‘Gang of Four’ Coordinated Washington Hunting Policy Behind Closed Doors

A long-awaited report on an investigation of the Washington Fish and Wildlife Commission has “substantiated in part” allegations that some members of the appointed body “engaged in repeated, undisclosed meetings and communications with advocacy organizations actively litigating against the department (of Fish & Wildlife), in violation of the Commission’s Rules of Procedure governing disclosure and conflicts of interest.”

The Washington Department of Fish and Wildlife (WDFW) manages the fish and wildlife resources.

The 68-page report, released July 31, looked at allegations that commissioners violated the Public Records Act, the Open Public Meetings Act and were essentially too cozy with organizations which oppose department policies.

Northwest Sportsman magazine, which has been covering the controversy surrounding the Commission and its troubles with an organization called the Sportsman’s Alliance, quoted Alliance Marketing Vice President Brian Lynn stating, “The report reveals serious issues and even potential crimes committed by WDFW Commissioners. It’s nice to see all the evidence the Sportsmen’s Alliance brought forward more than a year ago was taken seriously, and that the wrongdoing is now substantiated and on display for the citizens of Washington.”

He said it is time for Democrat Gov. Bob Ferguson to “hold these commissioners accountable.”

The findings by Chiedza Nziramasanga at Transformative Workplace Investigations have left many sportsmen and women with an “I told you so” reaction, and it is being discussed by members of the Hunting-Washington forum.

Here are the findings that are raising eyebrows:

Allegation 1: Violations of the Public Records Act (PRA)

Based on the preponderance of the evidence, this allegation is substantiated in part. The evidence establishes that commissioners did not consistently comply with PRA requirements, including through use of personal devices for commission business, failure to conduct complete searches, submission of inaccurate or incomplete declarations, and in some instances resistance to Office of the Governor/WDFW Commission Investigation Transformative Workplace Investigations 5 | P a g e production until compelled. Systemic factors, including delayed issuance of state equipment, divergent experiences with training, and high request volume, also contributed. The evidence does not establish that noncompliance was universally deliberate or the result of coordinated concealment.

Allegation 2: Violations of the Open Public Meetings Act (OPMA)

Based on the preponderance of the evidence, this allegation is substantiated in part. The evidence establishes that commissioners engaged in serial meetings through coordinated communications that collectively involved a majority discussing and shaping agency business outside of publicly noticed meetings, and that documentary evidence corroborates coordination on votes, policy drafting, and leadership elections conducted through private communications. The evidence does not establish that commissioners knowingly violated OPMA. The record reflects reliance on quorum-based guidance and an insufficient understanding of serial meeting prohibitions.

Allegation 3: Violations of the WDFW Commission Rules of Procedure – Ethical Conduct and Conflicts of Interest

Based on the preponderance of the evidence, this allegation is substantiated in part. The evidence establishes that multiple commissioners engaged in repeated, undisclosed communications and meetings with advocacy organizations, including organizations actively litigating against the Department, in violation of the Commission’s Rules of Procedure governing disclosure and avoidance of conflicts of interest or the appearance thereof. The evidence does not establish unlawful litigation collusion or statutory conflicts of interest, but does reflect appearance concerns, institutional risk, and inconsistent compliance with the Commission’s own disclosure standards.

Allegation 4: Staff Mistreatment and Alleged Retaliation Against the Director

Based on the preponderance of the evidence, this allegation is substantiated in part. The evidence establishes a significant breakdown in trust between certain commissioners and Department leadership, strained staff-commissioner dynamics, and isolated instances of confrontational or inappropriate tone toward named staff members. The evidence does not establish a coordinated pattern of harassment, systemic mistreatment of staff, or formal retaliatory employment action against WDFW Director (Kelly) Susewind following his request for an external investigation.

Allegation 5: Improper Timekeeping and Compensation Claims

Based on the preponderance of the evidence, this allegation is unsubstantiated. While Commissioner Smith claimed per diem compensation on a significantly higher number of days than her peers over an extended period, the Commission’s compensation structure permits a full day’s per diem for any day on which commission work is performed. The evidence does not establish that she falsely certified work performed, claimed compensation for days on which no commission-related activity occurred, or violated any established policy.

The report falls short of recommending specific commissioners be removed or not re-appointed when their terms end later this year. Instead, the report states, “The report recommends more training and compliance reviews for commissioners and leaves the question of what punishments commissioners should face up to the powers that be.”

“In each instance,” the report says, “the evidence stops short of establishing the most serious forms of the alleged misconduct. The PRA finding does not establish that noncompliance was universally intentional or the result of coordinated concealment. The OPMA finding does not establish knowing violations or deliberate concealment of decision-making. The ethical conduct and conflicts of interest findings do not establish unlawful litigation collusion or statutory conflicts of interest. The staff mistreatment finding does not establish systemic harassment, formal retaliatory employment action against the Director, or a coordinated effort to remove him in response to protected activity.”

The commissioners under scrutiny—Lorna Smith, Melanie Rowland, John Lehmkuhl and Barbara Baker—were all interviewed by Nziramasanga, along with Susewind and Deputy WDFW Director Amy Windrope and Commissioners Jim Anderson and Woody Myers. There was no immediate reaction.

As noted by Northwest Sportsman, the report was commissioned in June 2025 following the so-called Knoll Memo, a 10-page document authored last year by Thomas R. Knoll Jr., a WDFW criminal justice legal liaison, after he received records of interactions between certain commissioners and outside groups. All of this was detailed back in March by Northwest Sportsman.

One paragraph on Page 33 of the report is sure to raise hackles:

“Multiple commissioners acknowledged frequent communications among an identified group of four regarding substantive commission matters, including the spring bear hunt, conservation policy development, the vice-chair election, and motion drafting. Commissioner Rowland confirmed that the group referred to themselves as the “Gang of Four.” The communications went beyond information sharing. Commissioners discussed how to structure motions, anticipated voting outcomes, and coordinated support for leadership positions prior to public meetings — active coordination on agency business, not merely passive preparation. Commissioner Smith described four commissioners reaching agreement on the substance of the spring bear motion and then transmitting the language to Chair Baker under the Commission’s ‘no surprises’ norm, thereby extending the discussion chain to a fifth commissioner before the matter reached a public meeting.”

Smith and environmental attorney Claire Loebs Davis, founder and board president of Washington Wildlife First and managing partner for Animal & Earth Advocates, filed a federal civil rights lawsuit against Susewind and Windrope, alleging they are trying to stifle Smith and Davis’ First Amendment rights.

What the investigation underscores is a growing concern among Evergreen State hunters and anglers that the Commission has taken some actions which have limited opportunities. Washington hunters, in particular, have been complaining about game management in the state for decades, long before the embattled current commissioners came along. They often grumble about the agency, alleging, for example, that WDFW pays more attention to wolf reintroduction than providing big game hunting opportunities for deer and elk, with concerns wolves will eventually decimate game populations.

Hunters were furious when the commission cancelled the traditional spring black bear hunt a few years ago. They were also not happy when the commission voted to move the annual grouse season opener back two weeks, from Sept. 1 to Sept. 15, on the grounds that too many hens were being taken during the early part of the season. There is a suspicion the setback was also to accommodate Labor Day campers and hikers—non-consumptive recreationists who didn’t like hearing gunshots—while enjoying the three-day weekend.

All of the commissioners were appointed by former Gov. Jay Inslee. The terms of Smith, Rowland and Lehmkuhl’s expire at the end of this year, and time will tell if they are reappointed or replaced by Ferguson, who was elected when Inslee chose not to run for a fourth term.

There has not been a Republican governor in Washington for 40 years.

About Dave Workman

Dave Workman is a senior editor at TheGunMag.com and Liberty Park Press, author of multiple books on the Right to Keep & Bear Arms, and formerly an NRA-certified firearms instructor.