FILED
MAY 16 2017
STATE GRAND JURY OF SOUTH CAROLINA JAMES R, PARKS
CLERK, STATE GRAND JURY
STATE OF SOUTH CAROLINA
} CASE NO. 2017-G8-47-13
-VERSUS- )
) INDICTMENT FOR COMMON LAW
RICHARD M. QUINN, JR. ) MISCONDUCT IN OFFICE
)
DEFENDANT. )
)
Ata session of the State Grand Jury of South Carolina, convened at Columbia, South
Carolina, on this 16th day of May, 2017, the State Grand Jurors present upon their oath:
COMMON LAW MISCONDUCT IN OFFICE
That on or about January 1, 1999 through on or about April 15, 2017, in Richland
County, and while acting as a public official, the Defendant, RICHARD M. QUINN, JR,
willfully and dishonestly failed to properly and faithfully discharge the duties of his public office
imposed upon him by law and did commit acts or omissions in breach of his duty of good faith
and accountability to the public by using the office and position of Member of the South
Carolina House of Representatives and candidate for the office of State Treasurer, and by using
campaign funds to obtain personal profit and benefit to himself, to wit:
Defendant did send business to First Impressions, Inc. d/b/a Richard Quinn and
Associates (hereinafter, “RQ&A"); Mail Marketing Strategies, LLC (hereinafter, “MMS"); and
‘The Copy Shop—all business entities in which the Defendant has an economic interest—from
the House Republican Caucus’s campaign and operating accounts in the amount of
approximately $271,881.69, while serving as House Majority Leader; and/or,
Defendant, while serving as Majority Leader of the South Carolina House Republican
Caucus, failed to disclose contributions and expenditures made to and from the South Carolina
House Republican Caucus Operating Account, which were improperly used for campaignpurposes, and the caucus, while under Defendant's leadership, did not file a certified report as
required by law. The Caucus’s failure to provide full disclosure of Caucus contributions and
expenditures allowed Defendant and businesses in which Defendant has an economic interest to
collect approximately $255,188.12 from the House Republican Caucus during this time, without
accountability to the public, and thereby impugning the integrity of the political and
governmental process; and/or
Defendant did use his position as a member of the South Carolina House of
Representatives and Majority Leader of the South Carolina House of Representatives to solicit
other members of the South Carolina House of Representatives to use MMS—a business entity
in which he has an economic interest—for which he received or attempted to receive public
funds used for mailing provided by the House of Representatives; and/or,
Defendant did file fraudulent campaign disclosure forms pertaining to Defendant's
‘campaign account for the Office of South Carolina Treasurer; and/or,
Defendant, while a candidate for and elected member of the South Carolina House of
Representatives, District 69, did use his campaign account to gain an economic interest by
directing campaign funds to RQ&A, MMS, and The Copy Shop, all three businesses in which he
has an economic interest, for unlawful personal profit; and/or,
Defendant, while a candidate for and elected member of the South Carolina House of
Representatives, District 69, knowingly did file Candidate Campaign Disclosure Forms detailing
reimbursements and expenditures from his campaign account, which included improper and/or
false claims that money was spent for legitimate campaign or legislative purposes; and/or,
Defendant did fail to file statements with the appropriate supervisory office for goods or
services from a person he knows to be a lobbyist or a lobbyist's principal in an amount exceeding$200, from the filer, a member of the file's immediate family, an individual with whom the filer
was iated, or a business with which the filer was jated, to wit: the Defendant through
$50
RQ&A and MMS accepted approximatel
$4,558,860.76 from lobbyist’s principals, and failed
to report or file a statement regarding the economic interest or payment for goods and services to
the appropriate supervisory office; and/or,
Defendant did make, participate in making or attempt to use his office, membership, or
employment to influence govemmental decisions in which he, a family member, an individual
with whom he was associated, or a business with which he was associated had an economic
interest, to wit: the Defendant, through his businesses RQ&A, MMS, and The Copy Shop,
received substantial funds from lobbyist’s principals and used his public office to influence
governmental decisions involving those lobbyist principals; and/or,
Defendant did act as a lobbyist while holding office in the South Carolina House of
Representatives, to wit: the Defendant, through his businesses RQ&A, MMS, and The Copy
Shop, did attempt to influence the action or vote of members of the South Carolina General
Assembly by direct communication on behalf of entities which employed, retained, or appointed
Defendant's businesses for the purpose of influencing the action or vote of any member of the
General Assembly concerning legislation.
All against the peace and dignity of the State and in violation of the common law of
South Carolina.
Qc Boreas
David M. Pascoe
First Circuit Solicitor
Bill