Ladies of Liberty Tri-Cities: Alleged Violation of RCW 42.17A.205 for failure to register as a political committee (June 23; EY 23)

Case

#138402

Respondent

Ladies of Liberty Tri-Cities

Complainant

Joseph Gilmour

Description

On June 2, 2023, the Public Disclosure Commission (PDC) received a complaint alleging that Ladies of Liberty Tri-Cities, may have violated RCW 42,17A.205 by failing to register as a political committee.  

PDC staff reviewed your allegation; the Facebook attachments provided with the complaint; the applicable statute, rule(s), and reporting requirements; the June 14, August 11 and August 28, 2023, responses to the complaint provided by Hayley Hoyt on behalf of Ladies of Liberty Tri-Cities; and other relevant information to determine whether the record supports a finding of one or more violations. 

Based on staff’s review, we found the following:

The complaint alleged that Ladies of Liberty Tri-Cities, based on Facebook posts, hosted an event on May 10, 2023, and raised $3,000 in support of Semi Bird for Governor of Washington, without registering as a political committee pursuant to RCW 42.17A.205. You attached several Facebook posts as evidence of the alleged violation.

In its response to the complaint, received on June 14 and August 11, 2023, Ladies of Liberty Tri Cities, provided answers to written questions from staff, stating: “First of all, Ladies of Liberty is a SOCIAL GROUP that ANYONE can be a part of. We are NOT AFFILIATED with any political group. And we started this group in April of 2023. That’s 2 months ago…not 2 years ago as Mr. Gilmour states. We HOSTED an event at CG Public House (aka Country Gentleman restaurant) in Kennewick for Semi Bird on May 10th. (1) The COST OF THE EVENT WAS ZERO DOLLARS. It is stated several times in our advertisement to order food off of the restaurant menu. We did not rent the room or provide food or drink. (2) The Bird Campaign DID NOT give Ladies of Liberty of The High Heel Housewife any money or compensation to host this event. Therefore there was nothing to discount. There were however donation envelopes on the tables, so if guest wanted to donate to his campaign, they simply filled out the proper envelope, and donated. These were all given to his campaign manager to properly record and document. INDIVIDUAL donations reached $3,000. So again, Ladies of Liberty is a social club, NOT a political group.”

RCW 42.17A.005 defines political committee as “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.” Based on the evidence here, it appears that Ladies of Liberty Tri-Cities neither received contributions nor made expenditures in support of a candidate or ballot proposition. The Ladies of Liberty Tri-Cities was not the receiver of contributions when they hosted a function for the Semi Bird 2024 Campaign for Governor on May 10, 2023, since envelopes were put on the tables at the function for guests to donate to the Campaign individually, if they chose to do so. The Ladies of Liberty Tri[1]Cities hosted a social function and invited people to come order food from the restaurant menu, and a representative of the Bird campaign was present at the function/event to accept contribution checks. Those contributions were subsequently reported by the Bird campaign. 

Based on staff’s review of the complaint submitted, the written responses provided by the respondent, and the attachments provided by the complainant, no evidence was found to substantiate a violation of RCW 42.17A.205. 

PDC staff therefore determined that no evidence supported a finding of a violation warranting further investigation.

Accordingly, the PDC staff found that no further action was warranted and dismissed the complaint in accordance with RCW 42.17A.755(1). 

Disposition

Case Closed with No Evidence of Violations

Date Opened

June 14, 2023

Areas of Law

Areas of law not found

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