Citizens for Schools Walla Walla PAC: Alleged violations of RCW 42.17A.235, .240 & .445 & WAC 390-16-037 for failure to timely & accurately report contributions & expenditures & personal use of contributions (EY18-20, Aug23)

Case

#142028

Respondent

Citizens for Schools - Walla Walla PAC

Complainant

Glen Morgan

Description

The complaint alleged that Citizens for Schools Walla Walla PAC violated RCW 42.17A.235 and .240 by failing to timely report contributions and expenditures and RCW 42.17A.445 for possible personal use of contributions based on reports that include discrepancies in balances carried from one report to the next report. The complaint also alleged that the Respondent failed to properly describe expenditures on reports.

The PDC has dismissed this matter in accordance with RCW 42.17A.755(1) and will not be conducting a more formal investigation into these allegations or taking further enforcement action in this matter. The treasurer for the PAC amended several C-4 reports to include more detailed descriptions of expenditures, as contemplated by WAC 390-16-037, as follows:

C-4 Report 8/1/18 – 8/31/18 Amended 10/12/23

On October 12, 2013, Ms. Riggs amended the C-4 report covering the reporting period 8/1/18 – 8/31/18, originally filed 9/9/18, by adding the number of T-Shirts purchased (100) for $653.40. The amended description was filed five years and one month late.
On the same amended C-4 report, the description for a $728.23 expenditure was corrected to disclose that 2,000 flyers were printed.

C-4 Report 9/1/18 – 10/15/18 Amended 10/12/23

On October 12, 2013, Ms. Riggs amended the C-4 report covering the reporting period 9/1/18 – 10/15/18, originally filed 11/18/18, by adding additional detail describing several expenditures, as follows:
$9,166.48 “1000 Yard Signs”
$359.37 “30 Parade Signs”
$3,063.23 “2000 Additional Yard Signs”
$597.74 “2000 Flyers in Spanish”
$1,034.65 “1000 Door Hangers”
$9,965.00 28 Ads for Oct & Nov” (In the Walla Walla Union Bulletin newspaper)
$1,508.00 “52 Radio Spots each: KHET, KWHT-FM, KWVN-FM, 10/17/18-11/6/18”
$979.00 “Postage for mailing 3573 Postcards”
$2,585.67 “Printing & Prep for 3573 postcards”

C-4 Report 12/1/18 – 12/31/18 – Amended 10/18/23

On October 18, 2013 Ms. Riggs amended the C-4 report covering the reporting period 12/1/18 – 12/31/18, originally filed 12/31/18, by adding additional detail describing several expenditures, as follows:
$378.00 “Rdio Ads 11/2-11/5/18 9 spots each: KUJ, KZIU, 104.5 BOB”
$1,451.38 “Postage for 2nd postcard mailing-5297”
$3,667.35 “Printing & prep of 2nd postcard mailing-5297”
In addition, the amended report for the period 12/1-12/31/18 included two additional expenditures:
$395.28 “Dumpter rental & refuse dispose of signs”
$92.00 listed under Non-Itemized expenditures. This was for the committee’s PO Box rental. What appeared to be a missing $92.00 was caused by not initially reporting the Post Office Box rental and was not a personal use of campaign funds.
By reporting these additional expenditures on the amended last report for 2018, the amount carried forward from Line 18, $2,752.05, now equals the Line 1 starting balance for the first C-4 report in 2019.

Late Reporting of C-4 Reports

The C-4 report covering the period 4/1/20 – 4/30/20 was filed three years and six months late. However, no contributions were received during this period and expenditures totaled $106.
The C-4 report covering the period 5/1/20 – 5/31/20 was filed three years and five months late. However, there were no contributions received or expenditures made.
Because the contribution and expenditure activity for these two reports did not exceed $200, the reports were not required to be filed.

However, pursuant to WAC 390-37-060(1)(d), PDC staff issued a formal warning concerning the committee’s failure to include the detailed expenditure descriptions contemplated by WAC 390-16-037. Staff expects Citizens for Schools Walla Walla to disclose the detailed expenditure descriptions contemplated by WAC 390-16-037 in future reports and to file C-4 reports timely and accurately. The Commission will consider the formal written warning in deciding on further Commission action if there are future violations of PDC laws or rules.

Disposition

Case Closed with Written Warning

Date Opened

September 08, 2023

Areas of Law

RCW 42.17A.235, RCW 42.17A.240, RCW 42.17A.445, WAC 390-16-037