The Pierce County Superior Court invalidated a Washington campaign finance law requiring free legal advice given to a recall campaign to be treated as a reportable campaign contribution. Judge Katherine Stolz reasoned pro bono representation in civil rights cases would be threatened if such representation must be reported as a campaign contribution and therefore subject to applicable state political contribution limits.

As a result of the ruling, the Public Disclosure Commission cannot cap legal services to political committees in a federal civil rights case, nor can it compel political committees to report free legal services as campaign contributions.