Shaina Langley: Alleged violation of RCW 42.17A.405 for accepting overlimit contributions (EY24 JUN25)
Case
#174130
Respondent
Shaina Langley
Complainant
Megan Chandler
Description
The Public Disclosure Commission (PDC) completed its review of the complaint filed by Megan Chandler on June 3, 2025. The complaint alleged a violation of RCW 42.17A.405 for accepting an overlimit contribution in violation of Chapter 42.17A. RCW.
Applicable Laws and Rules
RCW 42.17A.405(2) limits candidates to receiving $1,200 in contributions from any one individual or per person for each election in which the candidate’s name appears on the ballot.
Background and Findings
On April 25, 2025, your campaign filed a Candidate Registration (C-1) report and selected the Full Reporting Option.
- The staff noted that only two candidates registered to run for the School Director, Position 1, in Everett SD 002. As such, there was no primary, and your name did not appear on the 2025 primary ballot.
- Accordingly, you were limited to one $1,200 contribution limit from any one source during the 2025 election year, which should have been attributed to the general only since there was/is no primary election for the position you are running for in 2025. However, in reviewing the C-3 reports for your 2025 campaign, you disclosed receiving $2,400 in total contributions from Nicole Pennington on April 22, 2025, and attributed half of it ($1,200) to the 2025 primary election. [BK1] [AE2] [AE3] Staff noted that while it was permitted to attribute half of the contribution to the primary before the 2025 declaration week (May 5-9, 2025), it should have been refunded back to the contributor after it became apparent that there was no primary. It was not until July 3, 2025, approximately eight weeks after the May 2025 declaration week, when the campaign finally refunded the overlimit contribution.
- In your response to the complaint received on June 16, 2025, you stated: “The contribution in question was received and deposited on 4/22. While no other candidates had filed for this election besides the incumbent, this was well before the deadline for candidate to file for office, and it was our belief that there was likely to be a primary. Hence, we saw no issue with accepting a maximum contribution for both the primary and general election cycles and were adhering to the regulations regarding keeping the general election contribution unspent until the general. However, when the filing deadline arrived and it became clear that there would not be a primary, we did not remember that the campaign had accepted a primary election contribution that would need to be refunded. We are in the process of refunding this contribution now, as soon as this process is complete, we will update our reports.”
- On August 11, 2025, the campaign filed a C-4 report showing a $1,200 refund to Nicole Pennington for the overlimit primary contribution at issue in this matter.
Summary and Resolution
It appears that the campaign was under the impression that there would be additional opponents in the primary and forgot to refund the overlimit contribution. Additionally, the campaign took responsibility by refunding the overlimit contribution and filing a report disclosing the refund.
Based on our findings, staff has determined that, in this instance, the failure to adhere to the statutory contribution limits does not amount to a violation that warrants further investigation.
Pursuant to WAC 390-37-060(1)(d), however, your campaign is receiving a formal written warning concerning the failure to adhere to the statutory contribution limits. This formal written warning includes the staff’s expectation that you will adhere to the statutory contribution limits in all future campaigns. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.
Accordingly, the PDC dismissed this matter in accordance with RCW 42.17A.755(1).
Disposition
Case Closed with Written Warning
Date Opened
June 12, 2025
Areas of Law
RCW 42.17A.405
Documents
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