September 22, 2022

Mr. Bernard Dean 35818.0101

Chief Clerk
Washington State House of Representatives
416 Sid Snyder Ave. SW
Olympia, WA 98504
[email protected]

Re: Report of Investigation

Representative Melanie Morgan

Dear Mr. Dean:

This letter will serve as the report of investigation into concerns raised about Representative
Melanie Morgan and her interactions with Individual 1 on October 19, 2021, and thereafter. The
initial complaint regarding Representative Morgan was not lodged by Individual 1 but was
instead raised by individuals who became aware of concerns related to interactions with
Individual 1. The concerns which were raised specifically alleged inappropriate and
unprofessional conduct.

The undersigned was requested to conduct an investigation in mid-January. The investigation

was significantly delayed by the refusal of Representative Morgan to make herself available for
an interview until after the 2022 legislative session was completed which ended on March 10,
2022. The undersigned was contacted by counsel for Representative Morgan, Mr. Ed Younglove,
on the afternoon of March 31, 2022, while the undersigned was in the midst of a three-week
trial.1 Arrangements were ultimately made to interview Representative Morgan on April 14, in-
person.2 A second remote meeting was held with Representative Morgan on April 27, 2022.

Methodology:

In conducting the investigation, the undersigned interviewed six (6) individuals.3 Unless
otherwise specified in the body of this report, the undersigned found the individuals interviewed
to be credible.

Credibility determinations were based on a myriad of factors including: whether an interviewee

appeared to be truthful; the ability to observe the interviewee including observations of body
language and demeanor; the ability of the interviewee to recall specific facts; the consistency of

1
Trial ended on April 8, 2022.
2
Due to a very heavy snowfall occurring on the morning of April 14, 2022, in the Bellevue area, the meeting was
changed from an in-person interview to a remote meeting.
3
In order to ensure that there is no opportunity for any form of retaliation, the individuals will be identified solely
by a number instead of name and position.

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Washington State House of Representatives
September 22, 2022

the interviewees’ recollection; the interviewees’ reputation for truthfulness; statements by others
that are corroborative or inconsistent with those of the declaring witness; contradictions by the
declaring witness; bias/unusual interest in the outcome; the nature of the relationship between
witnesses and/or the complaining party or the accused including any unusual hostility or
friendliness; and the existence of contemporaneous documentation of events.

In addition to interviewing witnesses, the undersigned also reviewed written communications

and documentation relating to the subject matter of the investigation. These documents were
used to corroborate some aspects of the statements made by those who were interviewed.

The interviews were conducted both in-person and via Microsoft Teams.

Complaint:

As previously indicated, the complaint which gave rise to the investigation was lodged on
November 18, 2021, by an employee of the State of Washington who originally complained
about the disrespectful treatment imposed on another employee of the state, not Individual 1, by
Representative Morgan.4 The November 18, 2021 complaint was focused on Representative
Morgan’s treatment of Individual 2 with whom the reporter, Individual 3 was familiar because
Individual 2 had provided staffing for a committee on which Individual 3 served. Individual 3
stated that they had had sufficient opportunity to observe the conduct and professionalism of
Individual 2 such that they felt that it was necessary to report what they, Individual 3, described
as serious “acts of indignity and misconduct” by Representative Morgan.

Interview with Individual 1:

The undersigned interviewed Individual 1 in January, 2022.

Individual 1 is a native of Washington State and has a bachelor’s in law degree. They reported
that they come from a family which has, for many years, resided in Section 8 housing. They
reported that they have dedicated their life to working with communities of color, assisting small
business owners in obtaining government contracts, and other government aid or assistance.
They reported that it was through this work that they met Representative Morgan. Individual 1
reported that Representative Morgan was present when they made a presentation for a Black
owned business. According to Individual 1, Representative Morgan asked whether they had any
interest in getting into politics. This conversation led to Representative Morgan recruiting
Individual 1 to be her campaign manager. Individual 1 reported that even though they had been
focused on obtaining a law degree, they decided that the offer from Representative Morgan to be
her campaign manager was likely a once in a life-time opportunity, so they accepted the offer.
Individual 1 signed on to be the campaign manager for Representative Morgan’s re-election in
2020.

4
The reporter is herein identified as Individual 3.
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Individual 1 reported that Representative Morgan is a micro-manager. Consequently,

Representative Morgan was not able to hold a campaign manager through an entire election
cycle. Individual 1 reported that they gave their all to Representative Morgan. They remained in
the position from November 2020 until June or July 2021. At that time, Representative Morgan
started making budget cuts. Despite the budget cuts, Representative Morgan wanted Individual 1
to remain available. Individual 1 reported that they did remain available to Representative
Morgan even though their salary had been cut. They reported that there were three total rounds
of salary reduction. At the time of the third salary reduction, they decided that they could no
longer work with Representative Morgan as her campaign manager. According to Individual 1,
in the last conversation that they had with Representative Morgan, Representative Morgan stated
that she hoped that they could continue to be friends and have a working relationship.

Despite this, Individual 1 reported that they continued to work with Representative Morgan
writing correspondence and also working on a weekly podcast. As a result, when Individual 1
requested a letter of recommendation from Representative Morgan, she was quite surprised that
Representative Morgan refused. When Individual 1 asked why she had refused, Representative
Morgan told her that she had been “insubordinate” but provided no further explanation.
Individual 1 reported that this was the end of their communication for several months.

Some months later, unexpectedly, Representative Morgan called Individual 1 and said that she
was in their neighborhood. Representative Morgan stopped by Individual 1’s home. Individual
1 was confused by this visit. When Representative Morgan arrived, Individual 1 told
Representative Morgan that they had been relying on the income that they had been making as
her campaign manager and had actually curtailed their efforts to connect with others who could
provide them with opportunities because they had accepted the position with Representative
Morgan. Representative Morgan responded that God would protect and take care of them.
Individual 1 reported that rather than argue, they decided not to pursue the discussion any further.

Individual 1 reported they had no contact with Representative Morgan for approximately four to
five months, then received an email from Individual 2 who said that Representative Morgan had
given their name to Individual 2 because Representative Morgan had an open administrative
assistant position. Individual 1 declined that position. 5

After turning down the position, Individual 2 reached out to them again. On this occasion, they
told Individual 1 that there was an open policy analyst position. Individual 1 reported that they
inquired of Individual 2 about the position and whether they believed that Individual 1 was
qualified. Individual 1 was told that the position was one which was being filled on an
emergency basis and that Individual 2 believed that they were qualified. The position was to
serve as the policy analyst6 for the Equity in Cannabis Task Force. Despite concerns about the

5
The above referenced information is for presenting background about the relationship which existed between
Representative Morgan and Individual 1 outside of the confines of the relationship which resulted in the current
investigation.
6
According to Individual 2, the role of policy analyst entails assisting the legislators and task force members to
understand scope and responsibilities of the task force and to provide strategic direction, develop and implement
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way that they had been treated by Representative Morgan during their employment relationship
which predated employment by the State, Individual 1 reported that they accepted the position
because Representative Morgan would not be their supervisor and they therefore believed that
they would be protected from Representative Morgan.

The undersigned inquired of Individual 1 about their understanding of Representative Morgan’s

background. They reported that they were aware that Representative Morgan had grown up in a
military family and spent a fair amount of time in Jamaica and the Virgin Islands, laying down
her roots in Tacoma in the late 1980’s or early 1990’s.

Individual 1 stated that they quickly learned that Representative Morgan is ambitious and has
plans to run for the U. S. Senate at some point. They also reported that Representative Morgan is
quite strategic about the committees and projects on which she works. It was against the above
referenced backdrop that Individual 1 reported she believes that Representative Morgan was
“acting to further her ambitions” while working on issues with the Task Force.

Individual 1 provided a detailed explanation about the Task Force, including the fact that it is
made up of 20 individuals, 10 of whom are governmental representatives and 10 of whom are
industry representatives.

Individual 1 reported that leading up to the incident on October 19, 2021, they had been
receiving complaints from some of the individuals on the Task Force that they believed
Representative Morgan was “slow-walking” the agenda. According to Individual 1, it was the
licensing sub-group that was being most impacted by this alleged slow-walking.

Individual 1 reported that there was a meeting held on September 22, 2021 where the work
groups brought proposals for consideration to be addressed at the meeting which was to be held
in October 2021. Individual 1 reported that because the licensing group had not been able to
present their proposals at the September meeting, there was discussion about starting the meeting
on October 28, 2021, with the licensing group and then moving to other issues, all of which the
work groups believed were important to finalizing the recommendations of the Task Force so
that they would be ready when the legislative session started.

Individual 1 attempted to discuss this concept with Representative Morgan and reached out to
her assistant to set times to discuss this issue on October 4, 2021. Individual 1 was advised that
Representative Morgan was unavailable and remained unavailable to discuss the Task Force
work with them until the October 19, 2021, meeting. (See attached email communication
regarding Representative Morgan’s availability Ex. 1).
Individual 1 reported that on October 19, 2021, when they brought up the proposed agenda,
Representative Morgan stated, “We can’t have all of this on the agenda. The Task Force is on
high alert and high scrutiny.” Individual 1 said that Representative Morgan went on to state that

work plans, create agendas, research policy proposals, relating to the mission of the task force and to develop and
present briefing materials for the task force and prepare talking points which they are generally expected to present
at task force and other meetings.
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it was imperative to follow the Open Public Meetings Act (“OPMA”), suggesting that the OPMA
would not permit discussion of anything other than the one item that had not been covered at the
previous meetings.

Individual 1 reported that they suggested that they wanted to get some clarity on the issue of the
limitations of the OPMA and asked if they could consult with a supervisor or ask for an opinion
from the Attorney General’s Office. According to Individual 1, Representative Morgan told
them, “[N]o, I’m not going to argue with you.” Individual 1 reported that they felt “humiliated.”
Individual 1 reported that not only did they feel humiliated, but they also felt undermined.
Individual 1 reported that this transpired in the presence of all those in attendance at the meeting,
Representative Morgan said, “I’m the elected official.”7 Individual 1 reported that after this
exchange, Representative Morgan immediately left the meeting saying, “I don’t think I need to
be at this meeting anymore” and directed that Individual 1 send the reduced agenda.

Individual 1 reported that after Representative Morgan left the meeting, they were comforted by
multiple people who attended the meeting, some saying that they “were sorry that [Individual 1]
had to be the speed bump in the meeting,” “that no one deserved to be treated in this manner,”
and that the manner in which Individual 1 was treated was “inappropriate.” Individual 1 further
reported that they received a message from one of the people in attendance at the meeting stating
that this individual, Individual 4, had been unable to sleep the night following the incident and
that they were not sure that they wanted to continue working on the Task Force. Likewise,
Individual 1 was advised by another person in attendance at the meeting that they could not
remain on screen because of the treatment that they observed being directed toward Individual 1.

Individual 1 reported that they were so upset by this interchange that they actually had to turn
their camera off so that people could not see that they were embarrassed and hurt. Individual 1
stated that Representative Morgan’s response undermined them in front of a group of people who
looked to them for information.

Individual 1 went on to state that they were concerned about Representative Morgan’s response
because they believed that the community was losing trust in the Committee and its work. They
reported that there had been members of the public who were openly stating that they did not
trust the Task Force. They went on to report that they had spoken to Individual 2 about this
concern and inquired about whether direct outreach to the members of the public would be
appropriate. When Individual 1 and Individual 2 attempted to follow up on the idea of outreach
to the community with Representative Morgan, Representative Morgan stated that she did “not
need for them to give members of the public who were disgruntled air-time” and that by raising
the issue, Individuals 1 and 2 were “overstepping.”

Individual 1 reported that this interchange was not the first time that they had witnessed or been
made aware that Representative Morgan was disrespectful. Individual 1 stated that
Representative Morgan has made statements to Individual 2, who is not Caucasian, to the effect
that Individual 2 they would “[N]ever understand because you will never walk in my shoes.”
7
Individual 1 cried during the discussion of the events of October 19, 2021.
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Individual 1 reported that they objected to this type of thinking because it implies that a person
cannot learn or understand simply because a person is not black.8

Individual 1 reported that after this exchange, Representative Morgan lodged complaints about
their performance with their supervisor who was Individual 2. Individual 1 believes that these
complaints were retaliatory in nature. Among the complaints was an accusation that Individual 1
does not have a good understanding of the OPMA and that they do not timely provide
information when requested.9 Individual 1 reported that they believed that there were eight
complaints in all but could not recall the details of all of them. Individual 1 reported that all of
the complaints were baseless. Individual 1 reported that their supervisor had responded to the
allegations raised by Representative Morgan. Individual 1 reported that they found the
complaints and concerns to be ironic in light of the fact that Representative Morgan had made no
effort to have any discussion with them about the alleged deficient performance.

Individual 1 reported that they were advised that at some point after October 21, 2021,
Representative Morgan had suggested that if Individual 1 was not removed from the Task Force,
that she, Representative Morgan, would resign. Individual 1 reported that again, they found this
statement to be ironic since Representative Morgan had, in their presence and the presence of
many others, complimented their presentation to the Commerce and Gaming Committee,
thanking them for the great presentation.10 Additionally, Representative Morgan had also sent a
text message complimenting her on the work that she had done. 11 Individual 1 reported that
regardless of Representative Morgan’s reported threat to resign from the Task Force they intend
to continue to do their job to the best of their ability.

At some point after the alleged threat of Representative Morgan to resign from the Task Force,
Individual 1 reported that they were contacted about a vacant legislative assistant position for
Representative Jamila Taylor. Individual 1 reported that shortly after receiving the contact, they
received a text from Representative Morgan asking if they were going to accept the job.
Individual 1 stated that they politely responded that they were committed to seeing the work of
the Task Force all the way through. In response, Representative Morgan stated that she had
made the recommendation because the Task Force job is temporary and ends at the end of 2022.

Individual 1 expressed concern and fear that people would not be forthcoming about the conduct
of Representative Morgan because they are fearful of “black backlash.”

8
It is clear to the undersigned that Individual 1 has a great deal of admiration for Individual 2 because of the manner
in which Individual 2 treated them, namely with respect. Individual 2 also provided what Individual 1 described as
“constructive feedback” which Individual 1 believed made her a better employee.
9
Representative Morgan provided multiple communications but none of those communications indicates that
Individual 1 failed to respond to and provide information in a timely manner when requested. In fact, some of the
communication provide by Representative Morgan indicates that Representative Morgan failed to timely respond to
requests for changes by the time set by staff so that they could timely post notices. See, Ex. demonstrating a lapse of
5 days between provision of the document and response.
10
This presentation and comment can be seen on the video of the November 18, 2021, Commerce and Gaming
Committee meeting.
11
See attached Ex. 4.
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Interview with Individual 2:

Individual 2 was interviewed in January 2022. Individual 2 has significant experience working
with various committees across a broad spectrum of disciplines. Individual 2 reported that they
commenced work with the Social Justice and Equity in Cannabis Task Force chaired by
Representative Morgan from its inception. That individual reported that the Task Force was
composed of a council which had as its responsibilities establishing priorities for the Task Force,
reviewing data to recommend changes in policies, and evaluation of the societal factors that
negatively impacted the ability of people of color to be more participatory in the cannabis
industry. This was accomplished by three sub-groups.

Individual 2 reported that during the first meeting of the Task Force, Representative Morgan was
voted into the position of chair which they believed was reasonable in light of the work that had
been done by Representative Morgan to get the bill which established the Task Force approved.
Individual 2 reported that at the initial meeting, a member of the community was voted in as the
co-chair of the committee. Individual 2 reported that Representative Morgan does a very good
job of running public meetings and does a very good job of making sure that all of the voices of
the Task Force members are recognized and heard.12 However, Individual 2 reported that the
demeanor of Representative Morgan is demonstrably different when the communications are
with the internal staff versus when her communications are “public facing.”

Individual 2 further reported that they have been disappointed in the manner in which
Representative Morgan has “made space”13 for the community at large to be heard in the process
of examining the inequities in the cannabis industry. Individual 2 reported that the initial
concern about community participation was the decision that Representative Morgan would be
the chair of the Task Force. In order to facilitate the representation of what was described as an
underrepresented community, the community pushed to have a community co-chair.

Individual 2 reported that when they expressed the need for such representation and input,
Representative Morgan reacted negatively to the suggestion, stating that there was no need for a
co-chair. Ultimately, however, the Task Force decided that there should be a community co-chair
of the Committee. The community co-chair was Ms. Paula Sardinas.

Another example of the negative reactions related to the use of the chat box during the public
zoom sessions. When the meetings of the Task Force started, the community gave input through
a chat box that was monitored by a staff member. Representative Morgan wanted the chat box
shut down because, according to Individual 2, Representative Morgan expressed the belief that
the chat box was “a distraction.” The chat box was eventually shut down despite objections from
Individual 2 and the community co-chair. When efforts were made to reconsider this decision,

12
Individual 2 was making the point that inquiry of the public participants on the Task Force or non-task force
members would result in different perceptions of Representative Morgan than inquiry made to state employees.
13
This term was intended by Individual 2 to mean that Representative Morgan was not, in their opinion, interested in
giving voice to the people most impacted by the policies which had deprived them of opportunities to equitably
participate in the receipt of license in the cannabis industry.
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Representative Morgan suggested that Individual 2 was overstepping, that she had made a
decision and that the decision was final.
Finally, another example posited by Individual 2 was that the community co-chair, Ms. Sardinas,
eventually left the Task Force14,15 and Representative Morgan refused to fill the co-chair
position.

According to Individual 2, after the departure of the community co-chair, Ms. Sardinas, the
community began to express significant unhappiness about the manner in which the Task Force
was moving. Apparently, the community members felt that the Task Force was not moving as
expeditiously as the community believed that they should be moving. The staff expressed
interest in trying to determine the cause of the community pushback. According to Individual 2,
Representative Morgan was not interested in pursuing the source of the pushback and angrily
suggested that such activity would be a waste of time and that it was not Individual 2’s job to
make such suggestions.

According to Individual 2, Representative Morgan became angry and “yelled” at Individual 2 for
what they felt was the entire meeting. Individual 2 reported that the communication was both
disrespectful and dismissive. According to Individual 2, during the course of this meeting,
Representative Morgan referred to this Individual 2 as “the administrative staff.” Individual 2
reported that they felt that this reference was intended to put them in their place. Individual 2
reported that the meeting lasted for approximately 45 minutes, and they felt that Representative
Morgan continued “the rant” for the entire time. At the time of the events, Individual 2 did not
report the conduct that was directed toward them by Representative Morgan to anyone who had
the ability to address it.

Individual 2 reported that the three sub-committees of the Task Force had community members
as “co-leads” who had never been involved in such work before their appointment. Those
individuals needed support and asked a lot of questions. Individual 2 reported that
Representative Morgan did not want the staff to provide the support despite the fact that it was at
the sub-committee/work group level where most of the work of the Task Force was being
performed. According to Individual 2, Representative Morgan attended one work group
meeting.16

When inquiry was made about Individual 1 and their participation in the work of the Task Force,
Individual 2 reported that they had been impressed with the speed at which Individual 1 picked
up the tactical day-to-day requirements of the job and the way that they kept things moving
forward. Individual 2 reported that Individual 1 had a passion for the work that was being done
and worked hard to ensure that they were performing well on behalf of the group. Individual 1

14
Ms. Sardinas resigned from the Task Force to focus more on her family business.
15
The undersigned did not interview Ms. Sardinas in light of the fact that Ms. Sardinas had previously filed an ethics
complaint against Representative Morgan which, in the opinion of the undersigned, would likely have resulted in
Ms. Sardinas having a biased view of Representative Morgan.
16
The work groups were the chairs of the various sub-committees of the task force.
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kept all stakeholders informed, engaged in appropriate critical thinking, and generally kept things
moving forward.

Inquiry was made about what led to the incident involving Individual 1 and Representative
Morgan on October 19, 2021. Individual 2 reported that there had been a meeting of the full
Task Force in September 2021 at which there were so many items on the agenda for a full Task
Force meeting that the agenda could not be completed. As a result, a special meeting was
planned. Because there was significant work to be done by the Task Force prior to its anticipated
report of recommendations, Individual 1 and others believed that the agenda should include not
only the item or items which had not been completed, but also other items. Representative
Morgan believed that when a special meeting is called, the only items which could be on the
agenda were the uncompleted business items from the previous meeting and insisted that the
agenda be so limited. Individual 2 was not present at the meeting but was advised by Individual
4 that when Individual 1 presented the agenda to Representative Morgan, the Representative
immediately went into what was described as a “rant.” Individual 2 reported that the conduct
was so disturbing that Individual 4 also wrote into the chat on the Teams Meeting that they were
“really sorry” for what happened during the meeting. Individual 2 reported that the day that they
became aware of the incident, they were provided with the name of others who had witnessed it.

According to Individual 2, the Open Public Meetings Act (OPMA) requirements limit discussion
to items that are on the published agenda, which must be published within 24 hours of the
commencement of the meeting. Consequently, as long as the agenda was published in the
appropriate locations and at least 24 hours before the commencement of the meeting, it would
have been appropriate to have more items than just the items which were not considered,
reviewed, and acted upon by the Task Force in the prior meeting17

Individual 2 reported that subsequent to the incident, they were advised by at least two people
with whom Representative Morgan had previously interacted that Representative Morgan had
interacted with them in a similar manner as the manner in which she interacted with Individual 1.
Consequently, they have limited their communications with her.

Individual 2 reported that it was extremely uncomfortable to file a complaint, particularly against
a woman of color. However, they believed that if the behaviors of Representative Morgan go
unchecked, she will continue to engage in this type of behavior with others.

Interview with Individual 3:

Individual 3 was interviewed in February 2022. Individual 3 lodged a written complaint about
Representative Morgan after having been advised by Individual 2 about the interactions which
occurred between Individual 1 and Individual 2 and Representative Morgan. The complaint
indicated that the conduct was disrespectful.

17
See RCW 42.30.080.
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During the course of the interview with Individual , they reported that they had had limited
interaction with both Individual 1 and Representative Morgan.

Individual 3 reported that they had been around powerful black women throughout their lives
and that this background informed their comments about Representative Morgan as well as their
comments about the reactions of others to the interactions between Representative Morgan and
other women of color. Individual 3 reported that the historical racism that has been experienced
by many African American women informs the skills that they (African American women)
develop, the manner in which they are viewed by others, and the strength that it requires to
navigate in a predominantly white institution, such as the House of Representatives.

Individual 3 reported that after receiving a complaint about the manner in which Representative
Morgan interacted with Individual 1, they had a conversation with Representative Morgan in
which Representative Morgan attempted to cast blame on Individual 2 and others, including
Individual 3, for a lack of training and mistakes that were made during some of the work that
Individual 1 was performing in support of the Social Equity in Cannabis Task Force (Task
Force).

According to Individual 3, during conversations with Representative Morgan, the Representative

reported that from her perspective, Individual 1 had and exhibited a greater connection to the
community partners who were participants on the Task Force Committee and who had different
perspectives about how to achieve the objectives of the Task Force than Representative Morgan.
In hearing the description of concern from Representative Morgan, Individual 3 reported that
they did not see communications with the community members as inappropriate or unusual,
particularly in light of the objectives of the Task Force which were to develop policies and
procedures that would potentially equalize the playing field for community members who were a
part of the Cannabis industry.

When Individual 3 was speaking to Representative Morgan, they received additional information
from Representative Morgan about other issues that she had with Individual 1. Representative
Morgan provided as an example of other performance deficiencies the failure to incorporate
some comments into an updated progress report. Representative Morgan suggested that this
alleged failure was a hindrance to the progress of the Task Force. Similar to their perspective on
how other concerns raised by Representative Morgan should be handled, Individual 3 reported
that from their perspective, this was a matter for coaching by Representative Morgan and/or
Individual 1’s supervisor. However, instead of providing the appropriate coaching, they believed
that Representative Morgan was actually pushing to have Individual 1 investigated. When
Representative Morgan suggested investigation, Individual 3 advised Representative Morgan that
she was fully empowered to investigate, but she appeared to prefer that it be done by someone
else.

Individual 3 reported that they had a meeting with Representative Morgan and another
individual, Individual 6, during which time Representative Morgan sought to have the
supervision of Individual 1 removed from her then current supervisor to the Director of the

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Office of Equity. Individual 3 reported that, although a move of the staff of the Task Force to the
Office of Equity might be possible in the future, that was not something that could occur at the
time because the Office of Equity was not adequately staffed to handle the supervision.
Individual 3 believed that the motivation for this request was that Representative Morgan felt the
communications would be easier if someone from the Legislative Branch, of which she was a
member, as opposed to the then current situation which was that Individual 1’s supervision was
run by the Executive Branch.

Individual 3 reported that they believed that those who had the perception that Representative
Morgan’s communications were abusive, and traumatizing were credible. Individual 3 reported
that they had come to that conclusion because of what was described as the intensity of voice,
direct criticism and over talking, all of which are the types of things that can be experienced as
intimidating or creating a sense of discomfort. Individual 3 believed that this was particularly
true in light of the fact that there was a hierarchical component to the relationship between
Representative Morgan and the individuals who complained and/or corroborated the accounts
about Representative Morgan’s interactions with staff. Individual 3 went on to state that it is
exceedingly important for leaders (both elected and not elected) to be conscious of not imposing
themselves in a way that could be perceived as inappropriate.

Individual 3 reported that the conversation with Representative Morgan was a difficult one and
one which was not well received. During the conversation, Individual 3 recounted that
Representative Morgan asserted that this was simply a situation wherein people of color were
being pitted against each other. She also articulated that this felt like the familiar trope of a racist
system in which people of color struggle.

Individual 3 reported that it was their belief that it is unlikely that this is the first time that it has
been suggested to Representative Morgan that her communications were/are problematic, and
that Representative Morgan puts up defenses when she receives such feedback. Individual 3 also
reported that it is difficult for Representative Morgan to hear these criticisms. They also reported
that the difficulty in hearing such criticism is likely related to a concern that if Representative
Morgan takes ownership of these criticisms, there may be bigger consequences that may impact
her career.

Individual 3 reported that they hope that this issue does not unduly impact Representative
Morgan’s career and that perhaps providing informal support and coaching might be beneficial.

Interview with Individual 4:

Individual 4 was interviewed in February, 2022. Individual 4 reported a significant amount of

experience in leadership positions which helped to form the backdrop of their perceptions about
the events \that have occurred. They reported that Representative Morgan is a difficult
individual with whom to work because she is extremely unpredictable. When inquiry was made
about the nature of the interactions and unpredictability, Individual 4 reported that a person never
knows whether they will be scolded or applauded when the Representative shows up. They

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reported that in addition to the unpredictability, Representative Morgan also fails to provide
information that is necessary for them to perform their job, even when specific requests are
made.

Individual 4 reported that they personally observed Representative Morgan tear Individual 1
down in front of an entire group of people. Individual 4 reported that the conduct was so
disturbing to them that they experienced sleepless nights even though the conduct was not
directed toward them. Individual 4 added that the conduct was traumatizing enough to cause
them to be unable to continue doing their job on the day on which the incident occurred.

Individual 4 reported that the event which gave rise to the interchange was one in which
Representative Morgan believed that Individual 1 was incorrect in their interpretation of the
OPMA, specifically Representative Morgan expressed the belief that, in this particular
circumstance, a special meeting agenda could only contain the subject matter which was not
covered in a prior meeting.

Individual 4 reported that even though Individual 1 tried to shake the incident with
Representative Morgan off as “a different method of leadership,” they believed that the conduct
of Representative Morgan constituted “abuse,” was “disgusting,” made them “angry,” was
“intimidating,” “unprofessional,” and constituted a violation of basic human rights.

Individual 4 went on to report that the manner in which Representative Morgan spoke to
Individual 1 was “like a parent scolding a child.” Individual 4 stated that Representative Morgan
said things such as “I’m not asking you, I’m telling you” and “I’m not here to argue.”

Individual 4 reported that they were present when Representative Morgan made a statement that
there had been an individual who previously attempted to file a complaint against her, and that
person was no longer employed. Individual 4 reported that they were not sure if this was
intended to intimidate, but they did not believe that it was appropriate for the Representative to
make such statements. 18

Interview with Individual 5:

Individual 5 was interviewed in February, 2022. Individual 5 credibly reported that they have
had interactions with Representative Morgan that they described as being “hostile” and
“inappropriate” on at least two occasions. Individual 5 reported that it is their impression that
Representative Morgan is the type of person who will push someone until she realizes that she
can no longer get away with the type of conduct in which she engages, after which time she will
step back and recalibrate.

Individual 5 reported that they had a call from an employee of the state reporting that they were
going to resign their current position with the State because Representative Morgan “yells” and

18
Individual 4 reported that Representative Morgan did not identify the person by name and Individual 4 did not
know the identity of the individual to whom Representative Morgan was referencing.
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“screams” at people, and that they could no longer tolerate their interactions with her. Individual
5 reported that from their perspective, Representative Morgan appears to have issues which
might be helped by coaching or some other form of assistance.

Individual 5 reported that the first time that they realized that Representative Morgan had issues
with the manner in which she interacts with people was when she became publicly angry that
there was “no fried chicken being served on the African American Legislative Day event.”

Individual 5 reported that, personally, they make an effort to avoid interactions with
Representative Morgan. They described as Representative Morgan as having acted in a manner
consistent with the manner in which she was described to have dealt with Individual 1 and others
since Representative Morgan commenced her service in the legislature. This individual went on
to report that they have been contacted on multiple occasions by members of the community who
have complained about the manner in which Representative Morgan acts. This individual
reported that many of the community members have used unflattering terms when describing
Representative Morgan.

Interview with Individual 6:

Individual 6 was interviewed in February, 2022. Individual 6 has interacted with both Individual
1 and Representative Morgan but has not “had occasion to observe interaction between the two
of them.” Individual 6 reported that they were contacted by Representative Morgan requesting
assistance in changing the reporting relationship for the staff associated with the Task Force
because Representative Morgan did not feel that the staff was acting in conformity with her
leadership. Individual 6 did not recall the specific issue which gave rise to this complaint but
reported that it could have been the staff making recommendations of which Representative
Morgan did not approve or about which she did not know.

Individual 6 reported that they also had conversations with others who were either part of or
were in some way related to the work of the Task Force. Individual 6 reported that they believed
that there was an effort to draw them (Individual 6) and their department into a dispute.
Consequently, Individual 6 suggested that the parties should not triangulate, but have direct
conversation with one another.

On inquiry about their past experience regarding interactions with Representative Morgan,
Individual 6 reported that on a calm day, Representative Morgan is straight-up and direct. On a
not calm day, Representative Morgan is even more direct. Individual 6 reported that this is the
case regardless to whom Representative Morgan is speaking. Individual 6 described
Representative Morgan as passionate and having the attitude that if she is given the platform,
“she will take it.” Individual 6 reported that as a result of this method of communication, there is
“white backlash” in all forms.19

19
Individual 6 appeared to assume that it was a Caucasian person who instigated the complaint which gave rise to
the investigation.
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Individual 6 went on to state that Representative Morgan is “not a slave and will never be one.”
Therefore, Individual 6 is not surprised that this is, referring to the investigation, going on.

The undersigned believes that Individual 6 was deflecting in their responses to avoid providing
information that might be damaging to Representative Morgan.

Interview with Individual 7:

Individual 7 was interviewed in February, 2022. Individual 7 was active in the Task Force. As a
member of the Task Force, that individual had opportunity to observe some interactions between
Representative Morgan and Individual 1.

Individual 7 reported that in their personal experience of 1:1 contact with Representative
Morgan, it was direct but respectful. When requested to provide an explanation, Individual 7
reported that in their communications, Representative Morgan is not someone who engages in
“niceties or beating around the bush.”

Individual 7 reported that the dynamic between them and Representative Morgan, as compared
to the dynamic between staff and Representative Morgan, was very different. Upon inquiry, the
individual stated that the dynamic between Representative Morgan and the staff was best
described as an “uncomfortable power dynamic.” Individual 7 went on to state that the
interactions between Representative Morgan and support staff were not the type of exchanges
that one might expect a member of the support staff to be subjected to or that the support staff
themselves would or should expect to experience.

Individual 7 reported that the meetings of the Task Force were “incredibly difficult” and at times,
were so difficult that those present at the meeting were unable to conduct business. This
individual went on to report that part of the disruption was caused by members of the public who
attended the meetings and who were jumping in and disrupting to the point that it made having
meetings difficult. This dynamic resulted in a change in the format of the meetings to a webinar
format. Individual 7 described the dynamic with some of the members of the public as
‘fireworks.” Individual 7 reported that Representative Morgan appropriately stepped in and
handled the issues caused by the non-Task Force participating public.

On the other hand, Individual 7 reported that Representative Morgan was not respectful or
appropriate with Task Force staff. Individual 7 reported that Individual 1 was attempting to push
through Task Force agenda items when Representative Morgan “came down” on Individual 1 in
front of others in a way that Individual 7 did not believe was appropriate, especially in light of
the fact that it did not appear that Individual 1 had done anything wrong.

Individual 7 further reported that Individual 1 was “stepping up to do as much as they could and
appeared to be attempting to follow rules and instructions.” However, Individual 7 observed that
Individual 1 was being treated at the very least, “rudely.” Individual 7 reported that from their

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perspective, when you are a member of the legislature, “[I]f you want to yell at a senator, fine,
but don’t yell at a staff member.”

When asked for greater detail about the October 19, 2021, incident Individual 7 reported that
there appeared to be a miscommunication about whether there would be a full Task Force
meeting or one that was limited to work that needed to be completed from the previous meeting.
Individual 1 thought it would be a full meeting and Representative Morgan insisted that it was
only to focus on completing the work that remained unfinished from the prior meeting.
Individual 7 reported that Representative Morgan kept insisting that having a full meeting could
not be done because it was a violation of the OPMA. Individual 7 reported that there were
perhaps as many as 15 people present at the meeting when this exchange was taking place.

Individual 7 reported that they felt that it is their experience that in a workplace, everyone should
be treated with dignity, respect, and cordiality. Individual 7 described the interchange as “over
the top,” especially in light of the power dynamic between Individual 1 and Representative
Morgan.20

Interview with Representative Melanie Morgan:

Representative Melanie Morgan was interviewed in April 2022. As previously indicated, the
request to interview the Representative was made significantly earlier than April. However, she
did not make herself available until April. There were two sessions with the Representative and
documents were provided by the Representative in May 2022.

Representative Morgan was questioned about the interchange which gave rise to the complaint
relating to her interactions with Individual 1 on October 19, 2021. The Representative reported
that she could not give a “blow-by-blow” stating that she was overwhelmed by the question and
that the meeting in question was not the only meeting that she chairs.

Representative Morgan recalled that she received a question about whether the meeting in
October 2021 should be a special meeting or should be a regular meeting. She reported that the
pattern had been to have a meeting every other month and having a meeting in October would
have been out of the pattern related to the meetings. Representative Morgan reported that she
responded that the meeting should be a special meeting. When asked why she made that
decision, she reported that the meeting had to be a special meeting to facilitate transparency.

When inquiry was made about what she meant by the need for transparency, Representative
Morgan reported that it was the “Chair’s prerogative” and that everyone knows that the decision
as to how frequently to meet is within the Chair’s purview. From her perspective, there was no
need to call another meeting. She also stated that the decision not to have a full meeting had to
do with taking into consideration using people’s time because, with the exception of the staff, the
participants in the meeting are volunteers.

20
The power dynamic was that of an elected official versus. an employee.
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When asked specifically what the interchange was between her and Individual 1 regarding the
setting of the meeting, Representative Morgan reported that she did not recall the exact words
that were exchanged at the meeting, but she did recall the flavor of the conversation. She
reported that she stated that there was no need for a regular meeting and that she was not going
to go back and forth about it. She stated that only the staff was going to have to attend the
meeting. When asked about the tenor exchange, she stated that the tenor is “I am a leader and I
am the Chair and I made the decision.” She reported that the staff kept coming back to the
suggestion that there be a full meeting, but she does not recall her reaction to that.

Inquiry was made of Representative Morgan about the tone of voice used in the interchange with
Individual 1. She stated that she did not raise her voice, did not use a condescending tone, and
she was not angry. She stated that she does not use condescending tones when speaking to
people.

She further stated that she did not think that she was in any way embarrassing Individual 1 when
she spoke to them. In fact, she stated that she doesn’t believe that she was saying anything that
should make anyone feel embarrassed. She also stated that she would be “surprised” if anyone
suggested that her communications were disrespectful. As support for her position,
Representative Morgan reported that Individual 1 had apologized to her for appearing to be
argumentative after the meeting was over. (See attached Ex. 2).21

Inquiry was made of Representative Morgan about whether, in responding to the inquiry from
Individual 1, she raised the issue of the OPMA. She stated that she “Does not believe that she
discussed the [OPMA].”

Representative Morgan did not have specific recollection of the length of time the meeting took,
what was discussed, or whether comments were made by others such as the co-leads.

Representative Morgan reported that she did not speak to anyone after the meeting about the
specific interchange. She stated that she did have a conversation sometime later with Individual
2 about Individual 1’s job performance.

When inquiry was made about what concerns she raised about Individual 1, she stated that
Individual 1 was inconsistent in her communications. She stated that Individual 1 was not
notifying her and not keeping her in the loop. When asked for specifics, she stated that a co-lead
had quit the committee and Individual 1 “had taken it upon herself to appoint a new co-lead.”
She stated that Individual 1 had appointed Dorian Waller as the co-lead.22 Representative
Morgan stated that she learned about the appointment by reviewing the agenda.

21
Individual 1 credibly reported that she did apologize to Representative Morgan because she did not want to be
further victimized by Representative Morgan.
22
There is no evidence to support the assertion by Representative Morgan about the attempt to appoint Dorian
Walker as co-lead of any task force sub-committee. Instead, Representative Morgan was advised in writing on
November 22, 2021, that when one of the sub-committee co-leads had resigned, Dorian Walker volunteered to
present information at the next task force meeting because the person who had been assigned the responsibility was
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Representative Morgan reported that there were other issues with communication including
things that were edited on the work plan and the timelines without notifying her. She reported
that it is imperative that she know every change that occurs, and this simply was not occurring.

Representative Morgan reported that one of the other issues that she had with Individual 1 was
that she started recording meetings without advising her that the recording was taking place and
that multiple individuals complained. She reported that someone inquired about the reason she
was being recorded because they were not aware that they were being recorded.23,24

She stated that in addition to the above, Individual 1 was argumentative and this was something
that was reported to her by all of the Task Force Committee members. She later modified the
accusation to state that not all of them complained. She complained that rather than acting in a
supporting role, she appeared to the Representative to be inserting her personal agenda into the
meetings.25 She stated that one of the community members agreed with this.

The above referenced complaints were memorialized in a communication from Representative

Morgan to Individual 2 on November 16, 2021, less than one month after the incident which
gave rise to the complaint and less than 10 days after the complaints were lodged with the
Department of Health.26

Representative Morgan reported that she also had a conversation with Individual 3 about
Individual 1. She reported that she told Individual 3 that she was willing to resign from the
Committee because she did not wish to be in charge of the Committee anymore. She stated that
she felt like she was trying to solve problems and she did not believe that this was happening
with the Committee.

Representative Morgan reported that she felt that some of the issues that she had with Individual
1 might be related to a lack of training. Consequently, she inquired of Individual 2 about training
for people in Individual 1’s position. She reported that she had never received any information
about whether there was appropriate training provided to Individual 1.

Representative Morgan was questioned about her relationship with Individual 2. She stated that
she felt that Individual 2 was attempting to minimize her as the Chair of the Committee. She
stated that she felt that it was imperative to “stand her ground” and she felt that there was a lot of
push and pull and that there was a “power struggle” about who was in charge of the Committee.

no longer on the Task Force. Despite having been advised of this more than 5 months prior to her interview with the
undersigned, Representative Morgan persisted in making this accusation. (See Attached Ex. 5)
23
In response to this allegation, Individual 1 reported that the recording took place on one occasion and occurred so
that there would be an opportunity to document what would be necessary to follow up for the next meeting. They
also credibly reported that the individual who made the inquiry did know that they were being recorded because the
fact of recording actually shows up on the screen for any and all such meetings.
24
It should also be noted that the documentary evidence presented regarding the recording is dated February 2022,
after the complaint had been lodged against Representative Morgan in November 2021. (See Ex. 6)
25
See attached Ex. 7, job description for the position held by Individual 1.
26
Complaints were lodged on November 1, 2021, November 8, 2021. .
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When asked for specific examples, Representative Morgan was unable to provide any specific
examples. She stated that this continued until Individual 1 was hired resulting in Individual 2 not
working with the Task Force any further.

Inquiry was made of Representative Morgan about her relationship with others who assisted with
the Task Force, including Individual 4. She reported that Individual 4 worked for Individual 1
and she did not know what their job was.

At one point during the course of the interview, Representative Morgan reported that Paula
Sardinas, former Task Force Co-Chair, had filed a complaint against her and she wondered
whether Individual 1 and Ms. Sardinas had gotten together to “gang up against her.”

Representative Morgan reported that all that was happening in this circumstance was that she
was a “black woman speaking directly.” She stated that she was frustrated by the accusations
and having to answer the questions which were being posed. She stated that she was “holding
back tears” during the course of the interview. She stated that she has been so impacted by the
complaint, that she does not know how to proceed and move forward, has declined to participate
in a few Task Force meetings because she does not know who on the staff is upset with her, and
she wants to avoid doing anything that would make anyone feel further intimidated.

Findings:

The undersigned makes the following findings with respect to the events of October 19, 2021.

1. On October 19, 2021, during a meeting with Representative Morgan, sub-committee co-
leads, and Task Force staff, Representative Morgan was asked by Individual 1 about the
potential for making a meeting which was scheduled for October 28, 2021, a full meeting
instead of a special meeting.

2. Representative Morgan did not wish to have a full meeting.

3. In response to the inquiry, Representative Morgan suggested that because the meeting
was being called to complete agenda items, it would be a violation of the OPMA to cover
agenda items other than the items that were not completed on the previous agenda.

4. Representative Morgan asserts that she does not recall referring to the OPMA, however,
multiple witnesses affirm that she very specifically stated that such a meeting would be in
violation of the OPMA.

5. Based on the multiple individuals who reported that Representative Morgan did state that
having a full meeting would be in violation of the OPMA, the undersigned does not find
the denial or the asserted lack of recollection of Representative Morgan to be credible.
Instead, the undersigned credits and finds the recollection of three interviewees who were
present at the meeting to be credible.

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6. The undersigned finds that by its terms, the OPMA requires that agendas be posted and
made public not less than 24 hours prior to a meeting and does not place any restrictions
on the content of the meeting as long as the public is advised of the agenda. (See RCW
42.30)

7. The undersigned finds that during the exchange regarding the extension of the agenda to
include more than the subject matters which had not been completed at the most recent
Task Force meeting, the Representative was rude, disrespectful, and dismissive of
Individual 1 in the presence of multiple other individuals.

8. The undersigned finds the manner in which Representative Morgan spoke to Individual 1
was so notable that it elicited concerns from at least two other members of the Task
Force, one of whom indicated that they had to leave the meeting because it was
traumatizing, while another apologized for not interceding and attempting to comfort
Individual 1 after Representative Morgan left the meeting. Additionally, the undersigned
finds that based upon these reactions, the assertion by Individual 1 that others also
apologized for the conduct of Representative Morgan is more probably than not true.

9. The undersigned finds it credible that one of the individuals present at the October 19,
2021, meeting notified Individual 1’s supervisor of the incident because they believed the
conduct to be inappropriate. The undersigned finds and credits the statement of that other
individual who was present that Representative Morgan had engaged in conduct which
was described as treating Individual 1 as “less than,” “gaslighting” and “rude”
particularly in light of the power dynamic between a staff member and a State Legislative
Representative.
10. The undersigned also finds credible the assertion by two individuals who were present at
the October 19, 2021, meeting, that Representative Morgan stated that a prior employee
had complained about her and was no longer employed.

11. The undersigned finds that Representative Morgan lodged a significant number of
complaints about Individual 1’s performance after a complaint was filed about the
October 19, 2021, interaction.

12. The undersigned finds that among the allegations lodged by Representative Morgan were
complaints that Individual 1 did not understand the OPMA, does not use proper channels
of communication, is late getting talking points to the chair, and that Individual 1 is not
aligned with the interests of the Chair.

13. The undersigned finds that some of the concerns raised appear to have been the result of a
failure by Representative Morgan to clearly define roles and expectations, and some of
which appeared to be the result of a failure to understand the traditional role which has
been fulfilled by Policy Analysts and others who are staffing committees such as the Task
Force.

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14. The undersigned finds that in addition, some of the concerns raised by Representative
Morgan were the direct result of unavailability of Representative Morgan to communicate
directly, as opposed to through an intermediary, such as her assistant, with those who
were charged with staffing the Task Force.

15. The undersigned finds that the Washington State House of Representatives Respectful
WorkpPlace Policy which states in pertinent part:

2. ABUSIVE BEHAVIOR AND BULLYING

Abusive behavior and bullying are also prohibited, regardless of the basis for
the conduct. Bullying is repeated and unreasonable actions of one or more
persons that are threatening, humiliating, degrading, or intimidating. Bullying
can take many forms and may include intimidation, isolation, verbal abuse,
undermining, sabotage, unreasonable work expectations, inappropriate use of
staff, or psychological mistreatment such as humiliating, manipulating, or
instilling fear.

16. The undersigned further finds that the Washington State House of Representatives
Respectful Workplace Policy also states:

3. RETALIATION
Retaliation against any person who reports or participates in an investigation
or proceeding relating to a potential violation of this policy is prohibited.
Examples of retaliation include adverse employment actions or retaliatory
harassment, such as ostracism or threat of an adverse employment action.

Conclusions:

Based on the above referenced information, the undersigned draws the following conclusions
with respect to the complaints lodged by Individual 1 and Individual 2.

1. Representative Morgan engaged in conduct directed toward Individual 1 on October

19, 2021, which was perceived by multiple individuals to be abusive and bullying.

2. The undersigned concludes that Representative Morgan engaged in abusive and

bullying conduct which was predicated on the manner in which Representative
Morgan addressed Individual 1’s suggestion that the next Task Force meeting be a full
meeting and cover topics beyond those which had not been covered in the September
meeting because that meeting went on for longer than necessary. These actions
occurred in the presence of multiple people and were legitimately perceived and
received as rude, disrespectful, and demeaning.

3. The undersigned concludes that engaging in rude, disrespectful, and demeaning

conduct is a violation of the Respectful Workplace policy.

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4. The undersigned concludes that the complaints filed by Individual 1 and Individual 2
about Representative Morgan’s conduct on October 19, 2021, were the cause of the
complaints lodged by Representative Morgan about Individual 1.

5. The undersigned finds that the lodging of complaints against Individual 1 after
learning of the complaints lodged by Individual 1 and Individual 2 constitutes
retaliation and was an adverse employment action.

6. The undersigned also concludes that Representative Morgan’s suggestion that she
would resign from the Task Force Committee if Individual 1 was not removed was
also retaliatory in nature because its intended purpose was to force the removal of
Individual 1 from their position.

If you have any questions regarding this report or its conclusions, please do not hesitate to
contact me.

Respectfully,

Sheryl J. Willert
(206) 628-2408
[email protected]

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