Description
The Public Disclosure Commission (PDC) completed its review of the complaint filed by Conner Edwards on May 16, 2025. The complaint alleged violations of: RCW 42.17A.235 & .240 for failure to accurately disclose carry forward amount from the 2021 campaign on 2025 reports; and WAC 390-16-037 for failure to accurately & completely report expenditure details during election year 2025.
Applicable Laws and Rules
A candidate that selects the Full Reporting option on their Candidate Registration (C-1 report) is required to report contributions and expenditures to the PDC on Cash Receipts Monetary Contributions reports (C-3 reports) and Campaign Summary Receipts & Expenditures reports (C-4 reports) pursuant to RCW 42.17A.235 & RCW 42.17A.240. The due dates for these reports are based upon the election cycle, the candidate’s election participation, and their financial activity.
Pursuant to RCW 42.17A.240(7), expenditures are disclosed on C-4 reports, which must include, but are not limited to: 1) the name and address of each person to whom an expenditure was made in the aggregate of more than $200 during the period covered by the report; 2) the amount, date, and purpose of each expenditure; and 3) the total sum of all expenditures. Purpose details should state the goods or services provided by the vendor, including the number of items purchased, identify any candidates or ballot propositions supported or opposed by the expenditure, and the name & address of any sub-vendors used. For advertising expenditures, campaigns should describe the type and number of ads, where they appeared or were broadcast, and when (e.g. run dates). An in-kind contribution is disclosed like an expenditure on the PDC’s Online Reporting of Campaign Activity (ORCA) software.
Background and Findings
• In 2021 you ran for Mayor of the City of Lynnwood and lost in the primary. You were at the time of the 2021 election an elected City Council Member for the City of Lynnwood. In 2023 you were the incumbent for your seat on the City of Lynnwood Council and won that election for which you are in the second year of your term. In 2025 you are a candidate for Mayor of the
City of Lynnwood. You filed a Candidate Registration (C-1) on February 25, 2025, for the Full Reporting option. In the prior elections you were also registered for the Full Reporting option. • Upon review of the reporting record and from further follow-up with you, PDC staff determined that on the last C-4, filed timely in 2021, you reported a loan that you made to your campaign and that there was a $241.38 Cash On Hand (COH) balance. You explained that at the end of the 2021 campaign you withdrew $241.38 from the campaign bank account as repayment for the loan but did not amend the C-4 reflecting the partial repayment of the loan balance. Upon being notified of the complaint, you worked with PDC staff to amend the report reflecting the payment to yourself which zeroed out the 2021 COH.
• In that the 2021 and 2025 committees are for the same purpose, election to the office of Mayor of the City of Lynwood, and that you have used the same bank account for each of these campaigns, the amended COH balance of $0 was accurately and timely reported as the starting balance of the 2025 campaign.
• The complaint also alleged a lack of expenditure description for 2025 expenditures submitted on May 14, 2025, for the period of April 1, 2025, to April 30, 2025. Upon being notified of the complaint on June 2, 2025, you amended the reporting on June 12, 2025. The report now reflects the missing quantities of 100 post cards and 1000 flyers.
• You have no prior warnings or violations within the PDC’s statute of limitations.
Summary and Resolution
You made minor or ministerial errors on required reports which did not materially harm the public interest. You made the necessary technical corrections within 2-14 days of being notified by PDC staff.
After consideration of all the circumstances, further proceedings would not serve the purposes of the Fair Campaign Practices Act. Under WAC 390-37-070, the executive director, at any time prior to consideration by the Commission, may dismiss a complaint which on its face, or as shown by investigation, provides reason to believe that a violation has occurred, but also shows that the respondent is in substantial compliance with the relevant statutes or rules, or shows that formal enforcement action is not warranted. The executive director must report at each regular Commission meeting all complaints dismissed.
Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1).
