Lawrence Patrick Hughes: Alleged violations of RCW 42.17A.435 & .405(2) by concealing the actual identity of the contributor and by exceeding contribution limits (EY24 OCT24)

Case

#161712

Respondent

Lawrence Patrick Hughes

Complainant

Dmitri Iglitzin and Marina Multhaup, on behalf of Washingtonians for Ethical Government

Description

• Allegation: Violations of RCW 42.17A.435 & .405(2) for concealing his identity as the actual contributor & and for over the limit contributions 

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. However, PDC staff reminded Lawrence Patrick Hughes about the importance of clearly stating to the recipient of a campaign contribution to whom the contribution is to be attributed, unless it is obvious. PDC staff expects in the future that Mr. Hughes will identify to whom his contributions are to be attributed, unless it is obvious, in accordance with PDC laws and rules.

A complaint was filed by Marina Multhaup and Dmitri Iglitzin, on behalf of Washingtonians for Ethical Government alleging, in part, that Lawrence Patrick Hughes may have violated RCW 42.17A.435 by unlawfully contributing money under the name of a deceased person and RCW 42.17A.405(2) by, through that means, making contributions in excess of the contribution limits.

Applicable Laws & Rules

RCW 42.17A.235 and .240 require candidates and political committees to file timely, accurate reports of contributions and expenditures including the name and address of each person who has made one or more contributions during the period.

RCW 42.17A.435 states, “No contribution shall be made and no expenditure shall be incurred, directly or indirectly, in a fictitious name, anonymously, or by one person through an agent, relative, or other person in such a manner as to conceal the identity of the source of the contribution or in any other manner so as to effect concealment.”

Relevant facts are as follows:

• Lawrence Patrick Hughes made contributions in his name and in the name of his spouse, after she had passed away, to the 2024 campaigns of Let’s Go Washington, Dave Reichert, and Jaime Herrera-Beutler.

Lawrence Patrick Hughes, Case 161712

• According to Nathan Alexander, legal counsel for Mr. Hughes, Mr. Hughes and Mary Ellen Hughes (“Mrs. Hughes”), throughout their life together, consistently gave to a variety of charitable causes, including to political candidates and causes, and they frequently supported the same candidates/causes. After Mrs. Hughes’ passing in October 2023, Mr. Hughes continued his philanthropic efforts and political giving.
• Mr. Alexander stated that Mr. Hughes asked Chris Hendley, family assistant, to send out his usual checks for campaign contributions. Mr. and Mrs. Hughes had joined their finances during their marriage and issued checks bearing both of their names. He said Mr. and Mrs. Hughes’ usual practice was to donate their legal maximum together on one check. Though written in one amount on one check, the total was split in half and treated as their separate contributions, consistent with their individual legal contribution limits. Mr. Alexander noted that, due to Mrs. Hughes’ passing, many of Mr. Hughes’ unused checks still bore Mrs. Hughes’ name together with his own. He said when Ms. Hendley sent out Mr. Hughes’ “usual” donations, she sent out checks for $4,800—as she had previously done when Mrs. Hughes was alive. Mr. Alexander said these once-usual checks, unbeknownst to Mr. Hughes and Ms. Hendley, accidentally took Mr. Hughes’ contributions above the allowable level for 2024 for contributions to the Reichert campaign.
• Mr. Alexander stated that Mr. Hughes also issued a single $100,000 check to Let’s Go Washington Sponsored by Brian Heywood, on July 25, 2024, but because of Mr. Hughes’ joint donation history with Mrs. Hughes—and because Mr. Hughes’ checkbook still included her name—Let’s Go Washington Sponsored by Brian Heywood appears to have erroneously recorded that single $100,000 donation from Mr. Hughes as two $50,000 donations, one from Mr. Hughes and one from Mrs. Hughes. 
• Mr. Alexander stated that Mr. Hughes has been a frequent campaign donor for more than thirty years, and this is the first time he has been accused of making contributions over legal limits or of concealing a contribution’s source. He said Mr. Hughes had no intention of circumventing campaign finance law and that any overpayment was an honest mistake stemming from a simple misunderstanding between Mr. Hughes and his assistant during a time when Mr. Hughes was adjusting to his newfound life as a widower after 65 years of marriage. Mr. Alexander said everyone involved is confident that this first-time offense will be an only-time offense.

Disposition

Case Closed with Reminder

Date Opened

November 04, 2024

Areas of Law

RCW 42.17A.405, RCW 42.17A.435

Documents

• 161712 Combined Case Closure Letter.pdf
• 161712 Lawrence Patrick Hughes Complaint.pdf
• 161712 L.P. Hughes Response Letter to PDC.pdf