Denholm, William "Denny": Alleged violation of RCW 42.17A.235 and .240 for failure to timely & accurately report expenditures. (EY '23; Oct '23)

Case

#143433

Respondent

Denny Denholm

Complainant

Erica Li, and Conner Edwards

Description

The PDC received two complaints alleging violations of RCW 42.17A.235 & .240. The first complaint alleged that a mailer expenditure for election year 2023 was not reported, and that case was resolved with a Warning letter. The second complaint, which was filed some months later, alleged 1) an expenditure description for election year 2023 was inaccurate; and 2) reports for election year 2023 were not accurate as evidenced by a negative ending balance on the campaign's last C-4 report. The allegations made in both complaints concerned reports filed for the same election year. After reviewing the second complaint and determining that it fell under the scope of the previously resolved case, PDC staff reopened this case to address the second complaint.

PDC staff reviewed the allegations and evidence submitted; the applicable statutes, rules, and reporting requirements; the response provided by Mr. Denholm (the “Respondent”); the applicable PDC reports filed by the Respondent; and other relevant information to determine whether the record supports a finding of one or more violations.

Based on the attached findings, staff has determined that, in this instance, failure to timely and accurately disclose an in-kind contribution/expenditure for a mailer and additional contributions and expenditures on a C-4 report field two days late does not amount to a violation that warrants further investigation.

Pursuant to WAC 390-37-060(1)(d), however, Denny Denholm received a formal written warning concerning his failure to timely and accurately disclose contributions and expenditures. The formal written warning included PDC staff’s expectation that Denny Denholm timely and accurately disclose contributions, in-kind contributions and expenditures, including accurate descriptions, on reports in future years. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules. This amends our previous warning letter, issued January 11, 2024.

The Respondent also made technical corrections to minor or ministerial errors on required reports which did not materially harmm the public interest, specifically to resolve negative ending balances on campaign reports, within 14 days, per staff's request. Accordingly, those matters are hereby resolved as technical corrections per WAC 390-37-060(b), and no further action is warranted.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

Disposition

Case Closed with Written Warning

Date Opened

October 16, 2023

Areas of Law

RCW 42.17A.235, RCW 42.17A.240

Documents

• 143433 Denholm Denny Warning Letter.pdf
• 143433 Denholm William Complaint.pdf
• 143433 Denholm William (Denny) Response.pdf
• 143433 Denholm William Complaint 2.pdf
• 143433 Denholm Denny Amended Warning_Tech Correct Letter.pdf