HELP EDUCATE LAKEWOOD PUPILS: Alleged violation of RCW 42.17A.235, and .240 for failure to timely and accurately report expenditures (EY'24, FEB'24)

Case

#148402

Respondent

HELP EDUCATE LAKEWOOD PUPILS (HELP)

Complainant

Conner Edwards

Description

PDC staff reviewed the allegation(s); the applicable statutes, rules, and reporting requirements; the response(s) provided by the Respondent; the applicable PDC reports filed by the Respondent; the Respondent’s data in the PDC contribution and expenditure database; and other relevant information, to decide whether the record supports a finding of one or more violations.

Based on staff’s review, we found the following:

• Help Educate Lakewood Pupils filed a Committee Registration (C-1pc) on December 07, 2023, for the Full Reporting option.  Jeannie Sahatdjian is the Treasurer for the committee.
• Per RCW 42.17A.235 and .240, under the Full Reporting option, a committee is required to disclose contribution and expenditure information by submitting Receipts and Expenditure Summary (C-4) reports and Cash Receipts, Monetary Contributions (C-3) reports to the PDC.  The Committee’s due dates for the C-3 and C-4 reports are determined by its activity and participation in the election cycle.
• The 21-day pre-election C-4 was due on January 23, 2024.  The committee filed a C-4 for the period 12/01/23 – 01/22/24, on January 23, 2024. The report was filed timely. 
• The 7-day pre-election C-4 was due on February 06, 2024. The committee filed a C-4 for the period 01/23/24 – 02/05/24, on February 08, 2024. The report was two days late.
• The post-election C-4, due on March 11, 2024, was filed timely.
• The Respondent does not have other similar warnings of PDC requirements. 

Based on our case review staff has determined that, in this instance, failure to timely and accurately file Summary Full Campaign Contribution and Expenditure reports (C-4 reports), showing contributions and expenditures undertaken by the February 2024 Special Election committee, does not amount to a finding of a violation that calls for further investigation.

Pursuant to WAC 390-37-060(1)(d), however, Help Educate Lakewood Pupils will receive a formal written warning concerning RCW 42.17A.235 and .240 for failure to timely and accurately file Summary Full Campaign Contribution and Expenditure reports (C-4 reports), showing contributions and expenditures undertaken by the February 2024 Special Election committee.  Staff expects the committee, moving forward, to file accurate and timely reports of contributions and expenditures in the ORCA system.  If violations of PDC laws or rules occur in the future, the Commission will consider this formal written warning in deciding on further Commission action.

Based on this information, the PDC finds that no further action necessary and has dismissed this matter per RCW 42.17A.755(1).

Disposition

Case Closed with Written Warning

Date Opened

February 08, 2024

Areas of Law

RCW 42.17A.235, RCW 42.17A.240

Documents

• 148402 HELP EDUCATE LAKEWOOD PUPILS Complaint.pdf
• 148402 Help Educate Lakewood Pupils Response.pdf
• 148402 Help Educate Lakewood Pupils Complaint Return Letter (combined).pdf