Vote4islandhealth Sponsored by Island Health Foundation: Alleged violation of RCW 42.17A.235 and .240 for failure to timely and accurately report contributions and expenditures and WAC 390-16-125 for exceeding mini reporting limits (EY24 APR25)

Case

#170154

Respondent

Vote4islandhealth Sponsored by Island Health Foundation

Complainant

Conner Edwards

Description

The complaint alleged violations of RCW 42.17A.235 and .240 for failure to timely and accurately report contributions and expenditures, and WAC 390-16-125 for exceeding mini reporting limits.

Applicable Laws and Rules

RCW 42.17A.235 requires each treasurer of a candidate or political committee, or an incidental committee, to file with commission a report of all contributions received, and expenditures made as a political committee on the next reporting date pursuant to the timeline established in the statute.

WAC 390-16-125 requires that a candidate or political committee wishing to change from mini to full reporting must apply electronically to the PDC for authorization to change reporting options before the contribution and expenditure limits are exceeded.

Background and Findings

The complaint alleged that Vote4islandhealth Sponsored by Island Health Foundation (The Committee), a single year ballot committee participating in the April 2025 special election, failed to timely and accurately file expenditure reports and exceeded the mini reporting contribution limit.

On February 5, 2025, 23 days before submitting its Committee Registration (C-1pc) on February 28, 2025, The Committee deposited an overlimit contribution after receiving a $7,000 contribution from one single source/contributor, in violation of the $500 contribution threshold from any one source/contributor for a political committee registered under the mini-reporting option. The staff noted that The Committee had two weeks or 14 days from February 5, 2025, to file a C-1pc with the PDC – as such, the C-1pc was filed late by The Committee.
The Committee mistakenly filed its C-1pc for the 2024 election year, rather than the correct election year of 2025.
While the Committee accepted a contribution in excess of the required threshold for the mini reporting option, staff noted that except for the post-election C-4 report, The Committee did file one C-3 report and the 21-day/7-day C-4 reports required for a committee registered under the full reporting option.
The staff noted that one of the C-4 reports filed by The Committee lacked the proper expenditure details and/or description as required by the rule. For example, The Committee’s 21-day pre-election C-4, which was filed late on April 5, 2025, (covering March 1 – March 31, 2025), failed to include the run dates for the newspaper ad that ran in the Anacortes American Newspaper, for a March 28, 2025, expenditure paid to goskagit.com in the amount of $643.80. Additionally, the staff also noted that the C-4 report (covering June 1, 2024 – February 28, 2025) and the C-3 report (for the $7,000 deposit on February 5, 2025), were also filed late.
On July 28, 2025, The Committee amended its 21-day pre-election C-4 report to include the required description/details associated with the ad that was run in the Anacortes American Newspaper for the March 28, 2025, expenditure. The Committee also filed the missing post-election C-4 report on July 25, 2025.
Lastly, regarding the C-1pc mistakenly filed by The Committee for 2024 instead of the correct election year of 2025, the PDC staff worked with the agency’s information technology department to move The Committee’s registration (C-1pc) to the correct election year.

Summary and Resolution

It appears that the failure to timely and accurately file the three reports filed by The Committee was a result of an oversight by The Committee, while the failure to adhere/commit to receiving no more than $500 in contributions from any one source/contributor appears to be the result of a lack of understanding of the requirements regarding a committee registered under the mini reporting option. The acceptance of an overlimit contribution is partially mitigated by The Committee’s filing of additional reports with the PDC, beyond what would have been required for a committee in compliance with mini reporting requirements, reducing the impact on the public.

Based on our findings, the staff has determined that, in this instance, the failure to timely and accurately file the required contribution (C-3) and expenditure (C-4) reports and comply with the contribution limits for political committees registered under mini reporting do not amount to violations that warrant further investigation.

Pursuant to WAC 390-37-060(1)(d), however, The Committee is receiving a formal written warning concerning the failure to timely and accurately file the required contribution (C-3) and expenditure (C-4) reports and the failure to seek approval from the PDC to change its registration to full reporting. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Accordingly, the PDC dismissed this matter in accordance with RCW 42.17A.755(1).

Disposition

Case Closed with Written Warning

Date Opened

April 09, 2025

Areas 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