Let's Go Washington (Sponsored by Brian Heywood)(4): Alleged violations of RCW 42.17A.235 & .240 for failure to report the actual contributor on reports (EY24 OCT24)

Case

#161496

Respondent

Let's Go Washington

Complainant

Dmitri Iglitzin and Marina Multhaup, on behalf of Washingtonians for Ethical Government

Description

• Allegation:  Violations of RCW 42.17A.235 & .240 for failure to report the actual contributor on reports 

The PDC has dismissed this matter in accordance with RCW 42.17A.755(1) and will not be conducting a more formal investigation into these allegations or taking further enforcement action in this matter.  

The complaint, filed by Marina Multhaup and Dmitri Iglitzin on behalf of Washingtonians for Ethical Government on October 29, 2024, concerned contributions made by Lawrence Patrick Hughes, Case 161712, received by Let's Go Washington Sponsored by Brian Heywood, Case 161496; Dave Reichert, Case 160779; and Jaime Herrera Beutler, Case 161493.

The complaint alleged that Let's Go Washington Sponsored by Brian Heywood may have violated RCW 42.17A.235 by failing to accurately record and report its true contributors; that Dave Reichert and Jaime Herrera-Beutler may have violated RCW 42.17A.235 and RCW 42.17A.405(14) by failing to accurately report their contributors and by accepting contributions which exceed the limits for individuals per election; and that Lawrence Patrick Hughes may have violated RCW 42.17A.435 by unlawfully contributing money under the name of a deceased person and RCW 42.17A.405(2) by, through that means, making contributions in excess of the contribution limits.

Applicable Laws & Rules

RCW 42.17A.235 and .240 require candidates and political committees to file timely, accurate reports of contributions and expenditures including the name and address of each person who has made one or more contributions during the period.

RCW 42.17A.435 states, “No contribution shall be made and no expenditure shall be incurred, directly or indirectly, in a fictitious name, anonymously, or by one person through an agent, relative, or other person in such a manner as to conceal the identity of the source of the contribution or in any other manner so as to effect concealment.”

Relevant facts for this Respondent are as follows:

• Let’s Go Washington Sponsored by Brian Heywood is a political committee formed to support several initiatives to the Legislature during 2023, three of which appeared on the 2024 general election ballot, and a 2024 initiative to the people.

Let’s Go Washington Sponsored by Brian Heywood, Case 161496 

• Jason Michaud, Treasurer for Let’s Go Washington Sponsored by Brian Heywood (LGW), stated, “On August 1, 2024, LGW received a check by mail which had been endorsed by Lawrence Hughes. Although the check was signed by Mr. Hughes, it contained the printed name of Mary Ellen Hughes. Given that Mary Ellen’s name appeared on the check, but the remitter's signature and accompanying return instrument indicated Mr. Hughes was the donor, the donation was initially split equally between the two individuals.”
• “Upon learning of Mary Ellen Hughes' passing through the media on October 30th 2024, LGW proactively amended the C3 report that same day to reflect Lawrence Hughes as the sole contributor, even prior to receiving any formal complaint regarding the matter.”

Lawrence Patrick Hughes, Case 161712

• According to Nathan Alexander, legal counsel for Mr. Hughes, Mr. Hughes and Mary Ellen Hughes (“Mrs. Hughes”), throughout their life together, consistently gave to a variety of charitable causes, including to political candidates and causes, and they frequently supported the same candidates/causes. After Mrs. Hughes’ passing in October 2023, Mr. Hughes continued his philanthropic efforts and political giving.
• Mr. Hughes issued a single $100,000 check to Let’s Go Washington Sponsored by Brian Heywood, on July 25, 2024, but because of Mr. Hughes’ joint donation history with Mrs. Hughes—and because Mr. Hughes’ checkbook still included her name—Let’s Go Washington Sponsored by Brian Heywood appears to have erroneously recorded that single $100,000 donation from Mr. Hughes as two $50,000 donations, one from Mr. Hughes and one from Mrs. Hughes. 
• Mr. Alexander stated that Mr. Hughes has been a frequent campaign donor for more than thirty years, and this is the first time he has been accused of making contributions over legal limits or of concealing a contribution’s source. He said Mr. Hughes had no intention of circumventing campaign finance law.

Staff reminded Lawrence Patrick Hughes about the importance of clearly stating to the recipient of a campaign contribution to whom the contribution should be attributed when it is not obvious.

Disposition

Case Closed with No Evidence of Violations

Date Opened

October 30, 2024

Areas of Law

RCW 42.17A.235, RCW 42.17A.240

Documents

• 161496 Combined Case Closure Letter.pdf
• 161496 Let’s Go Washington Complaint.pdf
• 161496 Response to Complaint.pdf