Commission meeting highlights: June 2026
After briefly having a full cast of five commissioners following the appointments of attorneys Teebah Alsaleh and Matthew Segal, the Public Disclosure Commission is again down to four.
James Oswald, who served on the commission since 2024, resigned on June 15. Commissioners are appointed by the governor. Interested parties may apply here.
At the June 25 regular meeting, the Commission voted to have Chair J Leach continue as chair, and to have Douglass North continue as vice chair until the completion of his term at the end of this year.
Commission imposes fines for repeat violators of campaign registration, personal financial reporting requirements
The Commission imposed a total of $6,000 in fines to three respondents who were required to file either a personal financial affairs report (F-1), campaign registration (C-1), or both. All had previous violations involving the same reports and had yet to comply with the terms of those past orders, causing their cases to be heard before the full Commission.
Candidates must file each report within two weeks of beginning their campaign. Elected and some appointed officials in Washington must file the F-1 annually by April 15, covering the previous year. Annual personal financial affairs statements have been required since the formation of the PDC more than 50 years ago, and are intended to reveal potential conflicts of interest.
In the first case, John P. Gibbons, a 2026 candidate for state Representative for the 45th Legislative District, was charged with failing to file both the C-1 and F-1. Gibbons was fined $500 in 2022 for failing to file the same reports while also running to represent the 45th Legislative District in the House of Representatives. To date, the fine has not been paid and the reports were not filed.
The Commission imposed a $1,000 fine for each report in the 2026 case, suspending half of each provided Gibbons pays all money owed and files the missing reports within 30 days, among other conditions.
The Commission also heard the case against Robert Scott, a fire commissioner for the West Thurston Regional Fire Authority. Scott was charged with failing to file an F-1 for calendar year 2025. Scott has two previous violations for failing to file an F-1 – in 2025, when he was a commissioner, and in 2024, when he was a candidate for the position.
Scott was fined $250 in 2024 and $800 in 2025. He has paid neither fine and filed neither report. The Commission imposed a fine of $3,000 for the 2026 case, with $1,500 suspended provided he pays all money owed and files the missing reports within 30 days, among other conditions.
In the third case considered at the June 25 meeting, Kyle A. Strengholt, a Lynden City Council member, was charged with failing to file his annual F-1 report due in 2026. Strengholt also failed to file the report as a candidate for the position in 2025. For that violation, the Commission imposed a fine of $500. To date, the fine has not been paid and the report has not been filed.
For the 2026 case, the Commission ordered a fine of $1,000 with $500 suspended provided Strengholt pays all money owed and files the missing reports within 30 days, among other conditions.
On June 24, Commission Chair J Leach heard cases against 27 candidates who had failed to file the C-1 or F-1 by the deadline. Those cases were heard at a brief hearing before Leach alone as presiding officer.
Commission considers enforcement case hampered by constitutional challenge
PDC staff asked the Commission for guidance during the June 25 meeting regarding an enforcement case in which the relevant law’s constitutionality is in question.
Chair J Leach recused himself from any decision-making, saying that he knows the respondent, state Court of Appeals Judge Tam Bui, and participated in one of her previous campaigns.
PDC staff investigated a complaint that Bui exceeded pre-election contribution limits under RCW 29B.40.070. The staff review determined that limits appeared to have been exceeded, said assistant attorney general Susie Giles-Klein at the June 25 meeting.
However, Bui and her attorney have questioned whether the statute itself is constitutional when a candidate is spending money on their own campaign in the 21 days before an election, in light of a court ruling that it is a matter of freedom of speech that a candidate can donate as much as they would like to their own campaign. Candidates are allowed to contribute to their own campaign without limit in Washington, but limits are in place regarding the size of contributions within 21 days of an election. PDC staff prepared a memo for the Commission outlining the issue.
The Commission cannot rule on the constitutionality of the laws it administers. Giles-Klein asked the Commission for guidance on how to proceed on behalf of PDC staff. Options include directing Executive Director Peter Frey Lavallee to dismiss the case – if the law could be unenforceable – or otherwise resolve the case, defer enforcement, or refer the matter to the Attorney General’s Office.
Giles-Klein also asked on behalf of staff that the Commission consider whether it should issue formal guidance to campaigns on the law.
“This case has presented a bit of a conundrum for us as staff,” said Executive Director Peter Frey Lavallee. He suggested asking the Legislature for clarification when it next convenes.
The Commission, with Leach abstaining, agreed to dismiss the case without prejudice, meaning staff could reopen the case in the future. The Commission asked staff to prepare a fuller briefing on how case law affects the state’s ability to apply time-bound limits on contributions to campaigns.
Cle Elum granted request to require more disclosure requirements
After receiving a request from the city of Cle Elum, the Commission voted to require stricter disclosure for its elected officials and future campaigns.
State law requires most candidates and committees to file campaign registrations and regular reports of contributions and expenditures (C series reports), and candidates and officials must file personal financial affairs reports (F-1).
Jurisdictions under 2,000 voters are exempt from these requirements. However, a jurisdiction can request to be subject to the requirements.
The city of Cle Elum had 1,543 registered voters as of the 2025 general election. On June 9, 2026, the city council passed a resolution to ask the PDC to require this disclosure within the city.
The city can later request that the Commission reverse its order.
First Jolene Unsoeld intern presents research project
Evergreen State College Junior Nathan Tippman, the first recipient of the PDC’s Jolene Unsoeld Public Policy Internship, presented research at the July 25 meeting on how a federal court case could impact campaign finance disclosure in Washington.
The internship included a requirement to complete a research project on a topic related to the Public Disclosure Commission, and present the results of that project to the Commission at the end of the quarter.
Tippman analyzed the National Republican Senatorial Committee (NRSC) vs the Federal Elections Commission (FEC) case, which challenges federal limits on expenditures from party committees made in coordination with candidates. His presentation reviewed possible effects the case could have on the PDC and campaign finance laws in Washington.
Enforcement report
Between May 20 and June 15, the PDC received 152 new complaints. At the end of that period, the agency had 158 active cases with 46 under initial review, 109 under formal investigation, one scheduled for a full hearing before the Commission, one scheduled for a brief hearing before the Commission chair, and one pending deferred enforcement.
On May 27, the PDC sent 52 hearing notices for candidates for the 2026 election who had late filings or who failed to file their candidate registration (C-1), personal financial affairs statements (F-1) or both. About half of those candidates went to a brief enforcement hearing on June 24. The remainder of the cases were resolved before the hearing.
Between May 20 and June 15, 48 cases were resolved, including one dismissed with no evidence of a violation, 20 written warnings, two signed statements of understanding admitting a violation, 14 technical corrections, four violations found by the Commission and two cases resolved with the complaint publication process.
In the runup to the election cycle, PDC staff have begun identifying cases eligible for an expedited path to resolution. These cases concern 2026 campaigns, and the focus in the process is on curing reporting deficiencies and providing education to promote future compliance.