Snohomish County Democrats: Alleged violation of RCW 42.17A.235 and .240 for failure to timely and accurately disclose contribution and expenditure information. (AUG'23, EY'18-EY23)

Case

#141707

Respondent

Snohomish County Democrats

Complainant

Glen Morgan

Description

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on August 21, 2023. The complaint alleged that the Snohomish County Democrats, a bona fide county party committee registered with the PDC during calendar years 2018, 2019, 2020, 2021, 2022 & 2023, may have violated RCW 42.17A.235 & .240: (1) for failure to timely file Monetary Contribution reports (C-3 reports) and Summary Full Campaign Contribution and Expenditure reports (C-4 reports) and; (2) RCW 42.17A.235 & .240 for failure to include detailed vendor information for in-kind contributions.

PDC staff reviewed the allegations and supporting documentation; the applicable statutes, rules, and reporting requirements; the response provided by Chair Monica Chilton and Treasurer Eric Valpey, on behalf of the Respondent; the applicable PDC reports filed by the Respondent; and queried the Respondent’s data in the PDC contribution and expenditure database, and other relevant information, to determine whether the record supports a finding of one or more violations.

It appears that although the Snohomish County Democrats did submit campaign reports late ranging from calendar year 2018 forward, many of the expenses were for party building activities, utilities and overhead. The late reported contributions made by the Respondent were mitigated by the fact that the recipients of those contributions timely disclosed them to the public before the election. Staff noted that the majority of reports filed in 2018 and discussed in the complaint are beyond the statute of limitations for any enforcement action.

Staff found no evidence that the Snohomish County Democrats purposely filed late or inaccurate campaign reports in order to conceal its activities from the public or adversely affect the outcome of previous elections.

Based on our findings staff has determined that, in this instance, failure to timely and accurately file campaign reports dating back from calendar year 2018 forward, including details of in-kind contribution activities, does not amount to a finding of a violation that warrants further investigation.

Pursuant to WAC 390-37-060(1)(d), however, the Respondent will receive a formal written warning concerning failure to timely and accurately file reports disclosing campaign activity. The formal written warning will include staff’s expectation that the Snohomish County Democrats timely and accurately files all future required reports of contributions and expenditures. The Commission will consider the 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 finds that no further action is warranted and has dismissed all allegations in this matter in accordance with RCW 42.17A.755(1).

Disposition

Case Closed with Written Warning

Date Opened

August 31, 2023

Areas of Law

RCW 42.17A.235, RCW 42.17A.240

Documents

• 141707 Snohomish County Democrats Response.pdf
• 141707 Snohomish County Democrats Warning - Respondent.pdf
• 141707 Snohomish County Democrats Complaint.pdf