Karen Howe: Alleged violations of RCW 42.17A.235 & .240 for failure to timely and accurately report contributions and expenditures; and RCW 42.17A.320 for incomplete sponsor identification. (EY25 JUL25)

Case

#175382

Respondent

Karen Howe

Complainant

Conner Edwards

Description

The Public Disclosure Commission (PDC) completed its review of a complaint filed with the PDC.

Applicable Laws and Rules
Per RCW 42.17A.235 and .240, a candidate that selects the Full Reporting option on their registration report is required to report contributions and expenditures to the PDC on Cash Receipts Monetary Contributions reports (C-3 reports) and Campaign Summary Receipts & Expenditures reports (C-4 reports) pursuant to RCW 42.17A.235 & RCW 42.17A.240. The due dates for these reports are based upon the election cycle, the candidate election participation, and their financial activity.

Pursuant to RCW 42.17A.240(7), expenditures are disclosed on C-4 reports, which must include, but are not limited to: 1) the name and address of each person to whom an expenditure was made in the aggregate of more than $750 during the period covered by the report; 2) the amount, date, and purpose of each expenditure; and 3) the total sum of all expenditures. Purpose details should state the goods or services provided by the vendor, including the number of items purchased, identify any candidates or ballot propositions supported or opposed by the expenditure, and the name & address of any sub-vendors used. For advertising expenditures, campaigns should describe the type and number of ads, where they appeared or were broadcast, and when (e.g. run dates). An in-kind contribution is disclosed like an expenditure on the PDC’s Online Reporting of Campaign Activity (ORCA) software.

RCW 42.17A.320 requires that all political advertising supporting or opposing a candidate or ballot proposition includes the sponsor's name and address.  

Background and Findings

The Respondent filed a Candidate Registration (C-1) on March 9, 2025, amended April 28, 2025, for Council Member City Of Sammamish, as the Full Reporting option.
The April 2025 C4 was filed approximately 2 months late.
The Misc. Receipts filed in the January C-3, filed on July 3, 2025, is missing from a corresponding C-4 report.
The campaign website, located at https://electkarenhowe.com/ is missing complete sponsor identification. 

Summary and Resolution
Having reviewed the complaint and the supporting evidence, PDC staff has determined that the Respondent appears to have violated RCW 42.17A. After consideration of all the circumstances, further proceedings would not serve the purposes of the Fair Campaign Practices Act. Under WAC 390-37-070, the executive director, at any time prior to consideration by the Commission, may dismiss a complaint which on its face, or as shown by investigation, provides reason to believe that a violation has occurred, but also shows that the respondent is in substantial compliance with the relevant statutes or rules, or shows that formal enforcement action is not warranted. 

Based on this, the PDC has dismissed this matter in accordance with RCW 42.17A.755(1) and WAC 390-37-060(1)(d). PDC staff reminded the Respondent about the importance of timely reporting.  As well, the Respondent was reminded to be sure to submit the Misc. Receipts, reported in the C-3 report for January 2025, either by submitting a C-4 report for January 2025 or by adding to the March C-4 report and amending the reporting period. And the Respondent was reminded to update the campaign website to include the campaign address. The Respondent is expected to comply with PDC statutes and rules in the future.

Disposition

Case Closed with Reminder

Date Opened

July 09, 2025

Areas of Law*

RCW 29B.25.090/42.17A.235, RCW 29B.25.100/42.17A.240, RCW 29B.30.050/42.17A.320

*On January 1, 2026, RCW 42.17A was recodified to RCW 29B

Documents

• 175382 Karen Howe Complaint.pdf