Cascade Party

Cascade Party: Alleged violation of RCW 42.17A.235 and .240 for failure to timely and accurately report and expenditures. (EY24 NOV24)

Case Details

Case Number

164334

Respondent

Cascade Party

Complainant

Conner Edwards

Date Opened

December 30, 2024

Case Status

Case Closed with Written Warning

PDC staff found evidence of minor violation and warned respondent.

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Area(s) of Law*

  • RCW 29B.25.090/42.17A.235
  • RCW 29B.25.100/42.17A.240

*On January 1, 2026, RCW 42.17A was recodified to RCW 29B

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Description

  • Allegation: Violation of RCW 42.17A.235 and .240 for failure to timely and accurately report and expenditures

The PDC dismissed this matter in accordance with RCW 42.17A.755(1).

However, pursuant to WAC 390-37-060(1)(d), Cascade Party of Washington received a formal written warning concerning its failure to initially file a complete political committee registration, for not including the name of its sponsor on its initial committee registration, and for late-filed reports of contributions and expenditures that needed more detailed expenditure descriptions. PDC staff expects that Cascade Party of Washington will file timely, complete reports in the future. The Commission will consider this formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

The Public Disclosure Commission (PDC) reviewed the three complaints filed by Conner Edwards on Nov. 13, 2024; April 1, 2025; and April 25, 2025, alleging that Cascade Party of Washington (CPW) may have violated RCW 42.17A.205, .235, and .240 by failing to timely and properly register and report its activities as a minor political party that is also a political committee. The complaints made the following allegations:

Complaint 1, filed Nov. 13, 2024

  • First Allegation: Complaint 1 alleged that Cascade Party of Washington may have violated RCW 42.17A.235 and .240 by not filing C-4 reports for contribution and expenditure activities occurring during the period July through October 2024. PDC staff asked Cascade Party of Washington to file the missing reports, and informed CPW that all political advertising for newspapers, radio, television, etc. needed to include the name and address of the vendor and the run dates for the ads, and for political advertising that is mailed, the number of mailers purchased. 
  • Second Allegation: Complaint 1 also alleged that Cascade Party of Washington may have violated RCW 42.17A.205 by failing to list all committee officers on its committee registration. Staff explained the definition of committee officer in WAC 390-05-245 and asked CPW to amend its committee registration to include all committee officers, based on that definition.

Complaint 2, filed April 1, 2025

  • The complaint alleged that Cascade Party of Washington may have violated RCW 42.17A.235 and .240 by failing to file C-4 reports of contributions and expenditures for activities occurring during July, Aug., Sep., Oct., and Dec. 2024. The complaint also alleged that the C-4 report for Feb. 2025 was filed four days late. 

Complaint 3, filed April 25, 2025

  • The complaint alleged that Cascade Party of Washington may have violated RCW 42.17A.205 by failing to include, in its political committee name, the name of a person who met the statutory definition of “sponsor” of the political committee based on the amount of contributions made by that person.

Applicable Laws and Rules

RCW 42.17A.005(6) "Bona fide political party" includes:

(a) An organization that has been recognized as a minor political party by the secretary of state.

RCW 42.17A.005(12) "Committee" unless the context indicates otherwise, includes a political committee such as a candidate, ballot proposition, recall, political, or continuing political committee.

RCW 42.17A.005(39) "Person" includes an individual, partnership, joint venture, public or private corporation, association, federal, state, or local governmental entity or agency however constituted, candidate, committee, political committee, political party, executive committee thereof, or any other organization or group of persons, however organized. (Emphasis added)

RCW 42.17A.005(41) "Political committee" means any person (except a candidate or an individual dealing with the candidate's or individual's own funds or property) having the expectation of receiving contributions or making expenditures in support of, or opposition to, any candidate or any ballot proposition.

RCW 42.17A.005(14) "Continuing political committee" means a political committee that is an organization of continuing existence not limited to participation in any particular election campaign or election cycle.

Findings

  • Cascade Party of Washington’s website states that it is an independent member-driven state party whose mission is to be the party of free speech and offer a new voice to the people of Washington at all levels of government.

CPW’s Response to Complaints 1 and 2

  • When seeking a response to the second allegation in Complaint 1, PDC staff stated, “The complaint alleges that Cascade Party of Washington has failed to list its committee officers on its committee registration. The initial committee registration listed only one committee officer, Treasurer Scott Nall. The current registration, filed Feb. 6, 2025, also lists only one officer, Erik Raistakka, Treasurer. The Cascade Party of Washington website lists its leadership as Chair Krist Novoselic; Vice Chair Kiera Obrien; Secretary Marjorie O’Rourke; Treasurer Erik Raistakka; and Board Members: Kelly Wright, Devin Doyle, Johann Peters, Dannon Townsend, Shane Ross, and Jesse A. James. If any of the individuals on the leadership team meet the definition of a committee officer of the political committee (see below) they must be listed on an amended committee registration.”
  • Erik Raistakka stated Cascade Party of Washington established itself as a bona fide political party during the 2024 campaign cycle. He stated, on Jan. 11, 2025, CPW held its convention and elected its first officer slate and adopted bylaws. Krist Novoselic was named chair, Kiera O'Brien was named vice chair, Marjorie O'Rourke was named secretary, and Erik Raistakka was named treasurer. 
  • Erik Raistakka stated that following CPW’s Jan. 11, 2025 convention, he spent two-months gaining full access to the party's bank account and agreed to update CPW’s PDC filings on a regular basis based on those financial records. 
  • Erik Raistakka stated that, as instructed previously by PDC staff, based on CPW’s difficulties in updating the party's filings online, CPW resubmitted its PDC filing registration in February 2025 and stated it would file required reports based on the re-registration date going forward. Erik Raistakka stated he attempted to start with initial contribution records based on its Cash-on-Hand balance on that day. He acknowledged that CPW’s February 2025 report was filed a few days late because of finalizing his full online access to the party’s bank records. Erik Raistakka stated the party’s March 2025 report was filed timely.
  • Cascade Party of Washington stated it took the following actions to bring its reporting into full compliance:
  • Updated the email information on file to contact@cascadeparty.org;
  • Added the four executive committee members to the committee registration; and 
  • Resubmitted the C4 reports from July 2024 to March 2025, as recommended by PDC staff, to attempt a "start fresh" as of February 2025.

CPW’s Response to Complaint 3

  • CPW asserted that it is a "bona fide political party" as defined under Washington Revised Code (RCW) 42.17A.005(6) and is not a "political committee" under RCW 42.17A.005(12). Erik Raistakka asserted that, as such, Cascade Party is not subject to the requirements imposed on political committees and is entitled to specific exemptions, including those related to fundraising, expenditure rules, and sponsor identification under RCW 42.17A.320.
  • Erik Raistakka stated CPW has been recognized as a minor political party by the Washington Secretary of State, satisfying the criteria for a "bona fide political party" under RCW 42.17A.005(6). He said the party has complied with the statutory requirements for minor political parties, including holding advertised conventions and securing signatures from at least 1,000 registered voters on a petition bearing the party’s name, as required during a presidential election year. He said these processes distinguish Cascade Party from entities classified as political committees, which can be formed by anyone at any time through simple filing.
  • Erik Raistakka stated CPW is not a political committee under RCW 42.17A.005(12) which defines a committee as including a candidate, ballot proposition, recall, political, or continuing political committee.
  • Erik Raistakka then stated, “The examples listed in the statute—candidate, ballot proposition, recall, political, or continuing committees—share the common characteristic of being entities that can be formed by any individual or group at any time through simple filing. In contrast, a bona fide political party, such as the Cascade Party, is subject to stringent statutory requirements that limit its formation to specific processes and timelines. The distinct definitions provided in RCW 42.17A.005(6) and (12) demonstrate that the legislature intended to treat bona fide political parties and political committees as separate entities with different obligations and privileges.”
  • Erik Raistakka went on to note that, “Unlike political committees, which are prohibited from maintaining exempt accounts, bona fide political parties are expressly permitted to raise and spend money under 'exempt' rules. This distinction further underscores the unique status of bona fide political parties under Washington law and supports the Cascade Party’s position that it is not subject to the restrictions imposed on political committees.”
  • Erik Raistakka also cited an example from RCW 42.17A.320 that exempts a “bona fide political party” from a certain type of sponsor identification requirement, to demonstrate a difference between a political party and a political committee.
  • Erik Raistakka concluded his response to Complaint 3 by stating, “The Cascade Party of Washington is a 'bona fide political party' as defined by RCW 42.17A.005(6) and is not a 'political committee' under RCW 42.17A.005(12). The clear statutory distinctions between these entities, combined with the Cascade Party’s compliance with the requirements for minor political party recognition, establish that it is not subject to the requirements imposed on political committees. Furthermore, as a bona fide political party, the Cascade Party is entitled to specific exemptions, including the ability to maintain exempt accounts and relief from sponsor identification requirements under RCW 42.17A.320.”

PDC Staff Response and Comments

  • Upon PDC advice and request, Erik Raistakka, Treasurer, acting in good faith on behalf of Cascade Party of Washington, included all committee officers on an amended committee registration, filed April 18, 2025.
  • Upon PDC advice and request, Erik Raistakka, Treasurer, acting in good faith on behalf of Cascade Party of Washington, filed missing reports and amended multiple C-3 and C-4 Reports of Contributions and Expenditures with additional detail for expenditures that included the name and address of vendors, a description of events, and run dates for advertising of the benefited party activities.
  • Erik Raistakka refunded contributions and deposited additional contributions. As a result, Cascade Party of Washington no longer meets the criteria of a sponsored committee. 

Characterization of and Reporting Requirements for Cascade Party of Washington

  • Under RCW 42.17A.005(6), Cascade Party Washington is a "Bona fide political party" because it has been recognized as a minor political party by the secretary of state.
  • Under RCW 42.17A.005(12) "Committee" includes, in addition to a candidate, ballot proposition or recall committee, a political committee and a continuing political committee. (Emphasis added)
  • RCW 42.17A.005(41) "Political committee" means any person (except a candidate or an individual dealing with the candidate's or individual's own funds or property) having the expectation of receiving contributions or making expenditures in support of, or opposition to, any candidate or any ballot proposition. (Emphasis added)
  • RCW 42.17A.005(39) "Person" includes an individual, partnership, joint venture, public or private corporation, association, federal, state, or local governmental entity or agency however constituted, candidate, committee, political committee, political party, executive committee thereof, or any other organization or group of persons, however organized. (Emphasis added)
  • It is the position of PDC staff, that in addition to being a Bona fide political party, under the law, Cascade Party of Washington is also a political committee subject to the registration and reporting requirements of RCW 42.17A, while at the same time enjoying the higher contribution limits under RCW 42.17A.405 for political parties and limited exceptions to specific sponsor identification requirements under RCW 42.17A.320.

Summary

Cascade Party of Washington did not initially include all officers on its committee registration or include the name of its sponsor in its political committee name and filed a limited number of C-4 Reports of Contributions and expenditures late, which for some reports needed more detailed expenditure descriptions. Mitigating factors include online registration and reporting issues experienced while CPW was working to meet the requirements of the Washington Secretary of State to become a bona fide political party and the fact that Cascade Party of Washington did not support or oppose candidates during the 2024 elections. In addition, CPW filed the missing reports, amended reports with more detailed expenditure descriptions and received additional contributions and refunded contributions such that the committee was no longer a sponsored committee. Also, the party’s Treasurer worked cooperatively with PDC staff to amend the committee’s registration and file amended reports of contributions and expenditures.

Penalties

None