CLC Files Complaint Alleging Illegal Payment Set-Up for Trump Legal Fees
Washington, D.C. — Today, Campaign Legal Center (CLC) filed a complaint with the Federal Election Commission (FEC) regarding an arrangement between the 2024 presidential campaign of Donald Trump, four other Trump-affiliated political committees, and Red Curve Solutions (Red Curve), an accounting and compliance firm. The arrangement seems designed to obscure the true recipients of a noteworthy portion of Trump’s legal bills and, in doing so, seems to violate federal law.
Red Curve is a domestic limited liability company (LLC) that offers compliance and FEC reporting services but does not appear to offer any legal services. It is managed by Bradley Crate, who also serves as the treasurer for each of the five Trump-affiliated committees concerned in this complaint, as well as over 200 other federal committees.
According to filings with the FEC, Red Curve appears to have been fronting legal costs for Trump since at least December 2022, with Trump-affiliated committees repaying the company later. This arrangement appears to violate FEC rules that require campaigns to disclose not only the entity being reimbursed (here, Red Curve) but also the underlying vendor. By not disclosing the vendors that actually provided legal services, the Trump-affiliated committees effectively blocked the public from knowing which attorneys and firms are being paid — and how much they are being paid — through this arrangement.
The arrangement also appears to have violated the federal ban on corporate political contributions: Red Curve is an LLC, which — if treated as a corporation for federal tax purposes — would be legally barred from making any contributions, such as an in-kind contribution or advance, to Trump’s campaign and any other “hard money” committee — even if that payment or advance is fully reimbursed.
“Voters have a right to know how the presidential campaigns and other committees supporting presidential candidates spend their money. When campaigns and committees obscure that information from the public, not only do they make it difficult to determine if the law has been violated, but they deny voters the ability to make an informed choice when casting a ballot,” said Erin Chlopak, senior director for campaign finance at Campaign Legal Center. “The steps taken by the Trump campaign, its affiliated committees and Red Curve Solutions concealed information about how campaign funds were used to pay former President Trump’s legal expenditures, including the amounts and ultimate recipients of these expenditures — and the FEC must investigate immediately.”
Between December 7, 2022, and March 18, 2024, Red Curve received 108 disbursements from these five committees — virtually all of which are described as “Reimbursement for Legal Fees” or “Reimbursement for Legal Expenses” — totaling $7,206,474.55. This appears to show that Red Curve was the largest single recipient of legal payouts from Trump since he left office in 2021.
Without complete information about how the campaign of the presumptive Republican nominee for president is spending donors’ money on legal expenses, voters lack crucial information they have a right to know.
The FEC should investigate this urgent matter immediately.
Campaign Legal Center Files FEC Complaints Alleging Scam PACs Defrauded Thousands of Donors
WASHINGTON, D.C. – Today, Campaign Legal Center (CLC) filed two complaints with the Federal Election Commission (FEC), alleging that “Patriots for American Leadership” and “Campaign for a Conservative Majority” fraudulently misrepresented that they were raising money for or on behalf of former President Trump’s reelection campaign. By using Trump’s voice on their fundraising robocalls and falsely claiming to support Trump’s reelection efforts, these “scam PACs” defrauded thousands of donors — many of whom were small donors giving less than $200. In reality, little to none of the money these PACs raised was used to engage in electoral advocacy — i.e., expenditures in support of, or contributions to, federal candidates or committees.
The fraudulent use of Trump’s voice to solicit funds presents a clear violation of federal campaign finance laws that prohibit engaging in fraudulent misrepresentation. CLC also plans to refer these matters to the Department of Justice for possible criminal prosecution.
Saurav Ghosh, CLC’s director of federal campaign finance reform, said, “Scam PACs like these harm the public by fraudulently using a candidate’s name, image or voice to convince donors that their money will be used to support the candidate, when in reality these schemes funneled virtually all of the money they raised back into fundraising or into the scam PAC operators’ own pockets. The FEC must not delay in investigating this serious matter.”
Federal campaign finance laws require political committees to accurately report their financial activity. But “Patriots for American Leadership” and “Campaign for a Conservative Majority” seem to have falsified their disclosure reports, and have failed to file required reports, in an apparent attempt to cover up their fraudulent activity. These efforts to conceal illicit activity support the conclusion that both scam PACs and their operators knowingly and willfully violated the law, such that more stringent penalties are needed to hold them accountable.
Federal authorities have a strong track record of holding individuals who engage in scam PAC schemes accountable, and it is imperative that the FEC investigate “Patriots for American Leadership” and “Campaign for a Conservative Majority” for engaging in blatant violations of law that harmed the public.
VICTORY: Federal Court Affirms That Tennessee Election Officials Cannot Deny Voter Registration to Eligible Tennesseans with Past Felony Convictions, Must Inform Potential Voters of Eligibility
Tennessee voters achieved a victory when a federal judge affirmed that Tennessee election officials cannot deny voter registration to eligible Tennesseans who have past felony convictions and that they must inform potential voters of eligibility requirements for voting after a felony. Campaign Legal Center represented voters in this lawsuit against Tennessee’s unequal, inaccessible voting rights restoration process.
“The Tennessee NAACP is pleased with the federal judge’s ruling,” said Gloria Sweet-Love, president of the Tennessee NAACP. “It takes us a step closer to removing barriers for formerly incarcerated Tennesseans who are seeking free and fair access to the ballot box. We must do all that we can — and we urge the courts and the state Election Division to do all they can — to guard against democratic backsliding, and ensure that all Tennesseans have voter protections.”
"This court decision marks a significant victory in our ongoing battle for voting rights restoration for those silenced by felony disenfranchisement, said Keeda Haynes, senior legal counsel at Free Hearts. "While we celebrate today, we remain vigilant in our fight against the evolving challenges and barriers to voting that have emerged since we first filed this lawsuit. Our commitment to 'free the vote' remains unwavering until every disenfranchised voice is heard."
“For too long, Tennessee has maintained policies designed to confuse, mislead, burden and shut out fully eligible voters who never lost the right to vote at all,” said Blair Bowie, director of Campaign Legal Center’s Restore Your Vote program. ”Yesterday’s ruling is a win for Tennesseans who have been wrongly denied a voice in their government for too long — and a step in the right direction.”
“This ruling is an important development towards the goal of ensuring that everyone who is entitled to vote gets to vote,” said Charles Grant, shareholder at Baker Donelson.
Tennessee has the second-largest disenfranchised population in the country, more than 470,000, second only to Florida, and disenfranchises over 20% of its Black citizens, the highest rate of Black disenfranchisement in the country.
Yet not every Tennessean with a prior felony conviction has lost the right to vote. For example, between 1973 and 1981, Tennessee did not have felony disenfranchisement, so felony convictions from that period did not take away the right to vote. Moreover, people whose felonies were reversed or expunged have the right to vote. And, even with the most complicated and error-ridden voting rights restoration process in the country, thousands of Tennesseans have successfully restored their right to vote.
However, for years, Tennessee’s voter registration form plainly misinformed potential voters on the law, incorrectly stating that a person with a felony conviction could not register if they had not received a pardon or restored their voting rights — even if they received a felony in the "grace period" mentioned above or had their conviction reversed or expunged.
Additionally, the policy of elections officials was to deny voter registration forms from anyone with a felony, even if that person indicated that they had never lost the right to vote.
In 2019, the Tennessee NAACP and Campaign Legal Center informed the Elections Division that these policies violated the National Voter Registration Act and in 2020, the groups, as well as Free Hearts and Baker Donelson, brought a lawsuit.
In August 2023, after being on notice of these violations for years, the Elections Division made a last minute attempt to come into compliance with the law and then asked the Court to dismiss the lawsuit as moot. However, on April 18, 2024, the District Court for the Middle District of Tennessee ruled that the Election Division’s policies violate the National Voter Registration Act.
Additionally, the Court expressed skepticism that the state would not go back on its recent policy changes if the case were dismissed, writing that “[t]he timing of Election Division’s policy change also raises suspicions that its cessation is not genuine.”
The Court’s ruling does not change the reality that, currently, Tennessee Election Officials have unlawfully created a “two-step” voting rights restoration process that makes it just one of three states that effectively permanently disenfranchises citizens with prior felony convictions. This process resulted from a major, bad faith misinterpretation of the law by the Elections Division last summer requiring all Tennesseans to restore their “full citizenship rights” before they can restore their voting rights — in addition to filling out the Certificate of Restoration (COR) form.
Then, earlier this year, TN Elections Division confirmed that it wrongly interprets Tennessee law to conclude that, if a person who was convicted of a felony doesn’t or cannot get their full gun rights restored, they won’t ever be able to restore full citizenship and, thus, their voting rights in Tennessee — a policy that threatens to preclude Tennesseans with many types of felonies, including anyone with a felony drug conviction, from ever restoring their right to vote.
Learn more about Tennessee’s felony disenfranchisement regime.
Learn more about Campaign Legal Center’s lawsuit against TN’s unequal, inaccessible voting rights restoration process, TN NAACP v. Lee.