CLC Alleges Straw Donor Illegally Funneled $50,000 to Super PAC Opposing Cheney

A hand emerges out of the dark holding a stack of $100 bills.

By Lica Porcile, a Summer 2022 CLC intern

Wealthy special interests use secret money, sometimes called dark money, to elect candidates that support their private agenda over the interests of everyday Americans. Voters have a right to know who is spending big money to influence their vote.

One way in which special interests keep their political spending secret is by routing those funds through “straw donors” to a super PAC, thereby preventing the true contributor’s name from appearing on public campaign finance reports.

This practice is illegal. Federal campaign finance laws explicitly prohibit straw donor schemes, in which one person (the true contributor) gives money to another (often an LLC, trust or other corporate entity) for the latter to give to a political committee in their name.

Campaign Legal Center (CLC) strives to protect voters’ right to know who is spending to influence their vote by filing complaints urging the Federal Election Commission (FEC) to enforce the straw donor ban.

On June 22, 2022, CLC filed a complaint alleging that an obscure shell company called “Snow Goose, LLC” was used as a straw donor to provide $50,000 to Wyoming Values, a super PAC.

Snow Goose, LLC has no documented activities. It has no apparent income or assets, no identifiable commercial activity and no physical or online presence. Its mailing and principal office address is simply that of its corporate registered agent, and the only person publicly associated with the LLC is its organizer, an attorney in Jackson, Wyoming.

Yet despite this lack of any ascertainable activity, Snow Goose gave $50,000 to Wyoming Values (a super PAC that has been vigorously opposing Liz Cheney’s reelection bid) only 10 weeks after it formed on Dec. 10, 2021.

An LLC with no investments, assets, income, business operations or commercial activity would not be able to make a $50,000 political contribution within roughly two months of its formation — unless someone else gave it those funds for that specific purpose.

This evidence supports the conclusion that Snow Goose was used as a “straw donor” to mask the identity of the true source of this $50,000 contribution, a blatant violation of federal law.

The requirement that a contribution be made in the name of its true source ensures that voters have the information necessary to evaluate candidates for public office, such as how much weight to give to different speakers and competing messages.

In this case, the “message” is particularly heated, highlighting voters’ need to know the speaker’s identity before casting their ballots.

Wyoming Values has spent over $560,000 opposing incumbent Cheney — who is currently in the national spotlight as vice chair of the House of Representatives Committee investigating the Jan. 6, 2021, coordinated attack on our country — and supporting one of her main opponents in the upcoming GOP primary, Harriet Hageman, who has vociferously criticized the January 6th Committee Hearings.

Cheney’s reelection effort has garnered national attention based largely on her prominent role on the January 6th Committee, amid its ongoing public hearings. Former President Donald Trump, a central focus of the hearings, has been a vocal critic of Cheney and has endorsed Hageman’s bid to unseat her.

For her work on the committee, Cheney has also been censured by the Republican National Committee (RNC) and expelled from the Wyoming Republican Party.

Secret election spending to undermine Cheney’s reelection campaign, and bolster that of her opponent Hageman, represents another potential response to Cheney’s important work investigating the coordinated plot to illegally overturn the results of the 2020 presidential election.

The Snow Goose straw donor scheme not only violated federal campaign finance laws, it deprived voters of essential information for them to make an informed choice in the 2022 midterm elections. Voters have a right to know who is spending to influence their vote, because in a democracy, voters decide the outcomes of elections.  

Shell Companies Masking the True Sources of Contributions