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.

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.

In 2025, the federal government quietly expanded two policies: A program that changes visa status based on social media posts the government disagrees with and a new policy that limits who can conduct voter registration at naturalization ceremonies.  

CLC and AO filed a lawsuit on behalf of CLC challenging the U.S. Department of State and U.S. Citizenship and Immigration Services (USCIS) failure to respond to Freedom of Information Act (FOIA) requests for documents on these programs. CLC filed these FOIA requests in October 2025.

Despite legal deadlines, the agencies that received these FOIA requests have failed to produce the requested records or provide final determinations, forcing the groups to file suit.  

In June 2025, the federal government announced that it would begin reviewing the social media accounts of foreign citizens who apply for certain visas to enter the United States, for the purpose of altering — and in some cases revoking — the relevant visas if the individual had made a statement that could be perceived as expressing “hostility toward the citizens, culture, government, institutions or founding principles of the United States.”

In December 2025, the federal government expanded this social media vetting program to include additional types of visas.

USCIS also implemented a new rule prohibiting anyone other than state or local election officials from registering new voters at administrative naturalization ceremonies. Campaign Legal Center has already sued to block this policy.

The State Department and USCIS have not provided any documents in response to CLC’s FOIA requests, despite laws and deadlines that require them to do so.

Transparency is at the heart of a healthy democracy: CLC’s lawsuit seeks to compel the U.S. Department of State and USCIS to produce records that could shed light on how these policies are being implemented and the dangers they pose to fundamental rights and democratic participation.

The requested records could reveal how federal officials are evaluating individuals’ speech, what standards are being applied, whether there are safeguards to prevent abuse, and how the administration is limiting access to voter registration at the very moment many new citizens become eligible to participate in the democratic process.

CLC filed a lawsuit on behalf of the League of United Latin American Citizens, Texas League of United Latin American Citizens, the League of United American Citizens Council 102, and Common Cause challenging Texas’ reliance on the federal Systematic Alien Verification for Entitlements (SAVE) program to verify the citizenship status of registered voters in Texas and remove voters from the rolls in a discriminatory and non-uniform manner.  

On October 16, 2025, the Texas secretary of State sent county election officials a list of voters flagged by SAVE for removal. October 21, 2025, just a day after publicly announcing that the state had run its entire list of more than 18 million voters through the federal SAVE system, the Texas secretary of State directed counties to investigate flagged voters, send them notices of cancellation of voter registration, and remove voters who failed to respond.  

Prior to issuing this directive, however, the secretary's office failed to do any investigation of their own despite the ease of — and prior history using — Department of Public Safety data to confirm whether voters flagged by SAVE were actually citizens. The office also did not provide guidance to counties about whether to compare the lists to other available data or how to determine the reliability of the purge lists.

In the absence of clear guidance, counties proceeded inconsistently in their investigations of flagged voters. Some counties did not further investigate these voters' citizenship status, opting instead to send letters to voters demanding they provide proof of citizenship. If a voter did not supply the required documents within 30 days, they were purged from the rolls. In at least a few counties, officials canceled the registrations of naturalized U.S. citizens who later provided proof of their citizenship to the county.  

The state's directive to counties is deeply problematic given the widely known unreliability of data from the Department of Homeland Security's (DHS) SAVE system, which relies on stale data and regularly misidentifies naturalized U.S. citizens as noncitizens.  

These databases often incorrectly classify eligible voters because they do not reliably update when people become naturalized and are therefore eligible to vote. Still, the state, nor most counties, did not take steps to compare the SAVE results to available data held in state agencies, nor did Texas instruct counties to do so.

As such, some Texans have already been illegally purged from the voter rolls, and the registrations of thousands more are at risk. Approximately 11% of Texas’ eligible voters are naturalized citizens, and over 704,000 Texans were naturalized between 2016 and 2024.

Citizenship inquiries through SAVE often produce outdated results, especially for naturalized citizens. Other states have tried using the DHS federal SAVE system in voter roll list maintenance, and those programs have often purged hundreds of eligible voters from the rolls.  

There are already strict laws in place that ensure only U.S. citizens can vote in federal elections. The safeguards we already have in place — including strict criminal punishment, financial penalties and even possible deportation — ensure that only eligible citizens can register and vote. In addition, every Texas voter already signs an attestation of citizenship under penalty of perjury when they register to vote.  

The National Voter Registration Act (NVRA) prohibits discrimination in maintaining voter registration lists, including discrimination against naturalized, acquired and derived citizens. Campaign Legal Center’s lawsuit alleges that Texas' purge program violates the NVRA’s provision prohibiting discriminatory voter list maintenance because the purge program has removed or threatened to remove predominantly naturalized and acquired U.S. citizens from the rolls.  

Additionally, the NVRA requires election officials to conduct list maintenance procedures in a uniform manner. Texas’ counties have conducted the purge program in a chaotic, non-uniform manner, in clear violation of the NVRA’s requirement.  

Finally, CLC contends that Texas has violated the NVRA’s public disclosure provision by refusing to furnish a list of noncitizens who have been removed from the voter rolls as a result of the purge program.  

This is not the first time CLC has fought back against the use of notoriously unreliable database matching systems.  

We successfully sued Texas in 2019 when it engaged in a similar effort that resulted in the targeting of tens of thousands of naturalized citizens. We successfully sued to halt an illegal purge program that swept up thousands of eligible voters in Alabama, and we’ve submitted an amicus brief in support of a challenge to the consolidation and distribution of flawed federal citizenship data to states and other federal agencies. CLC and cocounsel sued Ohio for a law that requires the use of unreliable state and federal database matching systems to identify potential non-U.S. citizens for removal from the voter registration lists.  

Our democracy works best when every eligible voter can make their voice heard — but Texas' unfair, illegal voter purge program puts far too many Texans’ freedom to vote this November in jeopardy. This case is part of a continued and urgent effort to ensure that all citizens, regardless of where they are born, have access to the ballot.