How Election Officials Are Preparing for the 2024 Presidential Election

Election officials spend months preparing for an election — from ordering ballots to conducting voter education and outreach. Yet much of this work goes largely unnoticed or is misunderstood by the electorate. Election officials are our neighbors and friends who consistently dedicate long hours before, during and after Election Day to ensure our elections are safe, secure and accurate.  

Campaign Legal Center Alleges Delaware Corporation Served as “Straw Donor” To Hide the True Source of Over $2.5 Million Going to Federal PACs

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WASHINGTON, D.C. Today, Campaign Legal Center (CLC) filed a complaint with the Federal Election Commission (FEC) against “Ardleigh Impact Corporation” (Ardleigh) and any unknown person(s) that made over $2.5 million in contributions to six federal committees in Ardleigh’s name, which is a violation of federal campaign finance laws.
  
The complaint alleges that Ardleigh, which was registered in Delaware in 2023, was used to hide the true source(s) of over $2.5 million in contributions made to six different federal committees since February 2024. The committees that received this money include the Congressional Leadership Fund; AFC Victory Fund; Buckeye Leadership Fund, Inc.; Conservatives for American Excellence Inc.; Defend Ohio Values PAC; and More Jobs, Less Government.
  
“Straw donor” contributions are prohibited under the Federal Election Campaign Act (FECA) because they undermine electoral transparency and deprive voters of essential information.  

While straw donor schemes are illegal, they have proliferated since the Citizens United ruling, which has allowed wealthy special interests to funnel unlimited amounts of money — often in secret — into our elections,” said Saurav Ghosh, director of federal campaign finance reform at Campaign Legal Center. “Voters have a right to know who is spending money to try and influence their votes and our government. Left unchecked, straw donor schemes like Ardleigh risk depriving voters of the information they need to meaningfully participate in the democratic process.” 

Ardleigh appears to have been used for the sole purpose of hiding the identities of the true contributors who provided over $2.5 million to these committees. The corporation provides no information on the true source(s) of this money, nor does it appear to have engaged in any commercial activities in the months leading up to the disbursement of these funds. This supports finding reason to believe that another source had to have provided Ardleigh with the money needed to make these contributions.
  
The FEC has issued civil fines in the recent past to those operating straw donor schemes to conceal the true sources of campaign spending. Federal campaign finance laws require transparency in all electoral spending. The FEC needs to investigate this straw donor scheme so that the public can know who is behind the $2.5 million contributed in Ardleigh’s name. 

See the complaint here.
 

Protecting Nevadans from Voter Purge Efforts (RNC v. Aguilar)

At a Glance

Partisan actors have filed lawsuits challenging Nevada’s voter list maintenance practices and seeking more aggressive removal of voters from the rolls than federal law requires. CLC is filing a friend-of-the-court (amicus) brief alongside the ACLU of Nevada in support of Nevada’s Secretary of State and county election officials, urging the court to dismiss the case. 

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About This Case/Action

The Republican National Committee, the Nevada Republican Party, and a Nevada voter filed a lawsuit against Nevada Secretary of State Francisco Aguilar and local election officials challenging the state’s efforts to maintain its voter rolls. The suit claims that the state must be violating its obligations under the National Voter Registration Act (NVRA) because certain misleading metrics show more registered voters than eligible voters in some counties.

CLC, with the ACLU of Nevada, filed a friend-of-the-court brief explaining that this suit is based on deeply flawed and misleading metrics that have been repeatedly rebuked by federal courts. Namely, the lawsuit uses incompatible data sources to piece together unreliable and inaccurate measures of voter registration rates. They rely on voter registration numbers taken from a single recent snapshot of the state’s voter roll on the one hand, and outdated census estimates of the citizen voting age population on the other.  No conclusions about a state’s voter roll management can be drawn from this apples-to-oranges comparison.

Unfortunately, this lawsuit is part of a years-long pattern of filing frivolous claims under the NVRA to bully states into conducting voter roll purges beyond what the law requires. CLC’s brief points out that these efforts are not only contrary to federal law but also risk improper removal of eligible voters from the state’s voter rolls. When states rush to purge voters without proper guardrails, eligible voters are invariably kicked off the rolls, directly infringing on the freedom to vote.  

This effort is ramping up during the 2024 election cycle. This is one of several cases filed across the country in recent weeks questioning—without evidence—states’ efforts to manage their voter rolls. Though they are billed as suits to promote election integrity, baseless claims of electoral misconduct actually have the opposite effect. They risk disenfranchising eligible voters, spread false information about elections, tie up election officials’ limited time in litigation during a busy election year, erode public confidence, and intensify the risk of harassment against the public officials working diligently to administer elections.  

CLC Files Complaint Alleging Illegal Payment Set-Up for Trump Legal Fees

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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

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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.