Pacific County Democratic Central Committee: Alleged violation of RCW 42.17A.235 and ,240 for failure to timely and accurately disclose contribution and expenditures (AUG'23, EY'23)

Case

#142009

Respondent

Pacific County Democrats

Complainant

Glen Morgan

Description

The Public Disclosure Commission (PDC) has completed its review of the complaint filed on August 30, 2023. The complaint alleged that the Pacific County Democratic Central Committee, a political committee, previously inactive and currently registered with the PDC, may have violated: (1) RCW 42.17A.235 & .240 for failure to timely and accurately file Summary Full Campaign Contribution and Expenditure reports (C-4 reports) disclosing a correct carry forward balance; and (2) RCW 42.17A.235 & .240 for failing to include contributor detail for in-kind contributions.

PDC staff reviewed the allegations; the applicable statutes, rules, and reporting requirements; the response provided by Treasurer Jennifer Manchester on behalf of the Respondent; the applicable PDC reports filed by the Respondent; 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 the discrepancy in the beginning balance and the omission of the address for vendors used in making in-kind contributions were unintentional and not done to conceal campaign information from the public. The committee has reported detailed information for vendors on current 2023 C-4 reports and has committed to continue to comply with this requirement in the future. Staff found no evidence that the Respondent purposely omitted information. Regarding the beginning balance, staff found that funds were collected prior to the Respondent meeting the definition of a political committee, was not yet required to register and report with the PDC and have since been identified.

Based on our findings staff has determined that, in this instance, failure to disclose an accurate carry forward balance and failure to include address information for vendors used to make in-kind contributions 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 disclosure of an accurate carry forward balance and failure to include the address for vendors used in making in-kind contributions. The formal written warning will include staff’s expectation that Pacific County Democratic Central Committee accurately files all future required reports of contributions and expenditures, including carry forward balances and detailed information regarding in-kind contributions. 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 this matter in accordance with RCW 42.17A.755(1).

Disposition

Case Closed with Written Warning

Date Opened

September 08, 2023

Areas of Law

RCW 42.17A.235, RCW 42.17A.240

Documents

• 142009 Pacific County Democratic Central Committee Warning - Respondent.pdf
• 142009 Pacific County Democratic Central Committee Complaint.pdf
• 142009 Pacific County Democratic Central Committee Response.pdf