Alecia Cunningham: Alleged violations of RCW 42.17A.235 & .240 for failure to timely and accurately disclosure contributions on reports (EY25 JUl25)

Case

#175316

Respondent

Alecia Cunningham

Complainant

Conner Edwards

Description

The Public Disclosure Commission (PDC) completed its review of a complaint filed with the PDC. 

Applicable Laws and Rules

Per RCW 42.17A.235 and .240, a candidate that selects the Full Reporting option on their registration 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 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 $750 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.

Pursuant to WAC 390-16-034. per RCW 42.17A.240, each report required under RCW 42.17A.235 shall disclose, in addition to the name and address of each person who has made one or more contributions in the aggregate amount of more than $250, their occupation, and the name and location (city and state) of their employer.

​Background and Findings

  • The Respondent filed a Candidate Registration (C-1) on May 12, 2025, amended June 9, 2025, for the position of Council Member for the City Of University Place, as the Full Reporting option.
  • The C3 for a deposit on June 18, 2025, for $2,315, was submitted 14 days late.
  • The contribution from Nishizawa Sayuri, for $1,000, is missing required information regarding their employer.
  • The Respondent's campaign may be using a mailbox service and it is unclear if the expenditure has been reported.  There are nonitemized expenses reported and the mailbox service may be included.
  • The Respondent has no similar Warnings or PDC violations.

 Summary and Resolution

Having reviewed the complaint and the supporting evidence, PDC staff has determined that the Respondent does appear to have violated RCW 42.17A. 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. 

Based on this, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1) and WAC 390-37-060(1)(d). PDC staff has reminded the Respondent about the importance of timely and accurate reporting. The Respondent is expected to comply with PDC statutes and rules in the future.

Disposition

Case Closed with Reminder

Date Opened

July 08, 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

Documents

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