Jepperson, Christina: Alleged violation of RCW 42.17A.235 and .240 for failure to timely and accurately report contributions and expenditures. (SEPT'23, EY'23)

Case

#142837

Respondent

Christina Jepperson

Complainant

Lael Johnson

Description

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

Based on staff’s review, we found the following:

• On May 19, 2023, Christina Jepperson submitted a Candidate Registration (C-1 report) declaring her candidacy in the 2023 election for School Director Position 2, of the Sedro Woolley School District 101, selecting the “Mini Reporting” option and listing herself as the Treasurer and the only officer.
• RCW 42.17A.235 describes the required filing deadlines for disclosure of campaign finance activities.  In addition, it requires committees to maintain books of accounts and records to verify the campaign activities.
• RCW 42.17A.240 describes the required content of each campaign report.
• WAC 390-16-105 states, in part , that a candidate committee is not required to comply with the provisions of RCW 42.17A.225 through 42.17A.240, except as otherwise prescribed, if the committee selects the mini reporting option on its registration and neither aggregate contributions nor aggregate expenditures exceed the amount of the candidate’s filing fee plus a sum not to exceed $7000 and does not receive more than $500 in contributions from any one donor. The candidate may donate more than $500 to his or her own election campaign if they don’t exceed the $7000 limit.
• On August 15 and September 1, 2023, Ms. Jepperson filed several C-4, and a C-3 reports showing contributions received and expenditures occurring in May, June, July, and August of 2023. The complaint alleged that the 2023 Jepperson Campaign did not provide required information about expenditures and that reports for contributions and expenditures were filed late.
• In their response to the complaint, Ms. Jepperson stated “I believe as a mini-filer I do not need to even submit or file because my total donations and total spent is so low. I only entered them to try and be transparent as possible with the public.” 
• After finding that the 2023 Jepperson Campaign had filed incomplete C-3 and C-4 reports, albeit not required for committees registered under the “Mini Reporting” option, staff requested the Campaign correct their reporting as part of the resolution to the complaint.  Ms. Jepperson worked with PDC filer assistance staff to amend the reported information.
• The Respondent does not have other warnings or violations of PDC requirements.

The 2023 Jepperson Campaign appears to have remained under the mini reporting thresholds as required by statute.  Ms. Jepperson is her own treasurer which likely contributed to their lack of knowledge about reporting and disclosure requirements.  Staff found no evidence that the Campaign filed incomplete reports to purposely confuse or conceal information from the public.

Based on our findings staff has determined that, in this instance, failure to accurately file C-3 and C-4 reports does not amount to a finding of a violation that calls for further investigation.

PDC staff did remind Ms. Jepperson about the importance of following filing requirements per the filing option chosen when registering their campaign committee with the PDC.  Staff expects, in the future, that Ms. Jepperson will timely and accurately file all required reports of contributions and expenditures if the campaign registers under the “Full Reporting” option.  If the campaign registers under the “Mini Reporting” option and chooses to file reports, there is still an obligation to file those reports accurately. As well, regardless of the reporting option registered under, it is the candidate’s responsibility to maintain books of account for all campaign activity.

Based on this information, the PDC finds that no further action necessary and has dismissed this matter per RCW 42.17A.755(1).

Disposition

Case Closed with Reminder

Date Opened

October 02, 2023

Areas of Law

RCW 42.17A.235, RCW 42.17A.240

Documents

• 142837 Jepperson Christina Complaint.pdf
• 142837 Jepperson_Christina Complaint Return Letter (combined).pdf
• 142837 Jepperson_Christina Response.pdf