To: Maureen Riordan, Voting Section Acting Chief
US Department of Justice - Voting Rights Division
950 Pennsylvania Avenue NW
Washington DC 20530

RE: Complaint against Washington Governor Bob Ferguson for violating Federal Election Laws

Sent PDF via email to: This email address is being protected from spambots. You need JavaScript enabled to view it.

Dear Ms Riordan,

The Washington Parents Network is a group of several thousand registered active voters in Washington state. We are concerned about our votes being diluted by hundreds of thousands of non-citizens being registered to vote in Washington state in violation of federal election laws. In this complaint, we provide evidence from the federal Election Assistance Commission 2024 report that Washington state likely has the least accurate voter rolls in the nation.

We believe this problem stems in part from the Washington legislature passing House Bill 2595 in 2018 allowing for Automatic Voter Registration (AVR) when a person obtains a Washington Drivers License at the Washington Department of Licensing (DOL).

While this law was intended to automatically register only US citizens, there is abundant evidence that this AVR law has been used to register hundreds of thousands of non-citizens in our state. For example, Section 202 (3) (e) of this Washington law provides: “Verification of citizenship information, via social security administration data match or manually verified by the agency during the client transaction.”

However, a recent study of Washington voters in 29 out of our 39 counties in Washington state concluded that more than 700,000 Washington voters have Washington Drivers Licenses but no Social Security number. More than 25,000 voters did not have either a Drivers License or a Social Security number. https://www.youtube.com/watch?v=CGU5sU9bfxg

Here is a quote from Glen Morgan who reported this study:

“Based on a review of 29 (out of 39) counties and nearly a million registered active voters, it appears that 14% or more of Washington State's voter rolls are not compliant with Federal law. This would be about 709,000+ voters, and it could be far worse. Missing social security numbers means the Secretary of State's claim that they use the Social Security Administration data to "verify" voter data is false and deceptive. Missing BOTH SS numbers AND Driver's License info (25,000+/- voters) means there is zero verification they exist at all. Finally, this doesn't include the massive number of social security numbers that have been handed out like candy at a parade to non-US citizens so they could obtain Apple Health and SNAP benefits on the taxpayer dime. “

Foreign Exchange Students registered to vote when getting a Drivers License
I, David Spring, personally host students from Japan who wish to learn English and take courses at a local College. They entered our state legally with student visas. However, because they want to drive while in our state, they went to the Washington DOL to obtain a Washington Drivers License. Several of these students have been illegally registered to vote by the Washington DOL Automatic Voter Registration program - even though they clearly are not US citizens, they do not speak English very well and they did not sign a statement swearing to be a US citizen as required by federal election laws.

Statistical Analysis also confirms Washington state has a growing problem with non-citizen voters
The Washington Secretary of State posts voter transactions that include not only monthly reports but also annual reports going all the way back to 2007. You can view these tables at this link:

https://www.sos.wa.gov/elections/data-research/reports-data-and-statistics/monthly-voter-registration-transactions

I used statistical analysis analysis of this data to estimate that the size of the non-citizen voter problem was between 500,000 to 1 million non-citizen voters that could not be accounted for by the normal population growth here in Washington state. Here is this analysis using the Secretary of State Voter Transactions table displayed at the above link and shown in the table below:

You can see from the highlighted line above that the year 2020 was extremely unusual. Motor Vehicle and Online Transactions that year combined for 1 million transactions. Click on the plus sign to show the monthly transactions and you will see that most of these transactions occurred in September and October of 2020. Compare this total to 2024 when they combined for 900,000 – 100,000 less than 2020 despite a growth in population.

Also look at 2008. When combining the two columns on the right, there was only 245,000 transactions. In 2012, there was a 50% jump to 400,000 transactions (despite a population increase of about 5%). And in 2016, there was an unexpected jump to 760,000 – nearly a 100% increase despite a 5% population gain. Then in 2020, there was a 1 million increase for a 30% jump - despite only a 5% population gain. Here is a graph of Registration Transactions by Month over a period of years:

In short, there were about 300,000 more registration transactions in July through October 2020 compared to prior years. This was despite the fact that there was no change in the rate of population increase from 2008 to 2020. This change is well outside of what can be explained by normal or random statistical variation for such a large sample size.

Here is a graph of total Registration Transactions from 2008 to 2024:

Note that these transactions include more than merely new registrations. Still, this distribution is also well outside of what can be explained by normal or random statistical variation for such a large sample size.

Huge increase in Voter Registrations after passage of the Washington State Automatic Voter Registration law
Here is a table of the increase in registered voters during the past 7 Presidential elections in Washington state:

Year	Registered Voters	Increase over previous Presidential election # (%)
2000	3335714	257506 (8.4%)
2004	3508208	172494 (5.2%)
2008	3630118	121910 (3.5%)
2012	3904959	274841 (7.6%)
2016	4270270	365311 (9.4%)
2020	4892871	622601 (14.6%)
2024	5017620	124749 (2.5%)

Source: https://www.sos.wa.gov/elections/data-research/voter-participation-statistics
Here is a graph of changes in the number of Registered voters going back to 2000:

The average change in population between Presidential elections was about 5 percent.

This was also the average rate of voter registration increases. The 2016 increase was at the outside edge of what can be explained by random statistical variation for such a large sample size. The 2020 increase is way outside the range of what could be explained by normal or random statistical variation for such a large sample size

It does not take a statistical expert to see that none of these graphs are statistically possible – and it got much worse peaking with the 2020 election. We do not need to look far for an explanation. Here is the note just below the Table on the Secretary of State website:

“Prior to 2008, Motor Vehicle registrations involved the Department of Licensing providing a form that customers could return if interested in registering to vote. In early 2008, DOL began electronically transmitting customer information to the Secretary of State, requiring no effort on the part of customers that wished to opt in. In July of 2019, Automatic Voter Registration (AVR) was implemented and individuals applying for or renewing an Enhanced Washington Driver’s License or Identification card are automatically registered to vote or have their registration information updated unless they opt out.”

Federal law requires that voters affirmatively swear that they are US citizens in order to register to vote. Automatically registering everyone who applies for a license without this affirmative statement is a violation of federal law.

Other examples of highly unusual Washington Voter Registration data

In Washington, an additional one million total ballots were counted in the 2020 Presidential Election (4 million ballots versus 3 million ballots) – an increase of 33% - despite a population increase of only 5% since 2016. Mail In Ballots increased by 33% as Washington is an All Mail In Ballot state – over six times the rate of population growth. Keep in mind that even the 15% increase in Registered voters was outside the range of values. The maximum that can be explained by normal variation is 10% and the expected increase is 5% of 4 million which is 80,000. So the increase of 1 million implies that 900,000 unexplained ballots were counted in the 2020 Washington state general election.

There is a well known principle in statistics called “Regression to the Mean.” It means that the larger the sample size is, the more likely values will tend towards the average. Washington state has a huge number of voters. Thus, there should be very little variation in the trend lines. The fact that there have been huge variations in the trend lines of voter registrations and name changes in recent years is evidence that something is very wrong with our voter rolls.

2004 to 2020 Washington Presidential Election Ballots
We can compare elections over time to see if there is a change in the trend line of the ballots to population ratio. The average of the previous 4 Presidential elections was 3 million votes plus or minus 100,000 votes. The 2020 election suddenly skyrocketed by a million ballots to an amazing 4 million votes. This dramatic change can not be explained by a population increase because Washington’s population growth rate has not changed much over this period (it has increased by about 100,000 per year):
2004 6.1 million
2008 6.5 million
2010 6.7 million Census confirmed
2012 6.9 million
2016 7.3 million
2020 7.7 million Census confirmed

But a closer look at the data reveals an even more ridiculous set of facts. Here is a summary of voter registration increases and Mail In Ballot increases compared to population increases in Washington state since 2016.

From 2016 to 2020, the Washington State population rose from about 7.3 million to about 7.7 million – an increase of about 400,000 or about 5%. According to the US 2020 Census, 21% of the Washington State population is under 18. Therefore the increase in the voting age population was .79 x 400,000 or 316,000.

During this same time, the number of registered voters rose from 4.27 million to 4.89 million – an increase of about 620,000 or 13%. In short, all 316,000 of the new voting age population who moved to Washington State between 2016 and 2020 registered to vote - PLUS an additional 303,000 people who already lived here registered to vote. In addition, 530,000 of the 620,000 or 85% of this increase occurred in a single year – 2020.

Even more remarkable, during this same time, the number of ballots counted rose from 3,363,440 in the 2016 General Election to 4,116,894 in the 2020 General Election – an increase of 753,454 ballots or 18.3%.

Even more remarkable, during this same time the number of ballots in the Presidential Race rose from 2,964,465 in 2016 to 3,954263 in 2020 – an increase of 989,798 ballots or 33%. Even if every new voting age person was registered to vote, an increase of 316,000 in new registered voters times an 80% turn out rate would lead to 0.8 x 316,000 or 253,000 additional ballots. Yet the actual increase in the 2020 Presidential race was 989,798 additional ballots. Thus, there appears to be 500,000 to 700,000 additional Mail In Ballots in 2020 - even after accounting for the increase in population – which is completely out of the trend line for any election in Washington state for the past 20 years.

This leads to an obvious question: How could the actual increase in the number of Presidential ballots in 2020 be more than six times the increase in state population? Where did the unexplained 500,000 to 700,000 additional ballots counted come from?

Recent Federal Election Reports also confirm highly unusual data for Washington State voter registrations

Every two years, the federal Election Assistance Commission (EAC) publishes reports on voter registrations in all 50 states as well as every county in all 50 states. To view these reports, go to this link and scroll down the page:

https://www.eac.gov/research-and-data/studies-and-reports

The EAC Report PDFs provide data on all 50 states. To see the county data, download the Excel Spreadsheets. We will begin with the 2024 report which can be downloaded directly at this link. At about page 200 of the 2024 EAC report, you will see the following Table 4 Voter List Maintenance — Confirmation Notices:

Washington sent confirmation notices to 23% of active voters – similar to the national average of 19.5% of active voters. However, while the national valid response rate with Address Update (2.9%) and without Address Update (4.4%) totals 7.3%, the valid response rate in Washington is much less than 1%.

This fact confirms that Washington has a huge percent of voters with bad addresses on their voter rolls.

In the last column in the table above, it appears that Washington also has a low percent of invalid responses. However, this is only because Washington has the highest rate of Unreturned confirmation notices in the nation – a fact shown on the following table:

While the national average for unreturned notices is 69.7%, the Washington rate is 98.3% - highest in the nation. This fact is evidence that Washington state has the least accurate voter roll addresses in the nation.

Despite having a huge percent of non-returned confirmation notices, Washington has a very low percent of voters removed from the rolls. The national average is 9.1% and the rate in Washington is only 6.5% - as is shown on the following table:

Table 5 of Voter List Maintenance – Removal Actions:

The above table also confirms that while the national average rate for removals due to the voter moving is 30.8%, the rate in Washington for voter moving removals is only 9.8%.

Washington also has a very high percent of confirmation notices returned where the new voter asked to be removed from the voter rolls. While the national average voter request for removal is only 2.6%, in Washington state it is an amazing 20.2% - second highest in the nation – with only Oregon having a higher rate of 22.1% (Note that Oregon has Automatic Voter Registration like Washington and appears to have problems similar to Washington in terms of registering huge numbers of non-citizens.

In Washington state, in 2024, 73,581 people – all of whom were likely automatically registered to vote while getting a drivers license – but who were almost certainly non-citizens, returned their voter registration confirmation card requesting to be removed from the voter rolls – as is shown on the following table:

The fact that Washington has such a huge rate of voter requests is clear evidence that Washington is registering non-citizens who do not want to be on the voter rolls. But keep in mind, 73,581 is only the ones who returned the confirmation cards. It is likely that there are also huge numbers of non-citizens who did not provide a valid address and therefore never got a confirmation card in the first place and are thus still on the Washington voter rolls..

Also, these problems were not limited to 2024. They are also present in the 2022 EAC report. For example, in the 2022 report, the unreturned confirmation notice rate nationally was 57.4% but in Washington was 98.1% (again highest in the nation). The voter request removals nationally were 4.5% - but 15.5% in Washington and 24.2% in Oregon. https://www.eac.gov/sites/default/files/2023-06/2022_EAVS_Report_508c.pdf

To see whether these problems are limited to certain counties in Washington state, we need to download the Excel Spreadsheet. To download the 2024 spreadsheet, go to this link:

https://www.eac.gov/research-and-data/studies-and-reports

Then click on 2024 plus sign and download the EAVS excel spreadsheet released on June 30, 2025. To understand the columns, you will also need to download the EAVS Data Codebook. To simplify matters, copy and paste only the Washington 39 counties into a new spreadsheet and then relabel the table columns to plain English using the Data Codebook. Then highlight King County and Pierce County. You will see that while King County had 78,080 DMV new registrations, King County also had a huge number of DMV Duplicate voter registrations - 56,377 to be exact. Pierce County DMV also has a problem with 25,978 Duplicate voter registrations.

King County removed 89,796 voters with only 6001 removed due to having moved. This is ridiculous. The national average is about 30% moved – so King County should have had about 30,000 moved – not just 6000. The actual rate in King County was only one fifth what it should have been.

Pierce County removed 45,851 voters with only 4704 having moved – this is also ridiculous but not as ridiculous as King County. Pierce County should have had about 15,000 moved not 4704. The actual rate in Pierce County was only one third of what it should have been.

King County Voter Request removals was 25,278 and Pierce County Voter Request removals was 7,666. These were both about ten times what they should have been.

While there are also significant problems with several other counties, the spreadsheet confirms that the biggest inaccuracies are in King County and to a lesser extent in Pierce County. This indicates that the primary source of the inaccurate voter roll problems in Washington state are the King County Department of Licensing and to a lesser extent, the Pierce County Department of Licensing.

US Census Data confirms we have a growing problem with non-citizen voters
One weakness of both the study provided by Glen Morgan and my statistical analysis is that neither study can be connected directly to non-citizens being registered. These unexplained voters could also be due to “ghost” voters or voters who do not actually exist but are inserted into the voter rolls by people interested in using these non-existent voters to artificially rig elections.

To correct for this problem, I published a study of non-citizens living here in Washington state according to the US Census Bureau. Here is a link to this report: https://washingtonfamilyrightscoalition.org/lessons-from-past-failed-initiatives/problems-with-the-washington-voter-id-initiative

Scroll down to Problem #8 to read this study. Here are quotes from this study: “According to the US Census, about 600,000 people living in Washington state are foreign born and not US citizens. Next, we need to estimate the percent of non-citizens registered to vote in our state. This unfortunately is going to be a very high figure since our Department of Licensing is registering voters automatically when they get a drivers license.”

“A detailed study published in 2024 estimated that 10% to 27% of illegal aliens are registered to vote in the US. While others have criticized this study and claimed that the actual number is 1% to 10% of illegal aliens registering to vote, I have reviewed the 2024 study and concluded it was accurately done. Given how bad things are here in Washington, with the Washington Department of Licensing automatically registering non-residents, I estimate that 20% of non-residents are being registered to vote here in Washington. This would put the number of non-resident registered voters in our state at 120,000.”

However, it could be as high as 600,000 to one million, given that there are huge numbers of illegal aliens in our state not in the US Census data.

Understanding the Source or Cause of the problem
Glen Morgan correctly identified the cause of the problem as the Washington State Department of Licensing. Here is his cartoon about what happens there:

Compare Glen’s cartoon to my cartoon about the Washington State Department of Licensing:

Additional evidence of non-citizens registered to vote at the Washington Department of Licensing

Glen Morgan also stated during his YouTube report that he has spoken with foreign exchange students who have automatically been registered to vote in our state. Several comments displayed during his video confirmed that this problem is widespread in Washington state.

Jury rejection letters:

On August 11, a viewer of We the Governed posted the following comment:

“I had jury duty, when they announced that Non Citizens could not server on a jury, 30 people out of 100 had to leave. These pools are filled from the voter rolls.”

Another viewer posted the following comment: “I house foreign college students. My Chinese student has been gone almost 3 years and I just received a Jury duty summons for her in my mailbox. You have to be registered to vote to get Jury duty!”

Another viewer named Rob Wastman posted the following comment:

“We get a ballot every election for a Chinese National student who lived with us for awhile. They registered him when he got his Washington ID. Although this ballot is never used, how many of them are out there? Enough to sway an election?”

There is an annual contest on social media in Washington state to see who can get the most ballots sent to them. The current record is a woman from Bellevue Washington who received 16 ballots addressed to her apartment number with different names on them.

Automatic Voter Registration Law provides no penalty for registering Non-citizens
Section 203 (2) of the 2018 Washington Automatic Voter Registration law states in part: “a person who is ineligible to vote and becomes registered to vote under section 102 or 201 of this act, and subsequently votes or attempts to vote in an election held after the effective date of the person's registration, is not guilty of violating RCW 29A.84.130, and shall be deemed to have performed an authorized act…”

Thus, the Automatic Voter Registration Act clearly violates federal laws by allowing non-citizens to vote without any penalties.

Federal laws violated by Washington State
On June 6, 2025, the US Department of Justice filed a 14 page Amicus brief in the US District Court, District of Oregon, Eugene Division, in a similar case called Judicial Watch v Tobias Read (current Oregon Secretary of State). Because Oregon Automatic Voter Registration problems are similar to the Washington Automatic Voter Registration problems, we will review this Oregon complaint. The case was previously called Judicial Watch, Inc. et al v. Griffin-Valade (previous Oregon Secretary of State). Here is a link to the US Department of Justice June 6 2025 brief: https://www.justice.gov/opa/media/1402891/dl?inline

Here are quotes from this brief:

“This case presents important questions regarding enforcement of the National Voter Registration Act, 52 U.S.C. §§ 20501-11 (the “NVRA”). Congress has vested the Attorney General with authority to enforce the NVRA on behalf of the United States. See 52 U.S.C. § 20510(a). Accordingly, the United States has a substantial interest in ensuring proper interpretation of the NVRA. The United States submits this Statement of Interest for the limited purpose of addressing the requirements under the NVRA for states to maintain and make available for public inspection certain records concerning the implementation of programs and activities conducted for the purpose of ensuring the accuracy and currency of official lists of eligible voters, id. § 20507(i). “

“On October 23, 2024, Plaintiffs, Judicial Watch, Inc., the Constitution Party of Oregon, Suni Danforth, and Hannah Shipman (“Plaintiffs”), sued then-Secretary of State of Oregon, Lavonne Griffin-Valade… Tobias Read was sworn in as Oregon’s Secretary of State on January 6, 2025 and, as the current Oregon Secretary of State, takes the place of Secretary Griffin-Valade as a Defendant in this civil action.”

“The complaint alleged that the Oregon Secretary of State and State of Oregon failed to comply with the state’s obligations under the NVRA: i) to “conduct a general program that makes a reasonable effort to remove the names of ineligible voters from the official lists of eligible voters by reason of” the death or a change in residence of registrants, under 52 U.S.C. § 20507(a)(4) (“Section 8(a)(4)”), and ii) to “maintain for at least 2 years” and “make available for public inspection . . . all records concerning the implementation of programs and activities conducted for the purpose of ensuring the accuracy and currency of official lists of eligible voters, . . . [,]” under id. § 20507(i) (“Section 8(i)”).”

“On January 10, 2025, the Plaintiffs filed the First Amended Complaint (“FAC”), ECF No. 12, which is the subject of the pending motion to dismiss. The FAC alleges the same claims under Sections 8(a)(4) and 8(i) of the NVRA as the original complaint, with some additional and revised factual allegations.”

FAC first amended complaint

“Section 8 of the NVRA, 52 U.S.C. § 20507, establishes requirements for the administration of voter registration for elections for federal office in covered states, including Oregon. Section 8(a)(4) requires each state to “conduct a general program that makes a reasonable effort to remove the names of ineligible voters from the official lists of eligible voters by reason of” the death of the registrant or “a change in the residence of the registrant, in accordance with subsections (b), (c), and (d)[.]” 52 U.S.C. § 20507(a)(4)(A)-(B). Subsections (b), (c), and (d) set forth procedures and requirements governing the removal of ineligible voters from official lists of voters as part of a state’s “program or activity to protect the integrity of the electoral process by ensuring the maintenance of an accurate and current voter registration roll for elections for Federal office[,]” id. § 20507(b). “

“Section 8(i) of the NVRA specifically provides that: Each State shall maintain for at least 2 years and shall make available for public inspection and, where available, photocopying at a reasonable cost, all records concerning the implementation of programs and activities conducted for the purpose of ensuring the accuracy and currency of official lists of eligible voters, except to the extent that such records relate to a declination to register to vote or to the identity of a voter registration agency through which any particular voter is registered.” Id. § 20507(i)(1).

“Section 8(i)(2) further specifies: The records maintained pursuant to paragraph (1) shall include lists of the names and addresses of all persons to whom notices described in subsection (d)(2) are sent, and information concerning whether or not each such person has responded to the notice as of the date that inspection of the records is made. Id. § 20507(i)(2).”

“Section 10 requires each state to “designate a State officer or employee as the chief State election official to be responsible for coordination of State responsibilities” under the NVRA. Id. § 20509. States are responsible for Section 8(i)’s requirements for maintaining and making available records.”

“By its plain terms, the NVRA identifies one entity, the state, that is required to carry out obligations for voter registration administration, id. §§ 20507, 20509, and, specifically under Section 8(i), to perform two actions: (1) “maintain” for at least two years records related to activities conducted to ensure the accuracy of eligible voter lists, and (2) “make available” those records to the public, id. § 20507(i)(1). “

“To the extent Oregon state laws or practices delegate the state’s Section 8(i) responsibilities to subdivisions or local authorities, they are inconsistent with Congress’ enactment of specific state obligations under the Elections Clause.”

On August 8, 2025, the federal District Court issued a 23 page ruling which can be read at this link: https://cases.justia.com/federal/district-courts/oregon/ordce/6:2024cv01783/182713/34/0.pdf?ts=1754485064

Here are quotes from this ruling:

“Plaintiffs bring this action alleging that the State of Oregon and its chief elections officer, the Secretary of State, failed to comply with two obligations under Section 8 of the National Voter Registration Act (“NVRA”). Pls.’ First Am. Compl., ECF No. 12 (“FAC”).2 Specifically, in Count I they claim that Oregon failed to conduct a general program to remove ineligible voters from voter registration rolls pursuant to § 8(a)(4), 52 U.S.C. § 20507(a)(4). In Count II they claim that Oregon failed to make available all records concerning the implementation of such a program pursuant to § 8(i), 52 U.S.C. § 20507(i).”

“Congress enacted the National Voter Registration Act in 1993, articulating in its opening lines the following purpose:
(1) to establish procedures that will increase the number of eligible citizens who register to vote in elections for Federal office;
(2) to make it possible for Federal, State, and local governments to implement this chapter in a manner that enhances the participation of eligible citizens as voters in elections for Federal office;
(3) to protect the integrity of the electoral process; and
(4) to ensure that accurate and current voter registration rolls are maintained. 52 U.S.C. § 20501(b)(1)–(4).”

“Section 8 of the NVRA establishes the requirements that states must follow in the administration of voter registration for federal elections. Generally, Section 8 prohibits states from removing registered voters from official voter lists unless the registrant requests it, state law compels it, or Section 8(a)(4) necessitates it. § 20507(a)(3). Under Section 8(a)(4), states are to “conduct a general program that makes a reasonable effort to remove . . . from the official lists of eligible voters” the names of voters who have become ineligible by reason of death or change in residence. § 20507(a)(4). “

“Section 8(i) further directs each state’s official to “maintain for at least 2 years” and “make available for public inspection and, where available, photocopying at a reasonable cost, all records concerning the implementation of programs and activities conducted for the purpose of ensuring the accuracy and currency of official lists of eligible voters.” § 20507(i). Those records must “include lists of the names and addresses of all persons to whom [Confirmation Notices] are sent, and information concerning whether or not each such person has responded to the notice.” § 20507(i)(2).’

“In the event a person “is aggrieved by a violation of” the NVRA, the Act provides a private right of action. § 20510(b). To exercise that right, the aggrieved person must first, in most circumstances, provide written notice of the violation to the chief election official of the state involved prior to commencing a lawsuit.”

“In June 2023, the U.S. Election Assistance Commission (“EAC”) published is biennial report to Congress as required by law. 52 U.S.C. § 20508(a)(3); States are mandated by federal regulation to provide election data to the EAC for use in this report, which covers state voter registration practices. See 11 C.F.R. § 9428.7(b). Plaintiffs reviewed the EAC Report cataloging data for Oregon for the year 2022 and concluded the following: First, “the largest number of removals under the NVRA are usually made pursuant to Section 8(d)(1)(B), for failing to respond to a Confirmation Notice and failing to vote in two consecutive general federal elections.”

“Second, Oregon’s self-reported data showed “that 19 counties removed zero voter registrations from November 2020 to November 2022 pursuant to Section 8(d)(1)(B). And only “10 other counties removed 11 or fewer voter registrations from November 2020 to November 2022 pursuant to Section 8(d)(1)(B).”

“Plaintiffs contrasted these findings with data from the U.S. Census Bureau which found that 14.5% of Oregon residents moved addresses over a one-year period and approximately 289,132 residents left the state in 2022 and 2023. From this data, Plaintiffs concluded that “there is no possible way Oregon’s counties can be conducting a general program that makes a reasonable effort to cancel the registrations of voters who have become ineligible because of a change of residence while removing so few registrations under Section 8(d)(1)(B).”

“Plaintiffs also “compared the total number of registrants, active and inactive, on Oregon’s voter rolls with the most recent five-year American Community Survey estimates from the Census Bureau of the citizen voting-age populations of Oregon’s counties. It “indicated that 35 of Oregon’s 36 counties had more voter registrations than citizens over the age of 18.”

“Excluding inactive registrations, “the same study showed that 10 of Oregon’s 36 counties had more active registrations than citizens over the age of 18.” These high registration rates, according to Plaintiffs, evidence “a statewide failure to conduct a general program that makes a reasonable effort to cancel the registrations” of ineligible voters.”

“Finally, Plaintiffs calculated Oregon’s percentage rate for inactive registrations and compared it to the national inactive registration rate of 11%. “Oregon’s inactive registration rate is about 20%. . . . Oregon’s median county inactive registration rate is about 18%, and its largest county, Multnomah, has an inactive registration rate of about 27%.” Oregon’s voter rolls also contain high counts of inactive registrations that show no voter activity for up to five consecutive general federal elections. Plaintiffs believe this too indicates a statewide failure to conduct a “program that makes a reasonable effort to cancel the registrations of voters who have become ineligible under the NVRA.”

“On August 4, 2023, Judicial Watch wrote a letter to the Secretary regarding several NVRA-related subjects, including the Oregon’s low number of Section 8(d)(1)(B) removals. The letter also requested the production of seven categories of public records pursuant to Section 8(i) of the NVRA.”

“Plaintiffs seek declaratory and injunctive relief, requesting an order that compels Defendants to develop and implement a program to remove ineligible registrants from voters rolls and that enjoins Defendants from refusing to allow Plaintiffs to inspect and copy records at a reasonable cost. Here, Plaintiffs allege that Defendants’ failure to comply with the NVRA’s voter list maintenance obligations has injured them in the following ways: increased concern that “the integrity of elections” is impaired by “the opportunity for ineligible voters to receive and cast ballots”; undermined “confidence in the integrity of the electoral process”; discouraged “participation in the democratic process”; and “fear that their legitimate votes will be nullified or diluted by unlawful ones.”

“Plaintiffs allege that they are “concerned” that Oregon’s practices have impaired the integrity of Oregon’s elections by “increasing the opportunity for ineligible voters to receive and cast ballots….”

“In King, the court likewise accepted an undermined confidence theory, explaining that “there can be no question that a plaintiff who alleges that his right to vote has been burdened by state action has standing to bring suit to redress that injury.” King, 993 F. Supp. 2d at 924; see also Green v. Bell, 2023 WL 2572210, *4 (W.D.N.C. 2023) (accepting both theories). For the reasons already explained, this Court does not find the reasoning of Griswold or King compelling… this Court is guided by the Ninth Circuit’s decisions. “

“Unlike associational standing, organizational standing arises where an organization has standing to sue on its own behalf for injuries the organization has sustained… the Constitution Party “purchases and relies on Oregon’s voter rolls to identify in-state voters and to contact them and encourage them to assist the candidates it supports.” These voter-contact and election-related activities are core activities of the Constitution Party,” as they are “of any political party.” The Constitution Party’s ability to contact eligible voters is impeded “because Defendants’ failure to conduct list maintenance required by the NVRA causes Oregon’s voter rolls to have many more outdated and ineligible registrations—both on its active and inactive voter lists—than they otherwise would.”

“As a result, the Constitution Party “wastes significant time, effort, and money trying to contact voters... who are listed on the rolls but who no longer live at the registered address or who are deceased…The voter rolls also allow the Constitution Party to keep track of its own members whose registrations have become inactive… If Constitution Party cannot monitor its members, it is plausible that it could lose its status as a minor party and no longer be entitled to limited liability or to nominate candidates.”

“Here, the explicit purpose of the NVRA is to establish procedures that increase the number of eligible, registered citizens; to enhance the participation of eligible citizens in elections; and to protect the integrity of the electoral process and accuracy of voter rolls. § 20510(b)(1). Like the APA, Congress provided in the NVRA a private right of action broadly to any “person who is aggrieved by a violation of this chapter,” limited specifically by the plaintiff’s compliance with the NVRA’s notice requirements. § 20510(b).”

“Plaintiffs failed to provide adequate notice before commencing a lawsuit on the public records claim… the NVRA’s private right of action imposes a mandatory notice requirement. To bring a civil action, the aggrieved party must first “provide written notice of the violation to the chief election official of the State involved.” § 20510(b)(1). Once the notice is received, a party must generally wait 90 days before filing suit in order to allow the official an opportunity to correct the identified violation. § 20510(b)(2)… “

“Plaintiffs alleged that “widespread ongoing noncompliance” and “systemic violations . . . caused by flawed practices and policies insufficient oversight and inadequate enforcement” were occurring and would continue.”

“The issue came down to a central premise on which the Ninth Circuit disagreed: that there was no reason to believe the violations identified in the field investigations were still occurring when plaintiffs sent their letter and filed their complaint. By the Ninth Circuit’s measure, it was “impossible” to read those allegations and conclude that there was no reasonable possibility that at least some of the violations were continuing as of the dates of the notice and complaint. The Ninth Circuit ultimately held that “[a] plaintiff can satisfy the NVRA’s notice provision by plausibly alleging that an ongoing, systematic violation is occurring at the time the notice is sent or, if no notice is sent, when the complaint is filed within 30 days of a federal election… Plaintiffs point solely to their FAC, which fails to allege an “ongoing, systematic” NVRA violation… the present matter is more aptly categorized as a discrete violation than an ongoing one.”

“Notice is sufficient “when it (1) sets forth the reasons that a defendant purportedly failed to comply with the NVRA, and (2) clearly communicates that a person is asserting a violation of the NVRA and intends to commence litigation if the violation is not timely addressed.” Jud. Watch, Inc. v. Pennsylvania, 524 F. Supp. 3d 399, 409 (M.D. Pa. 2021) “

Other States being investigated by the US Department of Justice
Other States recently began to receive letters on the National Voter Registration Act (NVRA) and Help America Vote Act (HAVA) from the U.S. Department of Justice. Harmeet Dhillon, who leads the Civil Rights division at DOJ, said at a congressional hearing in July 2025 that the department is aggressively enforcing list maintenance requirements in federal law.

“We are active, we are opening investigations, we are seeking information from states,” said Dhillon, adding that various states have received requests for information about their “list maintenance requirements and failure thereof, [and] their noncompliance with the [NVRA].”

On May 27, 2025, the DOJ sued North Carolina

On May 27, the U.S. Department of Justice filed a lawsuit against the new Board of Elections. The North Carolina lawsuit argues that some voter registrations, possibly hundreds of thousands, don’t comply with the Help America Vote Act of 2002. These registrations do not include the last four digits of an identifying number, such as a driver’s license or social security number. The DOJ wants the board to demand that these voters supply the information within 30 days. If they don’t provide the numbers in this time frame, their voter registrations could be canceled. The case is called United States of America v North Carolina State Board of Elections. Here is a link to the DOJ complaint:

https://www.democracydocket.com/wp-content/uploads/2025/05/1-2025-05-27-Complaint.pdf

Here are quotes from the complaint:

“The Attorney General of the United States hereby files this action on behalf of the United States of America to enforce the requirements of Section 303(a) of the Help America Vote Act of 2002 (“HAVA”), with respect to the conduct of elections for Federal office in the State of North Carolina. 52 U.S.C. § 21083(a)… Defendants have failed to maintain accurate lists in North Carolina’s computerized statewide voter registration in violation of Section 303(a)(5) of HAVA.”

“Under Section 303(a) of HAVA, a voter registration application for an election for federal office may not be accepted or processed by the State unless it includes a driver’s license number from the applicant, or if the applicant does not have a driver’s license, the last four digits of the applicant’s social security number. If an applicant has not been issued a current and valid driver’s license or social security number, the State must assign a special identifying number for voter registration. See 52 U.S.C. § 21083(a).”

“Section 303(a)’s requirement that States utilize a unique identifying number to voters who indicate they have neither a driver’s license nor a social security number is an integral part of the minimum Federal standards. As the House Report explained, “It is likely that states will find it necessary to create a unique identifier to distinguish registered voters who happen to have the same name and/or birth date. The unique identifier so created will be used to assure that list maintenance functions are attributable to the correct voter; so as to avoid removing registrants who happen to have the same name and birth date as a felon, for example.”

“In violation of HAVA’s mandate and clear Congressional intent, the State of North Carolina used a state voter registration form that did not explicitly require a voter to provide a driver’s license or the last four digits of a social security number.”

“Upon information and belief there currently are a significant number of voters that do not have a driver’s license number, last four digits of a social security number, or any other identifying number, as required by Section 303 of HAVA, listed in North Carolina’s state voter registration file. Those violations will continue absent relief from this Court.”

“Among the requirements of Section 303(a) of HAVA for the statewide voter registration list are the following:

(a) The list shall serve as the single system for storing and managing the official list of registered voters throughout the State, 52 U.S.C. § 21083(a)(1)(A)(i);

(b) The list must contain the name and registration information of, and must assign a unique identifier to, each legally registered voter in the State, 52 U.S.C. §§ 21083(a)(1)(A)(ii)-(iii).”

Proposed Remedy to the Washington State Inaccurate Voter Roll problem

The Washington government agency most directly involved in implementing the "Automatic Voter Registration" state law is the Washington State Department of Licensing. Governor Bob Ferguson appoints, with minimal legislative involvement or oversight, the Director and other senior management of the Department of Licensing. We have provided evidence from several sources that the Washington State Department of Licensing is registering huge numbers of non-citizens – in clear violation of federal election law – and also in violation of existing Washington state election laws.

The NVRA requires states to review their voter registration rolls periodically and to remove the records of individuals who no longer meet eligibility requirements. We have provide evidence from the federal Election Assistance Commission that Washington state likely has the least accurate voter rolls in the entire nation.

The US Department of Justice is required to enforce federal election laws. We therefore ask the US Department of Justice to open an investigation into Washington state “Automatic Voter Registration” practices and take whatever steps are needed to force Bob Ferguson and his Department of Licensing to comply with federal election laws and to take steps needed to clean up the voter rolls – especially in King and Pierce counties.

For more information, please contact me via email. Thank you for your assistance in this important matter.

Regards,

David Spring M. Ed.

Director, Washington Parents Network

This email address is being protected from spambots. You need JavaScript enabled to view it.

425-876-9149

6183 Evergreen Way

Ferndale, WA 98248

It is ironic that the “No King” protesters are overlooking our own King Reykdal here in Washington state. In the past few months, we have published articles (and filed three federal complaints totalling hundreds of pages) against Washington’s King Reykdal for his violating the Title IX civil rights of a half million girls, violating the Title VI civil rights of one million students and the FERPA civil rights of over one million parents. We have also written articles explaining how Reykdal has and still is violating Article 6, Section 2 of the US Constitution. In addition, we have explained that Reykdal has committed Contract Fraud by signing annual Federal Certification Contracts falsely claiming our state was in compliance with Title IX, Title VI and FERPA. Reykdal’s 8 year crime wave could cost Washington taxpayers billions of dollars in lost federal funding.

The US Department of Justice recently announced that they will begin a massive investigation of all of Reykdal’s crimes. This investigation will almost certainly lead to a federal court case – a case in which the US Supreme Court has already ruled TWICE! (see background below). Reykdal is certain to lose. So one would think that Reykdal might want to at least pretend to comply with federal laws. But think again. On June 3, 2025, Darby Kaikkonen, a former high ranking OSPI Director and the current Tumwater School Board President, filed a complaint against King Reykdal in federal court to “redress violations of (her) constitutional rights under the First and Fourteenth Amendments to the United States Constitution, as well as state law claims arising under Washington law.”

In addition to violating her First amendment “Free Speech” rights and her Fourteenth amendment “Due Process” rights, Darby is suing for wrongful termination of her $137,000 a year job at OSPI and illegal retaliation by Reykdal who fired Darby in revenge for her vote at a February 2025 Tumwater School Board meeting.

Here is a link to Darby’s 10 page complaint against Reykdal:
https://washingtonparentsnetwork.com/phocadownload/2025%20June%20Tumwater%20Complaint%20against%20Reykdal.pdf

So what exactly did Darby do to incur the Wrath of Reykdal?
On February 27, 2025, Darby had the audacity to vote in favor of a school board resolution to honor the Title IX right of girls to fair sports opportunities. Before we get to the truly despicable actions Reykdal took against Darcy, we will briefly review some important events leading up to his truly insane behavior.

Background of Title IX and Girls Rights to Fair Sports Opportunities
Most young people do not know this but, a long time ago, girls did not have a right to fair sports opportunities. All of the money and all of the scholarships went to boys competing in boys sports. Girls were supposed to stay in the kitchen and make meals. Then, in the 1960’s, there was a Womens Rights Movement. This resulted in a law being passed in 1972 by Congress called Title IX which provided that girls must be given equal opportunities in all academic programs and athletic programs that received federal funds. In order to get federal funds, states had to sign annual Title IX Certification Contracts assuring the federal government that they were giving girls fair academic and athletic opportunities.

Things went fairly well and girls sports expanded without controversy for the next 47 years until about 2015 when a group of crazy people in the Obama Department of Education issued a scam letter claiming that Title IX was actually about defending the rights of boys pretending to be girls to enter girls bathrooms, locker rooms and play on girls sports teams.

For several years, Washington had a law on the books allowing boys who pretended to be girls to play on girls sports teams. But it was widely ignored until December 2016 when the Washington Civil Rights Commission came up with a new interpretation of a previous Washington state non-discrimination law to mean that boys here in Washington could now not only compete in girls sports but also go into girls bathrooms and locker rooms.

In January, 2017, Reykdal took office and immediately warned schools in Washington that, effective immediately, they needed to let boys in girls locker rooms, bathrooms and sports teams. In the next couple of years, Reykdal also changed the school curriculum in Washington state to promote Transgender Clubs in elementary schools. A ton of kids were soon sucked in by the propaganda that all they needed to do to change from being a boy to a girl was to change their names and pronouns.

In March 2024, Biden tried to take this crazy intepretation of Title IX nationwide with the Biden Title IX Final Rule. About 27 states sued and won a series of legal victories in federal courts all around the US. These victories culiminated in a US Supreme Court ruling in August 2024 in the case of Tennessee v Cardona (Cardona was Biden’s Education Czar). The US Supreme Court ruled that the word “sex” in Title IX meant biological sex and protected the rights of girls to their own bathrooms, locker rooms and sports leagues.

On January 9 2025, based on the US Supreme Court August 2024 decision, a federal judge issued a national order to all states and school boards to immediately comply with the plain meaning of Title IX. The judge specifically stated that allowing boys to compete in girls sports would “render Title IX to be meaningless.” Unfortunately, Reykdal refused to comply with this federal court order. Sadly, just a few weeks later, a girl was injured by being forced to play against a boy in a Tumwater High school basketball game. We described this incident in our February 28, 2025 Washington Parents Network Title IX complaint against Chris Reykdal.

Here is a brief summary taken from our Title IX compliant:

Girl injured by Biological Male in Girls Basketball Game
This incident started in 2024, when a 14 year old biological girl basketball player named Frances, attending Tumwater High School, was traumatized by seeing a large biological male who at the time was 17 years old in her Girls Locker Room. This was a male who has never taken any Trans drugs but is nevetheless allowed in the Girls Locker Room simply because that is where he prefers to be. The male was a player on an opposing team’s Girls Basketball team. When Frances told her parents about this incident, her parents assured her they would support her decision should she decide she did not want to play basketball against a biological male. Then, on February 6, 2025, the now 15 year old girl saw this same biological male now 18 years old during warmups for her teams final game of the year.

Frances told her mother she would not play against this boy. The girl’s mother asked her coach if he was aware that the opposing team had a biological male on the team. The coach replied that he was not allowed to comment about this. The coach said the mother needed to talk to the athletic director. The mother then went to the athletic director who was also at the game and asked if he was aware that the person on the other team was a boy. The athletic director replied that he “does not discriminate. We follow WIAA and Washington State law.”

The mother pointed out that just one day earlier, President Trump had signed an executive order protecting girls from having to compete against biological males. The athletic director replied that “We do not have to follow that order. We follow Washington State law.”

The mother then went back to her seat and asked her 13 year old son to video tape the game so she would have a record of what happened. A male school employee threatened her son who then stopped video taping the game. Frances remained on the bench and watched as one of her team mates was injured by the biological male and was carried off the court crying in pain (see pictures below).

This is a picture of a biological girl in a white jersey in a Tumwater High School Junior Varsity game being forced to play against a much larger and much taller biological male in a red jersey who is pretending to be a girl:

The girl in white went around the boy in an attempt to drive the lane and shoot the ball.

She drives past the boy who then basically tackles her like it was a football game. Note that the boy later said it was an accident and perhaps he lost his footing when he knocked the girl down:

The girl fell to the ground and the biological male landed on top of her:

The male was not injured but the girl remained motionless on the ground:

The male got up. But the injured girl remained face down on the ground. The male briefly looked down at the injured girl and then walked away. The official, who was a biological female, failed to call a foul on this play – despite the fact that tackling another player is not allowed in a basketball game. The girl’s teammates helped the injured girl get up with the male calmly walking away - as two officials looked on and did nothing:

None of the three officials called a foul or even called for an injury timeout. Note that the injured girl is clearly limping as she is being carried off the court by one of her teammates

The injured girl is still being helped off the court and her teammates appear to be looking at the official in disguist as he holds the ball for the opposing team.

The above images are a perfect example of why it is not safe to force girls to play against biological males. Here we have an example of a 15 year old girl being forced to play against an 18-year old biological male – a male who has never even taken Trans drugs. His shear size alone is why the girl was injured.

Even though Frances was on the bench, she got very upset at the male player injuring the female player, who was a friend of hers. From Frances’s point of view, the boy had used his large body mass to deliberately knock over her friend. After this incident, Frances looked at the biological male and said “You are a man.” Then after the game, she complained about this incident on her social media page. This is the post Frances made:

Tumwater School Board Resolution
After the February 6, 2025 basketball game, several Tumwater parents got mad at how badly their girls had been abused by being forced to play against a biological male. The parents demanded that the school board pass a resolution in favor of protecting the Title IX right of girls to fair and safe sports opportunities.

On February 27, 2025, just three weeks after the Tumwater High School Girls basketball game, the Tumwater school board, including Darby Kaikkonen, voted 3 to 1 for a Resolution in support of amendments to the rules of the Washington Interscholastic Athletic Association (WIAA) to protect the right of girls to fair and safe sports opportunities. The amendments would have required athletes to compete based on their biological sex, not their gender identity. Here are quotes from the Tumwater School Board Resolution:

Darby explained her vote by saying she was a former competitive swimmer and thought it was important to protect girls sports. She said the issue “pits one historically marginalized group against another” : “I see myself in this issue, and most importantly, I see girls who are currently living it and the complexity of what they’re trying to work through. This is an impossible situation. These girls are faced with the same challenges that we all are, and that they can’t possibly stand up for themselves and share their voice and what they think is right without being accused of bigotry… You want to know why the voice for girls is quiet, and why so few people speak publicly about it?… It is fear.”

Here is a quote from Darby’s federal complaint:

“Kaikkonen maintains that she supported the amendments to ensure fair athletic opportunities for all students and to address concerns regarding equity and safety for female athletes. As a duly elected official, she believes she had an obligation to represent her constituents, and the freedom to do so under the First Amendment.”

On February 28, 2025, the Washington Parents Network filed a 99 page Title IX Civil Rights complaint against Chris Reykdal and Bob Ferguson for violating the Title IX rights of a half million girls here in Washington state over the past 8 years. Here is a link to our Title IX complaint:

https://washingtonparentsnetwork.com/news/washington-parents-network-title-ix-complaint

Reykdal’s office faces a federal probe of its own into its clash with a Clark County school district over the district’s gender inclusion policy. Kaikkonen’s work focused on reporting data for compliance with federal education policy, according to her lawsuit.

On March 4, 2025, Reykdal issued a threatening letter to the Tumwater School Board claiming that the proposed amendment violated state law (but failed to mention that the state law violated an important federal civil rights law called Title IX and was therefore null and void). Below is the threatening letter to the Tumwater School Board:

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On March 6, 2025, less than ten days after the vote and two days after the threatening letter, Darby was placed on administrative leave by OSPI. No reason, policy, conduct, or performance issue was identified as a basis for being being put on leave. She was prohibited from coming onto OSPI' s Old Capital Building grounds, or contacting any OSPI employee. Less than two weeks later, in a March 19 call from the office’s chief of staff, Tennille Jeffries-Simmons, she was fired. Again, no explanation was given.

As a result of her termination, Darby lost an annual salary of $137,000, including valuable health and retirement benefits. She has experienced reputational damage, anxiety, humiliation, and disruption to her family life.

Darby’s term on the Tumwater school board ends this year. She didn’t file to run for re-election. Meanwhile, King Reykdal posted the following inflamatory image on one of his social media pages:

If you agree that it is time to get replace Reykdal and Ferguson with folks more willing to honor the US Constitution, then please come to our next Washington Parents Network online meeting which will be Sunday, June 15^th from 4 to 5 pm where we will review our plan to restoring Family Rights here in Washington state. For the link, send an email to This email address is being protected from spambots. You need JavaScript enabled to view it.

We look forward to meeting you.

Regards,

David Spring M. Ed.

Director, Washington Parents Network

FOR IMMEDIATE RELEASE

Washington Parents Network files Title VI Complaint against Washington Superintendent Chris Reykdal

FERNDALE, WASHINGTON – Today, April 18, 2025, the Washington Parents Network filed a 64 page Title VI Complaint against Washington Superintendent, Chris Reykdal to end DEI and Critical Race Theory (more accurately known as Racial Shaming) Instruction in Washington state public schools. The complaint was filed with the US Department of Education Office of Civil Rights. Our complaint seeks to enforce an important federal law, called Title VI of the Civil Rights Act of 1964, which was passed 61 years ago, to end discrimination based on race or skin color in programs that receive federal funding. Our complaint details numerous violations of Title VI that have occurred and continue to occur in Washington state public schools on a daily basis.

US DEPARTMENT OF EDUCATION OFFICE FOR CIVIL RIGHTS

TITLE VI ADMINISTRATIVE COMPLAINT

April 18 2025

From: David Spring M. Ed. Director, Washington Parents Network

To: US Department of Education Office for Civil Rights
Lyndon Baines Johnson Department of Education Building
400 Maryland Avenue, SW Washington, DC 20202-1100

RE: Washington State Superintendent of Public Instruction violations of Title VI of the Civil Rights Act of 1964 (Title VI) and the Equal Protection Clause of the 14th Amendment to the US Constitution

Submitted Via Email: This email address is being protected from spambots. You need JavaScript enabled to view it.

To Whom It May Concern:

This is a Title VI Civil Rights Discrimination complaint filed under the U.S. Department of Education’s Office for Civil Rights’ (OCR) Complaint Resolution Process. The Washington Parents Network brings this complaint against Washington State Superintendent of Public Instruction in his official capacity in charge of the Office of the Superintendent of Public Instruction (OSPI) for requiring all 295 school districts in Washington state to discriminate against over one million students on the basis of race, color or national origin in programs or activities that receive Federal financial assistance in violation of both Title VI of the Civil Rights Act of 1964 (Title VI), 42 U.S.C. § 2000d et seq., and the Equal Protection Clause of the 14th Amendment to the US Constitution.

The Washington Parents Network makes this complaint on behalf of over 2,700 of our members who have students in school districts in Washington state and/or are teachers and/or are school board members in these school districts.

All of the school districts in Washington state receive federal funding and therefore must comply with Title VI and the Equal Protection Clause. However, as we review in detail below, recent Washington state laws as well as OSPI policies and Teacher Training procedures encourage and/or require school districts to violate Title VI of the Civil Rights Act and the Equal Protection Clause of the 14^th Amendment to the US Constitution.

Our complaint includes this 4 page cover letter and a 64 page summary of Title VI volations, divided into 10 sections, outlining how the Title VI rights of our members and their children and students were violated by policies advanced directly or indirectly by Chris Reykdal, who we contend has been violating the plain meaning of Title VI ever since he took office 8 years ago.

In this complaint, we provide 30 examples of violations of Title VI that have been inflicted on our children, parents, teachers and school board members during the past 8 years. These examples are evidence that all of our members and all of their children – and all of the children in Washington state - have been harmed by Reykdal’s failure to comply with Title VI.

Legal Basis for our Title VI Complaint
On July 9, 1868, the Fourteen Amendment to the US Constitution was ratified clarifying that no state can make any law that deprives citizens of their civil rights based on their race, skin color or country of national origin.

On July 2, 1964 Congress passed the Civil Rights Act clarifying that no program that recieves federal funding can discriminate against any person based on their race, skin color or country of national origin – and that federal funding is contrigent on programs agreeing to comply with these civil rights.

On June 23, 2003, in the case of Grutter v Bollinger, the US Supreme Court ruled that Michigan could include race as a factor in admissions. However, Justice O’Conner stated that such racial preferences policies would eventually need to end. Here is her quote” “The Court expects that 25 years from now, the use of racial preferences will no longer be necessary to further the interest approved today.”

On June 29, 2023, the US Supreme Court published a 237 page landmark decision in the case of Students for Fair Admission v Harvard which clarified that Title VI and the Equal Protection Clause of the 14^th Amendment requires “color blindness” in all federal, state and local programs. The Supreme Court concluded that Title VI prohibits any programs or activities that included “racial preferencing” or dividing people up based on skin color.

Racial preference educational programs have many names including but not limited to Critical Race Theory, Ethnic Studies – and most recently – Diversity, Equity and Inclusion or DEI.

What matters is not the name of the program but whether the program divides people up based on the color of their skin. Any educational program that divides people up based on the color of their skin is a violation of Title VI of the Civil Rights Act of 1964.

On January 20, 2025, based on the 2023 Supreme Court ruling in Students for Fair Admission v Harvard, President Trump issued a Presidental Order “Ending Radical and Wasteful Government DEI Programs and Preferences.”

On January 21, 2025, again citing Students for Fair Admission v Harvard, President Trump issued a Presidential Order “Ending Illegal Discrimination and Restoring Merit Based Opportunities.“

On February 14, 2025, based on these Presidential Orders, which were based on Students for Fair Admission v Harvard, the US Department of Education Office of Civil Rights (OCR) issued a Dear Colleague Letter requiring all state and local education agencies to comply with Title VI and the Equal Protection Clause.

On March 1, 2025, the Office for Civil Rights (OCR) released a Frequently Asked Questions  10 page document providing further guidance on OCR’s February 14, 2025, “Dear Colleague” letter. Here are quotes from the March 1, 2025 OCR FAQ:

“In Students v. Harvard, the Supreme Court reiterated that “discrimination that violates the Equal Protection Clause of the Fourteenth Amendment committed by an institution that accepts federal funds also constitutes a violation of Title VI.”

“Many schools have advanced racially discriminatory policies and practices under the banner of “DEI” initiatives… Schools may not operate policies or programs under any name that intentionally treat students differently based on race, engage in racial stereotyping, or create hostile environments for students of particular races.”

“The First Amendment rights of students, faculty, and staff, and the curricular prerogatives of states and local school agencies do not relieve schools of their Title VI obligations to refrain from creating hostile environments through race-based policies and stereotypes.”

On April 3, 2025, the OCR sent letters to State Commissioners overseeing K-12 State Education Agencies requiring them to certify their compliance with their antidiscrimination obligations under Students v Harvard in order to continue receiving federal financial assistance.

On April 8, 2025, Washington superintendent, Chris Reykdal, issued a press release refusing to comply with the OCR Certification letter. Reykdal falsely claimed that Students v Harvard only applied to “college admissions policies.“ Reykdal further falsely claimed that Washington educational programs already “met the requirements under Title VI.”

In our complaint, we explain why Students v Harvard applies to all programs that receive federal funding. We also provide 30 examples of why Reykdal’s DEI programs willfully and pervasively violate the Title VI rights of students, parents and school board members.

We ask OCR to conduct a Directed Investigation of Washington state illegal DEI programs and to withhold federal funds until Reykdal agrees to permanently end these DEI programs.

We further ask that the OCR seek retroactive reimbursement of federal funds based on Reykdal’s willful and pervasive violations of Title VI by his past 4 years of false claims of being in compliance with Title VI. We further ask for Triple Damages based on Washington State’s Breach of Contract with the US Department of Education. Given that Washington state has received more than $10 billion in federal education funds during the past 4 years, we believe that the total damages could exceed $30 billion dollars. However, the purpose of such a huge penalty is not to punish Washington tax payers. Instead, it is to force Washington state leaders to stop violating the Title VI Civil Rights of students, parents and teachers.

Finally, we ask for 4 years of remedial Civil RIghts Teacher Training programs to correct for the the past 4 years of racially charged and illegal Teacher Training programs.

Sincerely,

David Spring M. Ed.
Director, Washington State Parents Network
6183 Evergreen Way, Ferndale WA 98248
(425) 876-9149
This email address is being protected from spambots. You need JavaScript enabled to view it.

I Why Washington DEI programs violate Title VI