The lawsuit follows years of FEC inaction and alleges that Heritage Action for America failed to disclose the donors who funded the group’s election spending as mandated by federal law.

WASHINGTON, D.C. - Today, Campaign Legal Center (CLC) filed suit against Heritage Action for America, a 501(c)(4) arm of the Heritage Foundation. The complaint alleges that Heritage Action spent over $1 million on advertisements supporting Republican U.S. House of Representatives candidates during the 2018 election cycle but failed to publicly disclose its contributors in violation of campaign finance law.

CLC filed suit after more than three years of inaction by the Federal Election Commission (FEC) on an administrative complaint CLC filed with the agency in 2018. CLC sued the FEC in 2021 over its delay, and a federal court found that the agency’s failure to act violated the law, triggering CLC’s right to file suit directly against Heritage Action. The lawsuit adds to the growing number of cases where a district court has authorized CLC and other watchdogs to step in to enforce federal campaign finance laws directly after the FEC fails to act.

“Wealthy special interests use secret money to rig the political system in their favor. To reduce their undue influence, we need real transparency about who is spending big money on elections,” said Adav Noti, vice president and legal director at Campaign Legal Center. “Because the FEC failed yet again to do its job and left American voters in the dark, CLC is stepping up to enforce transparency requirements and ensure 501(c)(4) organizations like Heritage Action comply with federal law.”

The U.S. District Court for the District of Columbia ruled on May 3 that the FEC’s failure to act in this matter violated the law, and that CLC’s complaint against Heritage Action was “credible” and “outline[d] a legitimate threat to the health of our electoral processes.” This ruling cleared the way for CLC to take action directly against Heritage Action.

This is one of a series of cases in which CLC has stepped in to enforce federal campaign finance law — most recently, CLC filed suit against 45Committee, a dark money group that spent upwards of $38 million dollars during the 2016 cycle and Iowa Values, a dark money group supporting Iowa Sen. Joni Ernst.

Voters are entitled to real transparency about who is spending big money in elections — but repeated failures by the FEC to properly enforce campaign finance laws have only encouraged bad actors. In the absence of FEC action, groups like CLC are obligated to step up to ensure that federal campaign finance law is enforced.  

At Campaign Legal Center, we are advancing democracy through law. Learn more about our work.

The complaint alleges that mystery donors used an obscure limited liability company to secretly provide $500,000 to the Trump-affiliated super PAC Make America Great Again, Again!, Inc.

Washington, D.C. - Today, Campaign Legal Center (CLC) filed a complaint with the Federal Election Commission (FEC) alleging that “ML Organization, LLC,” William Pulte and other unidentified individuals violated federal campaign finance laws in connection with a $500,000 contribution made to a pro-Trump super PAC.

The complaint alleges that ML Organization was not the true source of a $500,000 contribution made in its name to Make America Great Again, Again! Inc. — which brands itself as the "ONLY Trump approved super PAC" and has plans to support Trump-endorsed candidates in the 2022 midterm elections — and that Pulte (or another unidentified person) was the true contributor. That $500,000 is the single largest contribution the super PAC has ever reported receiving.

“Voters have a right to know when wealthy special interests are spending money to influence elections and rig the political system in their favor. Shell companies like ML Organization, LLC are often used to funnel secret money to super PACs, concealing the true contributor’s identity,” said Saurav Ghosh, director of federal reform at Campaign Legal Center. “The facts indicate that this LLC is a straw donor and not the true source of this $500,000 contribution, an illegal tactic that erodes transparency.”

CLC uncovered that in 2016, Pulte purchased the residential property at the address for ML Organization disclosed on FEC reports, and Pulte has personally used that address in multiple filings with the state of Florida related to companies that he manages or directs. Pulte has made multiple contributions since 2016 but always disclosed a different address — the office location for one of his businesses — in connection with those contributions. As such, there is no connection on FEC disclosure reports between Pulte and the ML Organization address.

There is no record of ML Organization having any business activity or generating any income since it was registered as a Delaware domestic limited liability company (LLC) in April 2018. That lack of activity or income indicates that ML Organization lacked the means to contribute $500,000 without receiving funds for that purpose.

The complaint concludes, based on the available facts, that ML Organization is most likely owned and operated by Pulte or someone else in his household and was used as a conduit to funnel $500,000 to a super PAC, such that both ML Organization and Pulte (and/or the other unidentified contributors) violated the Federal Election Campaign Act’s straw donor ban.

Straw donor contributions like those alleged here are serious violations of federal campaign finance law that have led to criminal indictments and convictions in recent years. In some cases, straw donor schemes have even been used to conceal corruption or foreign influence in American elections.

At Campaign Legal Center, we are advancing democracy through law. Learn more about our work.