was mailed several months before the election for which the Respondent was a candidate, and sought to influence the outcome of an election for which the Respondent was not a candidate. 

The mailer did not appear to be an in-kind contribution to the Respondent because its purpose was to support Proposition 1 and any indirect benefit to the Respondent's mayoral candidacy was incidental and below the contribution limit for the office sought. Based on these findings, staff determined that, in this instance, the Respondent's appearance in an ad supporting a ballot measure did not amount to a finding of an actual violation warranting further investigation. The PDC dismissed the matter and did not conduct a more formal investigation into the complaint or pursue further enforcement in this case.

https://www.pdc.wa.gov/browse/enforcement-cases/46509
46474 02/04/2019 Glen Morgan Pierce County Democratic Central Committee Pierce County Democratic Central Committee (4): Alleged violation of RCW 42.17A.235 for failure to timely report contributions (EY 18; Feb 19) RCW 42.17A.235 Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the complaints filed by Glen Morgan on February 3, 2019 and February 5, 2019. Your complaints alleged that the Pierce County Democratic Central Committee (PCDCC), a bona fide political party committee may have violated: (1) RCW 42.17A.235 and .240 by failing to timely and accurately file Monetary Contribution reports (C-3 reports) disclosing proceeds from a low-cost fundraiser; and (2) RCW 42.17A.240 by failing to accurately disclose the unsuspended portion of a penalty as a debt.

PDC staff reviewed the allegations listed in the two complaints filed; the applicable statutes, rules, and reporting requirements; the response provided by Rick Offner, Treasurer for Pierce County Democratic Central Committee; and the applicable PDC reports filed by Respondent, to determine whether the record supports a finding of one or more violations.

Based on staff’s review, the late filed C-3 report cited in PDC Case 46474 was the result of an internal audit conducted by the PCDCC. The Commission encourages the practice of internal review and the submittal of missing or incorrect reports of campaign activities.

Based on these findings staff has determined that, in this instance, failure to timely file one C-3 report disclosing proceeds from a low-cost fundraiser and failure to disclose the October 27, 2017 unsuspended penalty owed to the AGO as a debt, does not warrant further investigation or enforcement action.

Pursuant to WAC 390-37-060(1)(d), the PCDCC received a formal written warning concerning failure to timely and accurately file Summary Full Campaign Contribution and Expenditure reports (C-4 reports) disclosing debt. The formal written warning included staff’s expectation that the PCDCC timely file accurate and complete C-4 reports in future years in accordance with PDC laws and rules. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

In addition, PDC staff reminded the PCDCC about the importance of timely filing all Monetary Contributions reports (C-3 reports) disclosing deposits made, no matter the source of contributions or the amount. The reminder included staff’s expectation that the PCDCC continue utilizing internal controls and audits to ensure timely and accurate reporting of all campaign activities in the future. 

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).

https://www.pdc.wa.gov/browse/enforcement-cases/46474
46472 02/04/2019 Glen Morgan Tanisha Harris Harris, Tanisha (3): Alleged violation of RCW 42.17A.235 for failure to timely report contributions (EY 16; Feb 16) RCW 42.17A.235 Request for Technical Correction
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Glen Morgan on February 4, 2019. The complaint alleged that Tanisha Harris may have violated RCW 42.17A.235 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing a $1,000 contribution to the 2016 Clark County Council Campaign. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Tanisha Harris; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Tanisha Harris made minor or ministerial errors on required reports, which did not materially impact the public interest. Upon notification of these errors, Tanisha Harris timely amended their reports, making the necessary technical corrections as requested by staff. 

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).
https://www.pdc.wa.gov/browse/enforcement-cases/46472
46470 02/04/2019 Glen Morgan Margaret Heldring Heldring, Margaret: Alleged violation of RCW 42.17A.605 for failure to provide recent photograph at time of Lobbyist Registration (EY 19; Feb 19) RCW 42.17A.605 Case Closed with Reminder
Allegation: Violation of RCW 42.17A.605 for failure to provide recent photograph at time of Lobbyist Registration
https://www.pdc.wa.gov/browse/enforcement-cases/46470
46468 02/04/2019 Glen Morgan Renee Hopkins Hopkins, Renee: Alleged violation of RCW 42.17A.605 for failure to provide photograph at time of registration, and .615 for failure to timely file monthly lobbyist reports (EY 19; Feb 19) RCW 42.17A.605, RCW 42.17A.615 Case Closed with No Evidence of Violations
  • Allegation One: Violation of RCW 42.17A.605 for failure to provide recent photograph at time of Lobbyist Registration.
  • Allegation Two: Violations of RCW 42.17A.615 for failure to file monthly lobbyist reports.
https://www.pdc.wa.gov/browse/enforcement-cases/46468
46467 02/04/2019 Glen Morgan Johnson Arledge Strategies Johnson Arledge Strategies: Alleged violation of RCW 42.17A.605 for failure to submit recent photograph for Rebecca Johnson at Lobbyist Registration (EY 19; Feb 19) RCW 42.17A.605 Case Closed with Reminder
Allegation: Violation of RCW 42.17A.605 for failure to provide a recent photograph of Rebecca Johnson at the time of Lobbyist Registration.
https://www.pdc.wa.gov/browse/enforcement-cases/46467
46466 02/04/2019 Glen Morgan Cody Arledge Arledge, Cody: Alleged violation of RCW 42.17A.605 for failure to provide recent photograph at time of Lobbyist Registration (EY 19; Feb 19) RCW 42.17A.605 Case Closed with Reminder
Allegation: Violation of RCW 42.17A.605 for failure to provide a recent photograph at the time of Lobbyist Registration.
https://www.pdc.wa.gov/browse/enforcement-cases/46466
46465 02/04/2019 Glen Morgan Daniel Strauss Strauss, Daniel: Alleged violation of RCW 42.17A.605 for failure to provide recent photograph at time of Lobbyist Registration (EY 19; Feb 19) RCW 42.17A.605 Case Closed with Reminder
Allegation: Violation of RCW 42.17A.605 for failure to provide a recent photograph at the time of Lobbyist Registration
https://www.pdc.wa.gov/browse/enforcement-cases/46465
46357 02/01/2019 Peggy Shepard Matthew Larson Larson, Matthew: Alleged violation of RCW 42.17A.575 by appearing in public service announcements during an election year 2017. (Jan 19) RCW 42.17A.575 Case Closed with No Evidence of Violations
  • Allegation: Alleged violation of RCW 42.17A.575 by appearing in public service announcements (e.g. a 4-part series on growth, economic development, adult living community & new hotel) during election year 2017.
https://www.pdc.wa.gov/browse/enforcement-cases/46357
46332 02/01/2019 Glen Morgan Kevin Ranker Ranker, Kevin (2): Alleged violation of RCW 42.17A.700 for failure to accurately and timely report financial interest in a business entity on Personal Financial Affairs Statement (F-1 report). (Jan 2019) RCW 42.17A.700 Case Closed with Reminder
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Glen Morgan on January 28, 2019. The complaint alleged that Senator Kevin Ranker may have violated RCW 42.17A.700 by failing to accurately and timely report financial interest in a business entity on his Personal Financial Affairs Statement (F-1 report). 

Based on our findings, staff has determined that, in this instance, failure to report financial interest in Coast Policy Group, LLC on F-1 reports for 2014 - 2017 does not amount to an actual violation warranting further investigation. PDC staff is reminding Senator Kevin Ranker about the importance of accurately disclosing all business interests and offices held on his Personal Financial Affairs Statement (F-1 report). 

Senator Kevin Ranker made minor or ministerial errors on required reports, which did not materially impact the public interest. Upon notification of these errors, Senator Kevin Ranker amended his reports, making the necessary technical corrections. The PDC has dismissed the matter and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/46332
46093 01/29/2019 Glen Morgan Ehren Flygare Advocates, Inc.: Alleged violations of RCW 42.17A.615 for failure to timely report lobbying activities as a lobbyist and .605 for failure to submit recent photograph at time of registration (EY 18; Jan 19) RCW 42.17A.605, RCW 42.17A.615 Resolved through Statement of Understanding

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Glen Morgan on January 28, 2019. The complaint alleged that Ehren Flygare/Advocates Inc., a registered lobbyist with a contract lobbying firm registered with the PDC, may have violated RCW 42.17A.615 by failing to timely file Lobbyist Monthly Expense Reports (L-2 Reports) disclosing lobbying expenditures for calendar years 2016, 2017, and 2018, and RCW 42.17A.605 by failing to provide a recent photograph of Ehren Flygare at the time he filed his Lobbyist Registration  (L-1 report). 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the responses provided by Ehren Flygare; the applicable PDC reports filed by Respondent; and the Lobbyist Application revision history screen; and queried the Respondent’s data in the PDC lobbyist compensation and expenses by source database, to determine whether the record supports a finding of one or more violations.  

The $450 penalty assessed resolves the allegations concerning the failure to timely and accurately file L-2 reports for calendar years 2016, 2017, and 2018, disclosing lobbying compensation and activities, including personal contributions made to legislators. In addition, Mr. Flygare has provided a photograph to comply with the lobbyist picture requirement as part of the L-1 filing requirements.  

Based on this information and the facts that Ehren Flygare/Advocates, Inc. has no prior PDC violations, demonstrated a good-faith effort to bring reports into compliance, and has hired a professional to file his PDC lobbying reports going forward, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1). 
 

https://www.pdc.wa.gov/browse/enforcement-cases/46093
46091 01/29/2019 Andreas Koeppen John Marchione Marchione, John: Alleged violation of RCW 42.17A.555 for misuse of public facilities to support Candidate Birney (EY 19; Jan 19) RCW 42.17A.555 Case Closed with No Evidence of Violations
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Andrew Koeppen on January 24, 2019. The complaint alleged that Angela Birney, Tanika Padhye, and John Marchione (Respondents) may have violated RCW 42.17A.555 by misusing public facilities to support the election campaign of candidate Birney.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the response provided by Respondents to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, no evidence supports a finding of an actual violation warranting further investigation.
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).
https://www.pdc.wa.gov/browse/enforcement-cases/46091
46090 01/29/2019 Andreas Koeppen Tanika Padhye Padhye, Tanika: Alleged violation of RCW 42.17A.555 for misuse of public facilities to support election campaign of Candidate Birney (EY 19; Jan 19) RCW 42.17A.555 Case Closed with No Evidence of Violations
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Andrew Koeppen on January 24, 2019. The complaint alleged that Angela Birney, Tanika Padhye, and John Marchione (Respondents) may have violated RCW 42.17A.555 by misusing public facilities to support the election campaign of candidate Birney.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the response provided by Respondents to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, no evidence supports a finding of an actual violation warranting further investigation.
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).
https://www.pdc.wa.gov/browse/enforcement-cases/46090
46089 01/29/2019 Andreas Koeppen Angela Birney Birney, Angela: Alleged violation of RCW 42.17A.555 for authorizing the use of public facilities to support an election campaign. (EY 19; Jan 19) RCW 42.17A.555 Case Closed with No Evidence of Violations
Dear Andrew Koeppen:
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Andrew Koeppen on January 24, 2019. The complaint alleged that Angela Birney, Tanika Padhye, and John Marchione (Respondents) may have violated RCW 42.17A.555 by misusing public facilities to support the election campaign of candidate Birney.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the response provided by Respondents to determine whether the record supports a finding of one or more violations.

Based on our findings staff has determined that, in this instance, no evidence supports a finding of an actual violation warranting further investigation.
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).
https://www.pdc.wa.gov/browse/enforcement-cases/46089
45913 01/25/2019 James Brewer Seattle School District Seattle School District: Alleged violation of RCW 42.17A.555 by using public facilities to promote a ballot proposition. (Jan 19) RCW 42.17A.555 Case Closed with Reminder

A complaint was filed against officials of the Seattle School District (SSD) alleging violations of RCW 42.17A.555 by using school district facilities to produce and distribute information that supported two SSD levy measures, Proposition #1, the Educational Program and Operations (EP&O) levy, and Proposition #2, the Building Excellence V (BEX V) Capital levy, both of which appeared on the February 12, 2019 special election ballot.

Staff's review found that SSD officials produced and distributed information about Proposition #1 and #2 for the February 12, 2019 special election, and that information was communicated in the district’s normal and regular manner.  Staff found that the majority of the information reviewed was a fair and objective presentation of the facts, however there was information that contained statements of opinion rather than facts or were not completely objective concerning the two levies.  

PDC staff has determined the facts in this instance do not warrant further investigation.  However, PDC staff reminded officials of the Seattle School District concerning the importance of communicating factual and objective bond and levy election information to all citizens of the district, without including potential statements of opinions, as required by PDC laws, rules and PDC Interpretation #01-03.  

Based on this information, the PDC has dismissed the complaint in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/45913
44956 01/11/2019 Dave Churchman Reachout Washington PAC Reachout Washington PAC: Alleged violations of RCW 42.17A.205 and .235 for failure to timely register as a political committee and report contributions and expenditures (EY 19; Jan 19) RCW 42.17A.235, RCW 42.17A.205 Case Closed with No Evidence of Violations
The complaint alleged that Reachout Northwest may have violated RCW 42.17A.205 by failing to timely register as a political committee within two weeks of the expectation of contributions and expenditures in support of a ballot proposition and RCW 42.17A.235 for failing to timely report contributions and expenditures as a political committee under the Full Reporting option.

PDC staff reviewed the allegations; the applicable statutes, rules and reporting requirements, and the response provided by David McMullen, Registered Agent, Reachout Northwest and Tom Perry, Treasurer Reachout Washington.

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).

https://www.pdc.wa.gov/browse/enforcement-cases/44956
44870 01/10/2019 John Kelly 26th Legislative District Democrats 26th Legislative District Democrats: Alleged violation of RCW 42.17A.205 for failure to timely report changes to Political Committee Registration (C-1pc) within 10 days of the change. (Jan 2019) RCW 42.17A.205 Resolved as Remedial
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by John Kelly on January 9, 2019. The complaint alleged that 26th Legislative District Democrats may have violated RCW 42.17A.205 by failing to timely report changes to its Political Committee Registration (C-1pc) within ten days of the change. 

Based on our findings, staff has determined that, in this instance, failure to timely file a C-1pc reporting officer changes does not amount to a violation warranting further investigation.
The alleged non-compliance that appears to constitute a violation of PDC laws and rules made by 26th Legislative District Democrats is remedial in nature and does not warrant further investigation or enforcement action. The violation involved expenditures totaling no more than $1000, occurred more than 30 days before the election, were inadvertent and minor in nature, and did not materially affect the public interest. The 26th Legislative District Democrats took corrective action as required by law for a remedial violation (within 5 business days after notification by PDC staff, or within 21 days after a report was due to be filed). The 26th Legislative District Democrats also substantially met all other required filing due dates within the previous 12-month period.
The PDC has dismissed the matter and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/44870
44855 01/10/2019 Daniel White Peninsula School District Peninsula School District: Alleged violations of RCW 42.17A.555 for using public agency facilities to promote or oppose a ballot proposition. (Jan 19) RCW 42.17A.555 Case Closed with Reminder
A complaint was filed against officials of the Peninsula School District (PSD) alleging violations of RCW 42.17A.555 by using school district facilities to produce and distribute information that supported a PSD bond measure that appeared on the April 24, 2018 special  election ballot.

Staff’s review found that officials of the Peninsula School District produced and distributed information about the April 24, 2018 bond measure and communicated that information in their normal and regular manner.  Staff noted that other than the one exception listed in the letter, the information distributed by the district was an objective and fair presentation of the facts, which staff has determined in this instance does not warrant further investigation.   

However, PDC staff reminded officials of the Peninsula School District concerning the importance of communicating factual bond and levy election related information to all citizens of the district, without including potential statements of opinions for all future elections, as required by PDC laws, rules and PDC Interpretation #01-03.   

Based on this information, the PDC has dismissed the complaint in accordance with RCW 42.17A.755(1).  
https://www.pdc.wa.gov/browse/enforcement-cases/44855
44695 01/07/2019 Glen Morgan Pierce County Democratic Central Committee Pierce County Democratic Central Committee: Alleged violation of RCW 42.17A.205 for failure to timely report changes to Political Committee Registration (C-1pc) within 10 days of the change. (Jan 2019) RCW 42.17A.205 Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the complaints filed by Glen Morgan on October 23, 2018 and January 3, 2019. The complaints alleged that the Pierce County Democratic Central Committee (PCDCC), a bona fide political party committee may have violated: (1) RCW 42.17A.235 and .240 by failing to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign; and (2) RCW 42.17A.205 by failing to timely file an amended Committee Registration (C-1pc report) within ten days disclosing any material change in the committee information.

PDC staff reviewed the allegations listed in the two complaints filed; the applicable statutes, rules, and reporting requirements; the response provided by Dominick Bergeron, former Treasurer for Pierce County Democratic Central Committee; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on staff’s review, the alleged late and incomplete filed C-3 and C-4 reports cited in the two complaints were primarily caused by a Committee reorganization and changes in officers, but we noted that the Committee implemented additional internal controls to ensure compliance by creating an oversight committee, by conducting an internal audit, and additional training.  These steps were taken, in part, by the Pierce County Democratic Central Committee to comply with the provisions of the settlement agreement. 

Based on these findings staff has determined that, in this instance, failure to timely and accurately file 19 filed C-3 and C-4 reports, including amendments, mostly disclosed little monetary activity, or were filed as a result of an internal audit process conducted by PCDCC, and therefore does not warrant further investigation or enforcement action.

Pursuant to WAC 390-37-060(1)(d), the PCDCC received a formal written warning concerning failure to timely and accurately file Monetary Contributions reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports) disclosing contribution and expenditure activities and failure to timely file an amended Committee Registration (C-1pc report) disclosing material changes. The formal written warning included staff’s expectation that PCDCC timely file accurate and complete C-3, C-4 and C-1pc reports in future years in accordance with PDC laws and rules. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.
 

https://www.pdc.wa.gov/browse/enforcement-cases/44695
44685 01/07/2019 Glen Morgan Kevin Ranker Ranker, Kevin: Alleged violation of RCW 42.17A.700 for failure to accurately and timely report real estate activity on Personal Financial Affairs Statement (F-1 report). (Jan 2019) RCW 42.17A.700 Case Closed with Reminder
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Glen Morgan on January 3, 2019. The complaint alleged that Senator Kevin Ranker may have violated RCW 42.17A.700 by failing to accurately and timely report real estate activity on his Personal Financial Affairs Statement (F-1 report). 

Based on our findings, staff has determined that, in this instance, failure to report financial interest in the lot property on F-1 reports for 2013 - 2017 does not amount to an actual violation warranting further investigation. 
PDC staff is reminding Senator Kevin Ranker about the importance of accurately disclosing all real estate activity on his Personal Financial Affairs Statement (F-1 report). 

Senator Kevin Ranker made minor or ministerial errors on required reports, which did not materially impact the public interest. Upon notification of these errors, Senator Kevin Ranker amended his reports, making the necessary technical corrections. 

The PDC has dismissed the matter and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/44685
44372 12/27/2018 Conner Edwards Up for Thurston County Up for Thurston County (2): Alleged violations of Chapter 42.17A RCW for failure to include sponsor name on registration, disclose proper sponsor ID, and designate earmarked contributions (EY 18; Dec 18) RCW 42.17A.270, RCW 42.17A.320, RCW 42.17A.405, RCW 42.17A.420, RCW 42.17A.205 Case Closed with Written Warning
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Conner Edwards on December 18, 2018. The complaint alleged that Up for Thurston County may have violated RCW 42.17A.320 for failure to disclose the name of controlling individuals or entities on political advertising; RCW 42.17A.205 for failure to disclose committee sponsorship by Puget Sound Energy after they made a contribution, constituting 100% of total contributions, on the day the committee was formed; RCW 42.17A.270 for failure to designate contributions earmarked to support election campaign of Candidate Oosterman; and RCW 42.17A.420 for making an earmarked in-kind contribution to Candidate Oosterman exceeding $5000, in the period beginning 21 days before an election. 

PDC staff reviewed your allegations; the applicable statutes, rules, and reporting requirements; the responses provided by Up for Thurston County; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, failure to disclose Puget Sound Energy as the 100% sponsor of Up for Thurston County on the day the committee was formed, and to include their sponsorship on political advertising, do not amount to actual violations warranting further investigation. 

Pursuant to WAC 390-37-060(1)(b), Up for Thurston County will receive a formal written warning concerning their failure to disclose the committee’s sponsorship by Puget Sound Energy at the time of registration, and failure to disclose the committee’s sponsorship by Puget Sound Energy on political advertising mailed within 21 days of the General Election. The formal written warning will include staff’s expectation that Up for Thurston County timely, accurately, and completely discloses committee sponsorship in the future. The Commission will consider the formal written warning in deciding on further 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 this matter in accordance with RCW 42.17A.755(1).
https://www.pdc.wa.gov/browse/enforcement-cases/44372
44370 12/27/2018 Jason Raines John Henry Henry, John (2): Alleged violation of RCW 42.17A.710 for failure to accurately and completely disclose financial activities in calendar year 2017. RCW 42.17A.710 Case Closed with Reminder
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Jason Raines on December 18, 2018. The complaint alleged that John Henry may have violated RCW 42.17A.710 for failure to accurately file a Personal Statement of Financial Affairs (F-1 report), certifying financial activities for calendar year 2017. 

PDC staff reviewed your allegations; the applicable statutes, rules, and reporting requirements; the response provided by John Henry; and the applicable PDC reports filed by Respondent to determine whether the record supports a finding of one or more violations. 

Based on these findings staff has determined that, in this instance, filing an F-1 report certifying the wrong reporting period does not amount to an actual violation warranting further investigation. PDC staff is reminding John Henry about the importance of the accurate, complete, and timely disclosure of financial affairs, and the complete and correct submission of reports of financial affairs in the future, in accordance with PDC laws and rules. 

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).
https://www.pdc.wa.gov/browse/enforcement-cases/44370
44063 12/17/2018 Cheryl Aichele Southwest WA Electricians PAC 48 of WA Southwest WA Electricians PAC 48 of WA: Alleged violations of RCW 42.17A.405 and .460 for making over-limit earmarked contributions (EY 18; Dec 18) RCW 42.17A.405, RCW 42.17A.460 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on December 12, 2018. Your complaint alleged that Southwest WA Electricians PAC 48 of WA (PAC 48), a registered political committee, may have violated RCW 42.17A.405 for making over-limit contributions to two candidate campaigns and RCW 42.17.460 for failure to report contributions earmarked for the same two candidates.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by IBEW 48 Business Manager & Financial Secretary on behalf of PAC 48; the applicable C-3 and C-4 reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

No evidence was found that PAC 48 made over-limit contributions to either of the 2018 candidate campaigns referenced above or to indicate that that funds received by CCDCC were earmarked as defined in RCW 42.17A.460 by PAC 48 or were otherwise specifically intended to benefit any of the same candidates.

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).

https://www.pdc.wa.gov/browse/enforcement-cases/44063
44062 12/17/2018 Cheryl Aichele Monica Stonier Stonier, Monica (2): Alleged violations of RCW 42.17A.405 for accepting over-limit contributions (EY 18; Dec 18) RCW 42.17A.405 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on December 12, 2018. Your complaint alleged that Monica Stonier, State Representative, in the 49th Legislative District running for re-election in the 2018 election, may have violated RCW 42.17A.405 for accepting over-limit contributions from the committee Southwest Wa Electricians PAC of WA (PAC 48), including a direct monetary contribution and a contribution made through the Clark County Democratic Central Committee earmarked for the Elect Monica Stonier campaign.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Marsha Manning, Treasurer for Elect Monica Stonier; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

No evidence was found to indicate that funds received by CCDCC from PAC 48 were earmarked as defined in RCW 42.17A.460 by PAC 48 or otherwise specifically intended to benefit the Elect Monica Stonier campaign.

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).

https://www.pdc.wa.gov/browse/enforcement-cases/44062
43945 12/13/2018 David Hammond Lincoln County Republican Central Committee Lincoln County Republican Central Committee: Alleged violations of RCW 42.17A.220 & .235 for failure to timely deposit contributions and timely & accurately report contributions for 2016 & 2018. (Dec 18) RCW 42.17A.220, RCW 42.17A.235 Case Closed with Written Warning
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by David Hammond on December 5, 2018. The complaint alleged that the Lincoln County Republican Central Committee (Committee), a bona fide county political party committee, may have violated RCW 42.17A.220 by failing to timely deposit monetary contributions received into the committee bank account, and RCW 42.17A.235 and .240 by failing to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports) disclosing contribution and expenditure activities undertaken by the Committee in 2016 and 2018.

PDC staff reviewed the allegations listed in the complaint, relevant statutes, rules and reporting requirements, the C-3 and C-4 reports filed by the Committee, and the response from the Committee’s Officers. 

Based on these findings, staff has determined that, in this instance, the Committee’s failure to timely file C-3 reports for calendar years 2016 and 2018 does not warrant further investigation or pursuing further enforcement action in this case.
Pursuant to WAC 390-37-060(1)(b), the Lincoln County Republican Central Committee will receive a formal written warning concerning its failure to timely file C-3 reports for calendar years 2016 and 2018.  The formal written warning will include staff’s expectation that the Lincoln County Republican Central Committee will timely file C-3 reports in future years in accordance with PDC laws and rules. The Commission may consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.
Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1).
https://www.pdc.wa.gov/browse/enforcement-cases/43945
43940 12/13/2018 Freedom Foundation (Maxford Nelsen) Amalgamated Transit Union Legislative Council of Washington Amalgamated Transit Union Legislative Council of Washington: Alleged violation of RCW 42.17A.205 for failure to timely & accurately register as a political committee. (Dec 18) RCW 42.17A.205 Investigation of Possible Violation
  • Allegation: Alleged violation of RCW 42.17A.205 for failure to timely & accurately register as a political committee.
https://www.pdc.wa.gov/browse/enforcement-cases/43940
43895 12/12/2018 Cheryl Aichele 17th Legislative District Democrats 17th Legislative District Democrats (3): Alleged violations of Chapter 42.17A RCW for failure to timely and accurately deposit and report contributions and committee officers (Dec 18) RCW 42.17A.205, RCW 42.17A.220, RCW 42.17A.270, RCW 42.17A.425, RCW 42.17A.460, WAC 390-17-015 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on December 7, 2018. Your complaint alleged that the 17th Legislative District Democrats, a bona fide legislative district party committee, may have violated: (1) RCW 42.17A.205 by failing to accurately and completely disclose committee officers on the Committee Registration (C-1pc report); (2) RCW 42.17A.425 for allowing persons not identified as committee officers on the C-1pc to authorize expenditures; (3) RCW 42.17A.220 for failure to timely deposit contributions within five business days of receipt; (4) RCW 42.17A.270 for failure to timely and accurately report earmarked contributions and WAC 390-17-015 for improper transfer of earmarked contributions; and (5) RCW 42.17A.460 for failure to report earmarked contributions as made from both the original contributor and the party as a conduit of earmarked contributions.

The complaint also alleged violations RCW 42.17A.490 regarding the limitations on use of contributions for a different office which is not applicable to bona fide party committees. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response(s) provided by the 17th Legislative District Democrats and Committee Chair, Harrison Toepfer; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on these findings staff has determined that, in this instance, failure to timely and accurately file a small number of C-3 and C-4 reports that included minor data entry errors, does not amount to an actual violation warranting further investigation.

PDC staff reminded the 17th LD about the importance of the timely disclosure of all contribution and expenditure activities, including the received date of contributions, and the timely filing of the C-1pc disclosing material changes, in future calendar years in accordance with the statutes and rules.

https://www.pdc.wa.gov/browse/enforcement-cases/43895
43859 12/11/2018 Cheryl Aichele Tanisha Harris Harris, Tanisha (2): Alleged violations of Chapter 42.17A RCW for accepting over-limit contributions and failure to accurately report contributions and expenditures (EY 16; Dec 18) RCW 42.17A.240, RCW 42.17A.405, WAC 390-16-034 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaints filed on December 7 and December 12, 2018. Your complaints alleged that Tanisha Harris, candidate for State Representative in 17th Legislative District in the 2016 and 2018 elections, and a candidate for Clark County Council in the 2016 election, may have violated: (1) RCW 42.17A.405 by accepting over-limits contributions for her two 2016 election campaigns, and the 2018 election campaign; (2) RCW 42.17A.240 by failing to accurately report aggregate totals for monetary and in-kind donations and by failing to report receipt of in-kind contributions on Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports); and (3) RCW 42.17A.240 and WAC 390-16-034 by failing to disclose the required occupation and employer information for individuals contributing more than $100 in the aggregate.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Marsha Manning, Treasurer for the three Elect Tanisha Harris campaigns referenced in the complaints; the applicable C-3 and C-4 reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on these findings staff has determined that, in this instance, failure to accurately disclose aggregate totals for individual contributors to the 2016 State Representative and 2016 County Council campaigns and failure to accurately disclose the occupation for one donor after their aggregate total exceeded $100 for the 2018 State Representative campaign, does not amount to an actual violation warranting further investigation.

PDC staff reminded Tanisha Harris about the importance of the timely and accurate disclosure of all contribution and expenditure activities, including individual donor information and aggregate totals of all future PDC reports in accordance with the statutes and rules.

https://www.pdc.wa.gov/browse/enforcement-cases/43859
43855 12/11/2018 Cheryl Aichele Clark County Democratic Central Committee Clark County Democratic Central Committee (3): Alleged violations of Chapter 42.17A RCW (Dec 18) RCW 42.17A.230, RCW 42.17A.235, RCW 42.17A.240, RCW 42.17A.270, WAC 390-16-037, WAC 390-17-015 Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the complaints filed on December 7 and December 12, 2018. The complaints alleged that the Clark County Democratic Central Committee, a bona fide county party committee registered with the Public Disclosure Commission, may have violated: (1) RCW 42.17A.230 for failure to timely and accurately report contributions from low-cost fundraisers, and failure to timely deposit contributions from fundraisers; (2) RCW 42.17A.235 for failure to timely report contributions and expenditures and failure to maintain sufficient books of account; (3) RCW 42.17A.240 and WAC 390-16-037 for failure to accurately report in-kind contributions and expenditures, expenditure details generally, and failure to report proceeds from fundraisers; (4) RCW 42.17A.270 for failure to timely and accurately report earmarked contributions and WAC 390-17-015 for improper transfer of earmarked contributions; and (5) RCW 42.17A.460 for failure to report earmarked contributions as made from both the original contributor and the party as a conduit of earmarked contributions.

The complaint also alleged violations RCW 42.17A.430 regarding the disposal of funds and RCW 42.17A.555 regarding the use of public facilities, neither of which are applicable to bona fide party committees. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Walter Smith, legal counsel for the Clark County Democratic Central Committee (CCDCC); the applicable C-3 and C-4 reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Staff found that CCDCC made several errors in reporting their 2016, 2017 and 2018 campaign activities that required amendments to be submitted to correct missing, incorrect or incomplete data regarding contributions and expenditures. Many of these errors were corrected by the committee after receiving the complaint and none of those errors appear to have been intentional or otherwise meant to mislead the public, and they were not material. 

Based on these findings, staff has determined that, in this instance, for calendar years 2016, 2017 and 2018, CCDCC’s failure to disclose specific expenditures timely and include the required description, failure to timely report a monetary contribution, reporting incorrect employer and occupation information for individual contributors giving more than $100 in the aggregate, and depositing a small number of contributions late, does not amount to an actual violation warranting further investigation.

Pursuant to WAC 390-37-060(1)(b), the Clark County Democratic Central Committee received a formal written warning concerning failure to accurately and timely disclose all contribution and expenditures, including detailed expenditure descriptions, all occupation and employer information for individual donors and timely deposits of contributions received. The formal written warning included staff’s expectation that CCDCC accurately and timely files all future required reports of contributions and expenditures and makes deposits within five business days of receipt of contributions. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.
 

https://www.pdc.wa.gov/browse/enforcement-cases/43855
43709 12/07/2018 Freedom Foundation (Maxford Nelsen) Williams Plant Services Williams Plant Services: Alleged violations of RCW 42.17A.495 & WAC 390-17 for failure to obtain employee authorization forms that comply with requirements & annually provide required notices. (Nov 18) RCW 42.17A.495, WAC 390-17-100, WAC 390-17-110 Case Closed with Written Warning

The complaint alleged that United Association of Plumbers and Pipefitters Local 598, PDC Case 43672, Plumbers & Steamfitters Local 598 PAC, PDC Case 43673, and 35 employer/contractors, PDC Cases 43675-43709, may have violated RCW 42.17A.495, WAC 390-17-100, and WAC 390-17-110: (1) by failing to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) by failing to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination for not contributing.   The statute and rules primarily apply to the employer/contractors, but also prohibit the union and the employer/contractors from discriminating against a union member who does not make political contributions.


Staff found that the current authorization form does not conform to the requirements in RCW 42.17A.495 and WAC 390-17-100, and that many of the employer/contractors have not been sending out the required annual notification to employees who have funds withheld for PAC contributions, as required by WAC 390-17-110.  The employer/contractors rely on the union to provide an authorization form that complies with the law and rules.  Staff made it clear what changes need to be made to the written authorization and annual notification.  The union, working with and on behalf of the employer/contractors, has developed an authorization form and annual notification that meets the requirement of the statute and rules.  The respondents have stated that they will incorporate the changes to the authorization form and annual notification.


Staff determined that, in this instance, the failure of the 35 employer/contractor respondents to fully comply with the law does not amount to an actual violation warranting further investigation.  However, pursuant to WAC 390-37-060(1)(b), the 35 employer/contractor respondents received a formal written warning concerning: (1) their failure to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) their failure to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination by the employer and the union for not contributing.  The employer/contractors were informed that the Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.  Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).
https://www.pdc.wa.gov/browse/enforcement-cases/43709
43708 12/07/2018 Freedom Foundation (Maxford Nelsen) Washington Building Trades Washington Building Trades: Alleged violations of RCW 42.17A.495 & WAC 390-17 for failure to obtain employee authorization forms that comply with requirements & annually provide required notices. (Nov 18) RCW 42.17A.495, WAC 390-17-100, WAC 390-17-110 Case Closed with Written Warning

The complaint alleged that United Association of Plumbers and Pipefitters Local 598, PDC Case 43672, Plumbers & Steamfitters Local 598 PAC, PDC Case 43673, and 35 employer/contractors, PDC Cases 43675-43709, may have violated RCW 42.17A.495, WAC 390-17-100, and WAC 390-17-110: (1) by failing to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) by failing to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination for not contributing.   The statute and rules primarily apply to the employer/contractors, but also prohibit the union and the employer/contractors from discriminating against a union member who does not make political contributions.


Staff found that the current authorization form does not conform to the requirements in RCW 42.17A.495 and WAC 390-17-100, and that many of the employer/contractors have not been sending out the required annual notification to employees who have funds withheld for PAC contributions, as required by WAC 390-17-110.  The employer/contractors rely on the union to provide an authorization form that complies with the law and rules.  Staff made it clear what changes need to be made to the written authorization and annual notification.  The union, working with and on behalf of the employer/contractors, has developed an authorization form and annual notification that meets the requirement of the statute and rules.  The respondents have stated that they will incorporate the changes to the authorization form and annual notification.


Staff determined that, in this instance, the failure of the 35 employer/contractor respondents to fully comply with the law does not amount to an actual violation warranting further investigation.  However, pursuant to WAC 390-37-060(1)(b), the 35 employer/contractor respondents received a formal written warning concerning: (1) their failure to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) their failure to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination by the employer and the union for not contributing.  The employer/contractors were informed that the Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.  Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/43708
43707 12/07/2018 Freedom Foundation (Maxford Nelsen) Waste Treatment Completion Company, LLC Waste Treatment Completion Company, LLC: Alleged violations of RCW 42.17A.495 & WAC 390-17 for failure to obtain employee authorization forms that comply with requirements & annually provide required notices. (Nov 18) WAC 390-17-110, WAC 390-17-100, RCW 42.17A.495 Case Closed with Written Warning

The complaint alleged that United Association of Plumbers and Pipefitters Local 598, PDC Case 43672, Plumbers & Steamfitters Local 598 PAC, PDC Case 43673, and 35 employer/contractors, PDC Cases 43675-43709, may have violated RCW 42.17A.495, WAC 390-17-100, and WAC 390-17-110: (1) by failing to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) by failing to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination for not contributing.   The statute and rules primarily apply to the employer/contractors, but also prohibit the union and the employer/contractors from discriminating against a union member who does not make political contributions.


Staff found that the current authorization form does not conform to the requirements in RCW 42.17A.495 and WAC 390-17-100, and that many of the employer/contractors have not been sending out the required annual notification to employees who have funds withheld for PAC contributions, as required by WAC 390-17-110.  The employer/contractors rely on the union to provide an authorization form that complies with the law and rules.  Staff made it clear what changes need to be made to the written authorization and annual notification.  The union, working with and on behalf of the employer/contractors, has developed an authorization form and annual notification that meets the requirement of the statute and rules.  The respondents have stated that they will incorporate the changes to the authorization form and annual notification.


Staff determined that, in this instance, the failure of the 35 employer/contractor respondents to fully comply with the law does not amount to an actual violation warranting further investigation.  However, pursuant to WAC 390-37-060(1)(b), the 35 employer/contractor respondents received a formal written warning concerning: (1) their failure to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) their failure to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination by the employer and the union for not contributing.  The employer/contractors were informed that the Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.  Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/43707
43706 12/07/2018 Freedom Foundation (Maxford Nelsen) University Mechanical Contractors University Mechanical Contractors: Alleged violations of RCW 42.17A.495 & WAC 390-17 for failure to obtain employee authorization forms that comply with requirements & annually provide required notices. (Nov 18) RCW 42.17A.495, WAC 390-17-100, WAC 390-17-110 Case Closed with Written Warning

The complaint alleged that United Association of Plumbers and Pipefitters Local 598, PDC Case 43672, Plumbers & Steamfitters Local 598 PAC, PDC Case 43673, and 35 employer/contractors, PDC Cases 43675-43709, may have violated RCW 42.17A.495, WAC 390-17-100, and WAC 390-17-110: (1) by failing to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) by failing to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination for not contributing.   The statute and rules primarily apply to the employer/contractors, but also prohibit the union and the employer/contractors from discriminating against a union member who does not make political contributions.


Staff found that the current authorization form does not conform to the requirements in RCW 42.17A.495 and WAC 390-17-100, and that many of the employer/contractors have not been sending out the required annual notification to employees who have funds withheld for PAC contributions, as required by WAC 390-17-110.  The employer/contractors rely on the union to provide an authorization form that complies with the law and rules.  Staff made it clear what changes need to be made to the written authorization and annual notification.  The union, working with and on behalf of the employer/contractors, has developed an authorization form and annual notification that meets the requirement of the statute and rules.  The respondents have stated that they will incorporate the changes to the authorization form and annual notification.


Staff determined that, in this instance, the failure of the 35 employer/contractor respondents to fully comply with the law does not amount to an actual violation warranting further investigation.  However, pursuant to WAC 390-37-060(1)(b), the 35 employer/contractor respondents received a formal written warning concerning: (1) their failure to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) their failure to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination by the employer and the union for not contributing.  The employer/contractors were informed that the Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.  Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/43706
43705 12/07/2018 Freedom Foundation (Maxford Nelsen) Truetemp Northwest, Inc. Truetemp Northwest, Inc.: Alleged violations of RCW 42.17A.495 & WAC 390-17 for failure to obtain employee authorization forms that comply with requirements & annually provide required notices. (Nov 18) RCW 42.17A.495, WAC 390-17-100, WAC 390-17-110 Case Closed with Written Warning

The complaint alleged that United Association of Plumbers and Pipefitters Local 598, PDC Case 43672, Plumbers & Steamfitters Local 598 PAC, PDC Case 43673, and 35 employer/contractors, PDC Cases 43675-43709, may have violated RCW 42.17A.495, WAC 390-17-100, and WAC 390-17-110: (1) by failing to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) by failing to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination for not contributing.   The statute and rules primarily apply to the employer/contractors, but also prohibit the union and the employer/contractors from discriminating against a union member who does not make political contributions.


Staff found that the current authorization form does not conform to the requirements in RCW 42.17A.495 and WAC 390-17-100, and that many of the employer/contractors have not been sending out the required annual notification to employees who have funds withheld for PAC contributions, as required by WAC 390-17-110.  The employer/contractors rely on the union to provide an authorization form that complies with the law and rules.  Staff made it clear what changes need to be made to the written authorization and annual notification.  The union, working with and on behalf of the employer/contractors, has developed an authorization form and annual notification that meets the requirement of the statute and rules.  The respondents have stated that they will incorporate the changes to the authorization form and annual notification.


Staff determined that, in this instance, the failure of the 35 employer/contractor respondents to fully comply with the law does not amount to an actual violation warranting further investigation.  However, pursuant to WAC 390-37-060(1)(b), the 35 employer/contractor respondents received a formal written warning concerning: (1) their failure to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) their failure to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination by the employer and the union for not contributing.  The employer/contractors were informed that the Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.  Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).
https://www.pdc.wa.gov/browse/enforcement-cases/43705
43704 12/07/2018 Freedom Foundation (Maxford Nelsen) Temp-Control Mechanical Corporation Temp-Control Mechanical Corporation: Alleged violations of RCW 42.17A.495 & WAC 390-17 for failure to obtain employee authorization forms that comply with requirements & annually provide required notices. (Nov 18) WAC 390-17-110, WAC 390-17-100, RCW 42.17A.495 Case Closed with Written Warning

The complaint alleged that United Association of Plumbers and Pipefitters Local 598, PDC Case 43672, Plumbers & Steamfitters Local 598 PAC, PDC Case 43673, and 35 employer/contractors, PDC Cases 43675-43709, may have violated RCW 42.17A.495, WAC 390-17-100, and WAC 390-17-110: (1) by failing to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) by failing to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination for not contributing.   The statute and rules primarily apply to the employer/contractors, but also prohibit the union and the employer/contractors from discriminating against a union member who does not make political contributions.


Staff found that the current authorization form does not conform to the requirements in RCW 42.17A.495 and WAC 390-17-100, and that many of the employer/contractors have not been sending out the required annual notification to employees who have funds withheld for PAC contributions, as required by WAC 390-17-110.  The employer/contractors rely on the union to provide an authorization form that complies with the law and rules.  Staff made it clear what changes need to be made to the written authorization and annual notification.  The union, working with and on behalf of the employer/contractors, has developed an authorization form and annual notification that meets the requirement of the statute and rules.  The respondents have stated that they will incorporate the changes to the authorization form and annual notification.


Staff determined that, in this instance, the failure of the 35 employer/contractor respondents to fully comply with the law does not amount to an actual violation warranting further investigation.  However, pursuant to WAC 390-37-060(1)(b), the 35 employer/contractor respondents received a formal written warning concerning: (1) their failure to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) their failure to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination by the employer and the union for not contributing.  The employer/contractors were informed that the Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.  Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/43704
43703 12/07/2018 Freedom Foundation (Maxford Nelsen) Stirrett-Johnson, Inc. Stirrett-Johnson, Inc.: Alleged violations of RCW 42.17A.495 & WAC 390-17 for failure to obtain employee authorization forms that comply with requirements & annually provide required notices. (Nov 18) WAC 390-17-110, RCW 42.17A.495, WAC 390-17-100 Case Closed with Written Warning

The complaint alleged that United Association of Plumbers and Pipefitters Local 598, PDC Case 43672, Plumbers & Steamfitters Local 598 PAC, PDC Case 43673, and 35 employer/contractors, PDC Cases 43675-43709, may have violated RCW 42.17A.495, WAC 390-17-100, and WAC 390-17-110: (1) by failing to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) by failing to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination for not contributing.   The statute and rules primarily apply to the employer/contractors, but also prohibit the union and the employer/contractors from discriminating against a union member who does not make political contributions.


Staff found that the current authorization form does not conform to the requirements in RCW 42.17A.495 and WAC 390-17-100, and that many of the employer/contractors have not been sending out the required annual notification to employees who have funds withheld for PAC contributions, as required by WAC 390-17-110.  The employer/contractors rely on the union to provide an authorization form that complies with the law and rules.  Staff made it clear what changes need to be made to the written authorization and annual notification.  The union, working with and on behalf of the employer/contractors, has developed an authorization form and annual notification that meets the requirement of the statute and rules.  The respondents have stated that they will incorporate the changes to the authorization form and annual notification.


Staff determined that, in this instance, the failure of the 35 employer/contractor respondents to fully comply with the law does not amount to an actual violation warranting further investigation.  However, pursuant to WAC 390-37-060(1)(b), the 35 employer/contractor respondents received a formal written warning concerning: (1) their failure to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) their failure to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination by the employer and the union for not contributing.  The employer/contractors were informed that the Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.  Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).
https://www.pdc.wa.gov/browse/enforcement-cases/43703
43702 12/07/2018 Freedom Foundation (Maxford Nelsen) Snelson Companies, Inc. Snelson Companies, Inc.: Alleged violations of RCW 42.17A.495 & WAC 390-17 for failure to obtain employee authorization forms that comply with requirements & annually provide required notices. (Nov 18) WAC 390-17-110, RCW 42.17A.495, WAC 390-17-100 Case Closed with Written Warning

The complaint alleged that United Association of Plumbers and Pipefitters Local 598, PDC Case 43672, Plumbers & Steamfitters Local 598 PAC, PDC Case 43673, and 35 employer/contractors, PDC Cases 43675-43709, may have violated RCW 42.17A.495, WAC 390-17-100, and WAC 390-17-110: (1) by failing to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) by failing to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination for not contributing.   The statute and rules primarily apply to the employer/contractors, but also prohibit the union and the employer/contractors from discriminating against a union member who does not make political contributions.


Staff found that the current authorization form does not conform to the requirements in RCW 42.17A.495 and WAC 390-17-100, and that many of the employer/contractors have not been sending out the required annual notification to employees who have funds withheld for PAC contributions, as required by WAC 390-17-110.  The employer/contractors rely on the union to provide an authorization form that complies with the law and rules.  Staff made it clear what changes need to be made to the written authorization and annual notification.  The union, working with and on behalf of the employer/contractors, has developed an authorization form and annual notification that meets the requirement of the statute and rules.  The respondents have stated that they will incorporate the changes to the authorization form and annual notification.


Staff determined that, in this instance, the failure of the 35 employer/contractor respondents to fully comply with the law does not amount to an actual violation warranting further investigation.  However, pursuant to WAC 390-37-060(1)(b), the 35 employer/contractor respondents received a formal written warning concerning: (1) their failure to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) their failure to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination by the employer and the union for not contributing.  The employer/contractors were informed that the Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.  Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/43702
43701 12/07/2018 Freedom Foundation (Maxford Nelsen) Perma Cold Engineering, Inc. Perma Cold Engineering, Inc.: Alleged violations of RCW 42.17A.495 & WAC 390-17 for failure to obtain employee authorization forms that comply with requirements & annually provide required notices. (Nov 18) RCW 42.17A.495, WAC 390-17-100, WAC 390-17-110 Case Closed with Written Warning

The complaint alleged that United Association of Plumbers and Pipefitters Local 598, PDC Case 43672, Plumbers & Steamfitters Local 598 PAC, PDC Case 43673, and 35 employer/contractors, PDC Cases 43675-43709, may have violated RCW 42.17A.495, WAC 390-17-100, and WAC 390-17-110: (1) by failing to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) by failing to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination for not contributing.   The statute and rules primarily apply to the employer/contractors, but also prohibit the union and the employer/contractors from discriminating against a union member who does not make political contributions.


Staff found that the current authorization form does not conform to the requirements in RCW 42.17A.495 and WAC 390-17-100, and that many of the employer/contractors have not been sending out the required annual notification to employees who have funds withheld for PAC contributions, as required by WAC 390-17-110.  The employer/contractors rely on the union to provide an authorization form that complies with the law and rules.  Staff made it clear what changes need to be made to the written authorization and annual notification.  The union, working with and on behalf of the employer/contractors, has developed an authorization form and annual notification that meets the requirement of the statute and rules.  The respondents have stated that they will incorporate the changes to the authorization form and annual notification.


Staff determined that, in this instance, the failure of the 35 employer/contractor respondents to fully comply with the law does not amount to an actual violation warranting further investigation.  However, pursuant to WAC 390-37-060(1)(b), the 35 employer/contractor respondents received a formal written warning concerning: (1) their failure to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) their failure to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination by the employer and the union for not contributing.  The employer/contractors were informed that the Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.  Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/43701
43700 12/07/2018 Freedom Foundation (Maxford Nelsen) Northwest Metal Fab & Pipe, Inc. Northwest Metal Fab & Pipe, Inc.: Alleged violations of RCW 42.17A.495 & WAC 390-17 for failure to obtain employee authorization forms that comply with requirements & annually provide required notices. (Nov 18) WAC 390-17-100, RCW 42.17A.495, WAC 390-17-110 Case Closed with Written Warning

The complaint alleged that United Association of Plumbers and Pipefitters Local 598, PDC Case 43672, Plumbers & Steamfitters Local 598 PAC, PDC Case 43673, and 35 employer/contractors, PDC Cases 43675-43709, may have violated RCW 42.17A.495, WAC 390-17-100, and WAC 390-17-110: (1) by failing to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) by failing to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination for not contributing.   The statute and rules primarily apply to the employer/contractors, but also prohibit the union and the employer/contractors from discriminating against a union member who does not make political contributions.


Staff found that the current authorization form does not conform to the requirements in RCW 42.17A.495 and WAC 390-17-100, and that many of the employer/contractors have not been sending out the required annual notification to employees who have funds withheld for PAC contributions, as required by WAC 390-17-110.  The employer/contractors rely on the union to provide an authorization form that complies with the law and rules.  Staff made it clear what changes need to be made to the written authorization and annual notification.  The union, working with and on behalf of the employer/contractors, has developed an authorization form and annual notification that meets the requirement of the statute and rules.  The respondents have stated that they will incorporate the changes to the authorization form and annual notification.


Staff determined that, in this instance, the failure of the 35 employer/contractor respondents to fully comply with the law does not amount to an actual violation warranting further investigation.  However, pursuant to WAC 390-37-060(1)(b), the 35 employer/contractor respondents received a formal written warning concerning: (1) their failure to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) their failure to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination by the employer and the union for not contributing.  The employer/contractors were informed that the Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.  Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/43700
43699 12/07/2018 Freedom Foundation (Maxford Nelsen) Michels Corporation Michels Corporation: Alleged violations of RCW 42.17A.495 & WAC 390-17 for failure to obtain employee authorization forms that comply with requirements & annually provide required notices. (Nov 18) RCW 42.17A.495, WAC 390-17-100, WAC 390-17-110 Case Closed with Written Warning

The complaint alleged that United Association of Plumbers and Pipefitters Local 598, PDC Case 43672, Plumbers & Steamfitters Local 598 PAC, PDC Case 43673, and 35 employer/contractors, PDC Cases 43675-43709, may have violated RCW 42.17A.495, WAC 390-17-100, and WAC 390-17-110: (1) by failing to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) by failing to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination for not contributing.   The statute and rules primarily apply to the employer/contractors, but also prohibit the union and the employer/contractors from discriminating against a union member who does not make political contributions.


Staff found that the current authorization form does not conform to the requirements in RCW 42.17A.495 and WAC 390-17-100, and that many of the employer/contractors have not been sending out the required annual notification to employees who have funds withheld for PAC contributions, as required by WAC 390-17-110.  The employer/contractors rely on the union to provide an authorization form that complies with the law and rules.  Staff made it clear what changes need to be made to the written authorization and annual notification.  The union, working with and on behalf of the employer/contractors, has developed an authorization form and annual notification that meets the requirement of the statute and rules.  The respondents have stated that they will incorporate the changes to the authorization form and annual notification.


Staff determined that, in this instance, the failure of the 35 employer/contractor respondents to fully comply with the law does not amount to an actual violation warranting further investigation.  However, pursuant to WAC 390-37-060(1)(b), the 35 employer/contractor respondents received a formal written warning concerning: (1) their failure to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) their failure to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination by the employer and the union for not contributing.  The employer/contractors were informed that the Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.  Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/43699
43698 12/07/2018 Freedom Foundation (Maxford Nelsen) McKinstry Company, LLC McKinstry Company, LLC: Alleged violations of RCW 42.17A.495 & WAC 390-17 for failure to obtain employee authorization forms that comply with requirements & annually provide required notices. (Nov 18) RCW 42.17A.495, WAC 390-17-110, WAC 390-17-100 Case Closed with Written Warning

The complaint alleged that United Association of Plumbers and Pipefitters Local 598, PDC Case 43672, Plumbers & Steamfitters Local 598 PAC, PDC Case 43673, and 35 employer/contractors, PDC Cases 43675-43709, may have violated RCW 42.17A.495, WAC 390-17-100, and WAC 390-17-110: (1) by failing to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) by failing to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination for not contributing.   The statute and rules primarily apply to the employer/contractors, but also prohibit the union and the employer/contractors from discriminating against a union member who does not make political contributions.


Staff found that the current authorization form does not conform to the requirements in RCW 42.17A.495 and WAC 390-17-100, and that many of the employer/contractors have not been sending out the required annual notification to employees who have funds withheld for PAC contributions, as required by WAC 390-17-110.  The employer/contractors rely on the union to provide an authorization form that complies with the law and rules.  Staff made it clear what changes need to be made to the written authorization and annual notification.  The union, working with and on behalf of the employer/contractors, has developed an authorization form and annual notification that meets the requirement of the statute and rules.  The respondents have stated that they will incorporate the changes to the authorization form and annual notification.


Staff determined that, in this instance, the failure of the 35 employer/contractor respondents to fully comply with the law does not amount to an actual violation warranting further investigation.  However, pursuant to WAC 390-37-060(1)(b), the 35 employer/contractor respondents received a formal written warning concerning: (1) their failure to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) their failure to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination by the employer and the union for not contributing.  The employer/contractors were informed that the Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.  Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/43698
43697 12/07/2018 Freedom Foundation (Maxford Nelsen) McClintock and Turk, Inc. McClintock and Turk, Inc.: Alleged violations of RCW 42.17A.495 & WAC 390-17 for failure to obtain employee authorization forms that comply with requirements & annually provide required notices. (Nov 18) WAC 390-17-110, RCW 42.17A.495, WAC 390-17-100 Case Closed with Written Warning

The complaint alleged that United Association of Plumbers and Pipefitters Local 598, PDC Case 43672, Plumbers & Steamfitters Local 598 PAC, PDC Case 43673, and 35 employer/contractors, PDC Cases 43675-43709, may have violated RCW 42.17A.495, WAC 390-17-100, and WAC 390-17-110: (1) by failing to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) by failing to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination for not contributing.   The statute and rules primarily apply to the employer/contractors, but also prohibit the union and the employer/contractors from discriminating against a union member who does not make political contributions.


Staff found that the current authorization form does not conform to the requirements in RCW 42.17A.495 and WAC 390-17-100, and that many of the employer/contractors have not been sending out the required annual notification to employees who have funds withheld for PAC contributions, as required by WAC 390-17-110.  The employer/contractors rely on the union to provide an authorization form that complies with the law and rules.  Staff made it clear what changes need to be made to the written authorization and annual notification.  The union, working with and on behalf of the employer/contractors, has developed an authorization form and annual notification that meets the requirement of the statute and rules.  The respondents have stated that they will incorporate the changes to the authorization form and annual notification.

Staff determined that, in this instance, the failure of the 35 employer/contractor respondents to fully comply with the law does not amount to an actual violation warranting further investigation.  However, pursuant to WAC 390-37-060(1)(b), the 35 employer/contractor respondents received a formal written warning concerning: (1) their failure to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) their failure to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination by the employer and the union for not contributing.  The employer/contractors were informed that the Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.  Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/43697
43696 12/07/2018 Freedom Foundation (Maxford Nelsen) MacDonald-Miller Facility Solutions MacDonald-Miller Facility Solutions: Alleged violations of RCW 42.17A.495 & WAC 390-17 for failure to obtain employee authorization forms that comply with requirements & annually provide required notices. (Nov 18) WAC 390-17-110, RCW 42.17A.495, WAC 390-17-100 Case Closed with Written Warning

The complaint alleged that United Association of Plumbers and Pipefitters Local 598, PDC Case 43672, Plumbers & Steamfitters Local 598 PAC, PDC Case 43673, and 35 employer/contractors, PDC Cases 43675-43709, may have violated RCW 42.17A.495, WAC 390-17-100, and WAC 390-17-110: (1) by failing to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) by failing to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination for not contributing.   The statute and rules primarily apply to the employer/contractors, but also prohibit the union and the employer/contractors from discriminating against a union member who does not make political contributions.


Staff found that the current authorization form does not conform to the requirements in RCW 42.17A.495 and WAC 390-17-100, and that many of the employer/contractors have not been sending out the required annual notification to employees who have funds withheld for PAC contributions, as required by WAC 390-17-110.  The employer/contractors rely on the union to provide an authorization form that complies with the law and rules.  Staff made it clear what changes need to be made to the written authorization and annual notification.  The union, working with and on behalf of the employer/contractors, has developed an authorization form and annual notification that meets the requirement of the statute and rules.  The respondents have stated that they will incorporate the changes to the authorization form and annual notification.


Staff determined that, in this instance, the failure of the 35 employer/contractor respondents to fully comply with the law does not amount to an actual violation warranting further investigation.  However, pursuant to WAC 390-37-060(1)(b), the 35 employer/contractor respondents received a formal written warning concerning: (1) their failure to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) their failure to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination by the employer and the union for not contributing.  The employer/contractors were informed that the Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.  Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/43696
43695 12/07/2018 Freedom Foundation (Maxford Nelsen) JR Merit, Inc. JR Merit, Inc.: Alleged violations of RCW 42.17A.495 & WAC 390-17 for failure to obtain employee authorization forms that comply with requirements & annually provide required notices. (Nov 18) WAC 390-17-100, RCW 42.17A.495, WAC 390-17-110 Case Closed with Written Warning

The complaint alleged that United Association of Plumbers and Pipefitters Local 598, PDC Case 43672, Plumbers & Steamfitters Local 598 PAC, PDC Case 43673, and 35 employer/contractors, PDC Cases 43675-43709, may have violated RCW 42.17A.495, WAC 390-17-100, and WAC 390-17-110: (1) by failing to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) by failing to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination for not contributing.   The statute and rules primarily apply to the employer/contractors, but also prohibit the union and the employer/contractors from discriminating against a union member who does not make political contributions.


Staff found that the current authorization form does not conform to the requirements in RCW 42.17A.495 and WAC 390-17-100, and that many of the employer/contractors have not been sending out the required annual notification to employees who have funds withheld for PAC contributions, as required by WAC 390-17-110.  The employer/contractors rely on the union to provide an authorization form that complies with the law and rules.  Staff made it clear what changes need to be made to the written authorization and annual notification.  The union, working with and on behalf of the employer/contractors, has developed an authorization form and annual notification that meets the requirement of the statute and rules.  The respondents have stated that they will incorporate the changes to the authorization form and annual notification.


Staff determined that, in this instance, the failure of the 35 employer/contractor respondents to fully comply with the law does not amount to an actual violation warranting further investigation.  However, pursuant to WAC 390-37-060(1)(b), the 35 employer/contractor respondents received a formal written warning concerning: (1) their failure to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) their failure to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination by the employer and the union for not contributing.  The employer/contractors were informed that the Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.  Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/43695
43694 12/07/2018 Freedom Foundation (Maxford Nelsen) Jordan Mechanical Group Jordan Mechanical Group: Alleged violations of RCW 42.17A.495 & WAC 390-17 for failure to obtain employee authorization forms that comply with requirements & annually provide required notices. (Nov 18) WAC 390-17-110, WAC 390-17-100, RCW 42.17A.495 Case Closed with Written Warning

The complaint alleged that United Association of Plumbers and Pipefitters Local 598, PDC Case 43672, Plumbers & Steamfitters Local 598 PAC, PDC Case 43673, and 35 employer/contractors, PDC Cases 43675-43709, may have violated RCW 42.17A.495, WAC 390-17-100, and WAC 390-17-110: (1) by failing to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) by failing to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination for not contributing.   The statute and rules primarily apply to the employer/contractors, but also prohibit the union and the employer/contractors from discriminating against a union member who does not make political contributions.


Staff found that the current authorization form does not conform to the requirements in RCW 42.17A.495 and WAC 390-17-100, and that many of the employer/contractors have not been sending out the required annual notification to employees who have funds withheld for PAC contributions, as required by WAC 390-17-110.  The employer/contractors rely on the union to provide an authorization form that complies with the law and rules.  Staff made it clear what changes need to be made to the written authorization and annual notification.  The union, working with and on behalf of the employer/contractors, has developed an authorization form and annual notification that meets the requirement of the statute and rules.  The respondents have stated that they will incorporate the changes to the authorization form and annual notification.


Staff determined that, in this instance, the failure of the 35 employer/contractor respondents to fully comply with the law does not amount to an actual violation warranting further investigation.  However, pursuant to WAC 390-37-060(1)(b), the 35 employer/contractor respondents received a formal written warning concerning: (1) their failure to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) their failure to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination by the employer and the union for not contributing.  The employer/contractors were informed that the Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.  Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/43694
43693 12/07/2018 Freedom Foundation (Maxford Nelsen) J.K. Johnson Mechanical Contractors J.K. Johnson Mechanical Contractors: Alleged violations of RCW 42.17A.495 & WAC 390-17 for failure to obtain employee authorization forms that comply with requirements & annually provide required notices. (Nov 18) RCW 42.17A.495, WAC 390-17-100, WAC 390-17-110 Case Closed with Written Warning

The complaint alleged that United Association of Plumbers and Pipefitters Local 598, PDC Case 43672, Plumbers & Steamfitters Local 598 PAC, PDC Case 43673, and 35 employer/contractors, PDC Cases 43675-43709, may have violated RCW 42.17A.495, WAC 390-17-100, and WAC 390-17-110: (1) by failing to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) by failing to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination for not contributing.   The statute and rules primarily apply to the employer/contractors, but also prohibit the union and the employer/contractors from discriminating against a union member who does not make political contributions.


Staff found that the current authorization form does not conform to the requirements in RCW 42.17A.495 and WAC 390-17-100, and that many of the employer/contractors have not been sending out the required annual notification to employees who have funds withheld for PAC contributions, as required by WAC 390-17-110.  The employer/contractors rely on the union to provide an authorization form that complies with the law and rules.  Staff made it clear what changes need to be made to the written authorization and annual notification.  The union, working with and on behalf of the employer/contractors, has developed an authorization form and annual notification that meets the requirement of the statute and rules.  The respondents have stated that they will incorporate the changes to the authorization form and annual notification.


Staff determined that, in this instance, the failure of the 35 employer/contractor respondents to fully comply with the law does not amount to an actual violation warranting further investigation.  However, pursuant to WAC 390-37-060(1)(b), the 35 employer/contractor respondents received a formal written warning concerning: (1) their failure to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) their failure to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination by the employer and the union for not contributing.  The employer/contractors were informed that the Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.  Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/43693
43692 12/07/2018 Freedom Foundation (Maxford Nelsen) JH Kelly, LLC JH Kelly, LLC: Alleged violations of RCW 42.17A.495 & WAC 390-17 for failure to obtain employee authorization forms that comply with requirements & annually provide required notices. (Nov 18) WAC 390-17-110, RCW 42.17A.495, WAC 390-17-100 Case Closed with Written Warning

The complaint alleged that United Association of Plumbers and Pipefitters Local 598, PDC Case 43672, Plumbers & Steamfitters Local 598 PAC, PDC Case 43673, and 35 employer/contractors, PDC Cases 43675-43709, may have violated RCW 42.17A.495, WAC 390-17-100, and WAC 390-17-110: (1) by failing to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) by failing to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination for not contributing.   The statute and rules primarily apply to the employer/contractors, but also prohibit the union and the employer/contractors from discriminating against a union member who does not make political contributions.


Staff found that the current authorization form does not conform to the requirements in RCW 42.17A.495 and WAC 390-17-100, and that many of the employer/contractors have not been sending out the required annual notification to employees who have funds withheld for PAC contributions, as required by WAC 390-17-110.  The employer/contractors rely on the union to provide an authorization form that complies with the law and rules.  Staff made it clear what changes need to be made to the written authorization and annual notification.  The union, working with and on behalf of the employer/contractors, has developed an authorization form and annual notification that meets the requirement of the statute and rules.  The respondents have stated that they will incorporate the changes to the authorization form and annual notification.


Staff determined that, in this instance, the failure of the 35 employer/contractor respondents to fully comply with the law does not amount to an actual violation warranting further investigation.  However, pursuant to WAC 390-37-060(1)(b), the 35 employer/contractor respondents received a formal written warning concerning: (1) their failure to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) their failure to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination by the employer and the union for not contributing.  The employer/contractors were informed that the Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.  Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).
https://www.pdc.wa.gov/browse/enforcement-cases/43692
43691 12/07/2018 Freedom Foundation (Maxford Nelsen) Joint Apprenticeship and Training Committee Joint Apprenticeship and Training Committee: Alleged violations of RCW 42.17A.495 & WAC 390-17 for failure to obtain employee authorization forms that comply with requirements & annually provide required notices. (Nov 18) WAC 390-17-110, WAC 390-17-100, RCW 42.17A.495 Case Closed with Written Warning

The complaint alleged that United Association of Plumbers and Pipefitters Local 598, PDC Case 43672, Plumbers & Steamfitters Local 598 PAC, PDC Case 43673, and 35 employer/contractors, PDC Cases 43675-43709, may have violated RCW 42.17A.495, WAC 390-17-100, and WAC 390-17-110: (1) by failing to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) by failing to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination for not contributing.   The statute and rules primarily apply to the employer/contractors, but also prohibit the union and the employer/contractors from discriminating against a union member who does not make political contributions.


Staff found that the current authorization form does not conform to the requirements in RCW 42.17A.495 and WAC 390-17-100, and that many of the employer/contractors have not been sending out the required annual notification to employees who have funds withheld for PAC contributions, as required by WAC 390-17-110.  The employer/contractors rely on the union to provide an authorization form that complies with the law and rules.  Staff made it clear what changes need to be made to the written authorization and annual notification.  The union, working with and on behalf of the employer/contractors, has developed an authorization form and annual notification that meets the requirement of the statute and rules.  The respondents have stated that they will incorporate the changes to the authorization form and annual notification.


Staff determined that, in this instance, the failure of the 35 employer/contractor respondents to fully comply with the law does not amount to an actual violation warranting further investigation.  However, pursuant to WAC 390-37-060(1)(b), the 35 employer/contractor respondents received a formal written warning concerning: (1) their failure to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) their failure to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination by the employer and the union for not contributing.  The employer/contractors were informed that the Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.  Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).
https://www.pdc.wa.gov/browse/enforcement-cases/43691
43690 12/07/2018 Freedom Foundation (Maxford Nelsen) Iron Mountain Management Iron Mountain Management: Alleged violations of RCW 42.17A.495 & WAC 390-17 for failure to obtain employee authorization forms that comply with requirements & annually provide required notices. (Nov 18) RCW 42.17A.495, WAC 390-17-100, WAC 390-17-110 Case Closed with Written Warning

The complaint alleged that United Association of Plumbers and Pipefitters Local 598, PDC Case 43672, Plumbers & Steamfitters Local 598 PAC, PDC Case 43673, and 35 employer/contractors, PDC Cases 43675-43709, may have violated RCW 42.17A.495, WAC 390-17-100, and WAC 390-17-110: (1) by failing to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) by failing to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination for not contributing.   The statute and rules primarily apply to the employer/contractors, but also prohibit the union and the employer/contractors from discriminating against a union member who does not make political contributions.


Staff found that the current authorization form does not conform to the requirements in RCW 42.17A.495 and WAC 390-17-100, and that many of the employer/contractors have not been sending out the required annual notification to employees who have funds withheld for PAC contributions, as required by WAC 390-17-110.  The employer/contractors rely on the union to provide an authorization form that complies with the law and rules.  Staff made it clear what changes need to be made to the written authorization and annual notification.  The union, working with and on behalf of the employer/contractors, has developed an authorization form and annual notification that meets the requirement of the statute and rules.  The respondents have stated that they will incorporate the changes to the authorization form and annual notification.


Staff determined that, in this instance, the failure of the 35 employer/contractor respondents to fully comply with the law does not amount to an actual violation warranting further investigation.  However, pursuant to WAC 390-37-060(1)(b), the 35 employer/contractor respondents received a formal written warning concerning: (1) their failure to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) their failure to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination by the employer and the union for not contributing.  The employer/contractors were informed that the Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.  Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/43690
43689 12/07/2018 Freedom Foundation (Maxford Nelsen) Intermech, Inc. Intermech, Inc.: Alleged violations of RCW 42.17A.495 & WAC 390-17 for failure to obtain employee authorization forms that comply with requirements & annually provide required notices. (Nov 18) WAC 390-17-100, WAC 390-17-110, RCW 42.17A.495 Case Closed with Written Warning

The complaint alleged that United Association of Plumbers and Pipefitters Local 598, PDC Case 43672, Plumbers & Steamfitters Local 598 PAC, PDC Case 43673, and 35 employer/contractors, PDC Cases 43675-43709, may have violated RCW 42.17A.495, WAC 390-17-100, and WAC 390-17-110: (1) by failing to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) by failing to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination for not contributing.   The statute and rules primarily apply to the employer/contractors, but also prohibit the union and the employer/contractors from discriminating against a union member who does not make political contributions.


Staff found that the current authorization form does not conform to the requirements in RCW 42.17A.495 and WAC 390-17-100, and that many of the employer/contractors have not been sending out the required annual notification to employees who have funds withheld for PAC contributions, as required by WAC 390-17-110.  The employer/contractors rely on the union to provide an authorization form that complies with the law and rules.  Staff made it clear what changes need to be made to the written authorization and annual notification.  The union, working with and on behalf of the employer/contractors, has developed an authorization form and annual notification that meets the requirement of the statute and rules.  The respondents have stated that they will incorporate the changes to the authorization form and annual notification.


Staff determined that, in this instance, the failure of the 35 employer/contractor respondents to fully comply with the law does not amount to an actual violation warranting further investigation.  However, pursuant to WAC 390-37-060(1)(b), the 35 employer/contractor respondents received a formal written warning concerning: (1) their failure to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) their failure to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination by the employer and the union for not contributing.  The employer/contractors were informed that the Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.  Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/43689
43688 12/07/2018 Freedom Foundation (Maxford Nelsen) Integrated Systems Integrated Systems: Alleged violations of RCW 42.17A.495 & WAC 390-17 for failure to obtain employee authorization forms that comply with requirements & annually provide required notices. (Nov 18) WAC 390-17-100, RCW 42.17A.495, WAC 390-17-110 Case Closed with Written Warning

The complaint alleged that United Association of Plumbers and Pipefitters Local 598, PDC Case 43672, Plumbers & Steamfitters Local 598 PAC, PDC Case 43673, and 35 employer/contractors, PDC Cases 43675-43709, may have violated RCW 42.17A.495, WAC 390-17-100, and WAC 390-17-110: (1) by failing to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) by failing to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination for not contributing.   The statute and rules primarily apply to the employer/contractors, but also prohibit the union and the employer/contractors from discriminating against a union member who does not make political contributions.


Staff found that the current authorization form does not conform to the requirements in RCW 42.17A.495 and WAC 390-17-100, and that many of the employer/contractors have not been sending out the required annual notification to employees who have funds withheld for PAC contributions, as required by WAC 390-17-110.  The employer/contractors rely on the union to provide an authorization form that complies with the law and rules.  Staff made it clear what changes need to be made to the written authorization and annual notification.  The union, working with and on behalf of the employer/contractors, has developed an authorization form and annual notification that meets the requirement of the statute and rules.  The respondents have stated that they will incorporate the changes to the authorization form and annual notification.


Staff determined that, in this instance, the failure of the 35 employer/contractor respondents to fully comply with the law does not amount to an actual violation warranting further investigation.  However, pursuant to WAC 390-37-060(1)(b), the 35 employer/contractor respondents received a formal written warning concerning: (1) their failure to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) their failure to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination by the employer and the union for not contributing.  The employer/contractors were informed that the Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.  Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/43688
43687 12/07/2018 Freedom Foundation (Maxford Nelsen) Infrasource Services, LLC Infrasource Services, LLC: Alleged violations of RCW 42.17A.495 & WAC 390-17 for failure to obtain employee authorization forms that comply with requirements & annually provide required notices. (Nov 18) WAC 390-17-100, RCW 42.17A.495, WAC 390-17-110 Case Closed with Written Warning

The complaint alleged that United Association of Plumbers and Pipefitters Local 598, PDC Case 43672, Plumbers & Steamfitters Local 598 PAC, PDC Case 43673, and 35 employer/contractors, PDC Cases 43675-43709, may have violated RCW 42.17A.495, WAC 390-17-100, and WAC 390-17-110: (1) by failing to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) by failing to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination for not contributing.   The statute and rules primarily apply to the employer/contractors, but also prohibit the union and the employer/contractors from discriminating against a union member who does not make political contributions.


Staff found that the current authorization form does not conform to the requirements in RCW 42.17A.495 and WAC 390-17-100, and that many of the employer/contractors have not been sending out the required annual notification to employees who have funds withheld for PAC contributions, as required by WAC 390-17-110.  The employer/contractors rely on the union to provide an authorization form that complies with the law and rules.  Staff made it clear what changes need to be made to the written authorization and annual notification.  The union, working with and on behalf of the employer/contractors, has developed an authorization form and annual notification that meets the requirement of the statute and rules.  The respondents have stated that they will incorporate the changes to the authorization form and annual notification.


Staff determined that, in this instance, the failure of the 35 employer/contractor respondents to fully comply with the law does not amount to an actual violation warranting further investigation.  However, pursuant to WAC 390-37-060(1)(b), the 35 employer/contractor respondents received a formal written warning concerning: (1) their failure to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) their failure to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination by the employer and the union for not contributing.  The employer/contractors were informed that the Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.  Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/43687
43686 12/07/2018 Freedom Foundation (Maxford Nelsen) Indian Eyes, LLC Indian Eyes, LLC: Alleged violations of RCW 42.17A.495 & WAC 390-17 for failure to obtain employee authorization forms that comply with requirements & annually provide required notices. (Nov 18) RCW 42.17A.495, WAC 390-17-110, WAC 390-17-100 Case Closed with Written Warning

The complaint alleged that United Association of Plumbers and Pipefitters Local 598, PDC Case 43672, Plumbers & Steamfitters Local 598 PAC, PDC Case 43673, and 35 employer/contractors, PDC Cases 43675-43709, may have violated RCW 42.17A.495, WAC 390-17-100, and WAC 390-17-110: (1) by failing to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) by failing to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination for not contributing.   The statute and rules primarily apply to the employer/contractors, but also prohibit the union and the employer/contractors from discriminating against a union member who does not make political contributions.


Staff found that the current authorization form does not conform to the requirements in RCW 42.17A.495 and WAC 390-17-100, and that many of the employer/contractors have not been sending out the required annual notification to employees who have funds withheld for PAC contributions, as required by WAC 390-17-110.  The employer/contractors rely on the union to provide an authorization form that complies with the law and rules.  Staff made it clear what changes need to be made to the written authorization and annual notification.  The union, working with and on behalf of the employer/contractors, has developed an authorization form and annual notification that meets the requirement of the statute and rules.  The respondents have stated that they will incorporate the changes to the authorization form and annual notification.


Staff determined that, in this instance, the failure of the 35 employer/contractor respondents to fully comply with the law does not amount to an actual violation warranting further investigation.  However, pursuant to WAC 390-37-060(1)(b), the 35 employer/contractor respondents received a formal written warning concerning: (1) their failure to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) their failure to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination by the employer and the union for not contributing.  The employer/contractors were informed that the Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.  Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/43686
43685 12/07/2018 Freedom Foundation (Maxford Nelsen) Fluid Controls and Components, Inc. Fluid Controls and Components, Inc.: Alleged violations of RCW 42.17A.495 & WAC 390-17 for failure to obtain employee authorization forms that comply with requirements & annually provide required notices. (Nov 18) RCW 42.17A.495, WAC 390-17-100, WAC 390-17-110 Case Closed with Written Warning

The complaint alleged that United Association of Plumbers and Pipefitters Local 598, PDC Case 43672, Plumbers & Steamfitters Local 598 PAC, PDC Case 43673, and 35 employer/contractors, PDC Cases 43675-43709, may have violated RCW 42.17A.495, WAC 390-17-100, and WAC 390-17-110: (1) by failing to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) by failing to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination for not contributing.   The statute and rules primarily apply to the employer/contractors, but also prohibit the union and the employer/contractors from discriminating against a union member who does not make political contributions.


Staff found that the current authorization form does not conform to the requirements in RCW 42.17A.495 and WAC 390-17-100, and that many of the employer/contractors have not been sending out the required annual notification to employees who have funds withheld for PAC contributions, as required by WAC 390-17-110.  The employer/contractors rely on the union to provide an authorization form that complies with the law and rules.  Staff made it clear what changes need to be made to the written authorization and annual notification.  The union, working with and on behalf of the employer/contractors, has developed an authorization form and annual notification that meets the requirement of the statute and rules.  The respondents have stated that they will incorporate the changes to the authorization form and annual notification.


Staff determined that, in this instance, the failure of the 35 employer/contractor respondents to fully comply with the law does not amount to an actual violation warranting further investigation.  However, pursuant to WAC 390-37-060(1)(b), the 35 employer/contractor respondents received a formal written warning concerning: (1) their failure to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) their failure to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination by the employer and the union for not contributing.  The employer/contractors were informed that the Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.  Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/43685
43684 12/07/2018 Freedom Foundation (Maxford Nelsen) Doubl-Kold Doubl-Kold: Alleged violations of RCW 42.17A.495 & WAC 390-17 for failure to obtain employee authorization forms that comply with requirements & annually provide required notices. (Nov 18) WAC 390-17-100, WAC 390-17-110, RCW 42.17A.495 Case Closed with Written Warning

The complaint alleged that United Association of Plumbers and Pipefitters Local 598, PDC Case 43672, Plumbers & Steamfitters Local 598 PAC, PDC Case 43673, and 35 employer/contractors, PDC Cases 43675-43709, may have violated RCW 42.17A.495, WAC 390-17-100, and WAC 390-17-110: (1) by failing to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) by failing to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination for not contributing.   The statute and rules primarily apply to the employer/contractors, but also prohibit the union and the employer/contractors from discriminating against a union member who does not make political contributions.


Staff found that the current authorization form does not conform to the requirements in RCW 42.17A.495 and WAC 390-17-100, and that many of the employer/contractors have not been sending out the required annual notification to employees who have funds withheld for PAC contributions, as required by WAC 390-17-110.  The employer/contractors rely on the union to provide an authorization form that complies with the law and rules.  Staff made it clear what changes need to be made to the written authorization and annual notification.  The union, working with and on behalf of the employer/contractors, has developed an authorization form and annual notification that meets the requirement of the statute and rules.  The respondents have stated that they will incorporate the changes to the authorization form and annual notification.


Staff determined that, in this instance, the failure of the 35 employer/contractor respondents to fully comply with the law does not amount to an actual violation warranting further investigation.  However, pursuant to WAC 390-37-060(1)(b), the 35 employer/contractor respondents received a formal written warning concerning: (1) their failure to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) their failure to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination by the employer and the union for not contributing.  The employer/contractors were informed that the Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.  Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/43684
43683 12/07/2018 Freedom Foundation (Maxford Nelsen) Day & Zimmermann NPS Day & Zimmermann NPS: Alleged violations of RCW 42.17A.495 & WAC 390-17 for failure to obtain employee authorization forms that comply with requirements & annually provide required notices. (Nov 18) WAC 390-17-100, WAC 390-17-110, RCW 42.17A.495 Case Closed with Written Warning

The complaint alleged that United Association of Plumbers and Pipefitters Local 598, PDC Case 43672, Plumbers & Steamfitters Local 598 PAC, PDC Case 43673, and 35 employer/contractors, PDC Cases 43675-43709, may have violated RCW 42.17A.495, WAC 390-17-100, and WAC 390-17-110: (1) by failing to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) by failing to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination for not contributing.   The statute and rules primarily apply to the employer/contractors, but also prohibit the union and the employer/contractors from discriminating against a union member who does not make political contributions.


Staff found that the current authorization form does not conform to the requirements in RCW 42.17A.495 and WAC 390-17-100, and that many of the employer/contractors have not been sending out the required annual notification to employees who have funds withheld for PAC contributions, as required by WAC 390-17-110.  The employer/contractors rely on the union to provide an authorization form that complies with the law and rules.  Staff made it clear what changes need to be made to the written authorization and annual notification.  The union, working with and on behalf of the employer/contractors, has developed an authorization form and annual notification that meets the requirement of the statute and rules.  The respondents have stated that they will incorporate the changes to the authorization form and annual notification.


Staff determined that, in this instance, the failure of the 35 employer/contractor respondents to fully comply with the law does not amount to an actual violation warranting further investigation.  However, pursuant to WAC 390-37-060(1)(b), the 35 employer/contractor respondents received a formal written warning concerning: (1) their failure to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) their failure to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination by the employer and the union for not contributing.  The employer/contractors were informed that the Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.  Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/43683
43682 12/07/2018 Freedom Foundation (Maxford Nelsen) Columbia River Electric Maintenance Columbia River Electric Maintenance: Alleged violations of RCW 42.17A.495 & WAC 390-17 for failure to obtain employee authorization forms that comply with requirements & annually provide required notices. (Nov 18) WAC 390-17-100, WAC 390-17-110, RCW 42.17A.495 Case Closed with Written Warning

The complaint alleged that United Association of Plumbers and Pipefitters Local 598, PDC Case 43672, Plumbers & Steamfitters Local 598 PAC, PDC Case 43673, and 35 employer/contractors, PDC Cases 43675-43709, may have violated RCW 42.17A.495, WAC 390-17-100, and WAC 390-17-110: (1) by failing to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) by failing to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination for not contributing.   The statute and rules primarily apply to the employer/contractors, but also prohibit the union and the employer/contractors from discriminating against a union member who does not make political contributions.


Staff found that the current authorization form does not conform to the requirements in RCW 42.17A.495 and WAC 390-17-100, and that many of the employer/contractors have not been sending out the required annual notification to employees who have funds withheld for PAC contributions, as required by WAC 390-17-110.  The employer/contractors rely on the union to provide an authorization form that complies with the law and rules.  Staff made it clear what changes need to be made to the written authorization and annual notification.  The union, working with and on behalf of the employer/contractors, has developed an authorization form and annual notification that meets the requirement of the statute and rules.  The respondents have stated that they will incorporate the changes to the authorization form and annual notification.


Staff determined that, in this instance, the failure of the 35 employer/contractor respondents to fully comply with the law does not amount to an actual violation warranting further investigation.  However, pursuant to WAC 390-37-060(1)(b), the 35 employer/contractor respondents received a formal written warning concerning: (1) their failure to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) their failure to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination by the employer and the union for not contributing.  The employer/contractors were informed that the Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.  Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/43682
43681 12/07/2018 Freedom Foundation (Maxford Nelsen) Central Washington Refrigeration Central Washington Refrigeration: Alleged violations of RCW 42.17A.495 & WAC 390-17 for failure to obtain employee authorization forms that comply with requirements & annually provide required notices. (Nov 18) RCW 42.17A.495, WAC 390-17-100, WAC 390-17-110 Case Closed with Written Warning

The complaint alleged that United Association of Plumbers and Pipefitters Local 598, PDC Case 43672, Plumbers & Steamfitters Local 598 PAC, PDC Case 43673, and 35 employer/contractors, PDC Cases 43675-43709, may have violated RCW 42.17A.495, WAC 390-17-100, and WAC 390-17-110: (1) by failing to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) by failing to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination for not contributing.   The statute and rules primarily apply to the employer/contractors, but also prohibit the union and the employer/contractors from discriminating against a union member who does not make political contributions.


Staff found that the current authorization form does not conform to the requirements in RCW 42.17A.495 and WAC 390-17-100, and that many of the employer/contractors have not been sending out the required annual notification to employees who have funds withheld for PAC contributions, as required by WAC 390-17-110.  The employer/contractors rely on the union to provide an authorization form that complies with the law and rules.  Staff made it clear what changes need to be made to the written authorization and annual notification.  The union, working with and on behalf of the employer/contractors, has developed an authorization form and annual notification that meets the requirement of the statute and rules.  The respondents have stated that they will incorporate the changes to the authorization form and annual notification.

Staff determined that, in this instance, the failure of the 35 employer/contractor respondents to fully comply with the law does not amount to an actual violation warranting further investigation.  However, pursuant to WAC 390-37-060(1)(b), the 35 employer/contractor respondents received a formal written warning concerning: (1) their failure to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) their failure to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination by the employer and the union for not contributing.  The employer/contractors were informed that the Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.  Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/43681
43680 12/07/2018 Freedom Foundation (Maxford Nelsen) Callies Welding and Fabrication, LLC Callies Welding and Fabrication, LLC: Alleged violations of RCW 42.17A.495 & WAC 390-17 for failure to obtain employee authorization forms that comply with requirements & annually provide required notices. (Nov 18) WAC 390-17-110, RCW 42.17A.495, WAC 390-17-100 Case Closed with Written Warning

The complaint alleged that United Association of Plumbers and Pipefitters Local 598, PDC Case 43672, Plumbers & Steamfitters Local 598 PAC, PDC Case 43673, and 35 employer/contractors, PDC Cases 43675-43709, may have violated RCW 42.17A.495, WAC 390-17-100, and WAC 390-17-110: (1) by failing to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) by failing to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination for not contributing.   The statute and rules primarily apply to the employer/contractors, but also prohibit the union and the employer/contractors from discriminating against a union member who does not make political contributions.


Staff found that the current authorization form does not conform to the requirements in RCW 42.17A.495 and WAC 390-17-100, and that many of the employer/contractors have not been sending out the required annual notification to employees who have funds withheld for PAC contributions, as required by WAC 390-17-110.  The employer/contractors rely on the union to provide an authorization form that complies with the law and rules.  Staff made it clear what changes need to be made to the written authorization and annual notification.  The union, working with and on behalf of the employer/contractors, has developed an authorization form and annual notification that meets the requirement of the statute and rules.  The respondents have stated that they will incorporate the changes to the authorization form and annual notification.


Staff determined that, in this instance, the failure of the 35 employer/contractor respondents to fully comply with the law does not amount to an actual violation warranting further investigation.  However, pursuant to WAC 390-37-060(1)(b), the 35 employer/contractor respondents received a formal written warning concerning: (1) their failure to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) their failure to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination by the employer and the union for not contributing.  The employer/contractors were informed that the Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.  Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/43680
43679 12/07/2018 Freedom Foundation (Maxford Nelsen) Brothers Pipeline Corporation Brothers Pipeline Corporation: Alleged violations of RCW 42.17A.495 & WAC 390-17 for failure to obtain employee authorization forms that comply with requirements & annually provide required notices. (Nov 18) WAC 390-17-100, WAC 390-17-110, RCW 42.17A.495 Case Closed with Written Warning

The complaint alleged that United Association of Plumbers and Pipefitters Local 598, PDC Case 43672, Plumbers & Steamfitters Local 598 PAC, PDC Case 43673, and 35 employer/contractors, PDC Cases 43675-43709, may have violated RCW 42.17A.495, WAC 390-17-100, and WAC 390-17-110: (1) by failing to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) by failing to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination for not contributing.   The statute and rules primarily apply to the employer/contractors, but also prohibit the union and the employer/contractors from discriminating against a union member who does not make political contributions.


Staff found that the current authorization form does not conform to the requirements in RCW 42.17A.495 and WAC 390-17-100, and that many of the employer/contractors have not been sending out the required annual notification to employees who have funds withheld for PAC contributions, as required by WAC 390-17-110.  The employer/contractors rely on the union to provide an authorization form that complies with the law and rules.  Staff made it clear what changes need to be made to the written authorization and annual notification.  The union, working with and on behalf of the employer/contractors, has developed an authorization form and annual notification that meets the requirement of the statute and rules.  The respondents have stated that they will incorporate the changes to the authorization form and annual notification.


Staff determined that, in this instance, the failure of the 35 employer/contractor respondents to fully comply with the law does not amount to an actual violation warranting further investigation.  However, pursuant to WAC 390-37-060(1)(b), the 35 employer/contractor respondents received a formal written warning concerning: (1) their failure to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) their failure to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination by the employer and the union for not contributing.  The employer/contractors were informed that the Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.  Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).
https://www.pdc.wa.gov/browse/enforcement-cases/43679
43678 12/07/2018 Freedom Foundation (Maxford Nelsen) BNB Mechanical, LLC BNB Mechanical, LLC: Alleged violations of RCW 42.17A.495 & WAC 390-17 for failure to obtain employee authorization forms that comply with requirements & annually provide required notices. (Nov 18) WAC 390-17-100, RCW 42.17A.495, WAC 390-17-110 Case Closed with Written Warning

The complaint alleged that United Association of Plumbers and Pipefitters Local 598, PDC Case 43672, Plumbers & Steamfitters Local 598 PAC, PDC Case 43673, and 35 employer/contractors, PDC Cases 43675-43709, may have violated RCW 42.17A.495, WAC 390-17-100, and WAC 390-17-110: (1) by failing to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) by failing to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination for not contributing.   The statute and rules primarily apply to the employer/contractors, but also prohibit the union and the employer/contractors from discriminating against a union member who does not make political contributions.


Staff found that the current authorization form does not conform to the requirements in RCW 42.17A.495 and WAC 390-17-100, and that many of the employer/contractors have not been sending out the required annual notification to employees who have funds withheld for PAC contributions, as required by WAC 390-17-110.  The employer/contractors rely on the union to provide an authorization form that complies with the law and rules.  Staff made it clear what changes need to be made to the written authorization and annual notification.  The union, working with and on behalf of the employer/contractors, has developed an authorization form and annual notification that meets the requirement of the statute and rules.  The respondents have stated that they will incorporate the changes to the authorization form and annual notification.


Staff determined that, in this instance, the failure of the 35 employer/contractor respondents to fully comply with the law does not amount to an actual violation warranting further investigation.  However, pursuant to WAC 390-37-060(1)(b), the 35 employer/contractor respondents received a formal written warning concerning: (1) their failure to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) their failure to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination by the employer and the union for not contributing.  The employer/contractors were informed that the Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.  Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/43678
43677 12/07/2018 Freedom Foundation (Maxford Nelsen) Applied Process Cooling Applied Process Cooling: Alleged violations of RCW 42.17A.495 & WAC 390-17 for failure to obtain employee authorization forms that comply with requirements & annually provide required notices. (Nov 18) RCW 42.17A.495, WAC 390-17-100, WAC 390-17-110 Case Closed with Written Warning

The complaint alleged that United Association of Plumbers and Pipefitters Local 598, PDC Case 43672, Plumbers & Steamfitters Local 598 PAC, PDC Case 43673, and 35 employer/contractors, PDC Cases 43675-43709, may have violated RCW 42.17A.495, WAC 390-17-100, and WAC 390-17-110: (1) by failing to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) by failing to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination for not contributing.   The statute and rules primarily apply to the employer/contractors, but also prohibit the union and the employer/contractors from discriminating against a union member who does not make political contributions.


Staff found that the current authorization form does not conform to the requirements in RCW 42.17A.495 and WAC 390-17-100, and that many of the employer/contractors have not been sending out the required annual notification to employees who have funds withheld for PAC contributions, as required by WAC 390-17-110.  The employer/contractors rely on the union to provide an authorization form that complies with the law and rules.  Staff made it clear what changes need to be made to the written authorization and annual notification.  The union, working with and on behalf of the employer/contractors, has developed an authorization form and annual notification that meets the requirement of the statute and rules.  The respondents have stated that they will incorporate the changes to the authorization form and annual notification.


Staff determined that, in this instance, the failure of the 35 employer/contractor respondents to fully comply with the law does not amount to an actual violation warranting further investigation.  However, pursuant to WAC 390-37-060(1)(b), the 35 employer/contractor respondents received a formal written warning concerning: (1) their failure to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) their failure to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination by the employer and the union for not contributing.  The employer/contractors were informed that the Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.  Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/43677
43676 12/07/2018 Freedom Foundation (Maxford Nelsen) Apollo Mechanical Contractors (formerly Apollo Sheet Metal) Apollo Mechanical Contractors: Alleged violations of RCW 42.17A.495 & WAC 390-17 for failure to obtain employee authorization forms that comply with requirements & annually provide required notices. (Nov 18) WAC 390-17-110, WAC 390-17-100, RCW 42.17A.495 Case Closed with Written Warning

The complaint alleged that United Association of Plumbers and Pipefitters Local 598, PDC Case 43672, Plumbers & Steamfitters Local 598 PAC, PDC Case 43673, and 35 employer/contractors, PDC Cases 43675-43709, may have violated RCW 42.17A.495, WAC 390-17-100, and WAC 390-17-110: (1) by failing to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) by failing to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination for not contributing.   The statute and rules primarily apply to the employer/contractors, but also prohibit the union and the employer/contractors from discriminating against a union member who does not make political contributions.


Staff found that the current authorization form does not conform to the requirements in RCW 42.17A.495 and WAC 390-17-100, and that many of the employer/contractors have not been sending out the required annual notification to employees who have funds withheld for PAC contributions, as required by WAC 390-17-110.  The employer/contractors rely on the union to provide an authorization form that complies with the law and rules.  Staff made it clear what changes need to be made to the written authorization and annual notification.  The union, working with and on behalf of the employer/contractors, has developed an authorization form and annual notification that meets the requirement of the statute and rules.  The respondents have stated that they will incorporate the changes to the authorization form and annual notification.


Staff determined that, in this instance, the failure of the 35 employer/contractor respondents to fully comply with the law does not amount to an actual violation warranting further investigation.  However, pursuant to WAC 390-37-060(1)(b), the 35 employer/contractor respondents received a formal written warning concerning: (1) their failure to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) their failure to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination by the employer and the union for not contributing.  The employer/contractors were informed that the Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.  Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/43676
43675 12/07/2018 Freedom Foundation (Maxford Nelsen) American Electric, Inc. American Electric, Inc.: Alleged violations of RCW 42.17A.495 & WAC 390-17 for failure to obtain employee authorization forms that comply with requirements & annually provide required notices. (Nov 18) WAC 390-17-100, WAC 390-17-110, RCW 42.17A.495 Case Closed with Written Warning

The complaint alleged that United Association of Plumbers and Pipefitters Local 598, PDC Case 43672, Plumbers & Steamfitters Local 598 PAC, PDC Case 43673, and 35 employer/contractors, PDC Cases 43675-43709, may have violated RCW 42.17A.495, WAC 390-17-100, and WAC 390-17-110: (1) by failing to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) by failing to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination for not contributing.   The statute and rules primarily apply to the employer/contractors, but also prohibit the union and the employer/contractors from discriminating against a union member who does not make political contributions.


Staff found that the current authorization form does not conform to the requirements in RCW 42.17A.495 and WAC 390-17-100, and that many of the employer/contractors have not been sending out the required annual notification to employees who have funds withheld for PAC contributions, as required by WAC 390-17-110.  The employer/contractors rely on the union to provide an authorization form that complies with the law and rules.  Staff made it clear what changes need to be made to the written authorization and annual notification.  The union, working with and on behalf of the employer/contractors, has developed an authorization form and annual notification that meets the requirement of the statute and rules.  The respondents have stated that they will incorporate the changes to the authorization form and annual notification.


Staff determined that, in this instance, the failure of the 35 employer/contractor respondents to fully comply with the law does not amount to an actual violation warranting further investigation.  However, pursuant to WAC 390-37-060(1)(b), the 35 employer/contractor respondents received a formal written warning concerning: (1) their failure to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) their failure to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination by the employer and the union for not contributing.  The employer/contractors were informed that the Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.  Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).
https://www.pdc.wa.gov/browse/enforcement-cases/43675
43673 12/07/2018 Freedom Foundation (Maxford Nelsen) Plumbers & Steamfitters Local 598 PAC Plumbers & Steamfitters Local 598 PAC: Alleged violations of RCW 42.17A.495 & WAC 390-17 for failure to obtain employee authorization forms that comply with requirements & annually provide required notices. (Nov 18) WAC 390-17-110, WAC 390-17-100, RCW 42.17A.495 Case Closed with Written Warning

The complaint alleged that United Association of Plumbers and Pipefitters Local 598, PDC Case 43672, Plumbers & Steamfitters Local 598 PAC, PDC Case 43673, and 35 employer/contractors, PDC Cases 43675-43709, may have violated RCW 42.17A.495, WAC 390-17-100, and WAC 390-17-110: (1) by failing to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) by failing to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination for not contributing.   The statute and rules primarily apply to the employer/contractors, but also prohibit the union and the employer/contractors from discriminating against a union member who does not make political contributions.


Staff found that the current authorization form does not conform to the requirements in RCW 42.17A.495 and WAC 390-17-100, and that many of the employer/contractors have not been sending out the required annual notification to employees who have funds withheld for PAC contributions, as required by WAC 390-17-110.  The employer/contractors rely on the union to provide an authorization form that complies with the law and rules.  Staff made it clear what changes need to be made to the written authorization and annual notification.  The union, working with and on behalf of the employer/contractors, has developed an authorization form and annual notification that meets the requirement of the statute and rules.  The respondents have stated that they will incorporate the changes to the authorization form and annual notification.


Staff determined that, in this instance, the failure of the 35 employer/contractor respondents to fully comply with the law does not amount to an actual violation warranting further investigation.  However, pursuant to WAC 390-37-060(1)(b), the 35 employer/contractor respondents received a formal written warning concerning: (1) their failure to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) their failure to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination by the employer and the union for not contributing.  The employer/contractors were informed that the Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.  Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/43673
43672 12/07/2018 Freedom Foundation (Maxford Nelsen) United Association of Plumbers and Pipefitters Local 598 United Association of Plumbers and Pipefitters Local 598: Alleged violations of RCW 42.17A.495 & WAC 390-17 for failure to obtain employee authorization forms that comply with requirements & annually provide required notices. (Nov 18) WAC 390-17-110, RCW 42.17A.495, WAC 390-17-100 Case Closed with Written Warning

The complaint alleged that United Association of Plumbers and Pipefitters Local 598, PDC Case 43672, Plumbers & Steamfitters Local 598 PAC, PDC Case 43673, and 35 employer/contractors, PDC Cases 43675-43709, may have violated RCW 42.17A.495, WAC 390-17-100, and WAC 390-17-110: (1) by failing to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) by failing to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination for not contributing.   The statute and rules primarily apply to the employer/contractors, but also prohibit the union and the employer/contractors from discriminating against a union member who does not make political contributions.


Staff found that the current authorization form does not conform to the requirements in RCW 42.17A.495 and WAC 390-17-100, and that many of the employer/contractors have not been sending out the required annual notification to employees who have funds withheld for PAC contributions, as required by WAC 390-17-110.  The employer/contractors rely on the union to provide an authorization form that complies with the law and rules.  Staff made it clear what changes need to be made to the written authorization and annual notification.  The union, working with and on behalf of the employer/contractors, has developed an authorization form and annual notification that meets the requirement of the statute and rules.  The respondents have stated that they will incorporate the changes to the authorization form and annual notification.


Staff determined that, in this instance, the failure of the 35 employer/contractor respondents to fully comply with the law does not amount to an actual violation warranting further investigation.  However, pursuant to WAC 390-37-060(1)(b), the 35 employer/contractor respondents received a formal written warning concerning: (1) their failure to obtain a proper written request from employees before withholding wages or salaries for contributions to Plumbers & Steamfitters Local 598 PAC; and (2) their failure to provide an annual notification to employees who have requested payroll deductions for political contributions of their right to withdraw their request at any time, and of the prohibition against discrimination by the employer and the union for not contributing.  The employer/contractors were informed that the Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.  Based on this information, the PDC found that no further action is warranted and dismissed this matter in accordance with RCW 42.17A.755(1).


https://www.pdc.wa.gov/browse/enforcement-cases/43672
43628 12/06/2018 Walter Smith Matthew Shea Shea, Matthew: Alleged violations of RCW 42.17A.430 & .445 by donating surplus funds to unregistered charitable organizations and personal use of surplus funds. (EY 18 Dec 18) RCW 42.17A.430, RCW 42.17A.445 Investigation of Possible Violation
A complaint was filed against Matt Shea, an incumbent State Representative in the 4th Legislative District, and a candidate for re-election to that office in 2014, 2016, and 2018, alleging violations of (1) RCW 42.17A.430 by making expenditures from the Matt Shea Surplus Funds account to three charitable organizations not registered pursuant to RCW 19.09; and (2) RCW 42.17A.445 for personal use of surplus funds.

After PDC staff conducted a preliminary review and assessment of the facts, PDC staff opened a formal investigation and held an Initial Hearing (Case Status Review Hearing) for Matt Shea for this case and PDC Case 43573 on February 14, 2019, pursuant to RCW 42.17A.755, and WACs 390-37-060 and 390-37-071.
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https://www.pdc.wa.gov/browse/enforcement-cases/43628
43601 12/05/2018 City of Spokane Valley Jeremiah Schreindl Schreindl, Jeremiah: Alleged violation of RCW 42.17A.555 by using public agency facilities to promote ballot propositions. (EY 18, Nov 18) RCW 42.17A.555 Case Closed with Reminder
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Cary Driskell on November 30, 2018. The complaint alleged that Jeremiah Schreindl may have violated RCW 42.17A.555 by using public agency facilities to promote or oppose two ballot propositions.
Based on our findings, staff has determined that in this instance, the Respondent’s use of City of Spokane Valley facilities does not amount to a violation that warrants further investigation.

PDC staff is reminding Jeremiah Schreindl about the importance of not using City of Spokane Valley facilities for promoting or opposing ballot propositions or assisting an election campaign.

The PDC has closed the matter and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/43601
43573 12/05/2018 Aaron Jarvis Matthew Shea Shea, Matthew: Alleged Violation of RCW 42.17A.430 for unauthorized use surplus funds. (NOV 2018) RCW 42.17A.430 Investigation of Possible Violation
A complaint was filed against Matt Shea, an incumbent State Representative in the 4th Legislative District, and a candidate for re-election to that office in 2014, 2016, and 2018, alleging violations RCW 42.17A.430 by making expenditures from the Matt Shea Surplus Funds account for unauthorized uses or purposes.
After PDC staff conducted a preliminary review and assessment of the facts, PDC staff opened a formal investigation and held an Initial Hearing (Case Status Review Hearing) for Matt Shea for this case and PDC Case 43628 on February 14, 2019, pursuant to RCW 42.17A.755, and WACs 390-37-060 and 390-37-071.
https://www.pdc.wa.gov/browse/enforcement-cases/43573
43572 12/05/2018 Brian Estes Mike Peetoom Peetoom, Mike: Alleged Violation fo RCW 42.17A.235 for failure to disclose contributions and expenditures. (NOV 2018) RCW 42.17A.235 Case Closed with Reminder
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Brian Estes on November 18, 2018. The complaint alleged that Michael Peetoom, a first-time candidate seeking the office of Council Member in Whatcom County, may have violated RCW 42.17A.235 for failure to timely or accurately file Monetary Contribution reports (C-3 reports) or Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign. 

PDC staff reviewed your allegations, the applicable statutes, rules, and reporting requirements; the response provided by Michael Peetoom; and the applicable PDC reports filed by the Campaign, to determine whether the record supports a finding of one or more violations. 

Based on these findings and the following facts, staff has determined that in this instance, the failure to accurately file the contribution and expenditure reports does not amount to a material violation warranting further investigation since: (1) Michael Peetoom was a first-time candidate for public office who lost the General Election in 2018; (2) The Campaign made minor or ministerial errors on required reports, which did not materially impact the public interest; (3) The $100 expenditure for signage represented less than .7 percent of the $14,447 in total expenditures made by the Campaign; and (4) Michael Peetoom amended the reports and made the necessary technical corrections. 

PDC staff is reminding Michael Peetoom about the importance of timely and accurately disclosing all contribution and expenditure activities, including the accurate filing of expense descriptions for all future PDC reports, including the C-1 and F-1 reports. Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1), and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/43572
43548 12/04/2018 Diana Izaguirre Matthew Beaton Beaton, Matthew: Alleged violation of RCW 42.17A.555 by using public office, agency or facilities to assist an election campaign. (EY 18 Nov 18) RCW 42.17A.555 Case Closed with No Evidence of Violations
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Diana Garza Izaguirre on November 5, 2018. The complaint alleged that Matt Beaton may have violated RCW 42.17A.555 by using a public agency, office or facilities to assist an election campaign.

Based on these findings, staff has determined that in this instance, no evidence supports a finding of an actual violation warranting further investigation.

The PDC has closed the matter and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/43548
43205 11/21/2018 Glen Morgan Kitsap County Democratic Central Committee Kitsap County Democratic Central Committee: Alleged violations of RCW 42.17A.220 for failure to timely deposit contributions and .235 for failure to timely report contributions and expenditures (EY 18; Nov 18) RCW 42.17A.235, RCW 42.17A.220 Case Closed with Written Warning
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Glen Morgan on November 21, 2018. The complaint alleged that the Kitsap County Democratic Central Committee may have violated RCW 42.17A.220 for failure to timely deposit contributions and .235 for failure to timely report contributions and expenditures.

Based on our findings, staff has determined that in this instance, failure to timely deposit contributions and to timely report contribution and expenditure activity do not amount to actual material violations warranting further investigation.

Pursuant to WAC 390-37-060(1)(b), Kitsap County Democratic Central Committee will receive a formal written warning concerning their failure to timely deposit contributions within five business days of receipt, and failure to timely report contribution and expenditure activity. The formal written warning will include staff’s expectation that Kitsap County Democratic Central Committee institutes procedures to ensure funds are timely deposited and reports are filed according to their statutory deadlines. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1), and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/43205
43200 11/21/2018 Roger Lenk John E. (Juan) Orozco Orozco, John: Alleged Violation of RCW 42.17A.555 for use of public facilities to support a political campaign. (NOV 2018) RCW 42.17A 555 Case Closed with No Evidence of Violations
The complaint alleged John E. (Juan) Orozco may have violated RCW 42.17A.555 for use of public facilities to support a political campaign, specifically you alleged Mr. Orozco used the Wapato City Council chamber to support his campaign for Wapato School Board and used his city-provided e-mail address on his Personal Financial Affairs Statement (F-1).

As a result of staff’s initial review, it was  found:

  • Listing his name as John E. Orozco, he filed a Personal Financial Affairs Statement (F-1) with the PDC on May 22, 2017 and Aug. 22, 2018.
  • As a candidate, Mr. Orozco listed email address “jorozco1125@gmail.com” in his F-1 filed May 22, 2017 (#100761474).
  • Once elected Mr. Orozco listed email address “jorozco@wapato-city.org” on his F-1 filed Aug. 22, 2018. (#1001298997).
  • In addition to the above, Mr. Orozco stated “the comment was made in jest….I am not running for any office.”
Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1) and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case.


https://www.pdc.wa.gov/browse/enforcement-cases/43200
43080 11/16/2018 David Hammond Grant County Republican Central Committee Grant County Republican Central Committee: Alleged violations of RCW 42.17A.220 and .235 for failure to timely deposit contributions, and to report contributions and expenditures (Nov 18) RCW 42.17A.220, RCW 42.17A.235 Investigation of Possible Violation
A complaint was filed with the PDC against the Grant County Republican Central Committee, a bona-fide political party committee, alleging the Committee may have violated RCW 42.17A.220 by failing to timely deposit contributions within five business days of receipt and RCW 42.17A.235 by failing to timely file Monetary Contribution reports (C-3 reports) and Campaign Summary Receipts and Expenditure reports (C-4 reports).

After PDC staff conducted a preliminary review and assessment of the facts, PDC staff opened a formal investigation and held an Initial Hearing (Case Status Review Hearing) for Grant County Republican Central Committee on Jan. 31, 2019, pursuant to RCW 42.17A.755, and WACs 390-37-060 and 390-37-071.
https://www.pdc.wa.gov/browse/enforcement-cases/43080
43061 11/15/2018 Andrew Saturn John Weidenfeller Weidenfeller, John: Alleged Violation of RCW 42.17A.555 for using public facilities to assist a political campaign. (NOV 2018) RCW 42.17A.555 Case Closed with Written Warning
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Andrew Saturn on November 9, 2018. The complaint alleged that John Weidenfeller, General Manager of Thurston County Public Utility District (PUD), may have violated RCW 42.17A.555 for using public facilities or resources to assist Linda Oosterman and oppose Andrew Saturn during the 2018 election campaigns for Thurston County PUD Commissioner. PDC staff reviewed your allegations, the statutes, rules, PDC Interpretation #04-02 Guidelines for Local Government Agencies in Election Campaigns, and the response from Mr. Weidenfeller.

Producing and distributing information to the Thurston County PUD Commissioners concerning the maintenance and operations of the PUD is part of Mr. Weidenfeller’s normal and regular duties as General Manager of the PUD. However, staff does not believe that rebutting statements made by Mr. Saturn in political advertisements and public forums as a candidate seeking election to the PUD, and providing that information to one of the incumbent Commissioners running against Mr. Saturn, is a permitted activity in accordance with PDC statues, rules and interpretations. 

Based on these findings PDC staff has determined that, in this instance, the letter produced and distributed to the Thurston County PUD Commissioners by Mr. Weidenfeller does not amount to an actual violation warranting further investigation or enforcement action. 

However, pursuant to WAC 390-37-060(1)(b), PDC staff issued a formal written warning to John Weidenfeller concerning the importance of complying with RCW 42.17A.555 and the prohibition of using PUD facilities to support or oppose a candidate or ballot proposition, in accordance with WAC 390-05-271 and 273. This formal written warning conveys staff’s expectation that in the future, Mr. Weidenfeller will fully comply with the prohibitions found in RCW 42.17A.555 concerning the use of public facilities, including using the facilities to rebut, respond, or attempt to clarify information that is critical of the PUD in political advertisements or statements made by candidates seeking public office, especially the office of PUD Commissioner. The Commission will consider this formal written warning if there are any future PDC law or rule violations by John Weidenfeller. 

Based on this information, the PDC has dismissed the complaint in accordance with RCW 42.17A.755(1).
https://www.pdc.wa.gov/browse/enforcement-cases/43061
43059 11/15/2018 Maralyn Chase David Powell Stand For Children Washington PAC: Alleged Violation of RCW 42.17A.320 for failure to accurately disclose sponsor identification for political advertising. (NOV 2018) RCW 42.17A.320 Case Closed with Reminder
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Danielle Franco-Malone on November 5, 2018. Your complaint alleged that the Stand For Children Washington PAC, a continuing political committee registered with the PDC, may have violated RCW 42.17A.320 by sponsoring political advertising that failed to list the correct sponsor identification on Facebook.  

PDC staff reviewed your allegations, the statutes and rules, and the response from Stand For Children Washington PAC.  

Based on these findings and the following facts, staff has determined that in this instance, the failure to disclose the correct sponsor identification does not amount to a material violation warranting further investigation since: (1) The Campaign acknowledged that the misspelling of the sponsor identification was an unintentional error resulting from the vendor’s staff; (2) The corresponding Facebook link contained a correct version of the sponsor committee name; and (3) The failure to correctly disclose the committee name of the sponsor was inadvertent and minor in nature, and did not materially impact the public interest. 

However, pursuant to WAC 390-37-060(1)(b), PDC staff issued a formal written warning to the Stand For Children Washington PAC concerning the importance of identifying the proper sponsor identification on all political advertising, including digital advertisements as required by PDC laws and rules. This formal written warning conveys staff’s expectation that the Stand For Children Washington PAC will fully comply with the political advertising requirements listed above in the future as a registered continuing political committee. The Commission will consider this formal written warning if there are any future PDC law or rule violations by the Stand For Children Washington PAC.

Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1), and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/43059
43055 11/15/2018 Mark Obtinario Twin Transit Twin Transit (Officials of): Alleged violations of RCW 42.17A.555 by using or authorizing the use of public facilities to support Proposition 1, a Transit Expansion ballot measure (EY 18; Nov 18) RCW 42.17A.555 Investigation of Possible Violation
Allegation: Violation of RCW 42.17A.555 by using the public facilities of Twin Transit to support passage of Proposition 1, a ballot measure on the November 6, 2018 general election ballot, concerning a sales and use tax to finance public transportation within the boundaries of the Lewis County Transportation Benefit Area.  The complaint concerns a website and other materials produced by Nelson/Nygaard Consulting Associates on behalf of Twin Transit describing the ballot measure.
https://www.pdc.wa.gov/browse/enforcement-cases/43055
43047 11/15/2018 Mark Obtinario Nelson/Nygaard Consulting Associates Nelson/Nygaard Consulting Associates: Alleged violations of RCW 42.17A.255 for failure to timely report independent expenditures, and RCW 42.17A.320 for failure to disclose sponsor ID on political advertising. RCW 42.17A.320, RCW 42.17A.255 Case Closed with No Evidence of Violations
The Public Disclosure Commission (PDC) has completed its review of the portion of the complaint filed by Mark Obtinario on October 24, 2018 that pertains to Nelson/Nygaard Consulting Associates. 
The complaint alleged that Nelson/Nygaard Consulting Associates may have violated: (1) RCW 42.17A.255 by failing to report, as an independent expenditure, its costs to create a website at LewisCountyTransitMeasure.com, and its costs to create and send a mailer, both promoting Proposition 1, a ballot measure on the November 6, 2018 general election ballot, concerning a sales and use tax to finance public transportation within the boundaries of the Lewis County Transportation Benefit Area; and (2) RCW 42.17A.320 by failing to include proper sponsor identification on the website and the mailer. 

The complaint also alleged that officials of Twin Transit may have violated RCW 42.17A.555 by using or authorizing the use of the public facilities of Twin Transit to promote Proposition 1. That portion of the complaint is being investigated separately under PDC Case 43055. 

PDC staff reviewed the allegations concerning Nelson/Nygaard Consulting Associates, the applicable statues, rules, and reporting requirements

Based on our findings, staff has determined that the alleged failure of Nelson/Nygaard Consulting Associates to file a C-6 report of Independent Expenditures and to include its name as the sponsor of political advertising on Twin Transit’s website and mailer concerning Proposition 1, is not an actual material violation warranting further investigation. 

Based on this information, the PDC has dismissed this matter, as it relates to Nelson/Nygaard Consulting Associates, in accordance with RCW 42.17A.755(1), and will not be conducting a more formal investigation into your complaint against Nelson/Nygaard Consulting Associates or pursuing enforcement action against this Respondent in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/43047
43026 11/14/2018 Brian Estes Vincent Buys Buys, Vincent: Alleged violation of RCW 42.17A.405 for accepting over-limit contributions, or RCW 42.17A.220 & .240 for inaccurately reporting contributions (EY 18; Nov 18) RCW 42.17A.405, RCW 42.17A.220, RCW 42.17A.240 Request for Technical Correction
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Brian Estes on October 30, 2018. The complaint alleged that Vincent Buys may have violated RCW 42.17A.405 for accepting over-limit contributions, or RCW 42.17A.220 & .240 for inaccurately reporting contributions.

Based on our findings, staff has determined that in this instance, failure to accurately report contributions does not amount to an actual material violation warranting further investigation.

Vincent Buys made minor or ministerial errors on required reports, which did not materially impact the public interest. Upon notification of noncompliance, Vincent Buys timely amended their reports, making the necessary technical corrections.

Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1), and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/43026
43018 11/14/2018 Ray Risdon Tony Cebe Cebe, Tony: Alleged violations of RCW 42.17A.555 for misuse of public facilities to oppose a ballot proposition (EY 18; Nov 18) RCW 42.17A.555 Case Closed with Written Warning
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Raymond Risdon on November 7, 2018. The complaint alleged that Anton Cebe may have violated RCW 42.17A.555 for misuse of public facilities to oppose a ballot proposition.

Based on our findings, staff has determined that in this instance, misusing a public uniform that was purchased with public funds, in order to oppose a ballot proposition, does not amount to an actual violation warranting further investigation.

Pursuant to WAC 390-37-060(1)(b), Anton Cebe will receive a formal written warning concerning misuse of a public uniform, paid for with public funds, in order to oppose a ballot proposition. The formal written warning will include staff’s expectation that Anton Cebe refrain from further appropriation of public facilities to support or oppose future candidates or ballot propositions. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1), and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/43018
43017 11/14/2018 Glen Morgan Active in Democracy Active in Democracy: Alleged violations of RCW 42.17A.220 and .235 for failure to timely deposit contributions, and to report contributions and expenditures (EY 18; Nov 18) RCW 42.17A.220, RCW 42.17A.235 Resolved through Statement of Understanding
  • Allegation One: Violation of RCW 42.17A.220 for failure to timely deposit contributions within 5 business days of receipt.
  • Allegation Two: Violation of RCW 42.17A.235 for failure to timely report contributions and expenditures.
https://www.pdc.wa.gov/browse/enforcement-cases/43017
43016 11/14/2018 Glen Morgan 41st District Deomcratic Organization 41st District Democratic Organization: Alleged violations of RCW 42.17A.220 and .235 for failure to timely deposit contributions, and report contributions and expenditures (EY 18; Nov 18) RCW 42.17A.220, RCW 42.17A.235 Case Closed with Written Warning
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Glen Morgan on October 29, 2018. The complaint alleged that 41st Legislative District Democratic Organization may have violated RCW 42.17A.220 and .235 for failure to timely deposit contributions, and report contributions and expenditures.

Based on our findings, staff has determined that in this instance, failure to timely deposit contributions and report contribution and expenditure activity does not amount to an actual material violation warranting further investigation.

Pursuant to WAC 390-37-060(1)(b), 41st Legislative District Democratic Organization will receive a formal written warning concerning failure to timely deposit contributions and report contribution and expenditure activity. The formal written warning will include staff’s expectation that 41st Legislative District Democratic Organization will timely deposit contributions and report contribution and expenditure activity in the future. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1), and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/43016
42988 11/14/2018 Steve Erickson Thomas SeGuine SeGuine, Thomas: Alleged Violation of RCW 42.17A.320 for failure to disclose sponsor identification and top five contributors for newspaper ads. (NOV 2018) RCW 42.17A.555 Case Closed with Reminder
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Steve Erickson on November 3, 2018. The complaint alleged that Tom Seguine, a candidate seeking the office of Washington Court of Appeals Judge in Division One, District 3, may have violated RCW 42.17A.320 for failure to disclose sponsor identification and top five contributors for political advertising.  

PDC staff reviewed the allegations, the statutes and rules, and the response from the Committee to Elect Tom Seguine (Campaign).

Based on these findings and the following facts, staff has determined that in this instance, the failure to disclose top five contributors and sponsorship information does not amount to a material violation warranting further investigation since: (1) The Campaign acknowledged that the sponsorship information was inadvertently omitted from a newspaper after graphics editing due to a lack of oversight of a vendor error; and (2) There was not sufficient evidence to demonstrate that the Campaign was required to disclose the top five contributors as specified by RCW 42.17A.320 and the Political Advertising Guide. 

PDC staff is reminding Thomas Seguine about the importance of ensuring that sponsor identification is disclosed for political advertising as required by RCW 42.17A.320, including the statement: “It is paid for by (name, address, city, state).” Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1), and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/42988
42987 11/14/2018 Brian Ritchie Rosemary O'Neil Snohomish County Emergency Radio System: Alleged Violation of RCW 42.17A.555 for using public facilities or resources to support a ballot measure. (NOV 2018) RCW 42.17A.555 Case Closed with Reminder
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Brian Ritchie on November 3, 2018. The complaint alleged that the Snohomish County Emergency Radio System, may have violated RCW 42.17A.555 for using public facilities or resources to support a ballot measure.  

PDC staff reviewed the allegations, the statutes and rules, the ballot proposition fact sheet, and the response from Snohomish County Emergency Radio System (SERS). 

Based on these findings, staff has determined that in this instance, the use of a public facilities does not amount to a material violation warranting further investigation since: (1) Historically, the PDC has routinely advised and held that with respect to election-related publications, one jurisdiction-wide objective and fair presentation of the facts per ballot measure is appropriate. (2) The Snohomish County Emergency Radio System has acknowledged that a few of the phrases in the fact sheet "should not have been used and will refrain from doing so in the future." (3) The Public Disclosure Commission holds that it is not only the right, but the responsibility of local government to inform the general public of the operational and maintenance issues facing local agencies. (4) The errors in the fact sheet are minor in nature and did not materially impact the public interest. 

PDC Staff is reminding the Snohomish County Emergency Radio System (SERS) about the importance of providing only an objective and fair presentation of the facts based on and expanded upon the information prepared by the agency in accordance with the normal and regular conduct of the agency. As defined by PDC Interpretation 04-02, the clause “objective and fair presentation of the facts” means that in addition to presenting the facts, the materials should present accurately the costs and other anticipated impacts of a ballot measure. Agencies should refrain from using terminology in fact sheets which may appear to exaggerate, overstate, inflate, or aggrandize the impact of the ballot measure in the effort to influence the outcome of the vote. 

Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1), and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case. 
https://www.pdc.wa.gov/browse/enforcement-cases/42987
42986 11/14/2018 Bruce Fein Michelle Caldier Caldier, Michelle: Alleged Violation of RCW 42.17A.635 and RCW 42.17A.555 for unathorized lobbying activities or unauthorized use of public facilities in order to support a political campaign. (NOV 2018) RCW 42.17A.635, RCW 42.17A.555 Case Closed with No Evidence of Violations
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Bruce Fein on November 3, 2018. The complaint alleged that Michelle Caldier, an incumbent candidate for the office of State Representative for the 26th Legislative, may have violated RCW 42.17A.555 for using public facility staff, resources, or hours to support a political campaign. 

PDC staff reviewed the allegations, the statutes and rules, the C-4 reports filed by the Campaign, and the response from Michelle Caldier.  
Based on our findings and the following facts, the purchasing and delivering of donuts to a public school does not amount to a material violation warranting further investigation since: (1) Activities relating to RCW 42.17A.555 does not apply to any person who is a state officer or state employee as defined in RCW 42.52.010. (2) There is no supporting evidence to demonstrate how Michelle Caldier may have violated a specific section of RCW 42.17A. 

Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1), and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/42986
42984 11/13/2018 Alan McDowell Rob Chase Chase, Rob: Alleged Violation of RCW 42.17A.555 for using public resources or facilities to engage in political campaign activities or ballot propositions. (NOV 2018) RCW 42.17A 555 Case Closed with Reminder
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Alan McDowell on November 3, 2018. The complaint alleged that Rob Chase, the Spokane County Treasurer, may have violated RCW 42.17A.555 for using public facilities or resources to scan a document in support of a political party plank proposal.

PDC staff reviewed the allegations, the statutes and rules, and the response from Rob Chase.  

Based on these findings and the following facts, staff has determined that in this instance, the use of public facilities to support political party plank does not amount of a material violation warranting further investigation since: (1) The alleged non-compliance  made by Rob Chase are minor or ministerial in nature and did not impact the public interest; and (2) The evidence provided is primarily based on the color scheme of the photographic background which is not substantial verification that a violation occurred. 

PDC staff is reminding Rob Chase that no elective official nor any employee of his or her office nor any person appointed to or employed by any public office or agency may use or authorize the use of any of the facilities of a public office or agency, directly or indirectly, for the purpose of assisting a campaign for election of any person to any office or for the promotion of or opposition to any ballot proposition. 

Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1), and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case. 
https://www.pdc.wa.gov/browse/enforcement-cases/42984
42983 11/13/2018 Jonathan Dilley Janice Louthan Louthan, Janice: Alleged Violation of RCW 42.17A.320 failure to disclose party preference status in radio ads and failure to disclose sponsor identification. (NOV 2018) RCW 42.17A.320 Case Closed with No Evidence of Violations
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Jonathan Dilley on November 2, 2018. The complaint alleged that Janice Louthan, a first-time candidate seeking the office of County Clerk for Grays Harbor County, may have violated RCW 42.17A.320 for failure to disclose party preference and sponsor identification in radio advertisements. 

PDC staff reviewed the allegations, the statutes and rules, the response from Janice Louthan, and a letter provided by the General Manager of Jodesha Broadcasting. 

Based on our findings and the following facts, staff has determined that in this instance, the failure to disclose political party preference and sponsor identification does not amount to a material violation warranting further investigation since: (1) Janice Louthan was a first-time candidate for public office in 2018; (2) The Campaign substantially met all other reporting requirements during the previous 12-month period. (3) The broadcasting station that was responsible for the ads acknowledged that the mistake occurred within their production department and not by the Campaign. (4) Janice Louthan is a candidate that lost the election and the radio ads did not materially impact the public interest.
 
Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1), and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case. 
https://www.pdc.wa.gov/browse/enforcement-cases/42983
42981 11/13/2018 Brian Aker Steven Gonzalez Gonzalez, Steven: Alleged Violation of RCW 42.17A.335 for making a false claim or implication of endorsement. (NOV 2018) RCW 42.17A.335 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Brian Aker on November 2, 2018. The complaint alleged that Justice Steven Gonzalez, candidate for reelection to State Supreme Court, Position 8, in the 2018 election, may have violated RCW 42.17A.335 for making a false claim of endorsement of a candidate for public office. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Philip Lloyd, Treasurer for Steven Gonzalez 2018 Campaign; and the applicable PDC reports filed by the Respondent, to determine whether the record supports a finding of one or more violations.

Staff found no evidence that Mr. Choi’s inclusion of a website paid for by the 2018 Gonzalez Campaign implied that Mr. Choi endorsed Justice Gonzalez or that the Gonzalez Campaign claimed such endorsement. Based on these findings staff has determined that, in this instance, no evidence supports a finding of an actual violation warranting further investigation. 

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).

https://www.pdc.wa.gov/browse/enforcement-cases/42981
42980 11/13/2018 Susan Peters Heather Clarke Washington Realtors Political Action Committee: Alleged Violation of RCW 42.17A.320, .435 for failure to disclose the top contributor, sponsor identification, and source of contributions. (OCT 2018) RCW 42.17A.445, RCW 42.17A.320 Case Closed with Written Warning
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Susan Peters on October 31, 2018. The complaint alleged that the WA Realtors PAC (Committee), a political committee registered with the PDC and affiliated with the Washington Association of Realtors, may have violated RCW 42.17A.320 by failing to include the committee’s top five contributors for independent expenditure advertisements sponsored by the committee, and RCW 42.17A.435 by failing to identify contributions. 

PDC staff reviewed the allegations listed in the complaint to determine whether a formal investigation or enforcement action is warranted. Staff reviewed all the exhibits submitted with the complaint, and the December 5, 2018 response letter received via email from Mark Lamb, attorney for the WA Realtors PAC (Committee). 

While the Committee failed to include Stand for Children PAC as its top contributor in the sponsor identification as required, PDC staff found no evidence of a material violation that would require conducting a more formal investigation into your complaint or pursuing enforcement action in this instance.

However, pursuant to WAC 390-37-060(1)(b), PDC staff issued a formal written warning to the WA Realtors PAC concerning the importance of identifying the complete sponsor identification on all political advertising including the top five contributors as required by the law. This formal written warning conveys staff’s expectation that the WA Realtors PAC will fully comply with the political advertising requirements listed above in the future as a registered political committee. The Commission will consider this formal written warning if there are any future PDC law or rule violations by the WA Realtors PAC. 

Based on the above, the PDC has dismissed your complaint in accordance with RCW 42.17A.755(1).
https://www.pdc.wa.gov/browse/enforcement-cases/42980
42973 11/13/2018 Norm Smith Citizens Against Newport Silicon Smelter (CANSS) Citizens Against Newport Silicon Smelter: Alleged violations of RCW 42.17A.205, .235 & .305 for failure to register as a political committee and report contributions, expenditures & electioneering communication. (EY 18 Oct 18) RCW 42.17A.205, RCW 42.17A.235, RCW 42.17A.305 Case Closed with No Evidence of Violations
  • Allegation One: Alleged violation of RCW 42.17A.205 for failure to register as a political committee.
  • Allegation Two: Alleged violation of RCW 42.17A.235 for failure to timely and accurately report contributions and expenditures. 
  • Allegation Three: Alleged violation of RCW 42.17A.305 for failure to report electioneering communication (e.g. Facebook ads supporting candidates).
https://www.pdc.wa.gov/browse/enforcement-cases/42973
42958 11/13/2018 Bret Uhrich Washington Conservation Voters Action Fund Washington Conservation Voters Action Fund: Alleged violation of RCW 42.17A.320 for failure to include sponsor ID on written political advertising (EY 18; Nov 18) RCW 42.17A.320 Case Closed with Written Warning
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Bret Uhrich on November 6, 2018. The complaint alleged that WA Conservation Voters Action Fund may have violated RCW 42.17A.320 for failure to accurately and completely disclose sponsor identification on text message based political advertising. 

PDC staff reviewed your allegations; the applicable statutes, rules, and reporting requirements; the response provided by WA Conservation Voters Action Fund; and PDC guidance concerning sponsor identification for text messages issued October 13, 2018, to determine whether the record supports a finding of one or more violations.

The guidance that WA Conservation Voters Action Fund cited in their response to the allegations states, “[s]ince some phones receiving the text will not be able to follow a link, we suggest campaigns include, in addition to a web address, mechanisms that allow the recipients to request sponsor ID information. Sponsors should make that process as easy as possible, perhaps by allowing the recipient to reply with a single character that then prompts another text message with the sponsor ID information. The message would look something like this: ‘Go to www.xyzcommittee.com or text * for sponsor information.’”] 

Based on these findings staff has determined that, in this instance, failure to provide an adequate avenue for voters to receive sponsor identification without connection to the Internet does not amount to an actual violation warranting further investigation. 

Pursuant to WAC 390-37-060(1)(b), WA Conservation Voters Action Fund will receive a formal written warning concerning failure to provide an adequate avenue for voters to receive sponsor identification without connection to the Internet. The formal written warning will include staff’s expectation that WA Conservation Voters Action Fund provides a mechanism in future political advertising for non-Internet capable devices to access the required sponsor identification disclosures quickly and easily. The Commission will consider the formal written warning in deciding on further 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 this matter in accordance with RCW 42.17A.755(1).
https://www.pdc.wa.gov/browse/enforcement-cases/42958
42952 11/13/2018 Andrew Saturn Linda Oosterman Oosterman, Linda (2): Alleged violations of RCW 42.17A.205 for failure to accurately and completely report committee officers, and RCW 42.17A.240 for failure to report in-kind contributions (EY 18; Nov 18) RCW 42.17A.240, RCW 42.17A.270, RCW 42.17A.205, RCW 42.17A.405 Case Closed with No Evidence of Violations
The Public Disclosure Commission (PDC) has completed its initial review of the complaint filed by Andrew Saturn on November 1, 2018. The complaint alleged that Linda Oosterman may have violated RCW 42.17A.205 for failure to accurately and completely report committee officers, and RCW 42.17A.240 for failure to report in-kind contributions.
Based on our findings, staff has determined that in this instance, no evidence supports a finding of an actual violation warranting further investigation.

Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1), and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/42952
42944 11/13/2018 Washington Senate Democratic Campaign (Samantha Kersul) Doug Ericksen Ericksen, Doug: Alleged Violation of RCW 42.17A.405 for accepting over-limit contributions. (OCT 2018) RCW 42.17A.405 Request for Technical Correction

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on October 31, 2018. Your complaint alleged that Doug Ericksen, current Senator and candidate for re-election in Legislative District 42 in the 2018 election, may have violated RCW 42.17A.405 for accepting over-limit contributions from two individual donors. 

Doug Ericksen made minor or ministerial errors on required reports, which did not materially impact the public interest. Upon notification of these errors, Senator Ericksen timely filed amended reports, making the necessary technical corrections as requested by staff.

Based on these finding, staff has determined that, in this instance, failure to accurately disclose and attribute two contributions from two individual donors to the Doug Ericksen 2018 Legislative Campaign, does not amount to an an actual violation warranting further invesitigation.

https://www.pdc.wa.gov/browse/enforcement-cases/42944
42940 11/13/2018 Michael Fertakis David Chan Chan, David (3): Alleged Violation of RCW 42.17A.235, .240 for failure to timely or accurately file contribution or expenditure reports. (OCT 2018) RCW 42.17A.235 Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the three complaints filed by Michael Fertakis in October 2018. The three complaints alleged that David Chan, candidate for Snohomish County Public Utility District Commissioner No. 1 in 2018, may have violated RCW 42.17A.235 and .240 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign. For your information, in order to more efficiently use PDC resources, these three complaints have been combined into one letter. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response(s) provided by David Chan; the applicable PDC reports filed by Respondent; and the October 17, 2018 Statement of Understanding with $300 civil penalty completed by Mr. Chan and acknowledging violations of RCW 42.17A.235 and .240, to determine whether the record supports a finding of one or more violations. 

The 2018 election was the first time David Chan filed as a candidate under the “Full Reporting” option and was required to file C-3 and C-4 reports using the PDC’s ORCA program disclosing campaign contribution and expenditure activities electronically. Serving as his own treasurer, Mr. Chan spent several weeks working with PDC Filer Assistance Staff on how to properly enter and correct information reported in ORCA, and he continued to work with staff throughout the 2018 election cycle.

In July 2018, two complaints were filed against David Chan alleging his campaign failed to timely and accurately file reports of campaign activities. On October 22, 2018, Mr. Chan completed a Statement of Understanding (SOU) acknowledging violations of RCW 42.17A.235 and .240 for failure to timely and accurately file C-3 and C-4 reports, and paid a $300 civil penalty, resolving similar allegations in PDC Cases 42329, 42397 and 42940.

Based on these findings staff has determined that, in this instance, failure to timely file a small number of C-3 and C-4 reports late disclosing details of a mailed political advertisement, does not amount to an actual violation warranting further investigation or additional enforcement action. Pursuant to WAC 390-37-060(1)(b), David Chan will receive a formal written warning concerning failure to timely and accurately disclosure of all contribution and expenditures. The formal written warning will include staff’s expectation that David Chan timely files all future required reports of contributions and expenditures, including all required vendor information during the accelerated reporting periods prior to and after any election in which his name appears on the ballot. The Commission will consider the formal written warning in deciding on further 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 this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/42940
42872 11/09/2018 Glen Morgan Win With Women PAC Win With Women PAC: Alleged violation of RCW 42.17A.220 and .235 for failure to timely deposit contributions and failure to timely report contributions and expenditures (EY 15-18; Nov 18) RCW 42.17A.220, RCW 42.17A.235 Case Closed with Written Warning
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Glen Morgan on October 29, 2018. The complaint alleged that Win with Women PAC may have violated RCW 42.17A.220 and .235 for failure to timely deposit contributions and failure to timely report contributions and expenditures.

Based on our findings, staff has determined that in this instance, failure to timely deposit contributions and report contributions and expenditures does not amount to an actual material violation warranting further investigation.

Pursuant to WAC 390-37-060(1)(b), Win with Women PAC will receive a formal written warning concerning failure to timely deposit contributions and report contributions and expenditures. The formal written warning will include staff’s expectation that Win with Women PAC pays closer attention to their primary source of contributions, and timely reports all contribution and expenditure activity. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1), and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/42872
42719 11/05/2018 Glen Morgan UFCW 21 PAC United Food & Commercial Workers Local 21 PAC: Alleged Violation of RCW 42.17A.220, .235, .240 for failure to timely and accurately file contribution and expenditure reports and failure to timely deposit contributions. (OCT 2018) RCW 42.17A.220, RCW 42.17A.235, RCW 42.17A.240 Violation Found by Commission
A complaint was filed with the PDC against the United Food & Commercial Workers 21 PAC (UFCW Local 21 PAC), a continuing political committee registered with the PDC, alleging that the UFCW Local 21 PAC may have violated: (1) RCW 42.17A.235 and .240 by failing to file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contributions and Expenditures reports (C-4 reports); and (2) RCW 42.17A.220 by failing to timely deposit monetary contributions into the committee bank account within five business days of receipt, as required for a political committee registered with the PDC.

After PDC staff conducted a preliminary review and assessment of the facts, PDC staff opened a formal investigation and held an Initial Hearing (Case Status Review Hearing) for UFCW Local 21 PAC on January 17, 2019, pursuant to RCW 42.17A.755, and WACs 390-37-060 and 390-37-071.

On February 26, 2019, PDC staff dismissed the allegation listed in the complaint concerning the failure to timely depositing monetary contributions into the Committee bank account in accordance with RCW 42.17A.755(1).   

At the February 28, 2019 Enforcement hearing, Commission unanimously accepted the amended Stipulation to Facts, Violations and Penalty, finding UFCW 21 PAC in violation of RCW 42.17A.235 and .240, and assessing a total civil penalty of $40,000 of which $20,000 is suspended on the condition that the Respondent is in compliance with all current reporting requirements, has no further violations of RCW 42.17A or WAC 390 for four years from the date of this Order, and pays the $20,000 non-suspended portion of the penalty within 30 days from the date of this Order.
the February 28, 2019, Enforcement Hearing 
https://www.pdc.wa.gov/browse/enforcement-cases/42719
42717 11/05/2018 Jim Brandy Glenn Blakeslee Blakeslee, Glenn (4): Alleged Violation of RCW 42.17A.555 for using public resources to support a political campaign. (OCT 2018) RCW 42.17A 555 Case Closed with Written Warning
The Public Disclosure Commission (PDC) has completed its review of the three complaints filed by Holly Jepson (PDC Cases 41960, 42389, and 42392), and the complaint filed by James Mundy (PDC Case 42717), against Glenn Blakeslee, a first-time candidate in 2018 seeking the office of Pend Oreille County Sheriff. The complaint alleged that Mr. Blakeslee, a Pend Oreille County Deputy Sheriff in 2018 may have violated RCW 42.17A.555 by using Pend Oreille County Sheriff resources to support your candidacy in 2018; and RCW 42.17A.235 and .240 by failing to disclose expenditures for political advertising in the form of newspaper and billboards on Summary Full Campaign Contribution and Expenditure reports (C-4 reports).

For your information, in order to more efficiently use PDC resources, the four complaints filed against Glenn Blakeslee have been combined into one letter. PDC staff reviewed the allegation listed in the four complaints and attached exhibits, the statutes, rules and PDC Interpretation #04-02 Guidelines for Local Agencies in Election Campaigns, and the Monetary Contributions reports (C-3 reports) and C-4 reports filed by Glenn Blakeslee for Sheriff (Campaign), and the responses from Mr. Blakeslee.

PDC staff’s review found no evidence that Glenn Blakeslee used the facilities of the Pend Oreille Sheriff’s Office to support his candidacy for County Sheriff in 2018, that would require conducting a more formal investigation into your complaint or pursuing enforcement action in this instance.

While the Campaign failed to timely disclose campaign expenditure for a billboard and newspaper advertisements, Mr. Blakeslee was a first-time candidate, and the late filed expenditures were disclosed 14 days prior to the November 6, 2018 general election being held. However, as part of staff’s review and the Campaign contacting PDC Filer Assistance, there were several C-3 reports filed that included $0 contributions that needed to be amended.
In addition, and an issue in disclosing monetary contributions received from couples into the Online Reporting of Campaign Activities (ORCA) campaign finance reporting software that resulted in $3,000 (+) in un-reported contributor information, and you failed to file a missing 2018 Post-General Election C-4 report. The Campaign has filed the missing Post-General Election C-4 report and filed two amended C-3 reports totaling $1,739 and are working on filing additional amended C-3 reports to be in full compliance.

Pursuant to WAC 390-37-060(1)(b), and with the understanding that the Blakeslee Campaign will file the necessary amended C-3 reports as soon as possible, Mr. Blakeslee is hereby formally warned concerning the failure to timely and accurately file campaign finance reports disclosing contribution and expenditure activities undertaken by his 2018 Campaign, including C-3 and C-4 reports in future years in accordance with PDC laws and rules. The formal written warning will include staff’s expectation that Mr. Blakeslee will timely file C-3 and C-4 reports, accurately disclosing his contribution and expenditure activities undertaken as a candidate in future years in accordance with PDC laws and rules. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Based on this information, the PDC has dismissed the four complaints in accordance with RCW 42.17A.755(1).
https://www.pdc.wa.gov/browse/enforcement-cases/42717
42716 11/05/2018 Norm Smith Wendy beach Beach, Wendy: Alleged Violation of RCW 42.17A.320 for failure to identify sponsor and disclose party preference on political advertising. (OCT 2018) RCW 42.17A.320 Case Closed with Reminder
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Norman Smith on October 25, 2018. The complaint alleged that Wendy Beach, a first-time candidate seeking the office of Commissioner for the Pend Oreille Public Utility District, may have violated RCW 42.17A.320 for failure to identify party affiliation on campaign signs and failure to disclose sponsor identification.

PDC staff reviewed your allegations, the statutes and rules, the C-1 report filed by the Campaign, and the response from Wendy Beach.  

Based on our findings and the following facts, staff has determined that in this instance, the failure to identify political party preference and sponsor identification does not amount to a material violation warranting further investigation since: (1) Wendy Beach was not required to list party preference for a nonpartisan office; (2) Wendy Beach was a first-time candidate for public office in 2018; (3) Wendy Beach is a candidate that lost the election and the failure to include sponsor information did not materially impact the public interest.      

PDC staff is reminding Wendy Beach about the importance of disclosing sponsor identification for political advertising as required by RCW 42.17A.320, including the statement: "It is paid for by (name, address, city, state)." It is also PDC guidance that the party preference on the Candidate Registration (C-1 report) should match the party preference on the declaration of candidacy and political advertising.

Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1), and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case. 
https://www.pdc.wa.gov/browse/enforcement-cases/42716
42715 11/05/2018 Norm Smith Sheryl Miller Miller, Sheryl: Alleged Violation of RCW 42.17A.320 for failure to identify sponsor and disclose party affiliation on political advertising. (OCT 2018) RCW 42.17A.320 Case Closed with Written Warning
The complaint alleged that Sheryl Miller violated RCW 42.17A.320 by failing to list the complete sponsor identification, including the sponsor's address and the words “Paid for” or “Sponsored by”, and by failing to identify your party affiliation or preference on political advertising sponsored by her campaign. 

The photographs provided as part of the complaint feature Miller’s campaign signs that failed to comply with the political advertising statutes and PDC rules for a candidate.

Based on these findings and the fact Sheryl Miller is a first-time candidate and was not elected to the Pend Oreille County Commission, staff determined that in this instance, the failure to include the complete sponsor identification and her party affiliation or preference on political advertising she sponsored does not amount to a material violation warranting further investigation.  

Pursuant to WAC to WAC 390-37-060(1) Sheryl Miller received a formal written warning concerning the failure to comply with the requirements to include her party preference and the complete sponsor identification on political advertising sponsored by her 2018 campaign in accordance with PDC statute and rules.

The formal written warning includes staff's expectation that Sheryl Miller clearly identify her party preference and list the complete sponsor identification on all political advertising sponsored by her campaign in future years in accordance with PDC laws and rules. The Commission will consider this formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1).
https://www.pdc.wa.gov/browse/enforcement-cases/42715
42706 11/05/2018 Bret Uhrich Evereett Maroon Maroon, Everett: Alleged Violation of RCW 42.17A.320 for failure to include sponsor identification and political party affiliation in political advertising. (OCT 2018) RCW 42.17A.320 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Bret Uhrich on October 24, 2018. The complaint alleged that Everett Maroon, candidate for State Representative in Legislative District 16, Position 1 in the 2018 election, may have violated RCW 42.17A.320 for failure include sponsor identification and political party preference on political advertisement sponsored by the Campaign. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; and the response provided by Everett Maroon, to determine whether the record supports a finding of one or more violations.

Although the general definition of political advertisement and “mass communication” includes text messages, it appears that the text messages sent by the Everett Maroon for 16th Legislative District Campaign were not created with this in mind. Mr. Maroon utilized the services of the “Text Out the Vote” messaging service called Hustle, which is connected with the Washington State Democrats, that creates direct political advertising messages and indirect or get out the vote messages for a variety of users. 

Based on these findings staff has determined that, in this instance, failure to include sponsor identification and political party preference on political advertisement does not appear to be an actual violation warranting further investigation. PDC staff reminded Everett Maroon about the importance of including any required sponsor identification and any required political party preference on political advertisement in accordance with PDC laws and rules. 

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).

https://www.pdc.wa.gov/browse/enforcement-cases/42706
42704 11/05/2018 Glen Morgan Rick Offner Pierce County Democratic Party: Alleged Violation of RCW 42.17A.220, .235, .240 for for failure timely or accurately file contribution or expenditure reports and failure to timely deposit contributions. (OCT 2018) RCW 42.17A.220, RCW 42.17A.235, RCW 42.17A.240 Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the complaints filed by Glen Morgan on October 23, 2018 and January 3, 2019. The complaints alleged that the Pierce County Democratic Central Committee (PCDCC), a bona fide political party committee may have violated: (1) RCW 42.17A.235 and .240 by failing to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign; and (2) RCW 42.17A.205 by failing to timely file an amended Committee Registration (C-1pc report) within ten days disclosing any material change in the committee information.

PDC staff reviewed the allegations listed in the two complaints filed; the applicable statutes, rules, and reporting requirements; the response provided by Dominick Bergeron, former Treasurer for Pierce County Democratic Central Committee; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on staff’s review, the alleged late and incomplete filed C-3 and C-4 reports cited in the two complaints were primarily caused by a Committee reorganization and changes in officers, but we noted that the Committee implemented additional internal controls to ensure compliance by creating an oversight committee, by conducting an internal audit, and additional training.  These steps were taken, in part, by the Pierce County Democratic Central Committee to comply with the provisions of the settlement agreement. 

Based on these findings staff has determined that, in this instance, failure to timely and accurately file 19 filed C-3 and C-4 reports, including amendments, mostly disclosed little monetary activity, or were filed as a result of an internal audit process conducted by PCDCC, and therefore does not warrant further investigation or enforcement action.

Pursuant to WAC 390-37-060(1)(d), the PCDCC received a formal written warning concerning failure to timely and accurately file Monetary Contributions reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports) disclosing contribution and expenditure activities and failure to timely file an amended Committee Registration (C-1pc report) disclosing material changes. The formal written warning included staff’s expectation that PCDCC timely file accurate and complete C-3, C-4 and C-1pc reports in future years in accordance with PDC laws and rules. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.
 

https://www.pdc.wa.gov/browse/enforcement-cases/42704
42700 11/05/2018 Glen Morgan Gerald Hudson Service Employees International Union Political Education & Action Fund Pac: Alleged Violation RCW 42.17A.220, .235, .235 for failure to timely and accurately file contribution and and expenditure reports and failure to timely deposit contributions. (OCT RCW 42.17A.220, RCW 42.17A.235, RCW 42.17A.240 Case Closed with Reminder
A complaint was filed against the Service Employees International Union Political Education & Action Fund PAC (SEIU PEAF PAC),  alleging that the SEIU PEAF PAC, a federal political committee, may have violated RCW 42.17A.235 and .240 by failing to timely file Monetary Contributions reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports) as a Washington State political committee disclosing contribution and expenditure activities undertaken during calendar year 2016.

The allegations involved contributions SEIU PEAF PAC made to Washington State political committees participating in 2016 elections, that were timely disclosed on six C-5 reports filed during calendar year 2016 as an out-of-state committee.  The monetary contributions received and disclosed by SEIU PEAF PAC during 2016 were all transfers from SEIU International, 1800 Massachusetts Avenue NW, Washington DC, 20036,

The remaining committee expenditures were for contribution and other activities involving political committees and candidate activities in other states and at the federal level.  
PDC staff reminded the Service Employees International Union and the SEIU PEAF PAC concerning the importance of timely and accurately filing campaign finance reports as an in-state political committee disclosing contribution and expenditure activities undertaken to support Washington State candidates and political committees, if they do not qualify as an out-of-state political committee in future years in accordance with WAC 390-16-049.   


https://www.pdc.wa.gov/browse/enforcement-cases/42700
42587 11/02/2018 Lori DiMarco Nicholas Power Power, Nicholas (3): Alleged violations of RCW 42.17A.405 for accepting over-limit contributions, and RCW 42.17A.235 and .240 for failure to accurately and timely report in-kind and monetary contributions (EY 18; Nov 18) RCW 42.17A.235, RCW 42.17A.240, RCW 42.17A.405 Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Lois J. DiMarco on October 30, 2018. The complaint alleged that Nicholas Power, a candidate for San Juan County Prosecuting Attorney in 2018, may have violated: (1) RCW 42.17A.405 for accepting over-limit contributions for political advertising costs approved in advance by the candidate; (2) RCW 42.17A.235 and RCW 42.17A.240 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing monetary or in-kind contributions for political advertising costs approved in advance by the Campaign; and (3) RCW 42.17A. for failure to accurately report the candidate’s personal funds expended in support of his 2018 campaign.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response(s) provided by Nicholas Power; the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

It appears that the mistakes made by the 2018 Power Campaign in regard to the disclosure of costs connected to two political advertisements done in support of Nicholas Power’s Campaign and presented in October 2018, were caused by a general misunderstanding of statutory filing obligations and miscommunication between the Campaign and the sponsors of the advertisements. No evidence was found that Mr. Power meant to mislead or deprive the public of information related to the cost the two political advertisements referenced above. 

Based on these findings staff has determined that, in this instance, failure to timely and accurately file C-4 reports disclosing in-kind contributions for political advertising costs, does not amount to an actual violation warranting further investigation or additional enforcement action.

Pursuant to WAC 390-37-060(1)(d), Nicholas Power (2018 candidate for San Juan County Prosecutor) received a formal written warning concerning failure to timely and accurately file C-4 reports disclosing in-kind contributions for political advertising costs. The formal written warning included staff’s expectation that Mr. Power timely files all future required reports of contributions and expenditures including all monetary and in-kind contributions and expenditures. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

https://www.pdc.wa.gov/browse/enforcement-cases/42587
42586 11/02/2018 Lori DiMarco Don Pollard Pollard, Don: Chapter 42.17A RCW for failure to timely register a political committee, report contributions and expenditures, over-limit contributions, and to disclose proper Sponsor ID on political advertising (EY 18; Nov 18) RCW 42.17A.405, RCW 42.17A.320, RCW 42.17A.305, RCW 42.17A.235, RCW 42.17A.260, RCW 42.17A.255, RCW 42.17A.205 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Lois J. DiMarco on October 30, 2018. The complaint alleged that Don Pollard, a contributor to the 2018 Nicholas Power for San Juan County Prosecutor Campaign, may have violated: (1) RCW 42.17A.205 for failure to register a political committee in support of the 2018 Nicholas Power for San Juan County Prosecutor Campaign; (2) RCW 42.17A.235 and RCW 42.17A.240 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures for political advertising costs related to two paid advertisements; (3) RCW 42.17A.405 for making over-limit contributions to the Power Campaign through political advertising purchased after review and approval by the candidate; (4) RCW 42.17A.255, .260 and .305 for failure to timely and accurately report independent expenditures or electioneering communications; and (5) RCW 42.17A.320 for failure to accurately and completely disclose sponsor identification on written political advertisement.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response(s) provided by Mr. Pollard and Nicholas Power in a related case (PDC Case 42587); the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on these findings staff has determined that, in this instance, no evidence supports a finding of an actual violation warranting further investigation.

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).

https://www.pdc.wa.gov/browse/enforcement-cases/42586
42577 11/02/2018 Lois DiMarco George Von Gehr Von Gehr, George: Alleged violations of Chapter 42.17A RCW for failure to timely register a political committee, report contributions and expenditures, over-limit contributions, and to disclose proper Sponsor ID on political advertising (EY 18; Nov 18) RCW 42.17A.235, RCW 42.17A.255, RCW 42.17A.260, RCW 42.17A.305, RCW 42.17A.205, RCW 42.17A.320, RCW 42.17A.405 Case Closed with No Evidence of Violations

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Lois J. DiMarco on October 30, 2018. The complaint alleged that George Von Gehr, may have violated: (1) RCW 42.17A.205 for failure to register a political committee in support of the 2018 Nicholas Power for San Juan County Prosecutor Campaign; (2) RCW 42.17A.235 and RCW 42.17A.240 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures for political advertising costs related to two paid advertisements; (3) RCW 42.17A.405 for making over-limit contributions to the Power Campaign through political advertising purchased after review and approval by the candidate; (4) RCW 42.17A.255, .260 and .305 for failure to timely and accurately report independent expenditures or electioneering communications; and (5) RCW 42.17A.320 for failure to accurately and completely disclose sponsor identification on written political advertisement.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response(s) provided by Mr. Von Gehr and Nicholas Power in a related case (PDC Case 42587); the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

Based on these findings staff has determined that, in this instance, any campaign activities, including possible payments made by George Von Gehr using personal funds to a vendor presenting political advertisements, does not support a finding of an actual violation warranting further investigation.

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).

https://www.pdc.wa.gov/browse/enforcement-cases/42577
42576 11/02/2018 Lois DiMarco Robert Allen Allen, Robert: Alleged violations of Chapter 42.17A RCW for failure to timely register a political committee, report contributions and expenditures, over-limit contributions, and to disclose proper Sponsor ID on political advertising (EY 18; Nov 18) RCW 42.17A.205, RCW 42.17A.235, RCW 42.17A.255, RCW 42.17A.260, RCW 42.17A.305, RCW 42.17A.320, RCW 42.17A.405 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Lois J. DiMarco on October 30, 2018. The complaint alleged that Robert Allen, a contributor to the 2018 Nicholas Power for San Juan County Prosecutor Campaign and sponsor of paid political advertisement for the Power Campaign, may have violated: (1) RCW 42.17A.205 for failure to register a political committee in support of Nicholas Power; (2) RCW 42.17A.235 and RCW 42.17A.240 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures for political advertising costs related to two paid advertisements; (3) RCW 42.17A.405 for making over-limit contributions to the Power Campaign through political advertising purchased after review and approval by the candidate; (4) RCW 42.17A.255, .260 and .305 for failure to timely and accurately report independent expenditures or electioneering communications; and (5) RCW 42.17A.320 for failure to accurately and completely disclose sponsor identification on written political advertisement.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response(s) provided by Mr. Allen and Nicholas Power in a related case (PDC Case 42587); the applicable PDC reports filed by Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

It appears that Mr. Allen was not aware of the requirement to register and report as a political committee when he began planning the political advertisements and that his intent was to make expenditures independently, without the involvement of the candidate and without exceeding any contribution limits. There is also evidence that Mr. Allen attempted to include the names of the individual sponsors of the ads and may have inadvertently included names of individuals who supported Mr. Power’s Campaign but were not actually sponsors of the specific advertisements referenced in the complaint.

Based on these findings staff has determined that, in this instance, failure to register and report as a political committee after receiving and spending funds for two political advertisements made in support of the 2018 Nicholas Power for San Juan County Prosecutor Campaign, and failure to include accurate sponsor identification on the same two written political advertisements, does not amount to a finding of an actual violation warranting further investigation.

PDC staff reminded Robert Allen about the importance of registering as a political committee, the timely disclosure of all contribution and expenditure activities, and the requirement to identify the true and accurate sponsor of political advertisements made in support of any candidate for public office, in accordance with the statutes and rules. The reminder included staff’s expectation that Mr. Allen follow all applicable statutes and rules regarding the disclosure of campaign activities to support any candidate for public office in future years.

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).

https://www.pdc.wa.gov/browse/enforcement-cases/42576
42571 11/02/2018 Lois DiMarco Nicholas Power Power, Nicholas (2): Alleged violation of RCW 42.17A.240 for failure to accurately report expenditure for postage (EY 18; Nov 18) RCW 42.17A.240, WAC 390-16-037 Request for Technical Correction
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Lois DiMarco on October 30, 2018. The complaint alleged that Nicholas Power may have violated RCW 42.17A.240 for failure to accurately report expenditure for postage and website.

Based on our findings, staff has determined that in this instance, failure to accurately report an actual violation warranting further investigation.

Nicholas Power made minor or ministerial errors on required reports, which did not materially impact the public interest. Upon notification of noncompliance, Nicholas Power timely amended their reports, making the necessary technical corrections.

Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1), and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/42571
42567 11/02/2018 Glen Morgan IBEW 112 PAC Intl Brotherhood of Electrical Workers (IBEW) 112 PAC: Alleged violations of RCW 42.17A.220 and .235 for failure to timely deposit and report contributions and expenditures (EY 18; Nov 18) RCW 42.17A.235, RCW 42.17A.240, RCW 42.17A.220 Case Closed with Written Warning
A complaint was filed against the IBEW 112 PAC (Committee), a local continuing political committee located in Kennewick, Washington, alleging the committee may have violated RCW 42.17A.235 and .240 by failing to timely file complete and accurate Monetary Contribution reports (C-3 reports) and Summary Full Campaign Cont

While the Committee failed to timely file the required Pre-Election C-4 reports, they did consistently file those reports on roughly the same interval from 2012 through 2018, and it did not appear the public was deprived of critical campaign information.  Based on these findings staff has determined that, in this instance, the Committee’s failure to timely file its C-3 and C-4 reports does not amount to an actual violation warranting further investigation.

Pursuant to WAC 390-37-060(1)(b), however, IBEW 112 PAC will receive a formal written warning concerning the failure to timely file C-3 and C-4 reports disclosing all contribution and expenditures in accordance with the PDC laws, rules, and reporting requirements.  The formal written warning will include staff’s expectation that IBEW 112 PAC timely file all future required reports of contributions and expenditures, especially the 21-Day and 7-Day Pre-Election C-4 reports, in accordance with RCW 42.17A.235. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules. Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1).




https://www.pdc.wa.gov/browse/enforcement-cases/42567
42565 11/02/2018 Glen Morgan 45th Legislative District Democrats 45th Legislative District Democrats (2): Alleged violations of RCW 42.17A.220 and .235 for failure to timely deposit and report contributions and expenditures. (EY 18; Nov 18) RCW 42.17A.220, RCW 42.17A.235, RCW 42.17A.240 Case Closed with Written Warning

Two complaints were  filed against the 45th Legislative District Democratic Central Committee (Committee), a bona fide legislative district political party committee registered with the PDC may have violated: (1) RCW 42.17A.220 by failing to timely deposit monetary contributions within five business days of receipt; and (2) RCW 42.17A.235 and .240 by failing to timely file Monetary Contributions reports (C-3 reports) and Campaign Summary Full Campaign Contribution and Expenditure reports (C-4 reports) disclosing contribution and expenditure activities, including in-kind and last-minute contributions and debts, and failing to provide the sub-vendor breakdown for expenditures undertaken by the Committee.     

Based on these findings staff has determined that, in this instance, the Committee’s failure to timely file its C-3 and C-4 reports, disclosing contribution information, including in-kind and last-minute contributions, debts, and other expenditure information, including a detailed sub-vendor breakdown when applicable, does not amount to an actual violation warranting further investigation.

However, pursuant to WAC 390-37-060(1)(b), PDC staff issued a formal written warning to the 45th Legislative District Democratic Central Committee concerning the importance of timely and accurately filing C-3 and C-4 reports disclosing contribution and expenditure activities undertaken by the political committee as required by PDC laws and rules. This formal written warning conveys staff’s expectation that the 45th Legislative District Democratic Central Committee will fully comply with the C-3 and C-4 reporting requirements in the future as required for a registered political committee, including the reporting of debt.  The Commission will consider this formal written warning if there are any future PDC law or rule violations by the 45th Legislative District Democratic Central Committee. 

Based on this information, the PDC has dismissed the two complaints you filed for PDC Cases 42565 and 16743, in accordance with RCW 42.17A.755(1).  

https://www.pdc.wa.gov/browse/enforcement-cases/42565
42563 11/02/2018 Glen Morgan Yes Libraries Pierce Yes Libraries Pierce: Alleged violations of RCW 42.17A.220 and .235 for failure to timely deposit and report contributions, and .555 for misuse of public facilities to support an election campaign (EY 18; Nov 18) RCW 42.17A.220, RCW 42.17A.235, RCW 42.17A.555 Case Closed with Reminder
The Public Disclosure Commission (PDC) has completed review of the complaint filed by Glen Morgan on October 29, 2018. The complaint alleged that Yes Libraries Pierce PAC may have violated RCW 42.17A.220 and .235 for failure to timely deposit and report contributions, and .555 for misuse of public facilities to support an election campaign.
Based on our findings, staff has determined that in this instance, failure to timely file reports of contributions and expenditures does not amount to an actual material violation warranting further investigation.

PDC staff is reminding Yes Libraries Pierce PAC about the importance of the timely disclosure of all contribution and expenditure activities, including the filing fee, and the timely filings of all future PDC reports.

Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1), and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/42563
42561 11/02/2018 Glen Morgan Shir Regev Regev, Shir: Alleged violations of RCW 42.17A.220 and .235 for failure to timely deposit and report contributions and expenditures (EY 18; Nov 18) RCW 42.17A.240, RCW 42.17A.235, RCW 42.17A.220, RCW 42.17A.205 Resolved through Statement of Understanding
A complaint was filed against Shir Regev, a candidate for State Representative in the 8th Legislative District in 2018, alleging violations of RCW 42.17A.205, .235, and .240 by exceeding the limitations of the Mini Reporting Option, failing to timely and accurately file an amended Candidate Registration (C-1 report), and Monetary Contribution reports (C-3 report) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contribution and expenditure activities undertaken by her Campaign.

Ms. Regev completed a Statement of Understanding (SOU) acknowledging violations of RCW 42.17A.205, .235, and .240 by failing to timely change from the Mini Reporting Option to the Full Reporting Option, and to timely file the accompanying C-3 and C-4 reports, and paying a $300 civil penalty to resolve this matter.
https://www.pdc.wa.gov/browse/enforcement-cases/42561
42558 11/02/2018 Glen Morgan Spokane County Democratic Central Committee Spokane County Democratic Central Committee (3): Alleged violations of RCW 42.17A.220 and .235 for failure to timely deposit and report contributions and expenditures (EY 18; Nov 18) RCW 42.17A.220, RCW 42.17A.235 Case Closed with Written Warning
Two complaints were filed against the Spokane County Democratic Central Committee (Committee), a bona fide county political party organization registered with the PDC for PDC Case 42558 and PDC Case 22310.  The complaints alleged that the Committee may have violated RCW 42.17A.235 and .240 by failing to timely file Monetary Contributions reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports) disclosing contribution and expenditure activities, including debts and outstanding obligations for legal services and the sub-vendor breakdown for expenditures made to a third party or as a reimbursement to an official.

PDC staff found no evidence of a material violation that would require conducting a more formal investigation of the two complaints or pursuing enforcement action in this instance.  The allegations concerning the late reporting of legal services and reimbursements owed to Committee officials for out-of-pocket expenditures to pay for an out-of-state speaker to attend a fundraiser, were rare and unique activities that the Committee had not previously experienced or been involved with. The Committee has established a Financial Oversight Committee and adopted internal controls to assist them in ensuring compliance wit the reporting requirements.  Pursuant to WAC 390-37-060(1)(b), the Spokane County Democratic Central Committee has been formally warned concerning their failure to timely file Monetary Contributions reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports).
https://www.pdc.wa.gov/browse/enforcement-cases/42558
42557 11/02/2018 Glen Morgan 25th Legislative District Democrats 25th Legislative District Democrats: Alleged violation of RCW 42.17A.220 and .235 for failure to timely deposit and report contributions and expenditures. RCW 42.17A.235, RCW 42.17A.220 Resolved through Statement of Understanding
Allegation One: Violation of RCW 42.17A.220 for failure to timely deposit contributions. within five business days of receipt Allegation Two: Violation of RCW 42.17A.235 for failure to timely report contributions and expenditures
https://www.pdc.wa.gov/browse/enforcement-cases/42557
42554 11/02/2018 Andrew Saturn Up for Thurston County Up for Thurston County: Alleged violations of Chapter 42.17A RCW for failure to accurately disclose independent expenditures/electioneering communications, committee officers, and controlling entities (EY 18; Nov 18) RCW 42.17A.260, RCW 42.17A.240, RCW 42.17A.320, RCW 42.17A.305, RCW 42.17A.205, RCW 42.17A.405, RCW 42.17A.255, RCW 42.17A.470, RCW 42.17A.270 Request for Technical Correction
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Andrew Saturn on November 1, 2018. The complaint alleged that Up For Thurston County may have violated Chapter 42.17A RCW for failure to accurately disclose independent expenditures/electioneering communications, committee officers, and controlling entities.

Based on our findings, staff has determined that in this instance, failure to accurately and completely disclose committee officers does not amount to an actual material violation warranting further investigation.

Up For Thurston County made minor or ministerial errors on required reports, which did not materially impact the public interest. Upon notification of noncompliance, Up For Thurston County timely amended their reports, making the necessary technical corrections.

Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1), and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/42554
42544 11/01/2018 Glen Morgan Derek Young Young, Derek: Alleged Violation of RCW 42.17A.235, .240 for failure to timely and accurately file contributions and expenditures. (OCT 2018) RCW 42.17A.235, RCW 42.17A.240 Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Glen Morgan on October 21, 2018. The complaint alleged that Derek Young, incumbent and candidate for Pierce County Council Position 7 in the 2018 election, may have violated RCW 42.17A.235 and .240 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Derek Young; and the applicable PDC reports filed by Respondent, to determine whether the record supports a finding of one or more violations. 

Although the 2018 Derek Young Campaign submitted C-3 and C-4 reports disclosing campaign contribution and expenditure activities late, the campaign responded promptly and filed the missing reports. Based on these findings staff has determined that, in this instance, failure to timely file the postprimary C-4 and six C-3 reports disclosing a small number of contributions mostly from individual donors, does not amount to an actual violation warranting further investigation. 

Pursuant to WAC 390-37-060(1)(b), Derek Young received a formal written warning concerning failure to timely and accurately disclosure of all contribution and expenditures. The formal written warning included staff’s expectation that Derek Young timely and accurately files all future required reports of contributions and expenditures, during the accelerated reporting periods prior to and after each election in which his name appears on the ballot. The Commission will consider the formal written warning in deciding on further 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 this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/42544
42541 11/01/2018 Kelly Wright Snohomish County Democratic Party Snohomish County Democratic Party (3): Alleged Violation of RCW 42.17A.220, .240 for accepting over-limit anonymous contributions and for failure to accurately file contribution reports. (OCT 2018) RCW 42.17A.220, RCW 42.17A.240 Case Closed with No Evidence of Violations
The complaint alleged the Snohomish County Democratic Party may have violated (1) RCW 42.17A.220 for accepting over-limit anonymous contributions (2) RCW 42.17A.240 for failing to accurately file contribution reports and (3) RCW 42.17A.235 for failing to timely report expenditures for the Blue Wave Gala.

PDC staff reviewed the allegations, and as a result of staff’s initial review, we found the allegations contained in the complaint are substantially similar to PDC complaint 40870, resolved Dec. 4, 2018.

Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1) and will not be conducting a more formal investigation into the complaint or pursuing further enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/42541
42538 11/01/2018 Conner Edwards Phil Lloyd Families Yes: Alleged Violation of RCW 42.17A.320 for failure to list the Top Five Contributors in political advertising. (OCT 2018) RCW 42.17A.320 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed 
on October 20, 2018. Your complaint alleged that Families Yes, a 2018 election year committee, 
may have violated RCW 42.17A.320 for failure to identify the “Top Five Contributors” to the 
committee in political advertisement mail piece they sponsored. 
 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; 
and the response provided by Phil Lloyd, Treasurer for Families Yes, to determine whether the 
record supports a finding of one or more violations. 

Although the committee, Families Yes, sponsored two mailers that did not include the “Top Five 
Contributors” as required at the time they were distributed, the committee followed up with their 
direct mail vendor as soon as the oversight was identified through receipt of the complaint and 
promptly made corrections to two additional mailers and other political advertisement to ensure 
compliance 
 

Based on these findings staff has determined that, in this instance, failure to include the required 
“Top Five Contributors” statement with the list of donors on two mailers they sponsored does 
not amount to an actual violation warranting further investigation. 
 

PDC staff is reminding Families Yes about the importance of included complete sponsor 
identification, including the “Top Five Contributors” when required on all future political 
advertisements they sponsor in accordance with the statutes and rules. 
 

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).

https://www.pdc.wa.gov/browse/enforcement-cases/42538
42513 11/01/2018 Mitchell Giddens Michael Killian Killian, Michael: Alleged violation of RCW 42.17A.320 for failure to identify party preference in political advertising. (EY 18 Oct 18) RCW 42.17A.320 Case Closed with Written Warning
The complaint alleged Michael Killian may have violated RCW 42.17A.320 by failing to identify a party preference in political advertising, specifically a radio advertisement.

Staff determined that in this instance, failure to include party preference does not amount to a material violation warranting further investigation or pursuing further enforcement action in this case.

Pursuant to WAC 390-37-060(1), Michael Killian received a formal written warning concerning the failure to comply with the requirement to include his party preference on political advertising sponsored by his 2018 campaign in accordance with RCW 42.17A.320, WAC 390-18-020 and WAC 390-05-274.

The formal written warning included staff's expectation Michael Killian clearly identify his party preference on all political advertising sponsored by his campaign in future years in accordance with PDC laws and rules. The Commission will consider this formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

The PDC has dismissed this matter in accordance with RCW 42.17A.755(1).


https://www.pdc.wa.gov/browse/enforcement-cases/42513
42398 10/30/2018 Don Long Travis Meacham AG Power Users of Grant County (2): Alleged Violation of RCW 42.17A.205, .210, .225, .235, .240 for failure to timely and accurately file contributions, expenditures, deposits, and statement of organization. (OCT 2018) RCW 42.17A.225, RCW 42.17A.240, RCW 42.17A.235, RCW 42.17A.210, RCW4 42.17A.205 Violation Found by Commission

A complaint was filed with the PDC against the AG Water and Power Users of Grant County alleging the Committee may have violated RCW 42.17A.205 by failing to timely register as a political committee and RCW 42.17A.235 by failing to timely file Monetary Contribution reports (C-3 reports) and Campaign Summary Receipts and Expenditure reports (C-4 reports). 

After PDC staff conducted a preliminary review and assessment of the facts, PDC staff opened a formal investigation and held an Initial Hearing (Case Status Review Hearing) for on Jan. 8, 2019, pursuant to RCW 42.17A.755, and WACs 390-37-060 and 390-37-071.

At its April 25, 2019 meeting, the Commission found AG Water and Power Users of Grant County in violation of RCW 42.17A.205 and RCW 42.17A.235 and .240 and assessed a total civil penalty of $10,000 of which $7,500 is suspended on the following conditions: (1) The Respondent is not found to have committed any further violations of Chapter 42.17A RCW or Title 390 WAC within four years of the date of this Final Order. The suspended penalty shall not be assessed based solely upon any remediable violation, minor violation, or error classified by the Commission as appropriate to address by a technical correction; (2) The Respondent remains in full compliance with all PDC reporting requirements and; (3) The non-suspended portion of the penalty ($2,500) is paid by the Respondent within 30 days of the date of the Final Order.

https://www.pdc.wa.gov/browse/enforcement-cases/42398
42397 10/30/2018 Michael Fertakis David Chan Chan, David (2): Alleged Violation of RCW 42.17A.235, .240 for failure to timely or accurately disclose contribution or expenditure reports. (OCT 2018) RCW 42.17A.240, RCW 42.17A.235 Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the three complaints filed by Michael Fertakis in October 2018. The three complaints alleged that David Chan, candidate for Snohomish County Public Utility District Commissioner No. 1 in 2018, may have violated RCW 42.17A.235 and .240 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign. For your information, in order to more efficiently use PDC resources, these three complaints have been combined into one letter. 

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response(s) provided by David Chan; the applicable PDC reports filed by Respondent; and the October 17, 2018 Statement of Understanding with $300 civil penalty completed by Mr. Chan and acknowledging violations of RCW 42.17A.235 and .240, to determine whether the record supports a finding of one or more violations. 

The 2018 election was the first time David Chan filed as a candidate under the “Full Reporting” option and was required to file C-3 and C-4 reports using the PDC’s ORCA program disclosing campaign contribution and expenditure activities electronically. Serving as his own treasurer, Mr. Chan spent several weeks working with PDC Filer Assistance Staff on how to properly enter and correct information reported in ORCA, and he continued to work with staff throughout the 2018 election cycle.

In July 2018, two complaints were filed against David Chan alleging his campaign failed to timely and accurately file reports of campaign activities. On October 22, 2018, Mr. Chan completed a Statement of Understanding (SOU) acknowledging violations of RCW 42.17A.235 and .240 for failure to timely and accurately file C-3 and C-4 reports, and paid a $300 civil penalty, resolving similar allegations in PDC Cases 42329, 42397 and 42940.

Based on these findings staff has determined that, in this instance, failure to timely file a small number of C-3 and C-4 reports late disclosing details of a mailed political advertisement, does not amount to an actual violation warranting further investigation or additional enforcement action. Pursuant to WAC 390-37-060(1)(b), David Chan will receive a formal written warning concerning failure to timely and accurately disclosure of all contribution and expenditures. The formal written warning will include staff’s expectation that David Chan timely files all future required reports of contributions and expenditures, including all required vendor information during the accelerated reporting periods prior to and after any election in which his name appears on the ballot. The Commission will consider the formal written warning in deciding on further 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 this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/42397
42394 10/30/2018 Washington Senate Democratic Campaign (Samantha Kersul) Timothy Sheldon Sheldon, Timothy: Alleged Violation of RCW 42.17A.240 for failing to accurately disclose and describe expenditures. (OCT 2018) RCW 42.17A.240, RCW 42.17A.235 Resolved through Statement of Understanding

A complaint was filed with the PDC against Tim Sheldon alleging the Candidate may have violated RCW 42.17A.240 by failing to accurately disclose and describe expenditures.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response from Tim Sheldon; the applicable C-4 reports filed by the 2018 Campaign; and data in the PDC contribution and expenditure database, to determine whether the record supports a finding of one or more violations.

There were payments made by the Campaign to consultants, vendors, or third parties, for which a more detailed description or explanation of the goods and services provided, and a sub-vendor breakdown was required. However, the Campaign and Senator responded promptly and worked with the PDC to amend the C-4 reports disclosing the required expenditure information and assisting in resolving the complaint.  

Staff would also note that Senator Sheldon has been in public office since 1986 with no prior PDC violations and has served as his own treasurer. 

Tim Sheldon completed a Statement of Understanding (SOU), paid a $900 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), acknowledging violations of RCW 42.17A.240 for failing to timely file the three Pre-Election C-4 reports listed above.  The $900 penalty assessed in this matter resolves the allegations listed in your complaint concerning amending C-4 reports to disclose the required expenditure details and information. 

Based on the above findings and the SOU, staff has determined that, in this instance, this matter does not warrant further investigation.  The PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1). 
 

https://www.pdc.wa.gov/browse/enforcement-cases/42394
42393 10/30/2018 Marla Johns Ronald Krebs Krebs, Ronald: Alleged Violation of RCW 42.17A.555 for using public agency resources to support a political campaign (OCT 2018) RCW 42.17A.555 Case Closed with No Evidence of Violations
A complaint was filed against Ronald Krebs, the incumbent San Juan County Sheriff and a candidate seeking re-election to that office in 2018, alleging that he may have violated RCW 42.17A.555 by using the public facilities of San Juan County to assist his candidacy for re-election in 2018 by authorizing two San Juan County Deputies to appear in uniform at a candidate forum in Eastsound in which he was appearing as a candidate.

No evidence was found that Sheriff Krebs, or the two officers  used San Juan County facilities to support his candidacy for re-election by appearing at the candidate forum.   Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1). 
https://www.pdc.wa.gov/browse/enforcement-cases/42393
42392 10/30/2018 Holly Jepson Glenn Blakeslee Blakeslee, Glenn (3): Alleged Violation of RCW 42.17A.235 failure to timely disclose political advertisement expenditures. (OCT 2018) RCW 42.17A.235 Case Closed with Written Warning
The Public Disclosure Commission (PDC) has completed its review of the three complaints filed by Holly Jepson (PDC Cases 41960, 42389, and 42392), and the complaint filed by James Mundy (PDC Case 42717), against Glenn Blakeslee, a first-time candidate in 2018 seeking the office of Pend Oreille County Sheriff. The complaint alleged that Mr. Blakeslee, a Pend Oreille County Deputy Sheriff in 2018 may have violated RCW 42.17A.555 by using Pend Oreille County Sheriff resources to support your candidacy in 2018; and RCW 42.17A.235 and .240 by failing to disclose expenditures for political advertising in the form of newspaper and billboards on Summary Full Campaign Contribution and Expenditure reports (C-4 reports).

For your information, in order to more efficiently use PDC resources, the four complaints filed against Glenn Blakeslee have been combined into one letter. PDC staff reviewed the allegation listed in the four complaints and attached exhibits, the statutes, rules and PDC Interpretation #04-02 Guidelines for Local Agencies in Election Campaigns, and the Monetary Contributions reports (C-3 reports) and C-4 reports filed by Glenn Blakeslee for Sheriff (Campaign), and the responses from Mr. Blakeslee.

PDC staff’s review found no evidence that Glenn Blakeslee used the facilities of the Pend Oreille Sheriff’s Office to support his candidacy for County Sheriff in 2018, that would require conducting a more formal investigation into your complaint or pursuing enforcement action in this instance.

While the Campaign failed to timely disclose campaign expenditure for a billboard and newspaper advertisements, Mr. Blakeslee was a first-time candidate, and the late filed expenditures were disclosed 14 days prior to the November 6, 2018 general election being held. However, as part of staff’s review and the Campaign contacting PDC Filer Assistance, there were several C-3 reports filed that included $0 contributions that needed to be amended.
In addition, and an issue in disclosing monetary contributions received from couples into the Online Reporting of Campaign Activities (ORCA) campaign finance reporting software that resulted in $3,000 (+) in un-reported contributor information, and you failed to file a missing 2018 Post-General Election C-4 report. The Campaign has filed the missing Post-General Election C-4 report and filed two amended C-3 reports totaling $1,739 and are working on filing additional amended C-3 reports to be in full compliance.

Pursuant to WAC 390-37-060(1)(b), and with the understanding that the Blakeslee Campaign will file the necessary amended C-3 reports as soon as possible, Mr. Blakeslee is hereby formally warned concerning the failure to timely and accurately file campaign finance reports disclosing contribution and expenditure activities undertaken by his 2018 Campaign, including C-3 and C-4 reports in future years in accordance with PDC laws and rules. The formal written warning will include staff’s expectation that Mr. Blakeslee will timely file C-3 and C-4 reports, accurately disclosing his contribution and expenditure activities undertaken as a candidate in future years in accordance with PDC laws and rules. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Based on this information, the PDC has dismissed the four complaints in accordance with RCW 42.17A.755(1).
https://www.pdc.wa.gov/browse/enforcement-cases/42392
42389 10/30/2018 Holly Jepson Glenn Blakeslee Blakeslee, Glenn (2): Alleged Violation of RCW 42.17A.555 for use of public facilities to support a political campaign. RCW 42.17A 555 Case Closed with Written Warning
The Public Disclosure Commission (PDC) has completed its review of the three complaints filed by Holly Jepson (PDC Cases 41960, 42389, and 42392), and the complaint filed by James Mundy (PDC Case 42717), against Glenn Blakeslee, a first-time candidate in 2018 seeking the office of Pend Oreille County Sheriff. The complaint alleged that Mr. Blakeslee, a Pend Oreille County Deputy Sheriff in 2018 may have violated RCW 42.17A.555 by using Pend Oreille County Sheriff resources to support your candidacy in 2018; and RCW 42.17A.235 and .240 by failing to disclose expenditures for political advertising in the form of newspaper and billboards on Summary Full Campaign Contribution and Expenditure reports (C-4 reports).

For your information, in order to more efficiently use PDC resources, the four complaints filed against Glenn Blakeslee have been combined into one letter. PDC staff reviewed the allegation listed in the four complaints and attached exhibits, the statutes, rules and PDC Interpretation #04-02 Guidelines for Local Agencies in Election Campaigns, and the Monetary Contributions reports (C-3 reports) and C-4 reports filed by Glenn Blakeslee for Sheriff (Campaign), and the responses from Mr. Blakeslee.

PDC staff’s review found no evidence that Glenn Blakeslee used the facilities of the Pend Oreille Sheriff’s Office to support his candidacy for County Sheriff in 2018, that would require conducting a more formal investigation into your complaint or pursuing enforcement action in this instance.

While the Campaign failed to timely disclose campaign expenditure for a billboard and newspaper advertisements, Mr. Blakeslee was a first-time candidate, and the late filed expenditures were disclosed 14 days prior to the November 6, 2018 general election being held. However, as part of staff’s review and the Campaign contacting PDC Filer Assistance, there were several C-3 reports filed that included $0 contributions that needed to be amended.
In addition, and an issue in disclosing monetary contributions received from couples into the Online Reporting of Campaign Activities (ORCA) campaign finance reporting software that resulted in $3,000 (+) in un-reported contributor information, and you failed to file a missing 2018 Post-General Election C-4 report. The Campaign has filed the missing Post-General Election C-4 report and filed two amended C-3 reports totaling $1,739 and are working on filing additional amended C-3 reports to be in full compliance.

Pursuant to WAC 390-37-060(1)(b), and with the understanding that the Blakeslee Campaign will file the necessary amended C-3 reports as soon as possible, Mr. Blakeslee is hereby formally warned concerning the failure to timely and accurately file campaign finance reports disclosing contribution and expenditure activities undertaken by his 2018 Campaign, including C-3 and C-4 reports in future years in accordance with PDC laws and rules. The formal written warning will include staff’s expectation that Mr. Blakeslee will timely file C-3 and C-4 reports, accurately disclosing his contribution and expenditure activities undertaken as a candidate in future years in accordance with PDC laws and rules. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Based on this information, the PDC has dismissed the four complaints in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/42389
42388 10/30/2018 Scott Hunt Lori Sanders Sanders, Lori: Alleged Violation of RCW 42.17A.320 for failure to disclose sponsor identification. (OCT 2018) RCW 42.17A.260 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on October 17, 2018. Your complaint alleged that Lori Sanders, a candidate for Benton County Commissioner Position 2 in 2018, may have violated RCW 42.17A.320 for failure to include sponsor identification on her campaign website. 
 

PDC staff reviewed the allegations; the applicable statutes, rules, reporting requirements and the response provided by Lori Sanders, to determine whether the record supports a finding of one or more violations. 

The campaign website created by The Committee to Elect Lori Sanders, County Commissioner, did not include complete sponsor identification as required by law, however, the public was able to reasonably identify the sponsor from the information about Lori Sanders and her candidacy. 
 

Based on these findings staff has determined that, in this instance, failure to include sponsor identification on a website created by The Committee to Elect Lori Sanders, County Commissioner, does not amount to, an actual violation warranting further investigation. 
 

PDC staff is reminding Lori Sanders about the importance of including sponsor identification on political advertisement. PDC staff expects in the future that Lori Sanders will review all political advertisements, she or her campaign sponsors, to ensure it contains any required sponsor identification in accordance with PDC laws and rules. 
 

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).

https://www.pdc.wa.gov/browse/enforcement-cases/42388
42387 10/30/2018 Washington Senate Democratic Campaign (Samantha Kersul) Jeffrey Harvey North Cascade Jobs Enterprise Washington: Alleged Violation of RCW 42.17A.260 for failure to timely file independent expenditure reports. (OCT 2018) RCW 42.17A.260 Violation Found by Commission

A complaint was filed with the PDC against North Cascade Jobs Enterprise Washington alleging the Committee may have violated RCW 42.17A.260 for failure to timely file independent expenditure (C-6) reports.

After PDC staff conducted a preliminary review and assessment of the facts, PDC staff opened a formal investigation and held an Initial Hearing (Case Status Review Hearing) for on Jan. 8, 2019, pursuant to RCW 42.17A.755, and WACs 390-37-060 and 390-37-071.
 

At its March 28, 2019 meeting, the Commission found North Cascade Jobs Enterprise Washington in violation of RCW 42.17 A.235, RCW 42.17 A.240, and RCW 42.17 A.305 and assessed a total civil penalty of $65,000 of which $32,500 is suspended on the following conditions: (1) the Respondent is not found to have committed any further violations ofRCW 42.17 A or WAC 390, as detailed in the Stipulation, within four years of the date of the Commission's Final Order; (2) the Committee files amended C-4 reports that are in full compliance with the disclosure requirements of RCW 42.17A.240, WAC 390-16-037, and WAC 390-16-205, within thirty days from the date of the final order, and is in compliance with all reporting requirements; and (3) the Respondent pays the non-suspended portion of the penalty ($32,500) within ninety days from the date of the final order.
 

https://www.pdc.wa.gov/browse/enforcement-cases/42387
42367 10/29/2018 MaryAnn Ottinger Leonid Ponomarchuk Ponomarchuk, Leonid: Alleged Violation of RCW 42.17A.240 for failure to properly itemize expenditures by quanitty. (OCT 2018) RCW 42.17A.240 Case Closed with Reminder
Allegation: Violation of RCW 42.17A.240 for failure to properly itemize expenditures by quantities.
https://www.pdc.wa.gov/browse/enforcement-cases/42367
42362 10/29/2018 MaryAnn Ottinger Mellissa Pfeifer Citizens for Judicial Excellence: Alleged Violation of RCW 42.17A.240 for failure to properly itemize expenditures by quantity. (OCT 2018) RCW 42.17A.240 Case Closed with No Evidence of Violations
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Mary Ottinger on October 17, 2018. The Complaint alleged that Citizens for Judicial Excellence may have violated RCW 42.17A.240 for failure to properly itemize printing material expenditures by quantity on the Summary Full Campaign Contribution and Expenditure report (C-4 report), disclosing contributions and expenditures undertaken by the Campaign. 

PDC staff reviewed the allegations, the statutes and rules, the initial and amended C-3, C-4, and C-6 reports filed by the Campaign, and the response from Citizens for Judicial Excellence. 

PDC Staff recommends that Citizens for Judicial Excellence disclose the estimated quantities for debts on the Schedule B of the C-4 report if the expenditures are for printing materials in the same manner that the Campaign discloses expenditures on the Schedule A of the C-4 reports.  Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1), and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case.  
https://www.pdc.wa.gov/browse/enforcement-cases/42362
42329 10/29/2018 Michael Fertakis David Chan Chan, David (1): Alleged Violation of RCW 42.17A.235, .240 for failure to timely or accurately file contribution or expenditure reports. (OCT 2018) RCW 42.17A.240, RCW 43.17A.235 Case Closed with Written Warning

Dear Michael Fertakis: The Public Disclosure Commission (PDC) has completed its review of the three complaints you filed in October 2018. The three complaints alleged that David Chan, candidate for Snohomish County Public Utility District Commissioner No. 1 in 2018, may have violated RCW 42.17A.235 and .240 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign. For your information, in order to more efficiently use PDC resources, these three complaints have been combined into one letter. 

PDC staff reviewed your allegations; the applicable statutes, rules, and reporting requirements; the response(s) provided by David Chan; the applicable PDC reports filed by Respondent; and the October 17, 2018 Statement of Understanding with $300 civil penalty completed by Mr. Chan and acknowledging violations of RCW 42.17A.235 and .240, to determine whether the record supports a finding of one or more violations. 

The 2018 election was the first time David Chan filed as a candidate under the “Full Reporting” option and was required to file C-3 and C-4 reports using the PDC’s ORCA program disclosing campaign contribution and expenditure activities electronically. Serving as his own treasurer, Mr. Chan spent several weeks working with PDC Filer Assistance Staff on how to properly enter and correct information reported in ORCA, and he continued to work with staff throughout the 2018 election cycle.

In July 2018, two complaints were filed against David Chan alleging his campaign failed to timely and accurately file reports of campaign activities. On October 22, 2018, Mr. Chan completed a Statement of Understanding (SOU) acknowledging violations of RCW 42.17A.235 and .240 for failure to timely and accurately file C-3 and C-4 reports, and paid a $300 civil penalty, resolving similar allegations in PDC Cases 42329, 42397 and 42940.

Based on these findings staff has determined that, in this instance, failure to timely file a small number of C-3 and C-4 reports late disclosing details of a mailed political advertisement, does not amount to an actual violation warranting further investigation or additional enforcement action. Pursuant to WAC 390-37-060(1)(b), David Chan will receive a formal written warning concerning failure to timely and accurately disclosure of all contribution and expenditures. The formal written warning will include staff’s expectation that David Chan timely files all future required reports of contributions and expenditures, including all required vendor information during the accelerated reporting periods prior to and after any election in which his name appears on the ballot. The Commission will consider the formal written warning in deciding on further 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 this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/42329
42328 10/29/2018 Pollowitz Sally Soriano Friends of Elaine Phelps: Alleged Violation Of RCW 42.17A.235, .240 for failure to timely or accurately file contribution or expenditure reports. (OCT 2018) RCW 42.17A.235 Case Closed with Written Warning
The complaint alleged the Friends of Elaine Phelps violated RCW 42.17A.235 and .240 by failing to timely file Monetary Contribution reports (C-3 reports) and Campaign Summary Contribution and Expenditure reports (C-4 reports) disclosing contribution and expenditure activities undertaken by the Committee in 2018. 

The Committee contacted PDC staff on several occasions to assist in setting up the Online Reporting of Campaign Activities (ORCA) campaign finance software provided by the PDC and the ongoing C-3 and C-4 reporting requirements.

During the period October 2 – 16, 2018, the Committee filed four C-3 reports disclosing the receipt of $6,925 in monetary contributions, and three of the C-3 reports were filed late. However, $5,000 of the late reported contributions had previously been timely disclosed by the Committee on the C-6 report filed August 2, 2018. 

Based on these findings, and the facts that Friends of Elaine Phelps: (1) is a first-time committee participating in its first election; (2) responded quickly to the allegations and contacted PDC staff for assistance to correct its filings; and (3) timely filed a C-6 report disclosing the electioneering communication which represented 70 percent of all committee expenditures, staff has determined that the failure to timely file C-3 and C-4 reports does not amount to a material violation warranting further investigation.

Pursuant to WAC to WAC 390-37-060(1) Friends of Elaine Phelps will receive a formal written warning concerning the failure to comply with the reporting requirements for a political committee under the Full Reporting option to timely file C-3 and C-4 reports disclosing contributions and expenditures activities in accordance with RCW 42.17A.235 and .240.

The formal written warning will include staff's expectation Friends of Elaine Phelps timely files complete and accurate reports in future years in accordance with PDC laws and rules. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.
Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1).


https://www.pdc.wa.gov/browse/enforcement-cases/42328
42326 10/29/2018 Emry Dinman Travis Meacham AG Power Users of Grant County: Alleged Violation of RCW 42.17A.205 for failure to register as a political committee. (OCT 2018) RCW 42.17A.205 Violation Found by Commission

A complaint was filed with the PDC against the AG Water and Power Users of Grant County alleging the Committee may have violated RCW 42.17A.205 by failing to register as a political committee.

After PDC staff conducted a preliminary review and assessment of the facts, PDC staff opened a formal investigation and held an Initial Hearing (Case Status Review Hearing) for on Jan. 8, 2019, pursuant to RCW 42.17A.755, and WACs 390-37-060 and 390-37-071.

At its April 25, 2019 meeting, the Commission found AG Water and Power Users of Grant County in violation of RCW 42.17A.205 and RCW 42.17A.235 and .240 and assessed a total civil penalty of $10,000 of which $7,500 is suspended on the following conditions: (1) The Respondent is not found to have committed any further violations of Chapter 42.17A RCW or Title 390 WAC within four years of the date of this Final Order. The suspended penalty shall not be assessed based solely upon any remediable violation, minor violation, or error classified by the Commission as appropriate to address by a technical correction; (2) The Respondent remains in full compliance with all PDC reporting requirements and; (3) The non-suspended portion of the penalty ($2,500) is paid by the Respondent within 30 days of the date of the Final Order.

https://www.pdc.wa.gov/browse/enforcement-cases/42326
42325 10/29/2018 Larry Seaquist John Kelly Kelly, John: Alleged Violation of RCW 42.17A.555 for using of public facilities to support a political campaign. (OCT 2018) RCW 42.17A 555 Case Closed with Reminder
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Larry Seaquist on October 16, 2018. The Complaint alleged that John Kelly, Parks Commissioner for the Key Peninsula Metro Park, may have violated RCW 42.17A.555 for using public facilities to support a political candidate.

PDC staff reviewed the allegations, the statutes and rules, the campaign flyer, and the response from Parks Commissioner John Kelly. 

Based on our findings, staff has determined that in this instance, the use of a public facilities does not amount to a material violation warranting further investigation since: (1) No public resources or funds were used to support a political campaign or distribute the flyers. (2) The flyer made no mention of the Key Peninsula Metro Park, which is the agency that John Kelly serves as Parks Commissioner. (3) The overall structure and language of the flyer implies a personal endorsement, even though some word choices could be misinterpreted. (4) Elected officials are authorized to use their title if it is not on behalf of the agency and does not use public facilities.

PDC staff is reminding Parks Commissioner John Kelly about the importance of clarifying that he is not speaking on behalf of the agency when using his title to endorse a political candidate. 

Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1), and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case. 
https://www.pdc.wa.gov/browse/enforcement-cases/42325
42268 10/26/2018 Michael Maddux Mary's Pistols Mary's Pistols: Alleged violations of Chapter 42.17A RCW for failure to register as political committee, report contributions and expenditures, disclose sponsor ID, or failure to report independent expenditures. RCW 42.17A.205, RCW 42.17A.235, RCW 42.17A.255, RCW 42.17A.320, RCW.42.17A.240 Resolved through Statement of Understanding
  • Allegation One: Violation of RCW 42.17A.205 for failure to register as a political committee within two weeks of the expectation of contributions or expenditures to support or oppose a candidate or ballot proposition.
  • Allegation Two: Violations of RCW 42.17A.235 and .240 for failure to timely and accurately report contributions and expenditures.
  • Allegation Three: Violations of RCW 42.17A.320 for failure to disclose accurate and complete sponsor identification in political advertising.
  • Allegation Four: Violations of RCW 42.17A.255 for failure to report independent expenditures in support or opposition to candidates or ballot propositions.
https://www.pdc.wa.gov/browse/enforcement-cases/42268
42258 10/26/2018 Priscilla Swanger Timothy Gray Gray, Timothy: Alleged violation of RCW 42.17A.555 for using public facilities in political advertising. (EY 18 Oct 18) RCW 42.17A.555 Case Closed with Written Warning

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Priscilla Swanger on October 10, 2018. The Complaint alleged that Timothy Gray, incumbent and candidate for Stevens County Auditor in 2018, may have violated; (1) RCW 42.17A.555 by using public facilities to support his re-election campaign; (2) RCW 42.17A.235 by failing to timely file Summary Full Campaign Contribution and Expenditure reports (C-4 reports); and (3) RCW 42.17A.240 by failing to disclose the candidate filing fee. 

PDC staff reviewed the applicable statutes, rules, and reporting requirements; the response(s) provided by Timothy Gray; and the applicable PDC reports filed by Respondent, to determine the allegations support a finding of one or more violations.

Although the Stevens County Auditor’s Office telephone number did appear in two political advertisements sponsored by the “Retain Tim Gray Auditor” campaign, the campaign took corrective action promptly. The 7-day pre-primary C-4 report was filed after the primary election but contained zero activity and the filing fee was paid using the personal funds of the candidate. 

Based on our findings staff has determined that, in this instance, including the Stevens County Auditor’s Office telephone number on two pieces of political advertisement, filing the 7-day preprimary C-4 report late disclosing zero activity, and failing to disclose the filing fee paid for using candidate’s personal funds does not amount to an actual violation warranting further investigation. 

Pursuant to WAC 390-37-060(1)(b), Timothy Gray will receive a formal written warning concerning; (1) using public facilities to support his re-election campaign by including the Stevens County Auditor’s Office telephone number in political advertisement; (2) failing to timely file the 7-day pre-primary C-4 report; and (3) failing to disclose the candidate filing fee. The formal written warning will include staff’s expectation that Mr. Gray will review all political advertisement sponsored by him or his campaign to avoid using facilities to support his candidacy and that he timely files all future required reports of contributions and expenditures, including all campaign activities, specifically those occurring during the accelerated reporting schedule prior to and after any election in which Mr. Gray participates in as a candidate for public office in the future. The Commission may consider the formal written warning in deciding on further 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 this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/42258
42257 10/26/2018 Lorilee Gill Thomas Taylor Taylor, Thomas: Alleged violations of RCW 42.17A.235 and .240 for failure to timely and accurately report contributions and expenditures (EY 18; Oct 18) RCW 42.17A.235, RCW.42.17A.240 Case Closed with Reminder
The Public Disclosure Commission (PDC) has completed its initial review of the complaint filed by Lorilee Gill on October 11, 2018. The Complaint alleged that Thomas Taylor may have violated RCW 42.17A.235 and .240 for failure to timely and accurately report contributions and expenditures.

Based on our findings, staff has determined that in this instance, failure to accurately register as a candidate, does not an actual material violation warranting further investigation.

PDC staff is reminding Thomas Taylor about the importance of the timely disclosure of all contribution and expenditure activities, including the filing fee, and the timely filings of all future PDC reports, including the F-1 report.

Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1), and will not be conducting a more formal investigation into the Complaint or pursuing further enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/42257
42253 10/26/2018 PDC Staff Shir Regev Regev, Shir: Alleged violation of WAC 390-16-125 for exceeding mini-reporting limitations without PDC authorization (EY 18; Oct 18) WAC 390-16-125 Resolved through Statement of Understanding
A Public Disclosure Commission staff generated complaint was filed against Shir Regev, a candidate seeking the office of State Representative in the 8th Legislative District in 2018, alleging violations of WAC 390-16-125 for exceeding mini-reporting limitations without PDC authorization to change to the Full Reporting Option.  After staff filed a complaint, a complaint was filed by Glen Morgan against Shir Regev alleging the same violations of RCW 42.17A.205, .235, and .240.

Ms. Regev completed a Statement of Understanding (SOU) acknowledging violations of RCW 42.17A.205, .235, and .240 by failing to timely change from the Mini Reporting Option to the Full Reporting Option, and to timely file the accompanying C-3 and C-4 reports, and paying a $300 civil penalty to resolve this matter.

https://www.pdc.wa.gov/browse/enforcement-cases/42253
42179 10/24/2018 Sandra Giachino Drew MacEwen MacEwen, Drew: Alleged violation of RCW 42.17A.335(1)(a) by making a false statement of material fact about a candidate for public office. (EY 18 Sep 18) RCW 42.17A.335 Case Closed with Reminder
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Sandra Giachino on October 9, 2018. The Complaint alleged that Drew MacEwen, incumbent and candidate for State Representative in Legislative District 35 in 2018, may have violated RCW 42.17A.335 by making false statements of material fact about his opponent, David Daggett, a candidate for public office.

PDC staff reviewed the applicable statutes; the response provided by Dan Brady on behalf of Drew MacEwen; and publicly available information regarding David Daggett’s political platform, to determine your allegations support a finding of one or more violations.

The statement regarding David Daggett’s position on second amendment issues appears to have been made based on the NRA scorecard and the complaint did not include any evidence to the contrary. However, staff was unable to find any publicly available statements where Mr. Daggett confirmed his official position on issues related to gun rights to determine if the statement included in the political advertisement was true or false. 

Based on these findings staff has determined that, in this instance, no evidence supports a finding of an actual violation warranting further investigation. PDC staff is reminding Drew MacEwen about the importance of vetting all information used in political advertisement, naming a candidate for public office and sponsored by any future campaigns he is involved with to avoid potential violations of RCW 42.17A.335.

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).
https://www.pdc.wa.gov/browse/enforcement-cases/42179
42178 10/24/2018 Sandra Giachino Timothy Sheldon Sheldon, Timothy: Alleged violation of RCW 42.17A.335(1)(a) by making a false statement of material fact about a candidate for public office. (EY 18 Sep 18) RCW 42.17A.335 Case Closed with No Evidence of Violations
The complaint alleged that the 2018 Tim Sheldon Campaign may have violated RCW 42.17A.335(1)(a) by sponsoring a political advertisement in the form of a telephone call that made false statements of material fact about a candidate for public office.  Specifically, that on August 22, 2018, a telephone call from an entity identified as Crossings Research, made false statements about Irene Bowling, a candidate for State Senator in the 35th Legislative District, and Senator Sheldon’s opponent.

No evidence was found that the 2018 Committee to Elect Tim Sheldon sponsored political advertisements in the form of telephone calls, either for polling or in opposition to Irene Bowling using Crossings Research, and the PDC will not conduct a more formal investigation into the complaint or pursue further enforcement action in this case.

Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1).


https://www.pdc.wa.gov/browse/enforcement-cases/42178
42112 10/23/2018 Fletcher Sandbeck Glen Morgan Morgan, Glen; A Brighter Thurston County PAC; Conscience of the Progressives PAC; Real Progressives in Thurston County PAC; Send a Message PAC: Alleged Violation of RCW 42.17A.205, .320, .335, .442 (See Case Description) (OCT 2018). RCW 42.17A.335, RCW 42.1&A.320, RCW 42.17A.442, RCW 42.17A.205 Case Closed with Reminder

As of Wednesday, October 24, 2018, the Public Disclosure Commission (PDC) had received 31 complaints that were filed against four political committees recently registered with the PDC: (1) A Brighter Thurston County PAC; (2) Conscience of the Progressives PAC; (3) Real Progressives in Thurston County PAC; and (4) Send a Message PAC.  Some of the complaints contained allegations against the Campaign Manager for the committees Glen Morgan and/or Treasurer Orin Wells in their individual capacities.

 

The complaints alleged that the four political committees listed above, and/or Messrs. Morgan and/or Wells individually, produced and distributed independent expenditure (IE) political advertising in the form of direct mail pieces that violated: (1) RCW 42.17A.205 by failing to timely disclose the committee officers and other required information on the Committee Registration (C-1pc report); (2) RCW 42.17A.320 by failing to include the party preference for a candidate featured in the IE political advertisements; (3) RCW 42.17A.335 by sponsoring IE political advertising that contained either false statements of material facts, or false endorsements about a candidate, made with malice; (4) RCW 42.17A.435 by concealing the source of contributions used by the political committees; and  (5) RCW 42.17A.442 for making unauthorized contributions to another committee without first receiving contributions of ten dollars or more each from at least ten persons registered to vote in Washington State.     

 

The IE advertisements sent the message that the sponsoring political committees requested recipients to write-in the names of four individuals that included Teresa Purcell, Joe Pakootas, Nathan Schlicher, and EJ Zita in the 2018 elections, even though those individuals are not declared candidates seeking public office in 2018. 

 

Complaints filed against Real Progressives in Thurston County PAC and A Brighter Thurston County PAC

 

  • The complaints against Real Progressives in Thurston County PAC and A Brighter Thurston County PAC alleged violations of RCW 42.17A by sponsoring an IE advertisement in opposition to Tye Menser, a 2018 candidate for Thurston County Commissioner.  The mailer mentioned Fuse Washington (Fuse), the state's largest progressive organization (whose goals according to its website include assisting progressive candidates in getting elected to office and to “give ordinary people a strong voice in politics”) and a Fuse publication entitled Fuse WA Progressive Voters Guide. The mailer requested that voter’s write-in EJ Zita as the real Progressive candidate for County Commissioner in 2018, despite the fact Ms. Zita is not a declared candidate for public office or registered with the PDC in 2018 and is not conducting a write-in campaign.  FUSE endorsed Tye Menser for Thurston County Commissioner in 2018, and in 2017 Fuse endorsed Ms. Zita for her campaign for Port of Olympia Commissioner.   A quote on the mailer from the Fuse Progressive Voters Guide about Ms. Zita was from the 2017 election, although the mailer does not so indicate.

 

Complaints filed against Conscience of the Progressives PAC (Sponsored by Send a Message PAC)

 

1. Erin Frasier, a 2018 candidate for State Representative in the 19th Legislative District:  The complaints allege violations of RCW 42.17A for sponsoring an IE advertisement mailer stating that Teresa Purcell, a 2016 candidate for State Representative in the 19th Legislative District, should be written in as a 2018 candidate as the real Progressive candidate.   The mailer mentions Fuse and the Fuse WA Progressive Voters Guide

 

  • The mailer requested that voter’s write-in Ms. Purcell as the real Progressive candidate for State Representative in the 19th Legislative District, despite the fact Ms. Purcell is not a declared candidate for public office or registered with the PDC in 2018 and is not conducting a write-in campaign.  Fuse endorsed Erin Frasier for State Representative in the 19th Legislative District in 2018, and in 2016 Fuse endorsed Ms. Purcell for her campaign for State Representative in the 19th Legislative District.   The quote from the Progressive Voters Guide about Ms. Purcell was from the 2016 election, although the mailer does not so indicate.

 

2. Connie FitzPatrick, a 2018 candidate for State Representative in the 26th Legislative District: The complaints alleged violations of RCW 42.17A for sponsoring an IE advertisement mailer stating that Nathan Schlicher, a 2014 candidate for State Senator in the 26th Legislative District, should be written in as a 2018 candidate as the real Progressive candidate.  The mailer mentions Fuse and the Fuse WA Progressive Voters Guide

 

  • The mailer requested that voter’s write-in Dr. Schlicher as the real Progressive candidate for State Representative in the 26th Legislative District, despite the fact Dr. Schlicher is not a declared for public office or registered with the PDC in 2018 and is not conducting a write-in campaign.  Fuse endorsed Connie FitzPatrick for State Representative in the 26th Legislative District in 2018.  Fuse endorsed Dr. Schlicher for his campaign for State Senator in the 26th Legislative District in 2013, and his candidacy for State Representative in 2014.   The quote from the Progressive Voters Guide about Dr. Schlicher was from either the 2013 or 2014 election, although the mailer does not so indicate.

 

 

3. Jessa Lewis, a 2018 candidate for State Representative in the 6th Legislative District:  The complaints allege violations of RCW 42.17A for sponsoring an IE advertisement mailer stating that Joe Pakootas, a 2016 candidate for Congress from the 5th Congressional District, should be written in as a 2018 candidate as the real Progressive candidate.  The mailer mentions Fuse and the Fuse WA Progressive Voters Guide

 

  • The mailer requested that voter’s write-in Mr. Pakootas as the real Progressive candidate for State Representative in the 6th Legislative District, despite the fact Mr. Pakootas is not a declared candidate for public office or registered with the PDC in 2018 and is not conducting a write-in campaign.  Fuse endorsed Jessa Lewis for State Representative in the 6th Legislative District in 2018, and in 2016 Fuse endorsed Mr. Pakootas for his campaign for Congress in the 5th Congressional District.   The quote from the Progressive Voters Guide about Mr. Pakootas was from the 2016 election, although the mailer does not so indicate.

 

All four committees created by Mr. Morgan were first-time committee’s that registered as continuing political committees, as opposed to registering as single-year political committees which would have provided a higher degree of transparency by requiring the disclosure of the candidates supported or opposed by each committee on the       C-1pc report.   

Concerning the allegations listed in the 45 complaints that Mr. Morgan and the political  committees that sponsored the mailers may have violated RCW 42.17A.335, by including defamatory statements against the official 2018 candidate, the purported write-in, and Fuse Washington, and that the sponsor of the advertising knew such statements were false or published them with a reckless disregard for the truth, PDC staff found:

  1. The five IE mailers distributed by the two committees were all similar in design and messaging, and directly opposed 2018 Democratic and non-partisan candidates that had completed a Declaration of Candidacy and filed a Candidate Registration (C-1 report) with the PDC.  
  2. The messages in each mailer urged voters to choose a different "real progressive" candidate and provided the name of a purported write-in candidate for each of the five races targeted by the mailings, and each IE mailer included a statement of support for the purported write-in candidate that was attributed to Fuse Washington.  
  3. In each of the five mailers, the purported write-in candidate was not a declared candidate for the 2018 election,  did not conduct a write-in campaign, and instead had publicly endorsed and in some instances contributed to the officially declared Democratic or non-partisan candidate that the mailers opposed.  
  4. In 2018, Fuse Washington did not endorse or support any of the five purported write-in candidates and had in fact has officially endorsed the official Democratic and non-partisan candidates and published the endorsements in their Voters Guide.  
  5. The statements attributed to Fuse Washington in the IE mailers about the purported write-in candidates came from previous publications of the Voters Guide from 2015-2017, where Fuse had supported the purported write-in candidate in an earlier election cycle as a declared candidate and/or for election to a different office than the office that is the subject of the mailer.
RCW 42.17A.335 does not prohibit every false statement made in a political advertising, but, limits the alleged violations to defamatory statements about a candidate that are published with actual malice and cause an injury to a person's reputation. There are three very specific categories of violation under the statute that apply exclusively to candidates:  (a) False statements of material fact about a candidate; (b) False representations that a candidate is the incumbent in an election; and (c) False claims stating or implying the support or endorsement of a candidate when the candidate does not have such support.  See RCW 42.17A.335(1).  
Staff’s review of the matter has determined that the allegations in the complaints regarding false statements of material fact, do not constitute violations of section 335, within the specific categories defined in the statute.  The mailers do not include an express false statement of material fact about a candidate, they do not make false claims regarding incumbency, and they do not directly or indirectly falsely claim or imply that a candidate has the endorsement or support of a person or organization.  
Although it might initially appear that category (c) is implicated where some complainants have alleged that these ads convey to voters that the non-candidate “write-ins” have the endorsement of certain organizations, the statute applies only to claims of support or endorsement where the candidate does not have such support or endorsement.  The purported write-in candidates in these races are not, in fact, candidates, and therefore the statute does not apply.
Based on this information, the PDC has dismissed the allegations listed in the 45 complaints filed against Mr. Morgan; Send a Message PAC; Conscience of the Progressives PAC; A Brighter Thurston County PAC; and Real Progressives in Thurston County PAC, in accordance with RCW 42.17A.755(1).  
Although PDC will not be conducting a formal investigation into these allegations or taking further enforcement action in this matter, staff is reminding Glen Morgan, and the four political committees concerning the importance of filing timely and accurate reports disclosing committee contribution and expenditure activities in future years as required by PDC laws and rules, including registering as a single-year committee where applicable.  

 

https://www.pdc.wa.gov/browse/enforcement-cases/42112
41960 10/22/2018 Holly Jepson Glenn Blakeslee Blakeslee, Glenn (1): Alleged Violation of RCW 42.17A.235 for failure to timely or accurately disclose campaign expenditures for a billboard advertisement. (OCT 2018) RCW 42.17A.235 Case Closed with Written Warning
The Public Disclosure Commission (PDC) has completed its review of the three complaints filed by Holly Jepson (PDC Cases 41960, 42389, and 42392), and the complaint filed by James Mundy Jr. (PDC Case 42717), against Glenn Blakeslee, a first-time candidate in 2018 seeking the office of Pend Oreille County Sheriff. 
The complaints alleged that Mr. Blakeslee, a Pend Oreille County Deputy Sheriff in 2018 may have violated RCW 42.17A.555 by using Pend Oreille County Sheriff resources to support their candidacy in 2018; and RCW 42.17A.235 and .240 by failing to disclose expenditures for political advertising in the form of newspaper and billboards on Summary Full Campaign Contribution and Expenditure reports (C-4 reports). 
For your information, in order to more efficiently use PDC resources, the four complaints filed against Glenn Blakeslee have been combined into one letter. PDC staff reviewed the allegation listed in the four complaints and attached exhibits, the statutes, rules and PDC Interpretation #04-02 Guidelines for Local Agencies in Election Campaigns, and the Monetary Contributions reports (C-3 reports) and C-4 reports filed by Glenn Blakeslee for Sheriff (Campaign), and the responses from Mr. Blakeslee. 

PDC staff’s review found no evidence that Glenn Blakeslee used the facilities of the Pend Oreille Sheriff’s Office to support his candidacy for County Sheriff in 2018, that would require conducting a more formal investigation into your complaint or pursuing enforcement action in this instance. 

While the Campaign failed to timely disclose campaign expenditure for a billboard and newspaper advertisements, Mr. Blakeslee was a first-time candidate, and the late filed expenditures were disclosed 14 days prior to the November 6, 2018 general election being held. However, as part of staff’s review and the Campaign contacting PDC Filer Assistance, there were several C-3 reports filed that included $0 contributions that needed to be amended. In addition, and an issue in disclosing monetary contributions received from couples into the Online Reporting of Campaign Activities (ORCA) campaign finance reporting software that resulted in $3,000 (+) in un-reported contributor information, and you failed to file a missing 2018 Post-General Election C-4 report. 

The Campaign has filed the missing Post-General Election C-4 report and filed two amended C-3 reports totaling $1,739 and are working on filing additional amended C-3 reports to be in full compliance. 

Pursuant to WAC 390-37-060(1)(b), and with the understanding that the Blakeslee Campaign will file the necessary amended C-3 reports as soon as possible, Mr. Blakeslee is hereby formally warned concerning the failure to timely and accurately file campaign finance reports disclosing contribution and expenditure activities undertaken by his 2018 Campaign, including C-3 and C-4 reports in future years in accordance with PDC laws and rules. The formal written warning will include staff’s expectation that Mr. Blakeslee will timely file C-3 and C-4 reports, accurately disclosing his contribution and expenditure activities undertaken as a candidate in future years in accordance with PDC laws and rules. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules. 

Based on this information, the PDC has dismissed the four complaints in accordance with RCW 42.17A.755(1).
https://www.pdc.wa.gov/browse/enforcement-cases/41960
41757 10/16/2018 Mark Nelson Pinky Vargas Vargas, Pinky (2): Alleged Violation of RCW 42.17A.240 for failure to itemize expenditures on the C-4 report. (OCT 2018) RCW 42.17A.240 Request for Technical Correction
The complaint alleged that the Friends of Pinky Vargas may have violated RCW 42.17A.240 for failing to itemize an expenditure on a Summary Full Campaign Contributions and Expenditure report (C-4 report) filed Sept. 10, 2018.

The Friends of Pinky Vargas Campaign made a minor error in providing the description for one expenditure that was timely disclosed on the initial C-4 report. The Campaign timely filed an amended C-4 report disclosing the information within 14 days of being notified about the complaint and filing error, making the necessary technical correction. The late filed information did not materially impact the public interest.

Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1).
https://www.pdc.wa.gov/browse/enforcement-cases/41757
41756 10/16/2018 Alex Brooks Robin Ball Spokane County Republican Central Committee: Alleged Violation of RCW 42.17A.320 for failure to include sponsor identification, party affiliation, paid-for-by information, and correct text formatting. (OCT 2018) RCW 42.17A.320 Case Closed with Reminder
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Alex Brooks on October 8, 2018. The complaint alleged that the Spokane County Republican Central Committee (SCRCC), and Donna O’Leary, an individual who is active in the SCRCC, may have violated RCW 42.17A.320 by failing to include sponsor identification (paid-for-by information), party affiliation, and correct text formatting in its political advertising that was for two “meet and greet the candidates” meetings, one held in 2016 and one in 2018. 

PDC staff reviewed the allegations listed in the complaint to determine whether a formal investigation or enforcement action is warranted. Staff reviewed all the exhibits submitted with the complaint, and the November 7, 2018 response letter received via email from Robin Ball with the SCRCC. 

While the 2018 ad organized and paid for by Donna O’Leary failed to include the paid-for-by and party preference information, PDC staff found no evidence of a material violation that would require conducting a more formal investigation into the complaint or pursuing enforcement action in this instance. 

Although PDC will not be conducting a formal investigation into these allegations or taking further enforcement action in this matter, staff has reminded the SCRCC and its district leader, Donna O’Leary, of the expectation and importance of including required Sponsor Identification and Party Preference information in political advertising so the public can identify who paid for the political advertising, and when required, the party preference of candidates featured in the advertising, in future years, as required by the PDC laws and rules.

Based on the above, the PDC has dismissed the complaint in accordance with RCW 42.17A.755(1).
https://www.pdc.wa.gov/browse/enforcement-cases/41756
41659 10/15/2018 Terrilee Brower Nicholas Power Power, Nicholas: Alleged violation of RCW 42.17A.235 for failure to timely report contributions and expenditures. (EY 18 Oct 18) RCW 42.17A.235 Case Closed with Reminder

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Terrilee Brower on October 3, 2018. The Complaint alleged that Nicholas Power, a candidate for San Juan County Prosecuting Attorney in 2018, may have violated RCW 42.17A.235 for failure to timely and accurately file Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign. 

PDC staff reviewed the applicable statutes, rules, and reporting requirements; the response provided by Nicholas Power; and the applicable PDC reports filed by Respondent, to determine your allegations support a finding of one or more violations. 

Nicholas Power was a first-time candidate for public office and lost in the November 6, 2018 general election. The majority of the money received and spent for his campaign came from personal funds in the form of monetary and in-kind loans or contributions. Based on these findings staff has determined that, in this instance, failure to timely file one C-3 report one day late and four C-4 reports between one and seven days late does not amount to an actual violation warranting further investigation. 

PDC staff is reminding Nicholas Power about the importance of the timely disclosure of all contribution and expenditure activities, specifically those occurring during the accelerated reporting schedule prior to and after each election in which his name appears on the ballot. PDC staff expects that Mr. Power will file all C-3 and C-4 reports timely in future years in accordance with PDC laws and rules. 

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).

https://www.pdc.wa.gov/browse/enforcement-cases/41659
41629 10/15/2018 Michael O'Neill James McNamara City of Longview: Alleged Violation of RCW 42.17A.555 for using public facilities to support a ballot proposition. (OCT 2018) RCW 42.17A 555 Case Closed with No Evidence of Violations
Allegation: Violation of RCW 42.17A.555 for using public facilities to support a ballot proposition.
https://www.pdc.wa.gov/browse/enforcement-cases/41629
41628 10/15/2018 Jordan Sears Carolyn Eslick Eslick, Carolyn: Alleged Violation of RCW 42.17A.220 for accepting over-limit anonymous contributions. (OCT 2018) RCW 42.17A.220 Case Closed with Written Warning
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Jordan Sears on October 4, 2018. The Complaint alleged that Representative Carolyn Eslick may have violated RCW 42.17A.220 for accepting over-limit anonymous contributions during election 2014 and election year 2018. 
PDC staff reviewed the applicable statutes, rules, and reporting requirements; the response provided by Representative Eslick; and the applicable PDC reports filed by Respondent to determine if the allegations support a finding of one or more violations. 

Although the 2014 Snohomish County Executive Campaign and the 2018 State Representative Campaign originally submitted C-3 reports that included anonymous contributions in excess of the $300 or one percent of the total contributions, the source of the previously unidentified contributions have now been disclosed and the majority of the remaining campaign contributions were reported in a timely manner. 

Based on our findings, staff has determined that, in this instance, failure to timely and accurately disclose individual donations received at fund-raising events in 2014 and 2018, does not amount to an actual violation warranting further investigation. Pursuant to WAC 390-37-060(1)(b), however, Carolyn Eslick will receive a formal written warning concerning acceptance of over-limit anonymous contirubtions. The formal written warning will include staff’s expectation that Carolyn Eslick maintain complete records of all fund-raising activities, including any itemized individual contribution details required by law, to ensure timely and accurate disclosure on C-3 and C-4 reports in future years as a candidate for public office. The Commission will consider the formal written warning in deciding on further 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 this matter in accordance with RCW 42.17A.755(1).
https://www.pdc.wa.gov/browse/enforcement-cases/41628
41627 10/15/2018 Glen Morgan Matthew Sutherland Sutherland, Matthew: Violation of RCW 42.17A.235, .240, .445 for failure to timely and accurately file expenditure reports and unauthorized use of campaign funds. (OCT 2018) RCW 42.17A.445, RCW 42.17A.235, RCW 42.17A.240 Case Closed with Written Warning
The Public Disclosure Commission (PDC) has completed its initial review of the Complaint filed by Glen Morgan on October 3, 2018. The Complaint alleged that Matthew Sutherland may have violated RCW 42.17A.235, .240, .445 for failure to timely and accurately file expenditure reports and unauthorized use of campaign funds.

Based on our findings, staff has determined that in this instance, failure to accurately, completely, and timely report contributions and expenditures does not an actual violation warranting further investigation.

Pursuant to WAC 390-37-060(1)(b), Matthew Sutherland will receive a formal written warning concerning failure to accurately and timely report contributions and expenditures, and failure to provide sufficient breakdowns of expenditure details. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1), and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/41627
41626 10/15/2018 Larry Seaquist Jesse Young Young, Jesse: Alleged Violation of RCW 42.17A.555 for using public facilities to assist a political campaign. (OCT 2018) RCW 42.17A 555 Case Closed with No Evidence of Violations
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Larry Seaquist on October 2, 2018. The Complaint alleged that Jesse Young, incumbent and candidate for State Representative in the 26th Legislative District in 2018, may have violated RCW 42.17A.555 for using public facilities by posting campaign signs on office space paid for with legislative funds. 

PDC staff reviewed the applicable statutes, rules, and the response provided by Representative Young, to determine your allegations support a finding of one or more violations. 

Based on our findings staff has determined that, in this instance, no evidence supports a finding an actual violation warranting further investigation. For your information, RCW 42.17A.555 does not apply to incumbent legislative candidates as they are covered by the Legislative Ethics Board. 

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).
https://www.pdc.wa.gov/browse/enforcement-cases/41626
41581 10/12/2018 Washington Senate Democratic Campaign (Samantha Kersul) Doug Ericksen Ericksen, Doug: Alleged violations of RCW 42.17A.700 & .320 for failure to timely and accurately report income & identify sponsor in political advertising. (EY 18 Oct 18) RCW 42.17A.320, RCW42.17A.700 Case Closed with Written Warning
  • Allegation One: Alleged violation of RCW 42.17A.700 for failure to timely and accurately report income from field consulting for Donald Trump campaign. 
  • Allegation Two: Alleged violation of RCW 42.17A.320 for failure to identify sponsor in political advertising (YouTube video).
https://www.pdc.wa.gov/browse/enforcement-cases/41581
41577 10/12/2018 Joe Hyer Andrew Saturn Saturn, Andrew: Alleged violation of RCW 42.17A.335(1)(a) by making a false statement of material fact about a candidate for public office. (EY 18 Sep 18) RCW 42.17A.335 Case Closed with Reminder
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Joe Hyer on September 26, 2018. The Complaint alleged that Andrew Saturn, a candidate for Thurston County Public Utility Commissioner in 2018, may have violated; (1) RCW 42.17A.335 by making false statements of material fact about his opponent, Linda Oosterman, a candidate for public office; and (2) RCW 42.17A.240 by failing to disclose on Summary Full Campaign Contributions and Expenditures (C-4 reports), the expenditure for the candidate filing fee and debts for advertisements appearing on Facebook. 
PDC staff reviewed your allegations, the evidence provided, the C-4 reports filed by the Andrew Saturn Campaign, and the response from the Campaign. 

Based on our findings, staff has determined that in this instance, no evidence supports a finding of a material violation warranting further investigation. Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1).

Mr. Saturn will be reminded about the importance of vetting all information used in political advertisement, naming a candidate for public office and sponsored by any future campaigns he is involved with to avoid potential violations of RCW 42.17A.335.
https://www.pdc.wa.gov/browse/enforcement-cases/41577
41543 10/11/2018 Marcus Griffith Adam Shetler Shetler, Adam (3): Alleged violation of RCW 42.17A.205 for failure to register as a candidate for 2019 election year within two weeks of declaring candidacy, receiving contributions and/or making expenditures. (EY 19 Oct 18) RCW 42.17A.205 Case Closed with Written Warning
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Marcus Griffith on October 1, 2018. The complaint alleged that Adam Shetler, a candidate for City Councilperson for the City of Vancouver may have violated RCW 42.17A.205 by failing to timely file a Candidate Registration (C-1 report) within two weeks of posting a statement on Facebook declaring his 2019 candidacy. 

PDC staff reviewed the allegations listed in the complaint, the statutes, rules and reporting requirements, and the C-1 reports and Personal Financial Affairs Statement (F-1 report) filed by Adam Shetler.

Mr. Shetler’s failure to respond to multiple staff requests to provide a response to the complaint and file the missing reports is troubling. 

However, PDC staff noted that he was a first-time candidate in 2018 who filed a C-1 and F-1 report, selecting the Mini Reporting Option on the C-1 report and appeared unfamiliar with the PDC requirements. Pursuant to WAC 390-37-060(1)(b), PDC staff issued a formal written warning to Mr. Shetler concerning the importance of the PDC laws and reporting requirements, including registering as a candidate within two weeks of declaring his candidacy. This formal written warning coveys our expectation that Mr. Shetler will fully comply with the requirement listed above in the future as a declared candidate, and obtain any necessary assistance to comply with the reporting requirements. The Commission will consider this formal written warning if there are any future PDC law or rule violations by Mr. Shetler. 

Based on this information, the PDC has dismissed the complaint in accordance with RCW 42.17A.755(1).
https://www.pdc.wa.gov/browse/enforcement-cases/41543
41533 10/10/2018 Keiki Weigle Arian Noma Noma, Arian: Alleged Violation of RCW 42.17A.320 for failure to identify political party affiliation on campaign signs. (OCT 2018) RCW 42.17A.320 Case Closed with Written Warning
The complaint alleged Arian Noma, a first-time candidate running for Okanogan County Prosecutor in 2018, may have violated RCW 42.17A.320 by failing to include his party preference as selected on his Declaration of Candidacy filed with Okanogan County Elections and on political advertisements sponsored by his campaign.

Pursuant to WAC 390-37-060(1) Arian Noma will receive a formal written warning concerning the failure to comply with RCW 42.17A.320. The formal written warning will include staff's expectation Mr. Noma will clearly identify his party preference on political advertising sponsored by his Campaign in future years in accordance with PDC laws and rules.

The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules. Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1).
https://www.pdc.wa.gov/browse/enforcement-cases/41533
41519 10/10/2018 James Lazar 42nd Leg District Commitee GOP Exempt 42nd Leg District Committee GOP Exempt: Alleged violation of RCW 42.17A.442 by contributing to another political committee when contributing committee has not received contributions of $10 of more from 10 Washington registered voters. (EY 18 Oct 18) RCW 42.17A.442 Case Closed with No Evidence of Violations
The complaint alleged the 42nd Leg District GOP Committee (Exempt) violated RCW 42.17A.442 by contributing to another political committee before receiving contributions of $10 of more from ten Washington registered voters.

It was found:
  • The 42nd Leg District Committee GOP Exempt filed a Political Committee Registration (C1-PC) on June 28, 2018, filing as a new, continuing bona fide political partly committee under full reporting.
  • On Oct. 16, 2018, the committee filed a Monetary Contributions (C-3) report, listing $100 in contributions received Oct. 11, 2018. In this report, ten donors each donated $10.
  • In a ruling dated Feb. 28, 2017, in State v. Grocery Manufacturers Association, Thurston County Superior Court Judge Anne Hirsch found RCW 42.17A.442 to be unconstitutional.

Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1) and will not conduct a more formal investigation into the complaint or pursue further enforcement action in this case.


https://www.pdc.wa.gov/browse/enforcement-cases/41519
41515 10/10/2018 John Rumelhart Pend Oreille County Fire District #2 Pend Oreille County Fire District #2: Alleged violation of RCW 42.17A.555 by using public facilities to promote a ballot proposition. (EY 18; Oct 18) RCW 42.17A.555 Case Closed with Reminder
The complaint alleged staff of Pend Oreille County Fire District #2 violated RCW 42.17A.555 by using public facilities to promote a ballot proposition, specifically Proposition No. 2, the Ten-Year EMS Levy on the Nov. 6, 2018 General Election ballot.

The PDC is reminding Christopher L. Haynes about the importance of timely filing C-6 reports in accordance with PDC laws, rules and reporting requirements. Mr. Haynes was directed to file a C-6 with the PDC to report this contribution.

The PDC has dismissed this matter in accordance with RCW 42.17A.755(1) and will not conduct a more formal investigation into the complaint or pursue further enforcement action in this case.


https://www.pdc.wa.gov/browse/enforcement-cases/41515
41473 10/09/2018 Jordan Sears Kristen Olbrechts Olbrechts, Kristen: Alleged violations of RCW 42.17A.430, .235 & 405 for transferring funds to another candidate/committee, failure to accurately report contributions made, and exceeding contribution limits. (EY 18; Sep 18) RCW 42.17A.235, RCW 42.17A.430, RCW 42.17A.405 Case Closed with No Evidence of Violations
The complaints alleged that: (1) Robert Sutherland may have violated RCW 42.17A.405 by disclosing the receipt of contributions on Monetary Contributions reports (C-3 reports) from the Kristen Olbrechts Campaign that exceeded the $1,000 per election contribution limits; and (2) Kristen Olbrechts may have violated RCW 42.17A.430 by transferring active campaign funds to Robert Sutherland campaign and RCW 42.17A.405 by making contributions to Robert Sutherland that exceeded contribution limits.

Staff determined no evidence supports a finding of an actual material violation warranting further investigation. Both the Sutherland and Olbrechts campaigns entered into a verbal agreement concerning services being provided for sign locations, structures and maintenance based on an established fair market value agreed to by both parties. The PDC found no evidence the fair market value established between the two parties resulted in any contributions being made and will not conduct a more formal investigation into the complaint or pursue further enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/41473
41472 10/09/2018 Jordan Sears Robert Sutherland Sutherland, Robert: Alleged violations of RCW 42.17A.235 & .405 for failure to accurately report contributions received and exceeding contribution limits. (EY 18; Sep 18). RCW 42.17A.235, RCW 42.17A.405 Case Closed with No Evidence of Violations
The complaints alleged that: (1) Robert Sutherland may have violated RCW 42.17A.405 by disclosing the receipt of contributions on Monetary Contributions reports (C-3 reports) from the Kristen Olbrechts Campaign that exceeded the $1,000 per election contribution limits; and (2) Kristen Olbrechts may have violated RCW 42.17A.430 by transferring active campaign funds to Robert Sutherland campaign and RCW 42.17A.405 by making contributions to Robert Sutherland that exceeded contribution limits.

Staff determined no evidence supports a finding of an actual material violation warranting further investigation. Both the Sutherland and Olbrechts campaigns entered into a verbal agreement concerning services being provided for sign locations, structures and maintenance based on an established fair market value agreed to by both parties. The PDC found no evidence the fair market value established between the two parties resulted in any contributions being made and will not conduct a more formal investigation into the complaint or pursue further enforcement action in this case.


https://www.pdc.wa.gov/browse/enforcement-cases/41472
41447 10/09/2018 Conner Edwards Pierce County Library System Pierce County Library System: Alleged violation of RCW 42.17A.555 by using public facilities to promote a ballot proposition. (EY 18; Sep 18) RCW 42.17A.555 Resolved through Statement of Understanding
The complaint alleged that the Pierce County Library System (PCLS) spent public funds for Facebook advertisements in support of Proposition No. 1, a PCLS levy lid lift on the November 6, 2018 general election ballot.  Specifically, Mary Getchell, PCLS Marketing and Communications Director, on behalf of the PCLS posted information on its Facebook page thanking the TNT editorial board for printing an article endorsing Proposition No. 1 on the November 6, 2018, general election ballot, and then spent $250 in library public funds to Facebook to boost that post.  By spending $250 to boost the post of the TNT endorsement of the PCLS levy lid lift, Ms. Getchell used the facilities of the Pierce County Library System to support Proposition No. 1.

An executed Statement of Understanding (SOU) signed by Mary Getchell, on behalf of the PCLS, was received by the PDC acknowledging a violation of RCW 42.17A.555, and paying a $150 civil penalty to resolve this matter. 
https://www.pdc.wa.gov/browse/enforcement-cases/41447
41420 10/08/2018 Jim Lazar Eileen Sobjack 42nd Legislative District Committee GOP: Alleged Violation of RCW 42.17A.240 for failure to properly itemize expenditures. (SEP 2018) RCW.42.17A.240 Request for Technical Correction
  • Allegation: Violation of RCW 42.17A.240 for failure to properly itemize expenditures as described in WAC 390-17-037.
https://www.pdc.wa.gov/browse/enforcement-cases/41420
41350 10/05/2018 Michael Maddux Joseph Waldron Gun Owners Action League of Washington: Alleged Violation of RCW 42.17A.230, .235, .240, .250 for failure to timely or accurately disclose contribution reporting information and failure to report as an out-of-state political committee. (SEP 2018) . RCW 42.17A.235, RCW 42.17A.240 Case Closed with Written Warning
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Michael Maddux on September 26, 2018. The Complaint alleged that Gun Owners Action League of WA (GOAL) may have violated RCW 42.17A.230, .235, .240, and .250, for failure to accurately disclose contributions, and failure to report as an out-of-state political committee.

Based on these facts, staff has determined that in this instance, failure to accurately itemize or disclose individual monetary contributions on C-3 reports as required by law by instead, reporting contributions as low-cost fund-raiser proceeds, does not amount to an actual material violation warranting further investigation. 
Pursuant to WAC 390-37-060(1)(b), Gun Owners Action League of WA will receive a formal written warning concerning GOAL’s misuse of the alternative reporting method of fund-raising activities (low-cost fund-raiser) allowed under RCW 42.17A.230. PDC staff expects that GOAL will file C-3 reports disclosing all monetary contributions received and deposited by the committee, and that the committee itemize these individual donations when required by law, in future calendar years. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules. 

PDC staff reviewed the remaining allegations concerning (1) the printing error that resulted in the incorrect address for the committee, (2) the address used for donations attributed to Joseph Waldron, and (3) GOAL’s failure to report as an out-of-state committee. 

Staff found no evidence to support those allegations beyond the admitted error made by the committee when printing their address on checks used for distributing campaign contributions. 

PDC staff has dismissed those allegations in accordance with RCW 42.17A.755(1). Based on this information, PDC staff has dismissed this matter in accordance with RCW 42.17A.755(1).
https://www.pdc.wa.gov/browse/enforcement-cases/41350
41292 10/03/2018 Brian Drake Jon Tunheim Tunheim, Jon: Alleged violations of RCW 42.17A.555 and .565 by using public facilities or agency to assist an election campaign and soliciting contributions from county employees. (EY 18; Sep 18). RCW 42.17A.565, RCW 42.17A.555 Case Closed with No Evidence of Violations
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Brian Drake on September 21, 2018. The Complaint alleged that Jon Tunheim, an incumbent Thurston County Prosecutor and a candidate seeking re-election to that office in 2018, may have violated RCW 42.17A.555 by using Thurston County public facilities to assist his re-election campaign, and RCW 42.17A.565 by soliciting contributions from Thurston County Prosecutor’s Office employees. 

The Complainant also provided supplemental information alleging that Jeff Lippert, Chief Criminal Deputy was introduced as “Campaign Manager” at a voter forum held on September 29, 2018 (a Saturday), and that he appeared as a representative of the campaign at a community candidates forum (Jubilee forum) on October 2, 2018 (a Tuesday), in violation of RCW 42.17A.555. 
PDC staff reviewed the allegations listed in the complaint including the supplemental allegation and the copy of an electronic disk/video submitted along with the complaint, the laws, rules, and PDC Interpretation #04-02 Guidelines for Local Government Agencies in Election Campaigns, the Candidate Registration (C-1 report) filed by Jon Tunheim, and the initial and supplemental responses from Mr. Tunheim. 

Although 20 staff members contributed to Mr. Tunheim’s campaign and about 11 exempt employees volunteered for his campaign, no evidence was provided or found that any of the employees conducted any campaign activities during work hours or using Thurston County Prosecutor’s Office resources. 

As such, the PDC staff found no evidence of a material violation that would require conducting a more formal investigation into your complaint or pursuing enforcement action in this instance. 

Based on this information, the PDC has dismissed the Complaint in accordance with RCW 42.17A.755(1)
https://www.pdc.wa.gov/browse/enforcement-cases/41292
41287 10/03/2018 Michael Maddux Systems Group Corporation of Washington DBA Sporting Systems Systems Group Corporation of Washington DBA Sporting Systems: Alleged violation of RCW 24.17A for failure to register as a political committee, report independent expenditures or electioneering communications and identify sponsor. (EY 18 Sep 18) RCW 42.17A.205 Case Closed with Reminder
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Michael Maddux on September 26, 2018. The Complaint alleged that Systems Group Corporation of Washington DBA Sporting Systems (SGCWDSS), may have violated RCW 42.17A by failing to register and report as a political committee disclosing contribution and expenditure activities in opposition to Initiative 1639, a statewide ballot proposition, and failure to include the sponsor identification on political advertising in opposition to I1639. 

PDC staff reviewed the allegations listed in the complaint to determine whether a formal investigation or enforcement action is warranted. Staff reviewed all the exhibits submitted with the complaint, and the response letter received via email from Daniel Mitchell with the SGCWDSS.

Staff’s review found that SGCWDSS did not solicit or accept contributions from the public in order to make the expenditures in opposition to I-1639, and there was no expectation of receiving any contributions from the public. Therefore, SGCWDSS was not a political committee. In addition, as noted above SGCWDSS made several in-kind contributions to the Committee, so the expenditures were not independent expenditures required to have been disclosed on a C-6 report. 
PDC staff found no evidence of a material violation that would require conducting a more formal investigation into your complaint or pursuing enforcement action in this instance. 
Staff has reminded SGCWDSS of the importance of including the complete sponsor identification, including the sponsor’s complete mailing address on all political advertising undertaken in future years, should SGCWDSS decide to oppose or support a ballot initiative or candidate for public office. 
Based on the above, the PDC has dismissed your complaint in accordance with RCW 42.17A.755(1)
https://www.pdc.wa.gov/browse/enforcement-cases/41287
41274 10/03/2018 Jared Karstetter, Jr. Chris Vance Vance, Chris: Alleged violations of RCW 42.17A.600, .615, and .255, .260 or .305 for failure to timely and accurately register as a lobbyist, report compensation & expenditures, and report independent expenditures. (EY 18; Sep 18) RCW 42.17A.260, RCW 42.17A.615, RCW 42.17A.255, RCW 42.17A.600, RCW 42.17A.305 Case Closed with Written Warning
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Jared Karstetter on September 8, 2018. The Complaint alleged that Chris Vance may have violated RCW 42.17A.600, .615, .255, .260 and .305 for failure to timely and accurately register as a lobbyist, report compensation and expenditures, and report independent expenditures.

Based on our findings, staff has determined that in this instance, failure to accurately file a small number of L-2 reports disclosing a small amount of personal contributions, does not amount to an actual material violation warranting further investigation.

Pursuant to WAC 390-37-060(1)(b), Chris Vance will receive a formal written warning concerning failure to timely and accurately file L-2 reports as a registered lobbyist. The formal written warning will include staff’s expectation that Chris Vance will file timely and complete L-2 reports, including the disclosure of personal contributions made to Washington state candidates and political committees in the future as required by law. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

PDC staff reviewed the remaining allegations concerning the false statements made by Mr. Vance during sworn testimony, his failure to timely register and accurately report as a lobbyist for the King County Corrections Guild, and the disclosure of Independent Expenditures. PDC staff found no evidence to support them beyond those specifically noted above and has dismissed those allegations in accordance with RCW 42.17A.755(1).
https://www.pdc.wa.gov/browse/enforcement-cases/41274
41265 10/03/2018 Roger Lenk Steve Young Young, Steve (2): Alleged violations of RCW 42.17A.205, .220, .235 for failure to file or timely register as a candidate and report contributions and expenditures. (EY 19 Sep 18) RCW 24.17A.205, RCW 24.17A.235, RCW 24.17A.220 Case Closed with Reminder
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Roger Lenk on September 21, 2018. The Complaint alleged that Steve Young may have violated RCW 42.17A.205, .220, and .235 by failing to timely register as a candidate seeking re-election to the Kennewick City Council in 2019, and by failing to timely and accurately report contributions and expenditures for his 2019 re-election campaign. 
PDC staff reviewed the allegations, the applicable statutes, rules, and reporting requirements, and the response provided by Mr. Young to determine whether your allegations support a finding of one or more violations. 

Based on our findings, staff has determined that in this instance, Steve Young’s failure to file a candidate registration within two weeks of making a public declaration of candidacy does not appear to be an actual violation warranting further investigation. 
PDC staff is reminding Mr. Young about the importance of timely filing a candidate registration in future elections even when making a public declaration that is conditioned on a future occurrence. 
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). 
https://www.pdc.wa.gov/browse/enforcement-cases/41265
41223 10/02/2018 Steve White Gina Mosbrucker Mosbrucker, Gina: Alleged violation of RCW 42.17A.330 for failure to use at least one picture of the candidate, taken within the last five years, in political advertising. (EY 18 Sep 18) RCW 42.17A.330 Case Closed with No Evidence of Violations
  • Allegation: Alleged violation of RCW 42.17A.330 for failure to use at least one picture of the candidate, taken within the last five years, in political advertising.
https://www.pdc.wa.gov/browse/enforcement-cases/41223
41189 10/01/2018 Lincoln Beauregard Maria Lorena Gonzalez Gonzalez, Maria Lorena: Alleged violation of RCW 42.17A.555 by using public facilities to support a ballot measure. (EY 18 Sep 18) RCW 42.17A.555 Case Closed with No Evidence of Violations
The Public Disclosure Commission (PDC) has completed its initial review of the complaint filed by Lincoln Beauregard on September 20, 2018. The Complaint alleged that the individual named above may have violated RCW 42.17A.555 by using public facilities to support a ballot measure (education levy).

Based on our findings, staff is deferring this matter to the SEEC, pursuant to WAC390-37-061(3)because the alleged violation is being addressed under an analogous local ordinance. The PDC has dismissed this complaint and will not be pursing further investigation or enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/41189
41188 10/01/2018 Lincoln Beauregard Teresa Mosqueda Mosqueda, Teresa: Alleged violation of RCW 42.17A.555 by using public facilities to support a ballot measure. (EY 18 Sep 18) RCW 42.17A.555 Case Closed with No Evidence of Violations
The Public Disclosure Commission (PDC) has completed its initial review of the complaint filed by Lincoln Beauregard on September 20, 2018. The Complaint alleged that the individual named above may have violated RCW 42.17A.555 by using public facilities to support a ballot measure (education levy).

Based on our findings, staff is deferring this matter to the SEEC, pursuant to WAC390-37-061(3)because the alleged violation is being addressed under an analogous local ordinance. The PDC has dismissed this complaint and will not be pursing further investigation or enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/41188
41186 10/01/2018 Lincoln Beauregard Sally Bagshaw Bagshaw, Sally: Alleged violation of RCW 42.17A.555 by using public facilities to support a ballot measure. (EY 18 Sep 18) RCW 42.17A.555 Case Closed with No Evidence of Violations
The Public Disclosure Commission (PDC) has completed its initial review of the complaint filed by Lincoln Beauregard on September 20, 2018. The Complaint alleged that the individual named above may have violated RCW 42.17A.555 by using public facilities to support a ballot measure (education levy).

Based on our findings, staff is deferring this matter to the SEEC, pursuant to WAC390-37-061(3)because the alleged violation is being addressed under an analogous local ordinance. The PDC has dismissed this complaint and will not be pursing further investigation or enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/41186
41185 10/01/2018 Lincoln Beauregard Michael O'Brien O'Brien, Michael: Alleged violation of RCW 42.17A.555 by using public facilities to support a ballot measure. (EY 18 Sep 18) RCW 42.17A.555 Case Closed with No Evidence of Violations
The Public Disclosure Commission (PDC) has completed its initial review of the complaint filed by Lincoln Beauregard on September 20, 2018. The Complaint alleged that the individual named above may have violated RCW 42.17A.555 by using public facilities to support a ballot measure (education levy).

Based on our findings, staff is deferring this matter to the SEEC, pursuant to WAC390-37-061(3)because the alleged violation is being addressed under an analogous local ordinance. The PDC has dismissed this complaint and will not be pursing further investigation or enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/41185
41184 10/01/2018 Lincoln Beauregard Debora Juarez Juarez, Debora: Alleged violation of RCW 42.17A.555 by using public facilities to support a ballot measure. (EY 18 Sep 18) RCW 42.17A.555 Case Closed with No Evidence of Violations
The Public Disclosure Commission (PDC) has completed its initial review of the complaint filed by Lincoln Beauregard on September 20, 2018. The Complaint alleged that the individual named above may have violated RCW 42.17A.555 by using public facilities to support a ballot measure (education levy).

Based on our findings, staff is deferring this matter to the SEEC, pursuant to WAC390-37-061(3)because the alleged violation is being addressed under an analogous local ordinance. The PDC has dismissed this complaint and will not be pursing further investigation or enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/41184
41183 10/01/2018 Lincoln Beauregard Robert Johnson Johnson, Robert: Alleged violation of RCW 42.17A.555 by using public facilities to support a ballot measure. (EY 18 Sep 18) RCW 42.17A.555 Case Closed with No Evidence of Violations
The Public Disclosure Commission (PDC) has completed its initial review of the complaint filed by Lincoln Beauregard on September 20, 2018. The Complaint alleged that the individual named above may have violated RCW 42.17A.555 by using public facilities to support a ballot measure (education levy).

Based on our findings, staff is deferring this matter to the SEEC, pursuant to WAC390-37-061(3)because the alleged violation is being addressed under an analogous local ordinance. The PDC has dismissed this complaint and will not be pursing further investigation or enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/41183
41182 10/01/2018 Lincoln Beauregard Bruce Harrell Harrell, Bruce (2): Alleged violation of RCW 42.17A.555 by using public facilities to support a ballot measure. (EY 18 Sep 18) RCW 42.17A.555 Case Closed with No Evidence of Violations
The Public Disclosure Commission (PDC) has completed its initial review of the complaint filed by Lincoln Beauregard on September 20, 2018. The Complaint alleged that the individual named above may have violated RCW 42.17A.555 by using public facilities to support a ballot measure (education levy).

Based on our findings, staff is deferring this matter to the SEEC, pursuant to WAC390-37-061(3)because the alleged violation is being addressed under an analogous local ordinance. The PDC has dismissed this complaint and will not be pursing further investigation or enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/41182
41181 10/01/2018 Lincoln Beauregard Lisa Herbold Herbold, Lisa: Alleged violation of RCW 42.17A.555 by using public facilities to support a ballot measure. (EY 18 Sep 18) RCW 42.17A.555 Case Closed with No Evidence of Violations
The Public Disclosure Commission (PDC) has completed its initial review of the complaint filed by Lincoln Beauregard on September 20, 2018. The Complaint alleged that the individual named above may have violated RCW 42.17A.555 by using public facilities to support a ballot measure (education levy).

Based on our findings, staff is deferring this matter to the SEEC, pursuant to WAC390-37-061(3)because the alleged violation is being addressed under an analogous local ordinance. The PDC has dismissed this complaint and will not be pursing further investigation or enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/41181
41179 10/01/2018 Lincoln Beauregard Jenny Durkan Durkan, Jenny: Alleged violation of RCW 42.17A.555 by using public facilities to support a ballot measure. (EY 18 Sep 18) RCW 42.17A.555 Case Closed with No Evidence of Violations
The Public Disclosure Commission (PDC) has completed its initial review of the complaint filed by Lincoln Beauregard on September 20, 2018. The Complaint alleged that the individuals named above may have violated RCW 42.17A.555 by using public facilities to support a ballot measure (education levy).

Based on our findings, staff is deferring this matter to the SEEC, pursuant to WAC390-37-061(3)because the alleged violation is being addressed under an analogous local ordinance. The PDC has dismissed this complaint and will not be pursing further investigation or enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/41179
41110 09/28/2018 Greg Laycock Sandy Malcolm Malcolm, Sandy: Alleged violation of RCW 42.17A.555 by using public office or agency facilities to promote a ballot proposition. (EY 18 Sep 18) RCW 42.17A.555 Case Closed with No Evidence of Violations
The Public Disclosure Commission (PDC) has completed its initial review of the complaint filed by Gregory Laycock on September 21, 2018. The Complaint alleged that Sandy Malcolm, Administrative Assistant for Kittitas County Fire Protection District #7 may have violated RCW 42.17A.555 by using a public office or agency to promote a ballot proposition.

Based on our findings, staff has determined that in this instance, no evidence supports a finding of a violation warranting further investigation.

The PDC has dismissed the matter and will not be conducting a more formal investigation into the Complaint or pursuing further enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/41110
41108 09/28/2018 Greg Laycock Bryan Pearson Pearson, Bryan: Alleged violation of RCW 42.17A.555 by using public facilities or office to promote a ballot proposition. (EY 18 Sep 18) RCW 42.17A.555 Case Closed with No Evidence of Violations
The Public Disclosure Commission (PDC) has completed its initial review of the complaint filed by Gregory Laycock on September 28, 2018. The Complaint alleged that Deputy Chief Brian Pearson, Kittitas County Fire District #7 may have violated RCW 42.17A.555 by using public facilities or office to promote a ballot proposition.

Based on our findings, staff has determined that in this instance, no evidence supports a finding of a violation warranting further investigation.

The PDC has dismissed the matter and will not be conducting a more formal investigation into the Complaint or pursuing further enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/41108
41106 09/28/2018 Melissa Beseda James Detro Detro, James: Alleged violation of RCW 42.17A.555 for using public facilities or office to assist an election campaign. (EY 18 Sep 18) RCW 42.17A.555 Case Closed with No Evidence of Violations
  • Allegation: Alleged violation of RCW 42.17A.555 for using public facilities or office to assist an election campaign.
https://www.pdc.wa.gov/browse/enforcement-cases/41106
41094 09/27/2018 Joe Kunzler Bruce Harrell Harrell, Bruce: Alleged violation of RCW 42.17A.555 by authorizing the use of public facilities to assist an election campaign. (EY 18 Sep 18) RCW 42.17A.555 Case Closed with No Evidence of Violations
The Public Disclosure Commission (PDC) has completed its initial review of the complaint filed by Joe Kunzler on September 17, 2018. The Complaint alleged that Seattle Council President Bruce Harrell may have violated RCW 42.17A.555 by authorizing the use of public facilities to assist Alex Tsimerman's election campaign.

Based on our findings, staff has determined that, pursuant to WAC 390-37-061(3), to defer this complaint to the jurisdiction of the SEEC because the alleged violation was addressed under an analogous local ordinance. The PDC has dismissed this complaint and will not be pursing further investigation or enforcement action in this case. 
https://www.pdc.wa.gov/browse/enforcement-cases/41094
41036 09/25/2018 Mark Nelson Pinky Vargas Vargas, Pinky (1): Alleged Violation of RCW 42.17A.555 for use of public facilities to support a political campaign. (SEP 2018) RCW 42.17A 555 Case Closed with No Evidence of Violations
The complaint alleged a violation of RCW 42.17A.555 by using public facilities to support her campaign by having a photograph taken in front of a fire station that included several fire fighters and using that photograph in political advertising.

PDC staff reviewed the allegations listed in the complaint, PDC laws, rules and, PDC Interpretation No. 04-02 Guidelines for Local Public Agencies in Election Campaigns, and the responses from Ms. Vargas, Shelby Kremenich, Campaign Manager, Friends of Pinky Vargas, and Colin Lowin, PAC Chair, International Association of Firefighters, Local 106 Bellingham/Whatcom Co. Union Firefighters (IAFF Local 106).

The sidewalk is considered public domain and the firefighters featured in the photograph were not using fire district uniforms or gear and were not on official duty.

The PDC has dismissed this matter in accordance with RCW 42.17A.755(1) and will not be conducting a more formal investigation into these allegations or taking further enforcement action in this matter.

https://www.pdc.wa.gov/browse/enforcement-cases/41036
41028 09/25/2018 Washington Senate Democratic Campaign (Samantha Kersul) Senate Republican Campaign Committee Senate Republican Campaign Committee (2): Alleged violation of RCW 42.17A.405(7) and RCW 42.17A.405(14) for accepting over-limit contribution from Shift Washington (EY 18; Sep 18) RCW 42.17A.405 Case Closed with No Evidence of Violations
The Public Disclosure Commission (PDC) has completed its review of the two Complaints filed by Samantha Kersul on September 19, 2018, against Shift Washington, a political committee registered with the PDC (PDC Case 41027), and the Senate Republican Campaign Committee, a caucus campaign committee (PDC Case 41028). The Complaints alleged that: (1) Shift Washington (SW) may have violated RCW 42.17A.405(7) by making an over-limit contribution to the Senate Republican Campaign Committee (SRCC), a caucus committee subject to contribution limits; and (2) the SRCC may have violated RCW 42.17A.405(7)(14) by accepting an over-limit contribution from Shift Washington. 

In order to more efficiently use PDC resources, the two Complaints filed with the PDC have been combined into one letter. PDC staff reviewed the allegations listed in the complaint, statutes, rules, reporting requirements and contribution limits, and the Monetary Contributions reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 report) filed by both committees, and the responses from SW.

Although the in-kind contribution was inadvertently recorded on the SRCC’s C-4 report for March 2018 instead of the Leadership Council’s C-4 for the same reporting period, both committees made a good faith effort and expeditiously filed amended C-4 reports to correct the error as soon as they were notified. The amended C-4 reports filed by both committees corrected the filing error by making the necessary technical corrections. 

Based on the above, the PDC found no evidence of a material violation that would require conducting a more formal investigation into the two Complaints or pursuing enforcement action in these instances for either Shift Washington or the Senate Republican Campaign Committee. As such, the PDC has dismissed the Complaints against Shift Washington (PDC Case 41027) and SRCC (PDC Case 41028) in accordance with RCW 42.17A.755(1).
https://www.pdc.wa.gov/browse/enforcement-cases/41028
41027 09/25/2018 Washington Senate Democratic Campaign Shift Washington Shift Washington: Alleged violation of RCW 42.17A.405(7) for making over-limit contribution to the Senate Republican Campaign Committee, a caucus committee (EY 18; Sep 18) RCW 42.17A.405 Case Closed with No Evidence of Violations
The Public Disclosure Commission (PDC) has completed its review of the two Complaints filed by Samantha Kersul on September 19, 2018, against Shift Washington, a political committee registered with the PDC (PDC Case 41027), and the Senate Republican Campaign Committee, a caucus campaign committee (PDC Case 41028). The Complaints alleged that: (1) Shift Washington (SW) may have violated RCW 42.17A.405(7) by making an over-limit contribution to the Senate Republican Campaign Committee (SRCC), a caucus committee subject to contribution limits; and (2) the SRCC may have violated RCW 42.17A.405(7)(14) by accepting an over-limit contribution from Shift Washington. 

In order to more efficiently use PDC resources, the two Complaints filed with the PDC have been combined into one letter. PDC staff reviewed the allegations listed in the complaint, statutes, rules, reporting requirements and contribution limits, and the Monetary Contributions reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 report) filed by both committees, and the responses from SW.

Although the in-kind contribution was inadvertently recorded on the SRCC’s C-4 report for March 2018 instead of the Leadership Council’s C-4 for the same reporting period, both committees made a good faith effort and expeditiously filed amended C-4 reports to correct the error as soon as they were notified. The amended C-4 reports filed by both committees corrected the filing error by making the necessary technical corrections. 

Based on the above, the PDC found no evidence of a material violation that would require conducting a more formal investigation into the two Complaints or pursuing enforcement action in these instances for either Shift Washington or the Senate Republican Campaign Committee. As such, the PDC has dismissed the Complaints against Shift Washington (PDC Case 41027) and SRCC (PDC Case 41028) in accordance with RCW 42.17A.755(1).
https://www.pdc.wa.gov/browse/enforcement-cases/41027
41024 09/25/2018 Eli Sanders Facebook, Inc. Facebook, Inc. (2): Alleged violations of RCW 42.17A.345 and Emergency Rule WAC 390-18-050 for failure to maintain and provide documents and books of account for public inspection (EY 18; Sep 18) RCW 42.17A.345, WAC 390-18-050 Referred to Attorney General by Commission
On October 12, 2018, PDC Executive Director Peter Lavallee recommended this case be referred to the Washington State Attorney General's Office, following staff’s assessment/investigation of the complaint filed by Eli Sanders, a reporter with The Stranger, against Facebook (2) in PDC Case 41024. On September 19, 2018, Mr. Eli Sanders filed a formal complaint with the PDC alleging that Facebook failed to comply with RCW 42.17A.235 and his request for all political advertisements that were “purchased using Facebook’s platforms, including Instagram, with the aim of influencing Seattle's 2018 referendum on the 'Employee Hours Tax.' (Commonly known as the 'head tax')." 

On April 11, 2018, a citizen action notice (CAN) was filed with the Attorney General's Office (AGO) pursuant to RCW 42.17A.765 and with the PDC against Facebook alleging violations of RCW 42.17A.345 for failing to provide political advertising information for Facebook advertisements that were purchased to support or oppose 2017 candidates for Seattle City Council. 
The allegations contained in the CAN and PDC complaints (PDC Case 34055) were substantially similar. On June 4, 2018, the PDC became aware that a lawsuit was filed by the AGO in Superior Court in the name of Washington State against Facebook, and PDC staff dismissed that complaint (technically we closed the matter as was our practice at that time so we may want to use that language if we include the info). 

Based on staff’s initial assessment of the complaint, the fact Facebook appears to have committed multiple apparent violations of RCW 42.17A, and the AGO has already filed a lawsuit against Facebook concerning these issues, Executive Director Lavallee referred this matter to the Attorney General for appropriate action based on RCW 42.17A.765(?) as amended by ESHB 2938.
https://www.pdc.wa.gov/browse/enforcement-cases/41024
41016 09/25/2018 Jason Raines John Henry Henry, John: Alleged violation of RCW 42.17A.710 for failure to accurately and completely disclose financial activity for calendar year 2017 (EY 18; Sep 18) RCW 42.17A.710 Case Closed with Reminder
The Public Disclosure Commission (PDC) has completed its initial review of the complaint filed by Jason Raines on September 17, 2018. The Complaint alleged that John Henry may have violated RCW 42.17A.710 for failure to accurately and completely disclose financial activity for calendar year 2017.

Based on our findings, staff has determined that in this instance, failure to file an accurate and complete F-1 report due to technical errors, does not amount to an actual material violation warranting further investigation.

PDC staff is reminding John Henry about the importance of the accurate and complete disclosure of financial activities on the F-1 report.

Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1), and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/41016
40884 09/21/2018 Kaylee Pigott Secure School Choice for Washington Secure School Choice for Washington: Alleged violations of RCW 42.17A.205, .240, & .320 for failure to accurately and completely register as a political committee, report contributions, and disclose Sponsor ID (EY 18; Sep 18) RCW.42.17A.240, RCW 42.17A.205, RCW 42.17A.320 Case Closed with Reminder
The complaint alleged Secure School Choice for Washington violated (1) RCW 42.17A.205 by failing to timely file a Committee Registration (C-1pc report) registering with the PDC as a political committee within two weeks of making an expenditure in any election campaign; (2) RCW 42.17A.240(2) for failing to properly disclose contributions received from contributors on Monetary Contribution reports (C-3 reports); and (3) RCW 42.17A.320 for failing to identify the complete sponsor identification on political advertisements sponsored by the Committee.

The Committee was merely posting information on its Facebook page, or merely reposting posts from other sites on its Facebook page. The contents posted on the Committee’s Facebook page did not require an expenditure of funds to distribute the information and did not meet the definition of a contribution in accordance with RCW 42.17A.005.  Therefore, the Committee did not have a reporting obligation.

Mr. Miller acknowledged that the Committee filed several C-3 reports that failed to include the complete address information as required for contributors. On Nov. 9, 2018, the Committee filed four amended C-3 reports for deposits made April 10, April 30 and May 14, 2018, to include the complete address for several contributors. Mr. Miller indicated he continues to try and reach donors to gather employer information.

Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1) and will not be conducting a more formal investigation into the complaint or pursuing further enforcement action in this case.

PDC staff is reminding Secure School Choice for Washington and Tyler Miller about the importance of filing timely and accurately C-3 reports and C-4 reports in accordance with PDC laws, including complete contributor information, and the political advertising requirements, including the importance of clearly identifying sponsorship information on all forms of advertising, including social media advertising.
https://www.pdc.wa.gov/browse/enforcement-cases/40884
40877 09/21/2018 Kaylee Pigott Washingtonians and the National Rifle Association for Freedom Washingtonians and the National Rifle Association for Freedom: Alleged violations of RCW 42.17A.205, .235, and .240 for failure to timely and accurately register as a political committee and report contributions and expenditures (EY 18; Sep 18) RCW.42.17A.240, RCW 42.17A.205, RCW 42.17A.235 Request for Technical Correction
  • Allegation One: Violation of RCW 42.17A.205 for failure to timely and accurately register as a political committee.
  • Allegation Two: Violation of RCW 42.17A.235 for failure to timely report contributions and expenditures.
  • Allegation Three: Violation of RCW 42.17A.240 for failure to report in-kind contributions from the National Rifle Association for legal challenges to Initiative 1639.
  • Allegation Four: Violation of RCW 42.17A.235 for failure to provide in-state address for campaign book inspection.
https://www.pdc.wa.gov/browse/enforcement-cases/40877
40874 09/21/2018 Elizabeth Hallock Chris Corry Corry, Chris: Alleged violation of RCW 42.17A.240 for failure to report in-kind contributions for Yakima Junior League event and RCW 42.17A.320 for failure to include party affiliation on cups (EY 18; Sep 18) RCW 42.17A.320, RCW.42.17A.240 Case Closed with No Evidence of Violations
The Public Disclosure Commission (PDC) has completed its initial review of the complaint filed by Elizabeth Hallock on September 10, 2018. The Complaint alleged that Chris Corry may have violated RCW 42.17A.240 for failure to report in-kind contributions for Yakima Junior League event and RCW 42.17A.320 for failure to include party affiliation on cups.

Based on our findings, staff has determined that in this instance, no evidence supports a finding of an actual material violation warranting further investigation.

Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1), and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case. 
https://www.pdc.wa.gov/browse/enforcement-cases/40874
40872 09/21/2018 Pat Pieper Arian Noma Noma, Arian: Alleged violation of RCW 42.17A.320 for failure to identify party affiliation on political advertising. (EY 18 Sep 18) RCW 42.17A.320 Case Closed with Written Warning
The complaint alleged Arian Noma, a first-time candidate running for Okanogan County Prosecutor in 2018, may have violated RCW 42.17A.320 by failing to include his party preference as selected on his Declaration of Candidacy filed with Okanogan County Elections and on political advertisements sponsored by his campaign.

Pursuant to WAC 390-37-060(1) Arian Noma will receive a formal written warning concerning the failure to comply with RCW 42.17A.320. The formal written warning will include staff's expectation Mr. Noma will clearly identify his party preference on political advertising sponsored by his Campaign in future years in accordance with PDC laws and rules.

The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules. Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/40872
40870 09/21/2018 Kelly Wright Snohomish County Democratic Central Committee Snohomish County Democratic Central Committee (2): Alleged violations of RCW 42.17A.235 and .240 for failure to accurately report contributions, expenditures, and debts (EY 18; Sep 18) RCW 42.17A.235, RCW.42.17A.240 Case Closed with Written Warning
The complaint alleged that the Committee may have violated RCW 42.17A.235 and .240 by failing to timely file complete and accurate Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contributions and Expenditure reports (C-4 reports) disclosing: (1) the receipt of a $900 contribution from the 44th Legislative District Democrats; (2) a $3,000 expenditure for a monetary contribution made to Jared Mead; and (3) the reporting of the Blue Wave Gala event held on September 29, 2018.

PDC staff reviewed the allegations listed in the complaint you filed, the statutes, rules and reporting requirements, the C-3 and C-4 reports filed by the Committee, and the response to the complaint provided by Richard Moralez, former Committee treasurer and Eric Halvorson, current Committee treasurer.   

Based on these findings, and the extenuating circumstances of the death of the Committee treasurer, staff has determined that in this instance, the failure to timely file C-3 and C-4 reports disclosing contributions and expenditures does not amount to a material violation warranting further investigation.

Pursuant to WAC to WAC 390-37-060(1), the Snohomish County Democratic Central Committee will receive a formal written warning concerning the failure to comply with the reporting requirements and to timely and accurately file C-3 and C-4 reports disclosing contributions and expenditures activities in accordance with RCW 42.17A.235 and .240.

PDC staff has the expectation the Snohomish County Democratic Central Committee will timely file complete and accurate reports in future years in accordance with PDC laws and rules, including the timely depositing of contributions within five business days of receipt.

The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1).  


https://www.pdc.wa.gov/browse/enforcement-cases/40870
40824 09/19/2018 Roger Lenk Marie Mosley Mosley, Marie - Alleged violation of RCW 42.17A.555 Using public facilities to assist a candidate's campaign (MAY 2017) RCW 42.17A.555 Case Closed with Written Warning
On May 8, 2017, the Public Disclosure Commission received a complaint from Roger Lenk alleging that Marie Mosley may have violated RCW 42.17A.555 by using her City of Kennewick email to assist the campaign of Dan Newhouse, a candidate for U.S. House of Representatives.
https://www.pdc.wa.gov/browse/enforcement-cases/40824
40733 09/17/2018 Kaylee Pigott Phil Watson Save Our Security: Alleged Violation of RCW 42.17A.320 for failure to disclose Top Five Contributors on the campaign website and political advertising. (SEP 2018) RCW 42.17A.320 Case Closed with No Evidence of Violations
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Kaylee Pigott on September 11, 2018. The Complaint alleged that the Save Our Security campaign may have violated RCW 42.17A.320 for failure to list the top five contributors on their campaign website. 

PDC staff reviewed the allegations, the statutes and rules, and the responses from Save Our Security. 
Based on our findings and the following facts, staff has determined that in this instance, the failure to disclose the top five contributors on the campaign website does not amount to a material violation warranting further investigation since: (1) Save Our Security was not required to list the top five contributors because the Campaign did not make website expenditures costing $1,000 or more. 
Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1), and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case. 
https://www.pdc.wa.gov/browse/enforcement-cases/40733
40731 09/17/2018 Craig Ritchie William Peach Peach, William (2): Alleged Violation of RCW 42.17A.220, .235, .240, .320 for failure to timely or accurately disclose contributions, expenditures, loans, and party affiliation. (SEP 2018) RCW 42.17A.235, RCW 42.17A.240, RCW 42.17A.220, RCW 42.17A.320 Resolved through Statement of Understanding
By December 14, 2018, the Public Disclosure Commission (PDC) received a signed Statement of Understanding from William Peach, acknowledging violations of RCW 42.17A.235 for failure to file a Monetary Contribution report (C-3 report) and three Summary Full Campaign Expenditure reports (C-4 reports) for the 2018 Campaign for Clallam County Commissioner; and a $600 payment of a civil penalty.

Having received these items, the PDC closed this case without pursuing further enforcement or fines.
https://www.pdc.wa.gov/browse/enforcement-cases/40731
40728 09/17/2018 Roger Lenk Don Britain and Marie Mosley Britain, Don and Mosley, Marie: Alleged Violation of RCW 42.17A.555 for using public facilities of City of Kennewick to oppose recall ballot proposition concerning Steve Young, a Kennewick City Council member. (SEP 2018) RCW 42.17A.555 Case Closed with No Evidence of Violations
Allegation: Violation of RCW 42.17A.555 for use of public facilities or public office for the opposition of a recall petition regarding Steve Young, Kennewick City Council Member.
https://www.pdc.wa.gov/browse/enforcement-cases/40728
40614 09/14/2018 Anthony Wallace Terry Cox Whatcom County Republican Party: Alleged Violation of RCW 42.17A.205 for failure to accurately identify the committee treasurer on the statement of organization (SEP 2018) RCW 42.17A.205 Case Closed with No Evidence of Violations
The Public Disclosure Commission (PDC) has completed its initial review of the Complaint filed by Anthony Wallace on September 5, 2018. The Complaint alleged that the Whatcom County Republican Party disclosed an inaccurate treasurer on the Political Committee Registration (C-1PC Report). PDC staff reviewed your allegations, the statutes and rules, the C-1PC report for the campaign, and the response from Russ Dzialo. 

Based on these findings and the following facts, staff has determined that in this instance, the failure to accurately identify the committee treasurer on the Political Committee Registration (C1PC) does not does not amount to a material violation warranting further investigation since: (1) Terry Cox is the registered treasurer on the C-1PC for the Whatcom County Republican Party; (2) There is no evidence that Russ Dzialo performed any actions as treasurer since his resignation; and (3) The Whatcom GOP updated the committee website to reflect the treasurer that is listed on the C-1PC. 
The PDC has closed the matter, and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case.


https://www.pdc.wa.gov/browse/enforcement-cases/40614
40612 09/14/2018 Jim Lazar William Peach Peach, William (1): Alleged Violation of RCW 42.17A.235, .240 for failure to timely or accurately file contributions or expenditures on C-4 reports. (SEP 2018) RCW 42.17A.235, RCW 42.17A.240 Resolved through Statement of Understanding
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Jim Lazar on September 5, 2018. The Complaint alleged that William Peach, an incumbent Clallam County Commissioner and a candidate seeking re-election to that office in 2018, may have violated RCW 42.17A.235 and .240 by failing to timely file Monetary Contributions reports (C-3 reports), and Campaign Summary Full Campaign Contribution and Expenditure reports (C-4 reports) disclosing contribution and expenditure activities undertaken by his Campaign. 
PDC staff reviewed the allegations listed in the complaint, exhibits, the statutes, rules and reporting requirements, and the C-3 and C-4 reports filed by the Committee to Re-elect County Commissioner Bill Peach (Campaign) and the response to the complaint. 

On December 10, 2018, William Peach, by way of his campaign treasurer, Sandy Schier, emailed a scanned copy of a signed Statement of Understanding (SOU) acknowledging four violations of RCW 42.17A.235 and agreeing to pay a $600 civil penalty that was assessed in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule). By completing the SOU, Mr. Peach, acknowledged violations of RCW 42.17A.235 by failing to timely file one C-3 report and three C-4 reports. 

Based on this information, the PDC has dismissed the complaint in accordance with RCW 42.17A.755(1). 
https://www.pdc.wa.gov/browse/enforcement-cases/40612
40611 09/14/2018 Conner Edwards Elizabeth Hallock Hallock, Elizabeth: Alleged Violation of RCW 42.17A.235, .240 for failure to accurately disclose contributions and expenditures on C-4 reports. (SEP 2018) RCW 42.17A.235, RCW 42.17A.240 Case Closed with Written Warning
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Conner Edwards on September 4, 2018. The Complaint alleged that Elizabeth Hallock (Liz for LD 14 House of Representatives) may have violated RCW 42.17A.235 and .240 for failure to accurately disclose contributions and expenditures on C-4 reports.

Pursuant to WAC 390-37-060(1)(b), Elizabeth Hallock (Liz for LD 14 House of Representatives) will receive a formal written warning concerning failure to accurately file C-4 reports. The formal written warning will include staff’s expectation that Elizabeth Hallock (Liz for LD 14 House of Representatives) will file timely and complete C-4 reports, specifically those occurring during the accelerated reporting schedule prior to and after any election in which her name appears on the ballot. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Based on these facts, staff has determined that in this instance, failure to accurately file C-3 reports disclosing a small percentage of total funds used for the campaign from outside donors and C-4 reports disclosing mostly out-of-pocket expenditures made by the candidate, does not amount to an actual material violation warranting further investigation. The PDC has dismissed this matter in accordance with RCW 42.17A.755(1).
https://www.pdc.wa.gov/browse/enforcement-cases/40611
40607 09/14/2018 Sidney Logan Mary Rollins Rollins, Mary: Alleged Violation of RCW 42.17A.235, .240 for failure to timely and accurately file contribution and expenditure reports. (Sep 2018) RCW 42.17A.235, RCW 42.17A.240 Case Closed with Reminder
Dear Sidney M Logan II: 

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Sidney Logal II on September 14, 2018. The Complaint alleged that Mary Rollins, a candidate seeking the office of Public Utility Commissioner in Snohomish County, may have violated RCW 42.17A.235 and RCW 42.17A.240 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports), disclosing contributions and expenditures undertaken by the Campaign. 

PDC staff reviewed the allegations, the statutes and rules, the initial and amended C-3 and C-4 reports filed by the Campaign, and the responses from Mary Rollins. 

Based on our findings and the following facts, staff has determined that in this instance, the failure to timely and accurately file the contribution and expenditure reports does not amount to a material violation warranting further investigation since: (1) The Mary Rollins Campaign was inexperienced with the campaign finance reporting requirements; (2) The late filed C-4 reports for the 7-Day Pre-Primary Election and 21-Day Pre-Primary Election involved no contributions received and no expenditures made. (3) Mary Rollins took corrective action after being notified of the noncompliance and did not win the election. (4) The total contributions received and expenditures made by the Campaign did not exceed $5,000. 
PDC Staff is reminding Mary Rollins about the importance of the timely disclosure of all contribution and expenditure activities, including the filing fee, and the timely filings of all future PDC Reports. The PDC has closed the matter, and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case. 
https://www.pdc.wa.gov/browse/enforcement-cases/40607
40599 09/14/2018 Washington Senate Democratic Campaign Mainstream Republicans of WA State PAC Mainstream Republicans of WA State PAC: Alleged violations of Chapter 42.17A RCW for failure to identify party affiliation in political advertising, and failure to timely and accurately report independent expenditures and electioneering communications (EY RCW 42.17A.260, RCW 42.17A.255, RCW 42.17A.320, RCW 42.17A.305 Resolved through Statement of Understanding
A complaint was filed against the Mainstream Republicans of Washington, a continuing political committee that has been registered and reporting with the PDC dating back to 1996, alleging violations of RCW 42.17A.260 by failing to timely file Independent Expenditures report (C-6 report) disclosing independent expenditure advertising in support of 2018 candidates; and RCW 42.17A.320 for failing to include the party preferences of Patty Kuderer, a Democratic incumbent State Senator in the 48th Legislative District and a candidate seeking re-election to that office in 2018, and Bill Hirt, Independent, on independent expenditure advertisements sponsored by the Committee.  

Pursuant to WAC 390-37-060(1)(b), the Mainstream Republicans of Washington were formally warned concerning their failure to include the party preference for Patty Kuderer on independent expenditure advertising undertaken in support of Rodney Tom in 2018.  
The PDC received a completed Statement of Understanding (SOU) that was signed by Lila Mowatt, on behalf of Mainstream Republicans of Washington, along with a $925 civil penalty that was assessed in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule).  The $925 penalty resolves the allegations listed in the complaint for failing to timely file C-6 reports, and by completing the SOU, the Mainstream Republicans of Washington acknowledged violations of RCW 42.17A.260 for failing to timely file C-6 reports disclosing 2018 primary and general election independent expenditure activities.
https://www.pdc.wa.gov/browse/enforcement-cases/40599
40597 09/14/2018 Washington Senate Democratic Campaign (Samantha Kersul) Martin McClendon McClendon, Martin: Alleged violation of RCW 42.17A.405 for accepting over-limit contributions from Senate Republican Campaign Committee (EY 19; Sep 18) RCW 42.17A.405 Case Closed with Written Warning
The Public Disclosure Commission (PDC) has completed its initial review of the complaint filed by Samantha Kersul on September 12, 2018. The Complaint alleged that Friends of Marty McClendon may have violated RCW 42.17A.405 for accepting over-limit contributions from Senate Republican Campaign Committee (SRCC).

Based on our findings, staff has determined that in this instance, while the contribution limits from the SRCC were exceeded after the 2018 primary election, the Campaign promptly refunded the over-limit contribution on September 14, 2018, and filed an amended C-3 report that same day.  In addition, staff's review of the C-4 reports filed by the Campaign found that the $3,595.11 in over-limit contributions received from the SRCC were not spent by the Campaign, and therefore did not amount to an actual material violation warranting further investigation.

Pursuant to WAC 390-37-060(1)(b), Friends of Marty McClendon will receive a formal written warning concerning accepting over-limit contributions. The formal written warning will include staff’s expectation that Friends of Marty McClendon properly monitor incoming contributions to stay within the limits of the law. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

https://www.pdc.wa.gov/browse/enforcement-cases/40597
40495 09/11/2018 Norbert Schlecht Marc Boldt Boldt, Marc: Alleged violations of RCW 42.17A.710 for failure to accurately and completely disclose personal and spousal income on F-1 reports. (EY 18; Sep 18) RCW 42.17A.710 Case Closed with Written Warning
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Norbert Schlecht on September 11, 2018. The Complaint alleged that Marc Boldt may have violated RCW 42.17A. for failure to accurately disclose personal and spousal income on a Personal Financial Affairs Statement (F-1 report).

Pursuant to WAC 390-37-060(1)(b), Marc Boldt will receive a formal written warning concerning failure to accurately disclose personal and spousal income on F-1 reports. The formal written warning will include staff’s expectation that Mr. Boldt will file timely and complete F-1 reports, including income from himself, his spouse and all other reportable information required under RCW 42.17A.710, when completing F-1 reports in future years as a candidate or elected or appointed official. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Based on these facts, staff has determined that in this instance, failure to disclose his income and income from his spouse which had no connection to his official duties as chair of the Clark County Council, does not amount to an actual material violation warranting further investigation. The PDC has dismissed this matter in accordance with RCW 42.17A.755(1).
https://www.pdc.wa.gov/browse/enforcement-cases/40495
40480 09/11/2018 Conner Edwards Philip Lloyd No Tax on Jobs: Alleged Violation of RCW 42.17A.240 for filing inaccurate expenditure reports based on information provided to the campaign by vendors or consultants (AUG 2018) RCW 42.17A.240 Request for Technical Correction
The Public Disclosure Commission (PDC) has completed its initial review of the complaint filed by Conner Edwards on August 31, 2018. The Complaint alleged that No Tax on Jobs, a 2018 City of Seattle ballot proposition committee registered with the PDC, may have violated RCW 42.17A.240 for failing to accurately disclose a detailed breakdown for a committee expenditure made to a vendor on the Summary Full Campaign Contribution and Expenditures (C-4 Report)

PDC staff reviewed the allegations, the statutes, rules and reporting requirements, the C-4 report filed by the No Tax on Jobs Committee (Committee), the response from the Committee, and the news article provided in your complaint.  

Based on our findings, staff has determined that in this instance, the No Tax on Jobs Committee failure to provide a detailed and accurate description for expenditures does not amount to a material violation warranting further investigation.

The No Jobs on Tax Committee made a minor error in providing the descriptions for two expenditures that were initially timely disclosed on the June 2018 C-4 report.  The Committee filed an amended June 2018 C-4 report disclosing the updated information one day prior to your complaint being filed, making the necessary technical correction. The corrected information did not materially impact the public interest, since the amended report disclosed fewer political advertisements.

Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1), and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/40480
40372 09/07/2018 James Lazar No on 1631 No on 1631: Alleged Violation of RCW 42.17A.240 & WAC 390-16-037 for failure to provide detailed description of expenditure. (EY 18; Aug 18) WAC 390-16-037, RCW.42.17A.240 Case Closed with Written Warning

The complaint alleged that the No on 1631 Committee Sponsored by Western States Petroleum Association violated RCW 42.17A.240 and WAC 390-16-037 by failing to provide a detailed description of an expenditure made to Amplified Strategies on a Campaign Summary Receipts and Expenditure reports (C-4 report) filed Aug. 10, 2018. 


On September 12, 2018, the Committee filed an amended C-4 for July of 2018. 


Pursuant to WAC to WAC 390-37-060(1) the No on 1631 Committee Sponsored by Western States Petroleum Association will receive a formal written warning concerning the failure to comply with the legal requirement . 

 

The formal written warning will include staff's expectation the No on 1631 Committee Sponsored by Western States Petroleum Association files timely and complete reports for the remainder of the 2018 election cycle, including the complete breakdown for all Committee expenditures. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.


https://www.pdc.wa.gov/browse/enforcement-cases/40372
40302 09/05/2018 Scott Henden Stephen Neupert North Kitsap Fire & Rescue: Alleged Violation of RCW 42.17A.555 for use of public facilities to support a political campaign for a tax increase levy. (AUG 2018) RCW 42.17A.555 Case Closed with Written Warning
The complaint alleged that the North Kitsap Fire and Rescue (the District), a public agency, may have violated RCW 42.17A.555 by using fire district facilities to produce and distribute a newsletter that provided citizens with information in support of Proposition 1, a four-year maintenance and operations levy for North Kitsap Fire and Rescue.
Pursuant to WAC to WAC 390-37-060(1) the District will receive a formal written warning concerning the need for election related information distributed by a public agency using public funds, needs to be an objective and factual presentation of the facts, and to not include language or photographs to provoke an emotional reaction to support a ballot proposition. The formal written warning will include staff's expectation that North Kitsap Fire and Rescue and its staff will follow the PDC guidance in PDC Interpretation #04-02.
The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

The PDC has dismissed this matter in accordance with RCW 42.17A.755(1).

https://www.pdc.wa.gov/browse/enforcement-cases/40302
40298 09/05/2018 Michael Killian Jacqueline Lopez Giddens Giddens, Jacqueline (3): Alleged Violation of RCW 42.17A.235 for failure to timely and accurately file contribution and expenditure reports to disclose a fair booth, signs, and related campaign materials. (AUG 2018) RCW 42.17A.235 Case Closed with Reminder
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Josephine Delvin on August 22, 2018. The Complaint alleged that Jacqueline Lopez Giddens, a first-time candidate seeking the office of County Clerk for Franklin County, may have violated RCW 42.17A.235 for failure to timely and accurately file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports) during the 2018 election campaign.

PDC staff reviewed the allegations, the statutes and rules, the C-3 and C-4 reports filed by the Committee to Elect Jacqueline Lopez Giddens (Campaign), and the responses from Jacqueline Lopez Giddens.

Based on ourfindings and the following facts, staff has determined that in this instance, the failure to timely and accurately file the contribution and expenditure reports does not amount to a material violation warranting further investigation since: (1) Jacqueline Lopez Giddens is a first-time candidate for public office; (2) The Campaign substantially met all other required filing due dates within the previous 12-month period. (3) The late 7-Day Pre-Primary Election C-4 report represented less than two percent of total monetary and in-kind contributions received.

PDC staff is reminding Jackie Lopez Giddens about the importance of the timely disclosure of all contribution and expenditure activities, including the 7-Day Pre-Primary Election C-4 report, and the timely filings of all future PDC reports.

The PDC has closed the matter, and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/40298
40294 09/05/2018 Michael Killian Jacqueline Lopez Giddens Giddens, Jacqueline (2): Alleged Violation of RCW 42.17A.235 for failure to timely and accurately file contribution and expenditure reports for radio ads. RCW 42.17A.235 Case Closed with No Evidence of Violations
Allegation: Violation of RCW 42.17A.235 for failure to timely and accurately file contribution and expenditure reports to disclose radio advertisements
https://www.pdc.wa.gov/browse/enforcement-cases/40294
40151 08/30/2018 William Biery Jon Cooke Jefferson County Republican Central Committee: Alleged Violation of RCW 42.17A.555 for unauthorized use of public facilities to support an auction event for a political campaign. (AUG 2018) RCW 42.17A 555 Case Closed with Written Warning
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by William Biery on August 20, 2018, against the Jefferson County Republican Party, a bona fide county political party organization registered with the PDC as a political committee.  The complaint alleged that the Jefferson County Republican Party (JCRP) may have violated RCW 42.17A.555 by receiving a donated auction item of several tours of the Jefferson County Clock Tower, a public building, from Jon Cooke, a Jefferson County employee with custodial keys to the Clock Tower.  

For your information the JCRP can not violate RCW 42.17A.555, only an elected official, an individual employed by a public agency, or an individual acting in his/her official capacity representing a public agency can violate RCW 42.17A.555.  Based on that fact, the PDC has dismissed this matter against JCRP in accordance with RCW 42.17A.755(1).  

PDC staff reviewed the allegations listed in the complaint, the statutes, rules and PDC Interpretation #04-02 Guidelines for Local Public Agencies in Election Campaigns, the Monetary Contributions report (C-3 report) filed by JCRP, and the response from Mr. Cooke.  

Mr. Cooke, as a Jefferson County employee facilitated the Clock Tower tours and then donated the tour as an auction item to the JCRP.  Since the tours involve a public building, the tours are subject to the prohibitions found in RCW 42.17A.555 against using public facilities to support or oppose a candidate or ballot proposition, which includes a political party organization.  

Pursuant to WAC 390-37-060(1)(b), Jon Cooke will receive a formal written warning concerning his use of public facilities by contributing several tours of the Jefferson County Clock Tower to the Jefferson County Republican Party.  The formal written warning will include staff's expectation that Mr. Cooke will not use public facilities to support or oppose a candidate, political committee, or ballot proposition, including a political party organization in future years in accordance with PDC laws and rules. The Commission will consider this formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules. 

Based on these findings, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1).
https://www.pdc.wa.gov/browse/enforcement-cases/40151
40030 08/28/2018 Conner Edwards III Branches Law III Branches Law: Alleged violations of Chapter 42.17A RCW for failure to timely report independent expenditures and electioneering communications, and for failure to include proper Sponsor ID on newspaper advertising (EY 18; Aug 18) RCW 42.17A.305, RCW 42.17A.260, RCW 42.17A.320, RCW 42.17A.255 Case Closed with Written Warning
The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Connor Edwards on August 27, 2018. The complaint alleged that III Branches Law, a law firm making independent expenditures and electioneering communications supporting four candidates in the 2018 election, and its principal Joan Mell, may have violated RCW 42.17A.255 and RCW 42.17A.260 by failing to timely and accurately file independent expenditures of one hundred dollars or more within five days of the expenditure (C-6 reports) and RCW 42.17A.255, .260 and .305 by failing to electronically submit reports within 24 hours, disclosing electioneering communications with a value of one thousand dollars or more within 60 days before the primary election (C-6).
 
PDC staff reviewed theallegations, the C-6 reports filed by III Branches Law, and the response from attorney Kenneth S. Kagan, PLLC on behalf of the client III Branches Law and its principal Joan Mell. 
  
Pursuant to WAC 390-37-060(1)(b), III Branches Law and its principal, Joan Mell, will receive a formal written warning concerning the failure to timely and accurately file independent expenditures of one hundred dollars or more within five days of the expenditure (C-6 reports) and RCW 42.17A.255, .260 and .305 by failing to electronically submit reports within 24 hours, disclosing electioneering communications with a value of one thousand dollars or more within 60 days before the primary election (C-6). The formal written warning will include staff’s expectation that the law firm file accurate and timely C-6 reports in future elections in which you participate.  The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.
 
Based on these facts, staff has determined that in this instance, no evidence to support finding a material violation warranting a more formal investigation into the complaint or pursuing further enforcement action in this case. The PDC has dismissed this matter in accordance with RCW 42.17A.755(1).
https://www.pdc.wa.gov/browse/enforcement-cases/40030
40029 08/28/2018 Chester Dow James Erb Erb, James (2): Alleged violations of RCW 42.17A.235 and RCW 42.17A.240 for failure to timely report debts and expenditures for mailers (EY 18, Aug 18) RCW.42.17A.240, RCW 42.17A.235 Case Closed with Written Warning
Allegation: Violation of RCW 42.17A.235 and RCW 42.17A.240 for failure to timely and accurately report debts and expenditures for mailed political advertising.
https://www.pdc.wa.gov/browse/enforcement-cases/40029
40026 08/28/2018 Glen Morgan Timm Ormsby Ormsby, Timm (2): Alleged violation of RCW 42.17A.235 and RCW 42.17A.240 for failure to timely and accurately report in-kind contributions from Truman Fund (EY 18, Aug 18) RCW 42.17A.235, RCW.42.17A.240 Request for Technical Correction
The Public Disclosure Commission (PDC) has completed its initial review of the Complaint filed by Glen Morgan on August 23, 2018. The Complaint alleged that Timm Ormsby may have violated RCW 42.17A.235 and RCW 42.17A.240 for failure to timely and accurately report in-kind contributions for legal services from the Harry Truman Fund.
Based on our findings, staff has determined that in this instance, misattribution of in-kind contributions that were timely disclosed does not amount to an actual material violation warranting further investigation.

Timm Ormsby made minor or ministerial errors on required reports, which did not materially impact the public interest. Upon notification of noncompliance, Timm Ormsby timely amended their reports, making the necessary technical corrections.

The PDC has closed the matter, and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/40026
40022 08/28/2018 Glen Morgan Marcus Riccelli Riccelli, Marcus (2): Alleged violation of RCW 42.17A.235 and RCW 42.17A.240 for failure to timely and accurately report in-kind contributions from Truman Fund (EY 18; Aug 18) RCW.42.17A.240, RCW 42.17A.235 Request for Technical Correction
The Public Disclosure Commission (PDC) has completed its initial review of the Complaint filed by Glen Morgan on August 23, 2018. The Complaint alleged that Marcus Riccelli may have violated RCW 42.17A.235 and RCW 42.17A.240 for failure to timely and accurately report in-kind contributions for legal services from the Harry Truman Fund.

Based on our findings, staff has determined that in this instance, misattribution of in-kind contributions that were timely disclosed does not amount to an actual material violation warranting further investigation.

Marcus Riccelli made minor or ministerial errors on required reports, which did not materially impact the public interest. Upon notification of noncompliance, Marcus Riccelli timely amended their reports, making the necessary technical corrections.

The PDC has closed the matter, and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/40022
39967 08/27/2018 Carol Bales Jerry Cooper Cooper, Jerry: Allleged Violation of RCW 42.17A.445 for unauthorized use of campaign funds for personal expenditures or contributions. (August 2018) RCW 42.17A.445 Case Closed with Reminder
The Public Disclosure Commission (PDC) has completed its initial review of the Complaint filed by Carol Bates on August 15, 2018. The Complaint alleged that Jerry C Cooper may have violated RCW 42.17A.445 for unauthorized use of campaign funds for personal expenditures or contributions.

Based on our findings, staff has determined that in this instance, there is no evidence to support a finding of a material violation warranting further investigation. 

PDC staff are reminding Jerry Cooper about the importance of the timely disclosure of all contribution and expenditure activities, including the filing fee, and the timely filings of all future PDC reports. The current use of the scooters for campaign activities is not a violation of RCW 42.17A.445. 
PDC staff have an expectation that the Jerry Cooper campaign will dispose of the scooters by the end of the election using one or more of the ways that are permitted by RCW 42.17A.430.  
PDC Staff are informing Jerry Cooper that the disbursement of surplus funds is reported as an expenditure on Schedule A to the C-4 report. According to WAC 390-16-221, these disposal options also apply to the disposal of items purchased by the campaign. When campaign assets are disposed of, the Campaign must attach an explanation to the C-4 report which would include the date, item description, the name of the recipient for the assets, and the fair market value of the items.
https://www.pdc.wa.gov/browse/enforcement-cases/39967
39963 08/27/2018 Scott Holley Rosemary Kaholokula Kaholokula, Rosemary: Alleged Violation of RCW 42.17A.320 for failure to disclose political advertising to include information for who paid for the ad. (August 2018) RCW 42.17A.320 Case Closed with Reminder
The Public Disclosure Commission (PDC) has completed its initial review of the complaint filed by Robert Holley on August 14, 2018. The complaint alleged that Rosemary Kaholokula, a first-time candidate seeking the office of Superior Court Judge in the Skagit County Superior Court, may have violated RCW 42.17A.320 for failure to properly disclose sponsorship information on political advertisements posted on a Facebook page.

PDC staff reviewed the allegations, the statutes and rules, the Facebook page referenced in the complaint, and the responses from the Committee to Elect Rosemary Kaholokula (Campaign). 

Based on our findings, staff has determined that in this instance, the failure to properly disclose sponsorship identification on Facebook political advertisements does not amount to a material violation warranting further investigation since: 
(1) Rosemary Kaholokula was a first-time candidate for public office in 2018; 
(2) The Campaign was inexperienced with sponsorship identification requirements; 
(3) The C-4 reports for the political advertising expenditures were timely filed; and 
(4) Rosemary Kaholokula promptly corrected the noncompliance after the Campaign received guidance and clarification from PDC staff. 
PDC Staff are reminding Rosemary Kaholokula about the importance of accurately and timely disclosing sponsorship identification on political ads as required by RCW 42.17A.320 and WAC 390-18-030. 

The PDC has closed the matter, and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/39963
39653 08/20/2018 Glen Morgan Sheryl Miller Miller, Sheryl: Alleged Violation of RCW 42.17A.235, .240, .205, .700 for failure to accurately and timely file contributions, expenditures, candidate registration, and personal financial affairs statement. (AUG 2018) RCW 42.17A.205, RCW 42.17A.235, RCW 42.17A.240, RCW 42.17A.700 Violation Found by Commission

At its June 27, 2019 meeting, the Commission found Sheryl Miller violated RCW 42.17A.235 by failing to timely file Monetary Contribution reports (C-3 reports) a Summary Campaign Contribution and Expenditure Reports (C-4 reports) disclosing contributions received and expenditures made during the 2018 campaign, and by failing to facilitate an inspection of the campaign books of account during the eight-day period preceding an election.  In addition, the Commission found Sheryl Miller violated RCW 42.17A.110 and WAC 390-16-043 by failing to provide the campaign books of account to PDC staff pursuant to a subpoena duces tecum being issued by PDC Staff. 

The Commission assessed a total civil penalty of $5,000 of which $4,500 is suspended on the following conditions:  
1. The missing C-3 and C-4 reports are filed with the PDC within 10 days of the date of this Final Order. 
2. The $500 non-suspended portion of the penalty is paid in accordance with a payment plan agreed to between you and PDC Staff within 10 days of the date of this Final Order. 
3. You remain in full compliance with all PDC reporting requirements and are not found to have committed any further violations of Chapter 42.17A RCW or Title 390 WAC within four years of the date of this Final Order. 

https://www.pdc.wa.gov/browse/enforcement-cases/39653
39601 08/20/2018 PDC Staff Nolan Wentz Wentz, Nolan: Alleged violation of WAC 390-16-125 for exceeding the $5,000 contribution and expenditure limitations of the Mini Reporting option without receiving PDC approval (EY 18; Aug 18) RCW 42.17A.235, WAC 390-16-125 Resolved through Statement of Understanding
This is a PDC staff generated complaint alleging that Nolan Wentz, a first-time candidate for Yakima County Sheriff in 2018, violated WAC 390-16-125 by exceeding the $5,000 contribution and expenditure limitations of the Mini Reporting option. 

Candidates under the Mini Reporting Option are prohibited from accepting contributions (monetary and in-kind) and making expenditures in excess of the $5,000 limit, without properly changing reporting options and filing the required reports in accordance with RCW 42.17A.205, .235, and .240 and PDC rules.  Mr. Wentz exceeded the limitations of the Mini Reporting option prior to properly changing to the Full Reporting option, and his request to change options was denied.  The attached letter to Mr. Wentz denying his request to change options, served as the basis for the staff generated complaint.

Mr. Wentz completed a Statement of Understanding (SOU) acknowledging violations of RCW 42.17A , and paid a $600 civil penalty in accordance with WAC 390-37-143, based on the mitigating facts that Mr. Wentz was: (1) a first-time candidate for public office; (2) used personal funds to contribute $6,000 (+) of the $9,779 in total contributions his Campaign received; and (3) the other candidates running for Yakima County Sheriff were under the Full Reporting option.  

By completing these steps, Mr. Wentz has satisfied the requirements set forth in WAC 390-16-125 and PDC staff has approved his request to change to the Full Reporting Option, with the understanding that his Campaign is expected to timely file accurate C-3 and C-4 reports for the remainder of the 2018 election cycle.  

https://www.pdc.wa.gov/browse/enforcement-cases/39601
39554 08/17/2018 Fred Brown Vicki Fosback Stevens County Prosecutor's Office - Fosback, Vicki: Alleged Violation of RCW 42.17A.555 for using social media to support a political committee during public agency hours. (July 2018) RCW 42.17A 555 Case Closed with No Evidence of Violations
The Public Disclosure Commission (PDC) has completed its initial review of the complaint filed by Fred Brown III on July 2, 2018. Your complaint alleged that Vicki Fosback may have violated RCW 42.17A.555 for using social media to support a political committee during public agency hours. 

Based on our findings, staff has determined that in this instance regarding the use of public facilities to support a political campaign, there is no evidence to support a finding of a material violation warranting further investigation.

The PDC has closed the matter, and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case. 
https://www.pdc.wa.gov/browse/enforcement-cases/39554
39294 08/15/2018 Fred Brown III Nancy Perow Krajcik Stevens County Sherrif's Office - Krajick, Nancy: Alleged Violation of RCW 42.17A.555 for using social media to support a political committee. (July 2018) RCW 42.17A 555 Case Closed with No Evidence of Violations
The Public Disclosure Commission (PDC) has completed its initial review of the complaint filed by Fred Brown III on July 2, 2018. Your complaint alleged that Nancy Krajcik may have violated RCW 42.17A.555 by posting comments on social media to support a political campaign during public agency hours. 

Based on our findings, staff has determined that in this instance regarding the use of public facilities to support a political campaign, there is no evidence to support a finding of a material violation warranting further investigation.

The PDC has closed the matter, and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case. 
https://www.pdc.wa.gov/browse/enforcement-cases/39294
39282 08/15/2018 Anthony Wallace Carol Frazey Frazey, Carol: Alleged violations of RCW 42.17A.235 for failure to timely & accurately report contributions & expenditures, keep current books readily available for public inspection & make a timely appointment for public inspection. (EY 18; Aug 18) RCW 42.17A.235 Case Closed with Reminder

The complaint alleged Carol Frazey violated RCW 42.17A.235 by: (1) failing to timely and accurately file Campaign Summary Receipts and Expenditure reports (C-4 reports); (2) failing to maintain campaign books of account and make those records available for public inspection within 10 days of an election.


Carol Frazey is a first-time candidate for public office in 2018, and her campaign was comprised of all volunteers, with no prior PDC violations. The Campaign made a good faith effort to comply with the PDC statutes, rules and reporting requirements, and timely filed the necessary amended reports when requested by PDC staff. In addition, Ms. Frazey facilitated the initial records inspection with the required 48 hours.


Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1). Ms. Frazey is reminded about the importance of filing accurate campaign finance reports for the remainder of the 2018 election cycle, including providing the proper breakdown and descriptions for expenditures, and complying with the public records inspection requirements.

https://www.pdc.wa.gov/browse/enforcement-cases/39282
39265 08/14/2018 Shayna Daitch Mychal Schwartz Schwartz, Mychal: Alleged violations of RCW 42,17A.235, .240 & .320 for failure to accurately & timely report contributions & expenditures, identify sponsor in political ads & timely report expenditures, in-kind contributions or debts. (EY 18; Aug 18) RCW.42.17A.240, RCW 42.17A.235, RCW 42.17A.320, WAC 390-16-037 Case Closed with Written Warning
The Public Disclosure Commission (PDC) has completed its initial review of the complaint filed by Shayna Daitch on August 6, 2018. The complaint alleged that Mychal Schwartz may have violated RCW 42,17A.235, .240 & .320 for failure to accurately & timely report contributions & expenditures, identify sponsor in political ads & timely report expenditures, in-kind contributions or debts.
Based on our findings, staff has determined that in this instance, failure to timely file reports of contributions and expenditures, and failure to provide accurate and complete sponsor ID on political advertising, do not amount to actual material violations warranting further investigation.

Pursuant to WAC 390-37-060(1)(b), Mychal Schwartz will receive a formal written warning concerning failure to timely file reports of contributions and expenditures, and failure to provide accurate and complete sponsor ID on political advertising. The formal written warning will include staff’s expectation that Mychal Schwartz timely and accurately disclose contributions, expenditures, and political advertising in the future. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

The PDC has closed the matter, and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/39265
39244 08/14/2018 Washington Senate Democratic Campaign Senate Republican Campaign Committee Senate Republican Campaign Committee: Alleged violation of RCW 42.17A.240 for failure to accurately report contributions made for coordinated advertising expenditures (EY 18, Aug 18) RCW.42.17A.240, WAC 390-05-210 Investigation of Possible Violation
  • Allegation: Violation of RCW 42.17A.240 for failure to accurately report contributions made to WA Forward for coordinated advertising expenditures.
https://www.pdc.wa.gov/browse/enforcement-cases/39244
39242 08/14/2018 Washington Senate Democratic Campaign The Leadership Council The Leadership Council: Alleged violation of RCW 42.17A.240 for failure to accurately report contributions made for coordinated advertising expenditures (EY 18, Aug 18) RCW.42.17A.240, WAC 390-05-210 Investigation of Possible Violation
  • Allegation: Violation of RCW 42.17A.240 for failure to accurately report contributions made to WA Forward as part of a coordinated advertising expenditure.
https://www.pdc.wa.gov/browse/enforcement-cases/39242
39241 08/14/2018 Washington Senate Democratic Campaign WA Forward WA Forward (1): Alleged violations of RCW 42.17A.235 and RCW 42.17A.240 for failure to report coordinated advertising expenditures, and RCW 42.17A.320 for failure to include party preference in advertising (EY 18, Aug 18) RCW.42.17A.240, RCW 42.17A.320, RCW 42.17A.235, WAC 390-05-210 Investigation of Possible Violation
  • Allegation One: Violation of RCW 42.17A.235 and RCW 42.17A.240 for failure to accurately and timely report contributions and expenditures for coordinated advertising campaigns.
  • Allegation Two: Violation of RCW 42.17A.320 for failure to include party preference for partisan candidates in political advertising.
https://www.pdc.wa.gov/browse/enforcement-cases/39241
39238 08/14/2018 Dennis Olson Indivisible Washington's 8th District Indivisible Washington's 8th District: Alleged violations of Chapter 42.17A RCW for failure to register and report as a political committee, and failure to report independent expenditures or electioneering communications (EY 18, Aug 18) RCW 42.17A.205, RCW 42.17A.235, RCW 42.17A.255, RCW 42.17A.260, RCW 42.17A.305, RCW.42.17A.240 No Jurisdiction
The Public Disclosure Commission (PDC) has completed its initial review of the complaint filed by Dennis Olson on 8/7/18. The complaint alleged that See Attachment may have violated Chapter 42.17A RCW for failure to register and report as a political committee, and failure to report independent expenditures or electioneering communications.

PDC staff reviewed your allegations, and as a result of staff’s initial review, we found the following:

Based on these initial findings, staff has determined that in this instance, the PDC does not have jurisdiction over the alleged violations.

The PDC has closed the matter,and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/39238
39237 08/14/2018 Dennis Olson Indivisible Seattle Indivisible Seattle: Alleged violations of Chapter 42.17A RCW for failure to register and report as a political committee, and failure to report independent expenditures or electioneering communications (EY 18, Aug 18) RCW 42.17A.205, RCW 42.17A.235, RCW 42.17A.255, RCW 42.17A.260, RCW 42.17A.305, RCW.42.17A.240 Case Closed with No Evidence of Violations
  • Allegation One: Violation of RCW 42.17A.205 for failure to register as a political committee.
  • Allegation Two: Violation of RCW 42.17A.235 and RCW 42.17A.240 for failure to report contributions and expenditures.
  • Allegation Three: Violation of RCW 42.17A.255, RCW 42.17A.260, and RCW 42.17A.305 for failure to report independent expenditures or electioneering communications.
https://www.pdc.wa.gov/browse/enforcement-cases/39237
39236 08/14/2018 Dennis Olson Indivisible Washington Indivisible Washington: Alleged violations of Chapter 42.17A RCW for failure to register and report as a political committee, and failure to report independent expenditures or electioneering communications. (EY 18, Aug 18) RCW 42.17A.205, RCW 42.17A.235, RCW 42.17A.255, RCW 42.17A.260, RCW 42.17A.305, RCW.42.17A.240 Case Closed with No Evidence of Violations
The Public Disclosure Commission (PDC) has completed its initial review of the complaint filed by Dennis Olson on 8/7/18. The Complaint alleged that Indivisible Washington may have violated Chapter 42.17A RCW for failure to register and report as a political committee, and failure to report independent expenditures or electioneering communications.

Based on our findings, staff has determined that in this instance, no evidence supports a finding of an actual material violation warranting further investigation.

The PDC has closed the matter, and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/39236
39227 08/14/2018 Justin Riley Christopher Thobaben Thobaben, Christopher: Alleged violations of RCW 42.17A.235 & .320 for failure to timely and accurately report campaign expenditures and identify sponsor on political signs. (EY 18; Aug 18) RCW 42.17A.320, RCW 42.17A.235 Case Closed with Reminder

The complaint alleged that Christopher Thobaben, a candidate for State Representative in the 18th Legislative District in 2018, may have violated; (1) RCW 42.17A.235 and RCW 42.17A.240 by failing to timely and accurately file Summary Full Reporting of Contribution and Expenditure Reports (C-4 report) disclosing contribution and expenditure activities, including in-kind contributions, debts or other obligations; and (2) RCW 42.17A320 by failing to include the proper sponsor identification on political advertising sponsored by his Campaign.



In his response, Mr. Thobaben stated that he had inadvertently failed to identify his participation in the August 2018 primary election inside of his ORCA (Online Reporting of Campaign Activity) dataset and therefore missed the deadline for July reports. In addition, he stated that he was in transit, returning from annual training with the Marine Corps Reserve when the filing deadline for the 21-day and 7-day pre-primary C-4 reports passed and that the reports were filed immediately upon receiving notification regarding the missing reports. Mr. Thobaben confirmed that the Campaign yard signs, clothing and bumper stickers were exempt from the sponsor identification requirements identified in WAC 390-18-030.


Based on the fact that Christopher Thobaben is a first-time candidate for public office, he has no prior PDC violations and took quick corrective action to address the non-compliance issues identified in the complaint, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1). Mr. Thobaben will be reminded about the importance of complying with the reporting requirements for a candidate under the Full Reporting option to timely file C-3 and C-4 reports disclosing contributions and expenditures, including in-kind contributions, debts or other obligations, undertaken by his Campaign, in accordance with RCW 42.17A.235 and ,240 for the duration of the 2018 election cycle.

https://www.pdc.wa.gov/browse/enforcement-cases/39227
39225 08/14/2018 David Johnson Daniel Franklin Indivisible Kirkland: Alleged violation of RCW 42.17A.205 & .305 for failure to timely register a political committee and report independent or electioneering communication expenditure. (EY 18; Aug 18) RCW 42.17A.205, RCW 42.17A.305 Case Closed with Reminder
  • Allegation One: Alleged violation of RCW 42.17A.205 for failure to timely report Indivisible Kirkland as a political committee 
  • Allegation Two: Alleged violation of RCW 42.17A.305 for failure to timely report independent expenditure or electioneering communication expenditure (e.g. website)
https://www.pdc.wa.gov/browse/enforcement-cases/39225
39203 08/13/2018 Carollynn Zimmers Rebecca Erickson Erickson, Rebecca: Alleged violation of RCW 42.17A.555 by using public office or agency facilities in a campaign. (EY 18; Aug 18) RCW 42.17A.555 Case Closed with No Evidence of Violations
  • Allegation: Alleged violation of RCW 42.17A.555 for using public office or agency facilities to assist an election campaign
https://www.pdc.wa.gov/browse/enforcement-cases/39203
39199 08/13/2018 Marcus Griffith Adam Shetler Shetler, Adam (2): Alleged violations of RCW 42.17A.235, .205 & .710 for failure to make an appointment for public inspection and file accurate & complete candidate registration & financial affairs forms. (EY 18; Aug 18) RCW 42.17A.205, RCW 42.17A.235, RCW 42.17A.710 Case Closed with Written Warning
  • Allegation One: Alleged violation of RCW 42.17A.235 by failing to make an appointment for public inspection within ten days of an election 
  • Allegation Two: Alleged violation of RCW 42.17A.205 for failure to accurately & completely report information required on C-1 Candidate Registration form 
  • Allegation Three: Alleged violation of RCW 42.17A.710 for failure to accurately & completely report information required on candidate’s F-1 Personal Financial Affairs Statement form
https://www.pdc.wa.gov/browse/enforcement-cases/39199
39188 08/13/2018 PDC Staff Jennifer Tyler Tyler, Jennifer: Alleged violations of RCW 42.17A.205 & .700 for failure to timely file C-1 Candidate Registration & F-1 Statement of Personal Financial Affairs. (Group Enforcement 18) RCW 42.17A.700, RCW 42.17A.205 Violation Found by Commission
Pursuant to the brief enforcement hearing (brief adjudicative proceeding) notice sent to Jennifer Tyler on August 16, 2018, A brief adjudicative proceeding was held on September 24, 2018, in Room 206, Evergreen Plaza Building, 711 Capitol Way, Olympia, Washington, to consider whether the Respondent violated RCW 42.17A.205 by failing to file a Candidate Registration (C-1 report) as a candidate for the 2018 election cycle, and RCW 42.17A.700 by failing to file a Personal Statement of Financial Affairs (F-1 report) as a candidate for the 20 l 8 election cycle, disclosing campaign information and financial activities for the previous 12 calendar months. Both reports were due to be filed within two weeks of declaring candidacy, or not later than June 1, 2018,

The hearing was held in accordance with Chapters 34.05 RCW and 42.17 A RCW and Chapter 390-37 WAC. Commission Chair Anne Levinson was the Presiding Officer. The Commission staff was represented by Tabatha Blacksmith, Compliance Coordinator.

At that hearing, Jennifer Tyler was found in violation of RCW 42.17 A.205 and
RC W 4 2. 17 A. 700 and assessed a penalty of $5 00, that Commission staff requested be reconsidered by the Commission Chair, due to new information not available at the time of the original hearing.

Having considered the evidence, the Presiding Officer finds as follows:

1. This matter was duly and properly convened and all jurisdictional, substantive, and procedural requirements have been satisfied.
2. The Respondent violated RCW 42.17 A.205 and RCW 42.17 A.700 by failing to file the C-1 and F-1 reports within two weeks of declaring candidacy or by June 1, 2018.

IT IS HEREBY ORDERED that the Respondent is assessed a civil penalty of $300, in accordance with the C-1 and F-1 penalty schedule set forth in WAC 390-37-143, payable within 30 days of the date of the Order. It is further ordered that the Respondent:
1. Pay the $300 civil penalty within 30 days of the date of this Order.

In the event the Respondent fails to pay the $300 civil penalty within 30 days of the date of the Order, PDC staff is directed to refer the matter to the Department of Enterprise Services (DES) for collection of the amount owed.

https://www.pdc.wa.gov/browse/enforcement-cases/39188
39180 08/13/2018 Carl Olson Our Olympic Communities Enterprise Washington Our Olympic Communities Enterprise WA: Alleged violations of RCW 42.17A.235, .240, .255, .260 & .305 & WAC 390-16-037 for failure to accurately report expenditures & political advertising and timely report contributions. (EY 18; Aug 18) RCW 42.17A.255, RCW 42.17A.305, RCW.42.17A.240, WAC 390-16-037, RCW 42.17A.260, RCW 42.17A.235 Case Closed with Written Warning
The Public Disclosure Commission (PDC) has completed its initial review of the complaint filed by Carl Olson on August 2, 2018. The complaint alleged that Our Olympic Communities Enterprise WA may have violated RCW 42.17A.235, .240, .255, .260 & .305 & WAC 390-16-037 for failure to accurately report expenditures & political advertising and timely report contributions.

Based on our findings, staff has determined that in this instance, failure to timely report contributions and accurately break down expenditure details do not amount to actual material violations warranting further investigation.

Pursuant to WAC 390-37-060(1)(b), Our Olympic Communities Enterprise WA will receive a formal written warning concerning failure to timely report contributions and accurately break down expenditure details. The formal written warning will include staff’s expectation that Our Olympic Communities Enterprise WA timely and completely report contribution and expenditure activity in the future. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

The PDC has closed the matter, and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/39180
39159 08/13/2018 Sarah Norman-Elbaum Citizens for Progress Enterprise Washington Citizens for Progress Enterprise Washington: Alleged violations of RCW 42.17A.240, WAC 390-16-037 & RCW 42.17A.255, .260 or .305 for failure to accurately report expenditures & timely report political advertising. (EY 18; Aug 18) RCW 42.17A.305, RCW.42.17A.240, wac 390-16-205, WAC 390-16-037 Violation Found by Commission

On August 2, 2018, Sarah Norman-Elbaum filed a complaint alleging that Citizens for Progress Enterprise Washington was hiding from the public its support for Wendy Weiker by failing to disclose on C-4 expenditure reports detailed information about its political advertising expenditures, including the names of candidates being supported.  After conducting a preliminary review and assessment of the complaint, PDC staff opened a formal investigation on October 17, 2019, and held an Initial Hearing (Case Status Review Hearing) on October 19, 2018, pursuant to RCW 42.17A.755, and WACs 390-37-060 and 390-37-071.   

After conducting a formal investigation, staff scheduled an enforcement hearing that was held March 28, 2019.  The hearing concerned allegations that Citizens for Progress Enterprise Washington violated RCW 42.17A.240 by failing to adequately describe the purpose of expenditures on C-4 reports as required by RCW 42.17A.240, WAC 390-16-037 and WAC 390-16-205, and RCW 42.17A.305 by failing to timely file C-6 reports of electioneering communications within 24 hours of presenting or mailing the advertisements and communications to the public.  The parties jointly submitted a signed Stipulation as to Facts, Violations and Penalty.  The Commission accepted the Stipulation, but proposed that the non-suspended portion of the penalty be paid within 30 days rather than within 90 days.  This change was accepted by the parties.  By accepting the Stipulation, the Commission found that Citizens for Progress Enterprise Washington violated RCW 42.17A.240 and RCW 42.17A.305 as described above. 

The Commission accepted the amended Stipulation and ordered that the Respondent is assessed a total civil penalty of $21,000 with $10,500 suspended on the following conditions: (1) that the Respondent is not found to have committed any further violations of RCW 42.17A or WAC 390 within four years of the date of the final order in this matter. The suspended penalty shall not be assessed based upon any remediable violation, minor violation, or error classified by the commission as appropriate to address by a technical correction. (2) that the Respondent files amended C-4 reports that are in full compliance with the disclosure requirements of RCW 42.17A.240, WAC 390-16-037, and WAC 390-16-205, within thirty days from the date of the final order, and is in compliance with all reporting requirements. (3) that the Respondent pays the non-suspended portion of the penalty ($10,500) within thirty days from the date of the final order.

https://www.pdc.wa.gov/browse/enforcement-cases/39159
39125 08/10/2018 Joe Yates Truth for Washington Truth for Washington (2): Alleged violation of RCW 42.17A.270 for failure to report earmarked contributions for Candidate Caldier opposition ad purchased on behalf of Candidate Boss campaign. (EY 18; Jul 18) RCW 42.17A.270 Case Closed with No Evidence of Violations
  • Allegation: Alleged violation of RCW 42.17A.270 for failure to report earmarked contributions for Candidate Caldier opposition ad purchased on behalf of Candidate Boss campaign.
https://www.pdc.wa.gov/browse/enforcement-cases/39125
39123 08/10/2018 Joe Yates Working Families of King County Working Families of King County: Alleged violation of RCW 42.17A.270 for failure to report earmarked contributions for Candidate Caldier opposition ad purchased on behalf of Candidate Boss campaign. (EY 18; Jul 18) RCW 42.17A.270 Case Closed with No Evidence of Violations
  • Allegation: Alleged violation of RCW 42.17A.270 for failure to report earmarked contributions for Candidate Caldier opposition ad purchased on behalf of Candidate Boss campaign
https://www.pdc.wa.gov/browse/enforcement-cases/39123
39122 08/10/2018 Joe Yates Marlyn Jensen Jensen, Marlyn: Alleged violation of RCW 42.17A.405(2) for making over-limit contribution to Candidate Boss campaign via Working Families of King County & Truth for Washington (EY 18; Jul 18) RCW 42.17A.405 Case Closed with No Evidence of Violations
The Public Disclosure Commission (PDC) has completed its review of the three complaints filed by Joe Yates on August 10, 2018, against two political committees, Truth for Washington (PDC Case 39125), and Working Families of King County (PDC Case 39123), and Marlyn Jensen (PDC Case 39122) an individual. 

The complaints alleged that: (1) Truth for Washington (TFW), and Working Families of King County (WFKC) may have violated RCW 42.17A.270 by receiving and spending earmarked contributions from Marylyn Jensen designated to benefit Randy Boss, a 2018 candidate for State Representative in the 26th Legislative District; and (2) Marlyn Jensen may have violated RCW 42.17A.405(2) by exceeding the contribution limits to Randy Boss by earmarking contributions through TFW and WFKC for independent expenditures made in opposition of Michelle Caldier, Randy Boss’s opponent. 
For your information, in order to more efficiently use PDC resources, the three complaints you filed have been combined into one letter. PDC staff reviewed the statutes, rules and reporting requirements, the complaint and the exhibits submitted including all other pertinent supplemental documentation and materials, campaign finance reports filed by TFW and WFKC, and the responses from Ms. Jensen, and the treasurer for TFW and WFKC. 

Staff reviewed the C-1 reports filed by Randy Boss for 2018 and dating back to 1996, and Ms. Jensen was never disclosed as being a committee officer or principal decision maker for any of his campaigns. As noted in the letter, Ms. Jensen’s contributions to WFKC did not make her a sponsor of the committee, and Ms. Jensen has never been listed as a Committee officer or principal decisionmaker for either TFW or WFKC, nor has she been paid any committee funds as either a consultant or vendor.

Based on our findings, there was no evidence provided or found by staff indicating that Ms. Jensen earmarked, instructed or designated her contributions made to WFKC, were to be passed through to TFW and spent or otherwise used to produce independent expenditure advertisements in opposition to candidate Caldier, on behalf of the Randy Boss Campaign. 
The PDC has dismissed the complaints against Marlyn Jensen, Truth for Washington, and the Working Families of King County in accordance with RCW 42.17A.755(1).
https://www.pdc.wa.gov/browse/enforcement-cases/39122
39112 08/10/2018 Dan Clark, et al. Clark Leadership Clark Leadership: Alleged violation of RCW 42.17A.235 and Emergency Rule WAC 390-16-043 for failure to properly allow for inspection of books of account. (EY 18, Aug 18) RCW 42.17A.235, WAC 390-16-043 Case Closed with No Evidence of Violations
The Public Disclosure Commission (PDC) has completed its initial review of the complaints filed by Daniel Clark, Kevin VanGelder, Frank Decker, Kalup Veneman, and Richard Colwell between August 17 and August 14, 2018. The complaints alleged that Clark Leadership PAC may have violated RCW 42.17A.235 and Emergency Rule WAC 390-16-043 for failure to properly allow for inspection of books of account.

Based on our initial findings, staff has determined that in this instance, no evidence supports a finding of a material violation warranting further investigation.The PDC has closed the matter,and will not be conducting a more formal investigation into your complaint or pursuing further enforcement action in this case.
https://www.pdc.wa.gov/browse/enforcement-cases/39112
39060 08/09/2018 PDC Staff Norbert Schlecht Norbert Schlecht: Alleged violations of RCW 42.17A.205 & .700 for failure to timely file C-1 Candidate Registration & F-1 Statement of Personal Financial Affairs. (Group Enforcement 18) RCW 42.17A.700, RCW 42.17A.205 Violation Found by Commission
Pursuant to the brief enforcement hearing (brief adjudicative proceeding) notice sent to NORBERT SCHLECHT on August 16, 2018, A brief adjudicative proceeding was held on September 24, 2018, in Room 206, Evergreen Plaza Building, 711 Capitol Way, Olympia, Washington, to consider whether the Respondent violated RCW 42.17A.205 by failing to file a Candidate Registration (C-1 report) as a candidate for the 2018 election cycle, and RCW 42.17A.700 by failing to file a Personal Statement of Financial Affairs (F-1 report) as a candidate for the 2018 election cycle, disclosing campaign information and financial activities for the previous 12 calendar months. Both reports were due to be filed within two weeks of declaring candidacy, or not later than June 1, 2018, 
The hearing was held in accordance with Chapters 34.05 RCW and 42.17A RCW and Chapter 390-37 WAC. Commission Chair Anne Levinson was the Presiding Officer. The Commission staff was represented by Tabatha Blacksmith, Compliance Coordinator. The Respondent did not participate in the hearing or submit any written materials. 
Having considered the evidence, the Presiding Officer finds as follows: 

1. This matter was duly and properly convened and all jurisdictional, substantive, and procedural requirements have been satisfied. 
2. The Respondent violated RCW 42.17A.205 and RCW 42.17A.700 by failing to file the C-1 and F-1 reports within two weeks of declaring candidacy or by June 1, 2018.

IT IS HEREBY ORDERED that the Respondent is assessed a civil penalty of $500, in accordance with the C-1 and F-1 penalty schedule set forth in WAC 390-37-143, payable within 30 days of the date of the Order. 
It is further ordered that the Respondent: 
1. Pay the $500 civil penalty within 30 days of the date of this Order. 
2. “Cease and desist” from failing to file the required PDC reports in accordance with RCW 42.17A.755(4). 
3. File the missing C-1 and F-1 reports within 30 days of the date of this Order. 
In the event the Respondent fails to pay the $500 civil penalty within 30 days of the date of the Order, PDC staff is directed to refer the matter to the Department of Enterprise Services (DES) for collection of the amount owed.

https://www.pdc.wa.gov/browse/enforcement-cases/39060
39056 08/09/2018 PDC Staff Kristina Perez Kristina Perez: Alleged violations of RCW 42.17A.205 & .700 for failure to timely file C-1 Candidate Registration & F-1 Statement of Personal Financial Affairs. (Group Enforcement 18) RCW 42.17A.700, RCW 42.17A.205 Resolved through Statement of Understanding
By September 19, 2018, the PDC received Kristina Perez's missing Personal Statement of Financial Affairs (F-1 report) and Candidate Registration (C-1 report); signed Statement of Understanding acknowledging a violation of RCW 42.17A.205 for failure to timely file C-1 report, and RCW 42.17A.700 for failure to timely file the F-1 report not later than June 1, 2018; and a $200 payment of a civil penalty.

Having received all three items prior to the Brief Adjudicative Proceeding of September 24, 2018, the PDC closed this case without pursuing further enforcement or fines.
https://www.pdc.wa.gov/browse/enforcement-cases/39056
39055 08/09/2018 PDC Staff Daniel McGill Daniel McGill: Alleged violations of RCW 42.17A.205 & .700 for failure to timely file C-1 Candidate Registration & F-1 Statement of Personal Financial Affairs. (Group Enforcement 18) RCW 42.17A.205, RCW 42.17A.700 Violation Found by Commission