Kate Kruller: Alleged violation of RCW 42.17A. 235, .240, and .320 for failure to timely and accurately report contributions and expenditures and failure to provide complete sponsor identification on campaign advertising (EY25 JUL25)

Case

#175855

Respondent

Kate Kruller

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'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 $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.
​
Per RCW 42.17A.320, all written political advertising, whether relating to candidates or ballot propositions, shall include the sponsor's name and address. The use of an assumed name for the sponsor of electioneering communications, independent expenditures, or political advertising shall be unlawful. For partisan office, if a candidate has expressed a party or independent preference on the declaration of candidacy, that party or independent designation shall be clearly identified in electioneering communications, independent expenditures, or political advertising.

RCW 42.17A.320 and WAC390-18-010, 020, 030, and 040 further outline requirements for sponsor identification on political advertising.
 

Background and Findings

  • The Respondent registered with the PDC on May 1, 2025, under the Full Reporting option, for City Council Member Position 5 of City of Tukwila.
  • After a review of the evidence, the C3 cited in the complaint was filed late but within 21 days of the due date.
  • The Post Office Box in-kind contribution was amended to the May 2025 C-4 report that was originally filed timely.
  • The campaign website was missing complete sponsor identification but following the complaint the Respondent took quick action to address the issue.
  • The Respondent has not been warned, admitted to a violation, or were found in violation up through the period of the 2025 Primary Election.

Summary and Resolution
Having reviewed the complaint and the supporting evidence, PDC staff has determined that the Respondent appears 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 reminded the Respondent about the importance of timely reporting and complete reporting, and providing complete sponsor identification on political advertising. They are expected to comply with PDC statutes and rules in the future.  For more information about PDC requirements, see the 'For Candidates' section and the 'Political Advertising Guide' section of the PDC website.

Disposition

Case Closed with Reminder

Date Opened

July 17, 2025

Areas of Law*

RCW 29B.25.090/42.17A.235, RCW 29B.25.100/42.17A.240, RCW 29B.30.050/42.17A.320

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

Documents

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