State Regulators Warned Judge Ferguson-Brown Over Campaign Disclosures in 2023. Her Next Campaign Failed to Disclose Again.

Kitsap County Superior Court Judge Cadine Ferguson-Brown, a familiar presence in the Clallam County courthouse through her regular assignments as a visiting judge, drew campaign finance complaints in each of her last two judicial campaigns, according to Washington State Public Disclosure Commission records reviewed by The Olympic Herald.

The first complaint, filed during her unsuccessful 2023 bid to keep her Mason County seat, ended with a formal written warning. 

PDC staff told the judge they expected her "to timely and accurately disclose in-kind contributions on C-4 reports in future years."

The second complaint, filed one year later during her Kitsap County campaign, involved exactly that: an in-kind contribution missing from a C-4 report.

Her 2024 committee left the judge's $2,173.91 candidate filing fee off its public reports. Ferguson-Brown paid the fee personally, and the campaign disclosed it as an in-kind contribution only after PDC staff relayed the new complaint. 

Her campaign treasurer acknowledged in writing that the same flawed reporting approach had been used in the 2023 race as well.

The PDC dismissed both matters without fines or formal enforcement, finding the errors were corrected quickly and caused minimal harm to the public. 

But the paper trail, spanning two campaigns, two counties, and two years, documents a recurring problem that both complainants said the public deserved to see: money moving through a judge's campaigns without timely disclosure, corrected only after citizens complained.

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 PDC 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, Bob Rogers filed a complaint with the PDC alleging violations of RCW 42.17A.235 and .240, the statutes requiring timely and accurate reporting of campaign contributions and expenditures. 

Rogers 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, Rogers alleged the gap reflected "a willful disregard for the laws of the State of Washington."

The PDC'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 Rogers filed his complaint, the campaign amended the report to add $200.95 in food and décor. The PDC found those in-kind contributions were reported nine days late.

The larger sums surfaced later still. The campaign told the PDC 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 sub-vendor breakdown reached the public record in complete form on July 19, 2023, after the committee amended its May report to fix a PDC filing-system glitch. 

It disclosed $6,000 to Sullivan for management and consulting, $935 for the Colonial House venue, $450 for treasurer services, $175 for event insurance, $155.89 in website fees, and smaller items down to a $10 liquor permit, plus another $1,652 in new debts owed to the consultant.

Money had been spent on the campaign's behalf since at least mid-February. The public could not see most of it until midsummer.

PDC staff determined the failures did not amount to a violation warranting further investigation and dismissed the complaint under RCW 42.17A.755(1). 

Staff credited the committee for taking quick corrective action after learning of the complaint, for making a good-faith effort to comply, and noted the problems were resolved months before the election.

The dismissal, however, was not the end of it.

The Formal Warning

On July 24, 2023, PDC Compliance Officer Tabatha Blacksmith, endorsed by Executive Director Peter Frey Lavallee, issued Ferguson-Brown a formal written warning under WAC 390-37-060(1)(d) concerning her failure to comply with the filing requirements. 

The letter stated that the Commission would consider the warning in deciding on further action if there were future violations of PDC laws or rules, and reminded the judge about the importance of timely C-4 reports overall.

That November, Mason County voters removed Ferguson-Brown from the bench, favoring challenger David Stevens by roughly 15 percentage points. 

Weeks later, Governor Inslee appointed her to a vacant seat on the Kitsap County Superior Court, an appointment announced December 27, 2023 and effective January 1, 2024, a sequence this publication has examined before.

A New County, the Same Paperwork

To hold the Kitsap seat, Ferguson-Brown stood for election in 2024. No challenger filed against her. As an unopposed Superior Court candidate, she was automatically confirmed as the winner, and no election was held.

With no opponent and no ballot contest, the PDC's disclosure system was the public's principal window into the campaign. 

On July 2, 2024, the commission received a complaint alleging that window was incomplete.

The complainant this time was Glen Morgan, who alleged that Ferguson-Brown's campaign failed to report her candidate filing fee, which Washington law sets at one percent of the office's annual salary, as a campaign expenditure. 

The requirement is not new. Morgan attached a 1974 Attorney General opinion, AGO 1974 No. 16, concluding 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 the same omission had occurred in the 2023 Mason County campaign. He closed with a warning of his own: "The public is watching."

PDC staff confirmed the core allegation in Case 157172: the campaign's May 2024 report failed to include the filing fee. 

After staff flagged the missing information on July 23, 2024, the campaign amended the report on August 4, disclosing a $2,173.91 in-kind contribution from the judge herself. Morgan's estimate had matched the disclosed amount to the penny.

In a written response, campaign treasurer Oliver Brown apologized and said the campaign had relied on information that was "incorrect and misleading," specifically a belief that a filing fee paid from a candidate's personal funds did not need to be reported because it never touched campaign accounts. 

Brown acknowledged the campaign operated on that mistaken premise in both the 2023 and 2024 filing periods, said the committee never intentionally withheld information, and stated it had corrected its records, added PDC training, and consulted compliance experts.

On November 4, 2024, the PDC dismissed the complaint, characterizing the problems as "minor or ministerial errors" that did not materially harm the public interest, noting the corrections came within two weeks of notification, and treating the matter as a cured technical violation.

A Warning Without a Mention

What the November 2024 resolution letter does not contain is any reference to the formal written warning issued sixteen months earlier.

The 2023 warning was specific. It concerned the failure to timely and accurately disclose in-kind contributions on C-4 reports, and it stated the Commission would weigh the warning if future violations occurred. 

The 2024 matter involved an in-kind contribution, the judge's own filing fee, 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 Morgan and to Ferguson-Brown resolve the case as a technical correction and say nothing about the 2023 warning at all.

Why This Matters in Clallam County

Ferguson-Brown's rulings do not stay in Kitsap County. As this publication has documented, Clallam County court administrators regularly bring her into our 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 in these pages, from her bail decisions in Mason County to the sentencing alternative she granted 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 versions of the same argument 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.