Let's Go Washington (Sponsored by Brian Heywood)(2): a 2022-2024 PAC: Alleged violations of RCW 42.17A.320 and .350 by failing to properly list the Top 5 and Top 3 contributors to political advertising.(EY24 OCT24)

Case

#160530

Respondent

Let's Go Washington

Complainant

Abby Lawlor

Description

• Allegation: Violations of RCW 42.17A.320 and .350 by failing to properly list the Top 5 and Top 3 contributors to political advertising.

The complaint alleged that Let’s Go Washington Sponsored by Brian Heywood (Let’s Go Washington or LGW) may have violated RCW 42.17A.320(6) and RCW 42.17A.350 by failing to include required sponsor identification on political advertising.

Background & Findings

• Let’s Go Washington Sponsored by Brian Heywood is a political committee that was formed to support several initiatives to the Legislature during 2023, three of which appeared on the 2024 general election ballot. LGW also supported a 2024 initiative to the people concerning the use of natural gas that appeared on the 2024 ballot.
• Let’s Go Washington sponsored three ads supporting the committee’s four initiatives that were posted on the committee’s YouTube page. The ads were named, “Pinocchio,” “Supposed to Help,” and “Need All Four.” The “Pinocchio” ad also aired on Fox 13 as a TV ad during the Seahawks - 49ers Game on October 11, 2024. The sponsor identification read,

“PAID FOR BY LET’S GO WASHINGTON SPONSORED BY BRIAN HEYWOOD. TOP FIVE CONTRIBUTORS: BRIAN HEYWOOD, BIAW MEMBER SERVICES CORPORATION, STEVE GORDON, LAWRENCE HUGHES, KEMPER HOLDINGS LLC.”

• The complaint alleged that the Top 5 Contributors should have included Main Street Matters to Washington, a political committee that contributed $1,400,000 during the 12 months before the ads were presented to the public, instead of Brian Heywood who the complaint alleged was not a Top 5 Contributor. The complaint further alleged that because Mainstreet Matters to Washington was a political committee, its Top 3 non-political committee contributors also needed to be identified in the political ads but were not identified.
• However, during the 12 months before the political ads at issue were presented to the public, Brian Heywood made monetary contributions that were loans to Let’s Go Washington totaling $1,456,000, making Mr. Heywood one of the Top 5 Contributors.
• In addition, the Respondent stated that the contributions to LGW from Mainstreet Matters to Washington were restricted by the contributor from being used for any political advertising supporting any ballot measure other than advertising exclusively supporting I-2066, concerning the use of natural gas. Thus, its contributions could not be used for the ads cited in the complaint.
• Because none of the Top 5 Contributors for the advertisements cited in the complaint were political committees, the requirement to list the Top 3 non-political committee contributors to a Top 5 Contributor is not relevant.

Disposition

Case Closed with No Evidence of Violations

Date Opened

October 14, 2024

Areas of Law

RCW 42.17A.320, RCW 42.17A.350

Documents

• 160530 Case Closure Letter Respondent-Complainant.pdf
• 160530 Let's Go Washington Complaint.pdf
• 160530 Response to Complaint.pdf