ILWU 19 PAC Alleged violations of RCW 42.17A.235 & .240 for failure to timely and accurately disclose contributions and expenditures on reports (EY25 JUL25)

Case

#176605

Respondent

ILWU 19 PAC

Complainant

Conner Edwards

Description

The complaints alleged violations of RCW 42.17A.235 and .240 by failing to timely disclose expenditures on Summary Expenditure (C-4) Reports and contributions on Monetary Contribution (C-3) Reports. 

The Committee instead filed monthly reports covering July (filed Aug. 27, 2025) and August (filed Oct. 10, 2025). These reports were filed 22 days and 66 days after the 2025 Primary Election. Working with PDC staff, the Committee updated its PDC financial reporting program to report as participating in the election and filed its 21-day and 7-day pre-general C-4 reports timely. As noted in the complaint, the Committee received a $10,000 contribution from its sponsor on June 6, 2025, but failed to report the contribution until Aug. 27, 2025, 22 days after the 2025 Primary Election. In total, the Committee made $4,650 in contributions to PACs and Candidates during the 2025 election. The Committee has no prior PDC enforcement action. 

Summary and Resolution
Based on our findings, staff has determined that, in this instance, any violation that may have occurred was minor and has been cured. After consideration of the circumstances, further proceedings would not serve the purposes of this chapter. Under WAC 390-37-060, 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. 

Pursuant to WAC 390-37-060(1)(d), however, you are receiving a formal written warning concerning the failure to timely disclosure of all contribution and expenditures. PDC staff expects the PAC to timely file all future required reports of contributions and expenditures. The Commission will consider this formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Based on this information, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1).

Disposition

Case Closed with Written Warning

Date Opened

July 29, 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

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