Kitsap County Superior Court Judge Cadine Ferguson-Brown, who regularly serves as a visiting judge in Clallam County, has been the subject of campaign finance complaints in each of her last two runs for office, according to records from the Washington State Public Disclosure Commission.
A complaint filed during her unsuccessful 2023 effort to retain her Mason County seat resulted in a formal written warning.
Commission staff informed the judge they expected her "to timely and accurately disclose in-kind contributions on C-4 reports in future years."
A subsequent complaint, lodged a year later during her Kitsap County campaign, concerned precisely that issue: an in-kind contribution that was missing from a C-4 report.
Her 2024 committee did not include the judge's $2,173.91 candidate filing fee in its public filings. Ferguson-Brown covered the cost herself, and the campaign reported it as an in-kind contribution only after commission staff forwarded the new complaint.
Her campaign treasurer later acknowledged in writing that the same reporting practice had been employed in the 2023 race.
The commission closed both cases without imposing fines or formal enforcement actions, determining that the errors were corrected promptly and caused minimal harm to the public.
The record, which spans two campaigns, two counties, and two years, documents a recurring issue that both complainants said the public needed to see: funds moving through a judge's campaigns without timely disclosure, corrected only after citizens raised the matter.
A Campaign the Public Couldn't See
By early 2023, Ferguson-Brown, then a Mason County Superior Court judge first appointed by Governor Jay Inslee in 2022, was running a visibly professional operation to keep her seat.
Her committee registered with the commission on January 30, 2023. A campaign website domain was registered on February 17. A contract treasurer and a professional consultant, Sullivan Campaign Services, were on board.
On April 14, the campaign held a kick-off event at the Colonial House in Shelton, a paid venue, where food was served.
Almost none of it appeared in the campaign's public reports.
On May 15, 2023, a complainant filed a complaint with the commission alleging violations of RCW 42.17A.235 and .240, the statutes requiring timely and accurate reporting of campaign contributions and expenditures.
The complainant noted that another judicial candidate using the same consultant and the same treasurer, Thurston County Superior Court candidate Anne Egeler, had reported more than $6,000 in itemized expenses over the same period, while Ferguson-Brown's filings showed nothing comparable.
Given the professionals involved, the complainant alleged the gap reflected "a willful disregard for the laws of the State of Washington."
The commission's review, documented in its July 24, 2023 resolution letter in Case 136778, confirmed the reporting gaps while accepting the campaign's explanations for most of them.
The campaign's April C-4 report, filed May 11, was one day late and omitted three in-kind contributions tied to the kick-off event.
Four days after the complaint was filed, the campaign amended the report to add $200.95 in food and décor. The commission found those in-kind contributions were reported nine days late.
The larger sums surfaced later still. The campaign told the commission that its consultant had been fronting expenses for months and did not bill the committee until late April, when Sullivan Campaign Services delivered a combined invoice the treasurer put at $6,315.89.
The full breakdown of sub-vendor payments entered the public record on July 19, 2023. This occurred after the committee revised its May report to address a filing-system error within the Public Disclosure Commission (PDC) system.
The records listed $6,000 paid to a consultant for management and advisory services. Other expenses included $935 for a venue rental, $450 for treasurer services, and $175 for event insurance. Website fees amounted to $155.89, while additional costs were recorded down to a $10 liquor permit. The committee also reported $1,652 in outstanding debt owed to the consultant.
Expenditures for the campaign began no later than mid-February, though the public did not see the majority of this spending until midsummer.
PDC staff concluded that these failures did not warrant further investigation regarding a violation. They dismissed the complaint under RCW 42.17A.755(1). Staff noted that the committee acted quickly to correct the issues after learning of the complaint and made a good-faith effort to comply. The problems were resolved months prior to the election.
Formal Warning
On July 24, 2023, PDC Compliance Officer Tabatha Blacksmith issued a formal written warning to a judge regarding her failure to meet filing requirements. This action was endorsed by Executive Director Peter Frey Lavallee. The warning was issued under WAC 390-37-060(1)(d).
The correspondence indicated that the Commission would consider this warning when evaluating future actions concerning violations of PDC laws or rules. It also emphasized the necessity of submitting C-4 reports on time.
That November, Mason County voters removed the judge from the bench. Challenger David Stevens won by a margin of roughly 15 percentage points. Weeks later, Governor Inslee appointed her to a vacant seat on the Kitsap County Superior Court. This appointment was announced on December 27, 2023, and became effective January 1, 2024.
A New County, Same Requirements
To retain the Kitsap seat, the judge ran for election in 2024. No challenger filed against her. As an unopposed candidate for Superior Court, she was automatically declared the winner without a ballot contest.
With no opponent and no ballot contest, the PDC's disclosure system served as the primary source of information regarding the campaign.
On July 2 2024, the commission received a complaint alleging that this disclosure system was incomplete. The complainant was Glen Morgan. He alleged that the campaign failed to report the candidate filing fee as a campaign expenditure. Washington law requires that this fee be set at one percent of the office's annual salary.
The requirement is not new. Morgan attached a 1974 Attorney General opinion, AGO 1974 No. 16, which concluded that candidates must treat filing fees as reportable expenditures under the disclosure law voters enacted by initiative in 1972.
He estimated the fee at $2,173.91 and alleged that the same omission had occurred in the 2023 Mason County campaign. He concluded with the statement: "The public is watching."
PDC staff confirmed the allegation in Case 157172. The May 2024 report for the campaign did not include the filing fee. After staff flagged the missing information on July 23, 2024, the campaign amended the report on August 4. The amendment disclosed a $2,173.91 in-kind contribution from the judge herself. Morgan's estimate matched the disclosed amount to the penny.
In a written statement, the campaign treasurer offered an apology and explained that the committee had relied on guidance deemed "incorrect and misleading." Specifically, the campaign operated under the assumption that filing fees paid from a candidate’s personal finances did not require reporting, as they did not pass through campaign accounts.
The treasurer acknowledged that this erroneous premise was applied during both the 2023 and 2024 filing periods. He stated that the committee had no intent to withhold information, has corrected its records, and has since engaged in compliance training and sought advice from experts.
A Warning Without a Mention
On November 4, 2024, the Public Disclosure Commission (PDC) dismissed the complaint. The agency characterized the issues as "minor or ministerial errors" that did not cause significant harm to the public interest, noting that corrections were made within two weeks of notification, thereby resolving the matter as a cured technical violation.
The resolution letter dated November 2024 makes no reference to a formal written warning issued sixteen months prior. That 2023 warning specifically addressed the failure to disclose in-kind contributions on C-4 reports on time and accurately, and stated that the Commission would consider the warning should future violations occur.
The 2024 matter involved a judge's filing fee, an in-kind contribution, missing from a C-4 report.
Whether PDC staff considered the earlier warning is not reflected in the written record. The resolution letters sent to the parties involved resolve the case as a technical correction and do not mention the 2023 warning.
Why This Matters in Clallam County
Rulings made by the judge in question are not limited to Kitsap County. As previously documented, Clallam County court administrators regularly bring her into the local courthouse as a visiting judge, where she has presided over sensitive criminal and civil matters.
Her judicial record is already the subject of ongoing scrutiny, from her bail decisions in Mason County to the sentencing alternative granted to a Silverdale child molester last month.
Campaign finance disclosure is a different kind of record, but it rests on the same principle.
Washington voters adopted the disclosure law on the premise that the public is entitled to know who pays for political campaigns, including campaigns for the bench.
Both complainants made similar arguments in their filings: undisclosed spending keeps the public from seeing who is financing a judicial candidate, and judges, of all candidates, should be expected to follow the rules they enforce on everyone else.
The through line is difficult to miss. In two consecutive campaigns, in two counties, the complete picture of Ferguson-Brown's campaign finances reached the public only after citizens filed complaints.
A committee formally warned in July 2023 to timely and accurately disclose in-kind contributions produced its next undisclosed in-kind contribution within a year.
The formal warning remains on file with the Commission, to be considered if there is a next time.
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