Automotive United Trades Organization, V Washington Public Discl

CourtCourt of Appeals of Washington
DecidedMay 14, 2019
Docket50652-1
StatusUnpublished

This text of Automotive United Trades Organization, V Washington Public Discl (Automotive United Trades Organization, V Washington Public Discl) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Automotive United Trades Organization, V Washington Public Discl, (Wash. Ct. App. 2019).

Opinion

Filed Washington State Court of Appeals Division Two

May 14, 2019

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

DIVISION II

AUTOMOTIVE UNITED TRADES No. 50652-1-II ORGANIZATION, a Washington nonprofit corporation,

Appellant,

v.

WASHINGTON PUBLIC DISCLOSURE UNPUBLISHED OPINION COMMISSION, an agency of the State of Washington,

Respondent.

LEE, J. — The Automotive United Trades Organization (AUTO) issued a citizen’s action

notice in which it accused Attorney General Bob Ferguson’s political campaign committee of

violating Washington’s campaign contribution laws. The Washington Attorney General’s Office

(AGO) and the King County Prosecuting Attorney’s Office (KCPAO) declined to act on this

citizen’s action notice; instead, they sent the Washington Public Disclosure Commission (PDC)

letters informing the PDC that it could take action on AUTO’s citizen’s action notice if it desired.

The PDC similarly declined to take action on AUTO’s citizen’s action notice, and sent a

letter to AUTO, the AGO, and the KCPAO detailing its decision. Nearly 60 days after receiving

the PDC’s letter, AUTO filed a petition to review the agency’s action under the Administrative

Procedure Act (APA). AUTO also filed a complaint claiming that the PDC violated the Open No. 50652-1-II

Public Meetings Act (OPMA) by not posting its citizen’s action notice on its regularly scheduled

meeting agenda. The superior court dismissed AUTO’s petition and complaint on summary

judgment.

AUTO appeals the superior court’s dismissal of its claims on summary judgment. We

affirm.

FACTS

A. AUTO’S PETITION FOR RULEMAKING

AUTO is a nonprofit trade association comprised of motor fuel retailers and suppliers doing

business in Washington State. AUTOMOTIVE UNITED TRADES ORGANIZATION,

http://www.autowa.org/index.html (last visited May 8, 2019). In February 2016, AUTO filed a

petition for rulemaking with the PDC, a state agency responsible for monitoring political

campaigns, candidates, and lobbyists, and enforcing Washington’s campaign finance disclosure

laws.

AUTO’s petition asked the PDC to adopt a new rule that would define political

contributions received from tribal governments as “public funds” under Washington’s campaign

disclosure and contribution laws. Clerk’s Papers (CP) at 33. In March 2016, the PDC denied this

request.

B. AUTO’S CITIZEN’S ACTION NOTICE

In May 2016, AUTO sent to the AGO a citizen’s action notice, which alleged that the

Friends of Bob Ferguson (Attorney General Bob Ferguson’s reelection campaign) had violated

campaign contributions laws by receiving contributions from Indian tribes. Because this citizen’s

2 No. 50652-1-II

action notice involved the Attorney General’s reelection campaign, the AGO had a conflict of

interest and declined to participate.

The AGO sent to the PDC and the KCPAO a letter explaining the conflict and informing

the PDC that it could act on AUTO’s citizen’s action notice under RCW 42.17A.130, which

authorizes the PDC “ ‘to carry out any function of the attorney general prescribed by this chapter.’

” CP at 36 (quoting RCW 42.17A.130). The AGO sent a copy of this letter to AUTO.

The AGO claimed that RCW 42.17A.765 authorized the local prosecutor to also act on its

citizen’s action notice.1 But the KCPAO declined to take action on AUTO’s citizen’s action

notice. The KCPAO sent a letter to AUTO and the PDC explaining its decision and stating that

the “PDC has primary enforcement authority in this area.” CP at 38.

The PDC discussed both the AGO’s and the KCPAO’s letters at its next regular meeting

on May 26. The posted meeting agenda for the May 26 meeting did not specifically identify

AUTO’s citizen’s action notice as a topic. However, the meeting agenda did identify “Follow Up

From Prior Meetings” and “Enforcement” as topics. CP at 54.

During the May 26 meeting, the PDC members debated whether the agency had statutory

authority to act on AUTO’s citizen’s action notice. The Executive Director of the PDC did not

1 Former RCW 42.17A.765 (2010) authorized the local prosecutor’s office to act on a citizen’s action notice for violation of campaign disclosure and contribution laws. In 2018, the legislature amended chapter 42.17A RCW and added a new section governing citizen’s actions based on violations of campaign disclosure and contribution laws. RCW 42.17A.775. Under RCW 42.17A.775, “a person must notify the attorney general and the commission that he or she will commence a citizen’s action within ten days if the commission does not take action or, if applicable, the attorney general does not commence an action.” RCW 42.17A.775(3). “Commission” is defined as the Public Disclosure Commission. RCW 42.17A.005(12); RCW 42.17A.100.

3 No. 50652-1-II

believe that the PDC could “stand in the shoes of the Attorney General” in this situation. CP at

132. Nonetheless, she explained that she “could ignore [her] feelings about what the statute says”

and send a letter to AUTO explaining that the PDC was not going to take any enforcement action

based on its citizen’s action notice. CP at 132.

On June 17, the PDC sent AUTO a 6-page letter explaining that the PDC was not going to

act on AUTO’s citizen’s action notice (June 17 letter). AUTO received the PDC’s letter on June

20. The letter first explained that the AGO and the KCPAO had deferred to the PDC on whether

to act on AUTO’s citizen’s action notice. The letter then addressed the merits of AUTO’s

grievance and explained in detail that political campaign contributions from Indian tribes are not

considered “public funds” by statute. CP at 108. As a result, the PDC concluded that the Friends

of Bob Ferguson had not violated Washington campaign finance laws by accepting contributions

from Indian tribes. The letter also stated that “[t]he PDC does not plan to commence an action

pursuant to RCW 42.17A.765(4).” CP at 112. The AGO, the KCPAO, and the Friends of Bob

Ferguson Campaign were copied on this letter.

C. AUTO’s LITIGATION AGAINST FRIENDS OF BOB FERGUSON

On July 6, 2016, AUTO filed a citizen’s action against Friends of Bob Ferguson. On

August 31, Friends of Bob Ferguson sent AUTO a letter explaining that AUTO’s claims were

contrary to Washington law and brought without a reasonable basis. The letter referenced the

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