Twitty, Jeannette: Alleged violation of RCW 42.17A.220(4) by exceeding anonymous contribution limits. (EY '23; Aug '23)

Case

#141053

Respondent

Jeanette Twitty

Complainant

Glen Morgan

Description

This case alleged a violation of RCW 42.17A.220(4) by exceeding anonymous contribution limits.

PDC staff reviewed the allegations and evidence submitted; the applicable statutes, rules, and reporting requirements; the response(s) provided by Jeannette Twitty (the “Respondent”); the applicable PDC reports filed by the Respondent; and other relevant information to determine whether the record supports a finding of one or more violations.

Based on our attached findings, staff has determined that, in this instance, misclassifying monetary contributions as anonymous contributions, and failure to timely and accurately report contributions and expenditures are not violations that warrant further investigation.

On March 28, 2024, Jeannette Twitty completed a Statement of Understanding (SOU) and paid a $200 civil penalty in accordance with WAC 390-37-143 (Brief Enforcement Penalty Schedule), acknowledging violations of RCW 42.17A.220(4) by incorrectly classifying monetary contributions as anonymous contributions on C-3 reports for election year 2023. The $200 penalty assessed resolves the allegation regarding over-limit anonymous contributions listed in the complaint.

Furthermore, pursuant to WAC 390-37-060(1)(d), Jeannette Twitty received a formal written warning concerning her failure to timely and accurately disclose all contributions and expenditures on reports. This formal written warning included staff’s expectation that Jeannette Twitty will timely file accurate reports of contributions and expenditures in the future, especially during the time-sensitive periods before and after an election. The Commission will consider this formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

PDC staff reminded Jeannette Twitty about the importance of 1) maintaining accurate records of contributors per RCW 42.17A.235(6)(a); 2) monitoring anonymous contributions to ensure they do not exceed the limits set forth in RCW 42.17A.220(4); and 3) returning anonymous contributions prior to deposit if accepting them would cause the committee to exceed limits. Staff also reminded Ms. Twitty to submit amended reports within 21 days of the original filings, when possible; and include sufficient expenditure descriptions on C-4 reports, in accordance with the PDC laws, rules and guidance.

Based on this information, the PDC finds that no further action is warranted and has dismissed this matter in accordance with RCW 42.17A.755(1).

Disposition

Resolved through Statement of Understanding

Date Opened

August 14, 2023

Areas of Law

RCW 42.17A.220

Documents

Penalties

Total penalties: $200

Balance Due: $0

Twitty, Jeannette

Penalty

$200 (Statement of Understanding)

Payments

$200 on 03/28/2024 (PAID - SOU)