Ticket Number: 
40030
Complainant: 
Conner Edwards
Respondent: 
III Branches Law
Created Date: 
August 28, 2018
Status of Investigations: 
Case Closed with Written Warning
Description: 

The Public Disclosure Commission (PDC) has completed its review of the complaint filed by Connor Edwards on August 27, 2018. The complaint alleged that III Branches Law, a law firm making independent expenditures and electioneering communications supporting four candidates in the 2018 election, and its principal Joan Mell, may have violated RCW 42.17A.255 and RCW 42.17A.260 by failing to timely and accurately file independent expenditures of one hundred dollars or more within five days of the expenditure (C-6 reports) and RCW 42.17A.255, .260 and .305 by failing to electronically submit reports within 24 hours, disclosing electioneering communications with a value of one thousand dollars or more within 60 days before the primary election (C-6). PDC staff reviewed theallegations, the C-6 reports filed by III Branches Law, and the response from attorney Kenneth S. Kagan, PLLC on behalf of the client III Branches Law and its principal Joan Mell.   Pursuant to WAC 390-37-060(1)(b), III Branches Law and its principal, Joan Mell, will receive a formal written warning concerning the failure to timely and accurately file independent expenditures of one hundred dollars or more within five days of the expenditure (C-6 reports) and RCW 42.17A.255, .260 and .305 by failing to electronically submit reports within 24 hours, disclosing electioneering communications with a value of one thousand dollars or more within 60 days before the primary election (C-6). The formal written warning will include staff’s expectation that the law firm file accurate and timely C-6 reports in future elections in which you participate.  The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules. Based on these facts, staff has determined that in this instance, no evidence to support finding a material violation warranting a more formal investigation into the complaint or pursuing further enforcement action in this case. The PDC has dismissed this matter in accordance with RCW 42.17A.755(1).