Challenging the FEC’s Delay in Enforcing the Law Against the GEO Group — CLC v. FEC (GEO Group Contractor Contribution)

At a Glance

This case is a challenge to the FEC’s delay in enforcing federal campaign finance law against GEO Group, one of America’s largest private prison companies, which illegally made $225,000 in contributions to a super PAC supporting then-candidate Donald Trump in 2016.

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Active
Updated
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Campaign Finance
About This Case/Action

In August 2016, the Obama administration announced that it would be phasing out federal private prison contracts like those held by GEO. The announcement sent GEO’s stocks tumbling. The next day, GEO contributed $100,000 to the pro-Trump super PAC Rebuilding America Now, and it made another $125,000 contribution just one week before the election. At the time, Mike Pence was telling donors that giving to the super PAC was “one of the best ways to stop Hillary Clinton and help elect Donald Trump our next president!” After Trump won, GEO gave $250,000 to the Trump Inaugural Committee.

GEO did not have to wait long to see its investment start to pay off. On Feb. 23, 2017, during his second full week on the job, Attorney General Jeff Sessions issued a one-paragraph memo reversing the Obama administration’s private prison phase-out, instead ordering officials to continue using for-profit facilities for federal inmates.

In April 2017, the Trump Administration awarded GEO a $110 million, 10-year federal contract to build and administer a new 1,000-bed immigration detention center in Texas. GEO expects $44 million a year in revenue from the facility. GEO also has enjoyed a soaring stock price; its stock shot up 21 percent the day after Trump won, and has continued to grow since then.

CLC filed an FEC complaint, which alleges that the contributions — made through a wholly-owned subsidiary, GEO Corrections Holdings, Inc. — violated the ban on federal contractors giving money in federal elections. This law has been in place for 75 years to protect the integrity of the contracting process.

CLC filed this case against the FEC on January 10, 2018 in the U.S. District Court for the District of Columbia after waiting more than a year for the FEC to resolve this complaint. CLC hopes the lawsuit will compel the FEC to act. 

There is recent precedent for the FEC taking action against government contractors for giving to super PACs. In September 2017, the FEC responded to a CLC complaint and found that the Massachusetts-based Suffolk Construction Company violated campaign finance law by making two $100,000 donations to a Hillary Clinton-affiliated super PAC in 2015. That company agreed to pay a $34,000 fine.

The reason that federal contractors have been barred from making contributions for the past 75 years is to prevent pay-to-play in the contracting process. Public officials are supposed to make contracting decisions based on what is best for the public, not based on who spent the most money getting them elected. GEO Group’s illegal donations have the appearance of a pay-to-play: since Trump was elected with GEO’s backing, the company has reaped enormous political and financial benefits, including a new $110 million taxpayer-funded contract.

The FEC is critical to the enforcement of the contractor contribution ban and in preventing pay-to-play politics. It is incumbent upon the FEC to enforce the longstanding federal contribution ban and take action against GEO Group to deter future violations. Without the contractor ban, the government contracting process becomes an obvious way for officials to reward friends and political donors.

In a separate but related case, CLC filed a lawsuit on June 15, 2017 seeking to compel the Department of Justice (DOJ) to disclose requested records that would gather information about how DOJ reached its conclusion to rescind official policy to phase-out the use of private prisons in the administration’s contracting process. Almost nine months later, the public still has not seen any documents that show how DOJ reached its decision to change course on its private prison policy.

Plaintiffs

Campaign Legal Center

Defendant

Federal Election Commission

Associated Cases & Actions

Exposing Pay-to-Play Scheme Enacted by the GEO Group

Doe v. FEC

At a Glance

Doe v. FEC is a case about a mystery donor's attempt to maintain secrecy around a $1.7 million donation to a super PAC whose spending was meant to influence the 2012 election. 

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Closed
Updated
Issues
Campaign Finance
About This Case/Action

Doe v. FEC is a case about a mystery donor's attempt to maintain secrecy around a $1.7 million donation to a super PAC whose spending was meant to influence the 2012 election. The nonprofit group Citizens for Reponsibility and Ethics in Washington (CREW) brought the original complaint against the super PAC, called Now or Never PAC, in February 2015 alleging that an unknown person made a contribution to Now or Never, violating the prohibition on contributions made in the name of another person.



CLC filed a motion to intervene in support of CREW's quest for transparency on January 3, 2018.



On March 23, 2018, the U.S. District Court issued an opinion that upheld the right of the Federal Election Commission to uphold its own disclosure policy and give the public the right to know the names of donors.



Importance of Case



Disclosure is critical because voters deserve to know the names of donors that are spending millions of dollars to influence their vote. Transparency is the foundation of an open democracy. Under the Federal Election Campaign Act, the FEC must be permitted to keep extensive recordkeeping and disclosure requirements of campaign contributions in order to remedy pay-to-play politics.

Plaintiffs

John Doe

Defendant

Federal Election Commission

Challenging the Consolidation and Distribution of Federal Citizenship Data for Voter Purges (League of Women Voters v. US Dept. of Homeland Sec.)

At a Glance

The League of Women Voters is challenging the Department of Homeland Security (DHS)’s consolidation and distribution of flawed federal citizenship data to states and other federal agencies under the Privacy Act, the Administrative Procedure Act, and the U.S. Constitution. Campaign Legal Center submitted an amicus brief urging the court to block this program. 

Status
Active
Issues
Voting and Elections
About This Case/Action

Historically, U.S. Citizenship and Immigration Services (USCIS) has maintained a database on immigrants that tracks their immigration status and citizenship status called “SAVE.” The original purpose of the SAVE database was to provide government agencies with a resource to check whether individuals were eligible for government benefits based on their immigration or citizenship status.  

In recent years, a handful of states have used SAVE as part of their voter registration system. SAVE can be used to attempt to confirm the citizenship status of an individual either at the time they apply to register or after they have been added to the state’s voter registration list.  

Because the SAVE system only contained information regarding immigrants, it could not be used to confirm the citizenship status of U.S.-born citizens.  

The information SAVE has about individuals is often outdated, meaning that people could be categorized as noncitizens in SAVE even long after they have become a naturalized citizen and eligible to vote.  

Now, the Department of Homeland Security (DHS) — which oversees USCIS — has entered into an agreement with the Social Security Administration (SSA) to incorporate SSA’s data into the SAVE system, data that includes U.S.-born citizens. As a result, many government agencies will be able to access this combined database of all Americans.  

This newly incorporated SSA data is notoriously unreliable. SSA is not entrusted with making citizenship determinations or formally tracking citizenship status. Incorporating unreliable citizenship data could result in citizens erroneously having their voter registration application denied or erroneously being purged from voter registration lists.    

On September 30, 2025, a group of plaintiffs led by the League of Women Voters filed suit in federal court challenging the legality of DHS’s data consolidation efforts. The suit claims that DHS’s centralization of data on Americans violates the Privacy Act, the Administrative Procedure Act, and the separation of powers required by the Constitution.

Campaign Legal Center submitted an amicus brief highlighting the separation-of-powers concerns implicated by DHS’s intervention in verifying voter eligibility.

Only Congress and the states have the power to set rules about our elections, not the president. This attempt to consolidate private and sensitive data by DHS is part of a larger effort to shift election administration functions into the executive branch.

Voter purges, or efforts to remove a significant number of voters from the registration rolls all at once, ultimately threaten Americans’ freedom to vote and tend to disproportionately target people with past felony convictions, voters of color, low-income voters and young voters.    

Associated Cases & Actions

Challenging the Trump Administration’s Unlawful Voter Data Collection

VICTORY: Groups Successfully Strike Down Provision of Anti-Voter Executive Order

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Washington, DC — On Friday, Oct. 31, a key part of an anti-voter executive order was permanently halted following successful, early action by a coalition of nonprofit groups to stop this unlawful power grab by the president, protect the freedom to vote and safeguard our system of checks and balances. 

The League of United Latin American Citizens (LULAC), Secure Families Initiative (SFI) and Arizona Students’ Association (ASA) — represented by Campaign Legal Center (CLC) and Democracy Defenders Fund (DDF) — sought to prevent the Election Assistance Commission (EAC) from taking any action to implement Section 2(a) of the president's March 25, 2025, executive order. In its opinion, the court held that Section 2(a) is an unconstitutional violation of the separation of powers. 

A judge for the U.S. District Court for the District of Columbia granted our motion for summary judgment and issued an injunction that permanently halts the EAC from implementing Section 2(a) of the president’s order, which ordered the EAC to add a documentary proof of citizenship (DPOC) requirement to the National Mail Voter Registration Form. 

"This is not just a victory for LULAC, but for every eligible voter," said Juan Proaño, LULAC Chief Executive Officer. "The Court sent a clear and powerful message: no president can unilaterally rewrite election law to suppress the vote. This ruling safeguards the voices of millions who depend on the integrity of our democratic system." 

“Efforts to silence the voices and votes of the American electorate must not stand,” said Roman Palomares, LULAC National President. “Our democracy depends on every voter’s confidence that they can cast their ballot freely and have it counted accurately.” 

“The Constitution is clear: Only the states and Congress have the power to regulate our elections, not the president,” said Bruce Spiva, senior vice president at Campaign Legal Center. “Maintaining — and enforcing — this separation of powers is critical. With the 2026 midterm elections only a year away, now more than ever, we must safeguard the freedom to vote for all Americans.” 

"This is a historic victory for active-duty military families, " said Brandi Jones, Acting-Co Director of Secure Families Initiative, “Generations of people throughout American history have fought to establish the right to vote for every American. Black Americans, Indigenous Americans, communities of color, and women have taken on this fight facing violence and at times death. We are proud to follow their footsteps.” 

“This ruling is a resounding victory for democracy and the rule of law,” said Amb. Norm Eisen (ret.), co-founder and executive chair of the Democracy Defenders Fund. “No president can trample the Constitution to impose burdensome restrictions that make it harder for Americans to vote—ID requirements would disproportionately impact certain citizens, such as those who cannot afford to meet them. Today’s decision reaffirms that Congress and the States run elections and that the president does not have the authority to manipulate our election systems for his benefit and his liking.” 

“This is a huge victory to protect student voting rights. DPOC requirements in AZ are already burdensome. This executive overreach of our elections would have made it even more difficult for voters to access the ballot,” said Kyle Nitschke, Co-Executive Director of the Arizona Students’ Association. 

Keep up with our action against the administration’s unlawful executive order at this link. Read more about how Campaign Legal Center is holding the current administration accountable at this link. 
 

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The nonpartisan Campaign Legal Center advances democracy through law. We safeguard the freedom to vote, defend voters’ right to know who is spending money to influence elections, and work to ensure public trust in our elected officials.
 
Learn more about CLC. Don't miss out on our latest resources: Subscribe to President Trevor Potter's newsletter on LinkedIn or email, tune in to the latest season of our award-winning podcast, Democracy Decoded, and join our livestreamed events.

Issues
Voting and Elections

Campaign Legal Center’s Megan McAllen on Maine’s Attempt to Limit the Risk of Corruption Posed by Super PACs

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Washington, D.C. — On Wednesday, October 29, 2025, Campaign Legal Center (CLC) submitted an amicus brief in Dinner Table Action, et al. v. Schneider, et al., a case in the U.S. Court of Appeals for the First Circuit, defending a Maine state law limiting contributions to super PACs.  

Megan McAllen, director of campaign finance litigation at CLC, released the following statement:

“Since 2010, the D.C. Circuit and other appellate courts have said that money given to groups making ‘independent expenditures’ — commonly known as super PACs — cannot constitutionally be limited because these contributions cannot corrupt. The last 15 years have shown us otherwise.

“Voters today live under a system where wealthy special interests can route millions of dollars through super PACs to influence the outcomes of elections. In turn, we see elected officials turn their backs on constituents and put the bottom line of their biggest donors above the public interest.  

“The corrosive influence of big money over elected officials has been recognized time and time again. And federal courts and juries have recognized that elected officials highly value super PAC largesse benefiting their candidacies and are willing to trade official acts for it — a clear instance of quid pro quo corruption.  

“As the record since 2010 bears out, a large check cut to a super PAC can readily serve as the ‘quid’ in a corrupt bargain between the PAC and a candidate. Now, an overwhelming majority of Maine voters are attempting to set the record straight and rein in super PACs.

“As Campaign Legal Center explains in our brief, the unlimited financial contributions super PACs are allowed to accept inherently create opportunities for corrupt quid pro quo exchanges. Maine’s law is a step in the right direction to addressing the pervasive threat corruption poses to public confidence in our democracy.”

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The nonpartisan Campaign Legal Center advances democracy through law. We safeguard the freedom to vote, defend voters’ right to know who is spending money to influence elections, and work to ensure public trust in our elected officials.

Learn more about CLC. Don't miss out on our latest resources: Subscribe to President Trevor Potter's newsletter on LinkedIn or email, tune in to the latest season of our award-winning podcast, Democracy Decoded, and join our livestreamed events.

Issues
Campaign Finance

Dinner Table Action et al. v. Schneider et al. and Equal Citizens et al. (Maine Super PAC Contributions)

At a Glance

Groups in Maine filed suit to challenge a state law limiting contributions to super PACs. Campaign Legal Center (CLC) has joined the case to help defend the law, arguing that super PACs consistently prove to be a viable pathway for wealthy special interests seeking to corrupt candidates and politicians.

Status
Active
Updated
Issues
Campaign Finance
About This Case/Action

In November 2024, Maine voters resoundingly approved — by nearly 75% — a citizen-initiated bill that restricts the amounts individuals and entities may contribute to political committees that make independent expenditures — commonly known as “super PACs” — and also requires disclosure of those contributions.

By approving the measure, Mainers were responding to the serious and well-documented threat of corruption posed by these ostensibly “independent” committees, which can generally accept unlimited contributions from almost any source provided they spend those funds independently of candidates. Maine’s new law places a $5,000 cap on the total amount any individual or entity may give annually to a super PAC.

Plaintiffs in the case — two Maine PACs, and two of the PACs’ officers, that seek to fund their independent electoral advocacy with large and undisclosed contributions — filed suit in late 2024 challenging Maine’s law as unconstitutional.

In the past, appellate courts — beginning with the D.C. Circuit 15 years ago in SpeechNow.org v. FEC  — have struck down limits on contributions to super PACs as violative of the First Amendment. SpeechNow and these later analogues all relied on the Supreme Court’s reasoning in Citizens United v. FEC that independent expenditures inherently cannot give rise to corruption or its appearance. These other courts extended this logic to super PACs because of their supposed legal separation from the candidates they support.

The Maine federal district court in this case did the same. In July of 2025, the lower court, likewise relying on Citizens United and the decisions of other appellate courts, enjoined the Maine law as inconsistent with the First Amendment.

That decision is now on appeal to the U.S. Court of Appeals for the First Circuit, where, in October 2025, CLC filed an amicus brief to defend the law and detail the many ways that super PACs can — and do — create opportunities for the exchange of corrupt quid pro quos, making it both constitutional and appropriate to limit the contributions they can accept.

What’s At Stake

As documented in CLC’s amicus brief, the faulty assumption in SpeechNow and similar cases that contributions to super PACs inherently cannot lead to corruption or its appearance has now been thoroughly disproven. Instead, the last 15 years of real-world experience with super PACs reveal countless examples of quid pro quo corruption involving super PACs. This record confirms what common sense already suggests: The transfer of massive sums to a super PAC supporting a candidate creates indebtedness on the part of that candidate and thus exposes our political system to a real and unacceptable risk of corruption.

The Supreme Court has long recognized that letting corruption go unchecked harms our democracy by undermining the public’s faith in self-government. Anticorruption measures like Maine’s law are vital to counter the widespread and damaging perception that American democracy is for sale.

Maine voters made their choice clear: The wave of unlimited super PAC contributions unleashed after SpeechNow must be reined in to prevent corruption and reinforce public confidence in democratic governance. The courts should respect that choice.

VICTORY: Section of Anti-Voter Executive Order Permanently Halted in Court

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Washington, DC — Today, a judge for the U.S. District Court for the District of Columbia granted our motion for summary judgment and issued an injunction that permanently halts the Election Assistance Commission (EAC) from implementing Section 2(a) of the president’s March 25, 2025 executive order, which ordered the EAC to add a documentary proof of citizenship (DPOC) requirement to the National Mail Voter Registration Form. The League of United Latin American Citizens (LULAC), Secure Families Initiative (SFI) and Arizona Students’ Association (ASA) — represented by Campaign Legal Center (CLC) and Democracy Defenders Fund (DDF) — sought to prevent the EAC from taking any action to implement Section 2(a) of President Trump’s anti-voter executive order. In its opinion, the court held that Section 2(a) is an unconstitutional violation of the separation of powers.  

Trevor Potter, president of Campaign Legal Center, issued the following statement:  

“This federal court ruling reaffirms that no president has the authority to control our election systems and processes. The Constitution gives the states and Congress — not the president — the responsibility and authority to regulate our elections. We are glad that this core principle of separation of powers has been upheld and celebrate this decision, which will ensure that the president cannot singlehandedly impose barriers on voter registration that would prevent millions of Americans from making their voices heard in our elections.”

Follow our action against the administration’s unlawful executive order. Read more about our lawsuit.

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The nonpartisan Campaign Legal Center advances democracy through law. We safeguard the freedom to vote, defend voters’ right to know who is spending money to influence elections, and work to ensure public trust in our elected officials.  

Learn more about CLC. Don't miss out on our latest resources: Subscribe to President Trevor Potter's newsletter on LinkedIn or email, tune in to the latest season of our award-winning podcast, Democracy Decoded, and join our livestreamed events.

Issues
Voting and Elections

Lawsuit Filed Against Trump Administration for Concealing Records About Shadowy Voter Data Maintenance Efforts

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Washington, DC — Today, American Oversight and Campaign Legal Center (CLC) filed suit against the Trump administration for failing to release records about new federal voter data maintenance efforts, including the Department of Homeland Security’s overhaul of the Systematic Alien Verification for Entitlements (SAVE) system, which has evolved into a federal voter data system using various sources to flag potential noncitizens on state voter rolls — changes that could be used to justify large-scale voter purges and disenfranchise eligible voters. To date, the Trump administration has provided no explanation of how the system operates or what safeguards exist to protect Americans’ voter information from improper use.

The set of three lawsuits seek to compel the U.S. Department of Homeland Security (DHS), U.S. Citizenship and Immigration Services (USCIS), and the Social Security Administration (SSA) to release emails and related records that could shed light on how the administration is using federal data systems to verify the citizenship of those on state voter rolls. The records could also reveal how agencies are coordinating to build or operate a shared voter-maintenance database.

“The Trump administration has quietly built a federal voter-roll program that could strip power from the states and silence millions of voters, yet it has offered virtually no explanation for how the system operates or how they will safeguard voters’ rights and protect the integrity of future elections. Given this administration’s record of weaponizing federal agencies to advance false claims of voter fraud, the public has every reason to be concerned,” said Chioma Chukwu, executive director of American Oversight. “The impact will fall hardest on those already forced to fight for access to the ballot — Black, brown, immigrant, low-income, disabled, and young voters — under the false banner of ‘fraud prevention.’ The public has a right to know what this system is, what data is being used, and whether proper safeguards are in place to protect voters. Transparency is essential to protecting the integrity of our elections and combating dangerous voter fraud conspiracies intended to disenfranchise marginalized communities.”

"Federal agencies appear to be collecting and sharing the highly sensitive personal information of millions of Americans with little to no public oversight or clarity into their purpose, and under the guise of so-called 'voter roll maintenance,’ which is a function entrusted to the states," said Jonathan Diaz, Director of Voting Advocacy and Partnerships at Campaign Legal Center. "These efforts are part of a troubling pattern of actions by the Trump administration to insert the executive branch into election processes that the Constitution assigns to Congress and the states, which could undermine Americans' freedom to vote. We will keep pushing for the federal government to be transparent on where this data is coming from and how it is being used so that every voter can vote with confidence that their voice will be heard in our elections.”

Louisiana was the first to use a new federal system to check the citizenship status of registered voters. However, Louisiana officials have reported that the system flagged just 79 instances of voting by suspected noncitizens in at least one election since the 1980s — a figure that represents only 0.0027 percent of the state’s 2.9 million registered voters, and may include some individuals who are in fact eligible to vote.

The lawsuit asks the court to order DHS, USCIS, and SSA to release all nonexempt, responsive records, including communications with DOGE and state election officials, contracts with outside entities, and any guidance or training materials related to implementation of the program.

Since returning to the White House, Trump has repeatedly used federal power to influence the 2026 midterm election cycle. With a history of punishing states that refuse to do his bidding, he has publicly pressed states to redraw congressional maps ahead of the midterms, intervening directly in the redistricting process in states like Texas, Missouri, and North Carolina to lock in additional Republican seats rather than wait for the usual post-census period.

Additionally, Trump ordered the Department of Justice (DOJ) to investigate ActBlue, the main online fundraising platform for Democratic candidates, while ignoring its GOP counterpart, WinRed. The DOJ has also demanded detailed voter registration data from states, threatening legal action against some Democratic-led states that have not complied. Furthermore, Trump has also indicated he will sign an executive order outlawing voting machines and mail-in ballots, despite courts blocking his earlier executive actions that sought to impose proof-of-citizenship requirements for voter registration.

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The nonpartisan Campaign Legal Center advances democracy through law. We safeguard the freedom to vote, defend voters’ right to know who is spending money to influence elections, and work to ensure public trust in our elected officials.

Learn more about CLC. Don't miss out on our latest resources: Subscribe to President Trevor Potter's newsletter on LinkedIn or email, tune in to the latest season of our award-winning podcast, Democracy Decoded, and join our livestreamed events.

Issues
Voting and Elections
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