August 05, 2025
Commission Chair J Leach began the Public Disclosure Commission’s Thursday, July 24, meeting by thanking Commissioner Nancy Isserlis for her years of service to the agency.
Isserlis’ five-year term ended in December, but state law allows her to stay on the Commission while waiting for her successor to be appointed. Isserlis’ last meeting will be the August 2025 regular meeting, which will be conducted remotely.
“She has been a true laborer in the trenches for us,” Leach said. “We’re going to lose a lot when we lose Nancy.”
Commissioners are appointed by the Governor. With Isserlis’ departure, the Commission will be down two members. Former Chair Allen Hayward resigned early this year.
Two candidates issued fines for failing to file reports, in repeat violations
The Public Disclosure Commission issued fines to two candidates in the 2025 general election who failed to file their candidate registration (C-1) and personal financial affairs statement (F-1) within two weeks of becoming a candidate, as is required by state law.
Both have previously been found in violation of this requirement.
Brett Johnson, a candidate for Pierce County Charter Review Commissioner, failed to file both the C-1 and F-1 within two weeks of becoming a candidate, on May 9, 2025. Johnson has two prior violations: for failing to find the F-1 in 2021 while a candidate for Tacoma City Council, and for failing to file an F-1 in 2022 while running for the state House of Representatives. The 2021 report has since been filed but the 2022 report remains outstanding.
PDC commissioners found Johnson in violation for the two missing reports from election year 2025 and issued a fine of $2,500 for each violation, for a total of $5,000, with half suspended on the condition that he follow file all missing reports and pay fines within 30 days, among other conditions.
Michael Luzzo, a candidate for School Director for the Kennewick School District, also failed to file a C-1 or F-1 for the 2025 election within two weeks of becoming a candidate.
Luzzo has a prior violation, from 2021, for failing to file the same reports. The Commission imposed a penalty of $1,000 per violation, with half suspended provided all fines are paid and reports filed within 30 days, among other conditions.
The Commission also reviewed an enforcement case against Adam Smith, a Spokane Valley City Council candidate, for failing to file the C-1 and F-1. The Commission agreed to continue the case until its August meeting.
PDC issues $11,000 in penalties to 2024 candidate after investigation reveals dozens of violations
The Washington Public Disclosure Commission voted unanimously July 24 to impose a total of $11,000 in fines to a successful 2024 candidate for the state House of Representatives and his campaign, after an investigation revealed numerous potential violations of state law throughout the campaign.
Shaun Scott, who won his election and now represents Washington’s 43rd district in the state House, stipulated to violations of state public disclosure law by him and his campaign.
The Commission accepted the stipulation during its July 24 regular meeting, and then deliberated on the amount of penalty to assess.
Scott's campaign, registered under the name The Fighting 43rd, was issued a $10,000 penalty for reporting incomplete or inaccurate information on contribution and expenditure forms, failing to file or filing reports late, failing to accurately report debt, failing to provide campaign books of account upon a request for inspection, failing to include complete sponsor identification on advertisements and using an assumed name for sponsor ID.
PDC staff identified problems with dozens of reports leading up to the 2024 primary and general elections.
Among the issues, the committee filed late mandatory pre-general election reports – which are expedited reports designed to provide information during critical voting periods. The late reports, which were due in October 2024 and filed in March 2025, included more than $46,000 in contributions and more than $33,500 in expenditures. That activity – disclosed after the election – represented a significant portion of the campaign’s total $147,000 in fundraising.
Scott stipulated to one violation himself: that he used campaign funds for personal use, which is prohibited by state law. Specifically, Scott admitted campaign funds for $756 in haircuts. The Commission imposed a $1,000 fine for this violation.
Half of each violation is suspended on the condition that the non-suspended portion of the fines are paid within 90 days, and that the amount spent on personal use is refunded to Scott’s campaign, among other requirements.
Commission approves increased recommended penalty ranges for disclosure law violations
The Public Disclosure Commission unanimously approved a rule change at its July 24 meeting that would increase recommended penalties for violations of public disclosure law.
The Commission uses penalty schedules to levy fines for violations based upon the nature of the activity and potential harm to the public, among other factors. The current penalty schedules used for stipulations (WAC 390-37-062), brief adjudicatory proceedings (WAC 390-37-143), and full commission hearings (WAC 390-37-182) were set in 2018. Public Disclosure Commissioners have expressed interest in updating the penalty schedules several times over the past year, and PDC staff initiated the formal rulemaking process in October 2024.
PDC staff proposed increasing the penalty ranges by $500 to $1,000 for most categories of violations in order to give the Commission more flexibility in assessing penalties.
The Commission held a public hearing and approved the new rules on July 24. The rules will go into effect on Nov. 5, for all compliance cases initiated on that date or after.
The Commission is still limited by statute to fines of $10,000 per violation, but can assess higher penalties by agreement of the parties, or by referring cases to the state Attorney General’s Office for prosecution if higher penalties are warranted.
Agency continues to discuss options for campaign reporting schedule reform
The Public Disclosure Commission is continuing to discuss proposals intended to standardize and simplify the campaign expenditure reporting calendar, with the intention of helping campaigns keep track of deadlines and improving transparency.
Currently, campaign expenditure reports, known as C-4 reports, have due dates that depend on the amount of a candidate’s or committee’s financial activity and their election participation. For that reason, a committee participating in the 2025 general election has different C-4 due dates than a committee participating in the April 2025 special election.
The schedule for these mandatory reports is not reflective of the move to mail voting. The first of the pre-election reports, the 21-day pre-election report, covers a roughly six-week period just prior to voter receiving their mail ballots.
That six-week period is one of the busiest for campaigns, yet it also is the least transparent to the public. In 2020, campaigns spent $50 million during that period prior to the general election. By the time they reported how they had spent the money, the public and media had little time to digest the information prior to the beginning of voting.
Staff have proposed a plan that would require all candidates and committees to file expenditure reports (regardless of financial activity) on the 10th of each month in January – June, November and December. In the critical election-season months of July, August, September and October, all candidates and committees would submit two reports monthly — one on the 10th and the second on the 25th.
These changes would need to be codified into state law. PDC staff are considering drafting agency request legislation to propose to the state Legislature.
Enforcement update
Between June 16 and July 15, the PDC received 90 new complaints, held three initial hearings and closed 35 cases. As of July 15, the agency had 192 open cases.
Staff issued 241 hearing notices to candidates for failure to file campaign registrations and financial affairs statements in 2025, compared to 173 in 2023, the previous local election year.
Of the 241 cases filed, 152, or 59 percent, went to a brief enforcement hearing in June. The remaining cases were either settled with statements of understanding (in which the candidates admitted to a violation) or closed by staff for other reasons.
Staff also plans to do a general enforcement effort for candidates who have filed late or failed to file mandatory 21-day and 7-day pre-primary election expenditure reports. Those hearings are scheduled for September.