Cassandra Franklin: Alleged violations of RCW 42.17A.235 & .240 for failure to timely and accurately report contributions and expenditures. (EY25 JUL25)

Case

#175425

Respondent

Cassie Franklin

Complainant

Conner Edwards

Description

• Allegation: Violations of RCW 42.17A.235 & .240 for failure to timely and accurately report contributions and expenditures

• The Public Disclosure Commission (PDC) completed its review of two complaints filed by Conner Edwards on July 3, 2025 and August 26, 2025. The complaints alleged violations of RCW 42.17A.235 and .240 by failing to timely and accurately report contributions and expenditures during your 2025 re-election campaign. The PDC dismissed this matter in accordance with RCW 42.17A.755(1). However, Pursuant to WAC 390-37-060(1)(d), Cassie Franklin received a formal written warning concerning the importance of ensuring her campaign treasurer is fully aware of the reporting requirements, including when C-3 reports are due and the requirements for expenditure descriptions. The formal written warning includes staff’s expectation that future campaigns timely file all future required reports of contributions and expenditures and include a complete description for expenditures. The Commission will consider this formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

  PDC staff reviewed examples cited by the complainant concerning possible inadequate descriptions for monetary expenditures and in-kind contributions and asked Respondent to review the examples and file amended reports, as needed, for descriptions of monetary expenditures, in accordance with WAC 390-16-037, and in accordance with WAC 390-16-205 when an agent is used to make expenditures on behalf of the campaign. Staff asked Respondent to report, as needed in amendments, the number of items printed, and for signs, including yard signs and decals, the number of items purchased.

  Background & Findings

  ·       Cassie Franklin was elected to the Everett City Council in 2015. Franklin was elected Mayor of Everett in 2017 and 2021 and is a candidate for reelection in 2025.

  ·       Franklin’s 2025 reelection campaign started in January 2022 with Michael Swanson serving as treasurer. Lindsay Cortes became Franklin’s treasurer for her 2025 campaign in March 2024.

  Below are the allegations included in the complaints and staff’s notations of possible inadequate descriptions of monetary expenditures and in-kind contributions, along with the campaign’s response and summary of amended reports.

  The first complaint alleged that:

  • C-3 Report 110 295 353 totaling $5,650 was filed 22 days late. Staff confirmed that the C-3 was filed 22 days late.
  • C-3 Report 110 295 354 totaling $500 was filed 15 days late. Staff confirmed that the C-3 was filed 15 days late.
  • Proper expenditure descriptions are missing for several entries in the campaign’s 2025 C-4 reports, typically relating to printing expenses.

  The Franklin campaign stated, “We have carefully reviewed the issues noted and taken corrective action where necessary. Specifically, we have filed amended C4 reports to include additional subvendors and correct any expense reporting discrepancies where necessary. These updates should now accurately reflect all required disclosures.  However, many of the items noted from 3/15/23-4/08/25 did not use subvendors, so no action was taken other than clarifying that in our response below.”

  The second complaint alleged that:

  • As of Aug. 8, 2025, the campaign had not disclosed any contributions received in August 2025. Response from Lindsay Cortes, Treasurer: “We acknowledge that C-3 reports for contributions received in August were filed on September 2, 2025, instead of on a weekly basis, as required beginning June 1. This was due to a misunderstanding on my part—I believed weekly C-3 filings were required only through the primary election. I now understand that the weekly filing requirement continues through the general election, and I have taken corrective action to ensure that all future C-3 reports are filed timely on Mondays as required. Apologies for this oversight.”
  • C-3 reports of deposits made in August for contributions received in July, filed Aug. 22, 2025, were due by Aug. 11 and were filed 11 days late. Response from Lindsay Cortes, Treasurer: “The original C-3 covering July 30 contributions was filed on August 4, 2025, in compliance with the reporting deadline. An amended C-3 was later filed on August 22, 2025, to correct an error where $600 was incorrectly attributed to the wrong spouse (corrected from Maureen Lico to James Lico). The contributions themselves were reported timely, and the amendment was filed promptly upon discovery of the error.”
  • An amended C-3 filed Aug. 22, 2025 included previously unreported contributions totaling $600. Response from Lindsay Cortes: “As noted above, these contributions were reported on the timely August 4 C-3. The August 22 filing was an amendment correcting the name of the spouse making the contribution, not a late report of new contributions.”
  • The campaign's Stripe account for accepting contributions did not include "a formal sponsor ID statement." Response from Lindsay Cortes: “There are limited editing capabilities on our Stripe contribution page. Our contribution page now includes the URL back to the campaign’s homepage, which contains the full sponsor identification statement, in line with PDC staff’s guidance that this is sufficient. The URL is listed in the title ‘Donate to the Re-Elect Mayor Cassie Franklin Campaign - mayorcassiefranklin.com,’ and on the page image. The Stripe contribution page was already set up to reference Cassie's main website in the "thank you" message after a donation is made. This has been in place since it was created in 2023. A screenshot of the ‘thank you’ message is attached.”
  • An expenditure did not include a station-by-station breakdown. Response from Lindsay Cortes: “The July 18, 2025, expenditure to North Sound Media has been updated to include the specific stations (KRKO and KXA, Everett, WA).”
  • Expenditures did not include subvendor information, run dates, or the number of pieces printed. Response from Lindsay Cortes: “We have updated our July 2025 expenditures to include more detail about subvendor information, addresses, run dates, and the number of pieces printed for Terra Firma Consulting, Strategies 360, and Sound Publishing.”

  Separate from the allegations in and responses to the two complaints filed by the Complainant, staff asked the campaign to amend certain reports.

  Summary and Resolution

  Cassie Franklin is an experienced candidate who ran for her third term as Mayor of Everett in 2025. During her 2025 campaign, Franklin switched to a new treasurer which resulted in a misunderstanding about when C-3 reports were to be filed and a lack of clarity on required expenditure descriptions. The treasurer acknowledged that two C-3 reports for $5,650 and $500 were filed 22 and 15 days late, respectively, and responded promptly when asked to amend reports, updating July expenditures to include subvendor information where needed, run dates, and the number of pieces printed. The treasurer  noted that in several instances, no subvendors were used. Additional descriptive information for expenditures not included in the complaints was requested, and amendments were promptly received.

  Saff determined that in this instance, filing two C-3 reports late and initially providing incomplete expenditure descriptions do not amount to a finding of a violation warranting further investigation.

Disposition

Case Closed with Written Warning

Date Opened

July 10, 2025

Areas of Law

RCW 42.17A.235, RCW 42.17A.240

Documents

• 175425 Response to Complaint.pdf
• 175425 Response to Complaint 2.pdf
• 175425 Cassie Franklin Resolution.pdf
• 175425 Cassie Franklin Complaint.pdf
• 175425 Cassie Franklin Complaint 2....pdf