CLC’s Nonpartisan Record as a Government Watchdog

Apr 26, 2017

For more than 15 years, CLC has held government officials and regulatory agencies accountable in our efforts to improve our democracy and protect the fundamental right of all Americans to participate in the political process.  

CLC supports the enforcement of campaign finance and ethics laws, filing complaints against government agencies, such as the Federal Election Commission (FEC), participating in legal action against candidates, political parties and agencies who fail to uphold campaign finance laws, and utilizing the media to call out potential violations of the law. In keeping with our mission, CLC has taken action against candidates and organizations on both sides of the aisle, and will continue to do so. We have been recognized as nonpartisan by publications on both sides of the political aisle, including The Daily Caller and The Huffington Post.


 CLC’s Recent Actions Against Democratic Candidates or Officeholders

Campaign Staffer of Late Democratic Congressman Using Campaign Funds to Pay Large Salary

CLC filed a complaint with the FEC alleging that the treasurer of former Democratic Congressman Mark Takai’s campaign committee illegally converted the late Congressman’s leftover campaign funds to personal use, nearly 18 months after the Congressman left office.

After a Member of Congress leaves office, their campaign committee may legally donate leftover funds to charity, transfer funds to their party, make contributions to other candidates, or pay for the costs of winding-down their campaign or closing their office, which FEC regulations anticipate should take about six months. Yet nearly eighteen months after Takai’s passing, his campaign committee appears to be doing little else besides providing campaign treasurer Dylan Beesley a source of income.

FEC Complaint Filed Against Democratic Super PAC Highway 31

In March 2018, CLC filed a complaint with the FEC alleging that Highway 31, a super PAC that backed Democratic candidate Doug Jones in Alabama’s December 2017 U.S. Senate special election, violated campaign finance law by cooking up a secrecy scheme to spend $4.2 million on the race while keeping their donors in the shadows until after election day. Despite laws requiring that super PACs disclose their donors, Alabama voters went to the polls on election day without knowing who was backing Highway 31.

CLC’s complaint alleges that the vendors do not extend over $1 million in credit to newly-created PACs in the ordinary course of business, and should have been reported as contributors, and/or that Senate Majority PAC and Priorities USA Action may have guaranteed that those vendor bills would be paid, and should have been reported as contributors on Highway 31’s pre-election report.

FEC Complaint Filed Against Law Firm for Alleged Straw Donor Scheme Involving Democratic Candidates and Committees

In November 2016, CLC filed a complaint with the FEC concerning alleged illegal reimbursements for political campaign contributions. Lawyers at Boston-based Thornton Law Firm gave large sums of money to the Democratic Senatorial Campaign Committee, and Senators Elizabeth Warren, Chuck Schumer, Harry Reid, Barack Obama and presidential nominee Hillary Clinton, among others, and were allegedly reimbursed by the firm.

CLC’s Brendan Fischer stated, The FEC must investigate this scheme. Thornton employees made contributions to these campaigns and were promptly reimbursed by the firm, allowing the firm to collectively give far more to individual candidates in a single year than the firm could have donated directly under federal law. This appears to be a clear violation of the law and the FEC should take this seriously.”

Our complaint and the resulting news reports, led to Democrats returning more than $1 million. According to news reports, the Department of Justice has opened an investigation of the firm for its reimbursement scheme.

FEC Complaint Filed Against Super PAC Supporting Hillary Clinton, Correct the Record

In October 2016, weeks before the 2016 presidential election, CLC filed a complaint against a super PAC supporting Hillary Clinton, Correct the Record, for effectively acting as an arm of the Clinton campaign. The super PAC asserted it could coordinate directly with the Clinton campaign as long as it didn’t run paid advertising – claiming that they were running blog content from unpaid volunteers. In reality, it was a multi-million dollar operation. In our complaint, we stated, “Correct the Record is a $6 million Washington D.C.-based political committee that spends millions on opposition research, message development, surrogate training and booking, professional video production, and press outreach for the benefit of the Clinton campaign—and by its own admission, does so in full coordination with the Clinton campaign.”

CLC’s Larry Noble Weighs in on Presidential Candidate Hillary Clinton’s Conflicts of Interest with the Clinton Foundation

In August 2016, CLC’s Larry Noble warned that the perception of donors to the Clinton Foundation receiving special access to Clinton’s State Department, even with no direct evidence, has created "a very serious perception problem" that threatens to undermine the public's faith in the government and its institutionsHe said that barring foreign and corporate donations to the Clinton Foundation is a start, but that alone won't counteract appearances that the game is rigged. He told The Hill, “You'd still have large individual donations that could raise a question.”

Through media interviews, Noble advised the Clintons to sever ties with the Clinton Foundation if Hillary Clinton were to win the presidency, noting the real conflicts of interest that would be at play. He told Newsmax, “I'd want to know what other safeguards they're going to have [to ensure] the foundation is not being used as a conduit to get access to the White House.” The Clintons must "sever all connections and not have any contact with the foundation.”

CLC Files FEC Complaint Against Government Contractor for Violating Contribution Ban; Hillary Clinton Super PAC for Accepting It

In July 2016, CLC filed a complaint against a super PAC supporting Hillary Clinton, Priorities USA Action, for accepting a $200,000 contribution from a federal contractor, Suffolk Construction Company, in violation of the 75-year old federal contractor ban. CLC’s Paul S. Ryan told The Hill, “Super PACs and their deep-pocketed donors should not be allowed to skirt and violate the laws we have in place to protect the integrity of our democracy.”

CLC Files FEC Complaint Against “Ghost Corporation” That Funded Democrat-supporting Super PAC

In February 2016, CLC filed a complaint calling on the FEC to investigate whether DE First Holdings LLC  was created as a “shell corporation” with the purpose of hiding the true identity of the donor who gave $1 million to a Democrat-supporting super PAC called Coalition for Progress. CLC’s Paul S. Ryan told Mother Jones, "We have seen a pretty dramatic increase in the use of the LLCs to contribute to super-PACs, and I don't think that's going to change anytime soon. But I think the dismissal of these complaints from 2011 will be viewed as a greenlight to continue laundering money into super-PACs."

CLC Urges FEC to Reject Request From Democratic Super Pac to Break Coordination Laws

In October 27, 2015, CLC filed comments urging the FEC to reject a request from Democratic super PACs that raise money for Senate and House campaigns to break coordination laws in the pre-candidate exploration period.  CLC’s Paul S. Ryan said, “The laws passed by Congress are the laws of the land despite the complete breakdown of campaign finance law enforcement at the FEC and we will not hesitate to urge the Department of Justice (DOJ) to criminally investigate what would be knowing and willful violations of the law if these groups proceed with their plans.”

FEC Complaint Filed Against Obama Super Pac Donor

In April 2015, CLC filed a complaint against rapper Pras Michel, citing evidence that he gave money to a super PAC supporting the re-election of President Obama through an LLC without disclosing that he was the source of the funds. Paul S. Ryan wrote in The Hill“We filed a complaint against the President-Obama-supporting super PAC Black Men Vote and its primary funder, hip hop artist Pras Michel.”

FEC Complaint Filed Against Democratic Presidential Candidate Martin O’Malley

In March 2015, CLC filed a complaint against Martin O’Malley, a Democratic candidate for president, for raising millions for his presidential run while denying he was a candidate subject to fundraising within contribution limits.  In the complaint, CLC stated, "These 2016 presidential candidates must take the American people for fools — flying repeatedly to Iowa and New Hampshire to meet with party leaders and voters, hiring campaign staff and raising millions of dollars from deep-pocketed mega donors, all the while denying there are even 'testing the waters.'"

CLC Urges Obama to Issue Executive Order on DisclosureTake Action on Money in Politics

In March 2015, CLC sent a letter to President Barack Obama urging him to issue an executive order requiring full disclosure of political spending by business entities receiving federal government contracts. CLC President Trevor Potter told The Washington Post,  “We have heard this order has been ready for the president's signature for the last several years, and I don't know of anyone on the outside who really knows whether the presidential pen will move across that piece of paper or not, or when. I have no idea why this was not done by the president years ago given [White House] statements about the importance of disclosure.”

CLC’s Meredith McGehee told The American Prospect, “Hope is mitigated by experience with this Administration which since taking office has done almost nothing to address money in politics problems, other than occasional lip service.”

Legal Brief Filed Countering Democratic Governors Association Effort to Circumvent Campaign Finance Laws

In May 2014, CLC filed a friend-of-the-court brief asking a court to reject arguments from the Democratic Governors Association, which was seeking to circumvent Connecticut campaign finance law. The DGA was attempting to open the door for groups seeking to support candidates in Connecticut elections yet avoid registering as political committees and abiding by the state’s limits, prohibitions and reporting rules. (Press Release)

FEC Complaint Filed Against Super PAC Backing Democratic Candidates
In March 2014, CLC filed a complaint with the FEC against the Senate Majority PAC, a super PAC backing Democratic candidates, for allegedly making an in-kind contribution to U.S. Senate candidate Bruce Braley by using Braley campaign b-roll footage in an ad. The airing of the ‘Oil Billionaires’ ad constituted a clear violation of federal law by Senate Majority PAC.

CLC Criticizes Obama for Broken Promises on Campaign Finance Reform  

In April 2013, CLC sent a letter to the White House criticizing President Obama for his failures and broken promises on campaign finance reform. CLC called attention to Organizing for Action, a privately-funded 501(c)(4) group that was functioning as an arm of the Administration. The letter stated, “We recognize that the critical test for an officeholder is not how an official functions within the boundaries of the flawed campaign finance system that exists, but what the officeholder is prepared to do to fix the system. You have not met this critical test.”

CLC’s Recent Actions Against Republican Candidates or Officeholders

FEC Complaint Filed Against Trump Campaign for Wrongly Attributing Post-Election Day Campaign Contributions

In March 2017, CLC filed a complaint with the FEC alleging the Trump campaign violated election law by illegally accepting campaign contributions after Election Day and falsely attributing those contributions to 2016 “debt retirement,” even though no such net debt existed. CLC’s Larry Noble told The Daily Beast, “By falsely reporting post-election contributions as being for 2016 debt retirement, Trump may be trying to illegally double what a contributor can give for the 2020 primaries.”

FEC Complaint Filed Against Super Pac for Allegedly Coordinating With Trump Campaign 

In December 2017, CLC filed a complaint with the FEC alleging that the super PAC supporting Donald Trump, Make America Number 1, was not truly independent of the Trump campaign. CLC argued that the super PAC secretly subsidized Steve Bannon’s work for the Trump campaign by funneling $280,000 in payments to a firm described as a ‘front’ for Bannon.

FEC Complaint Filed Against Private Prison Contractor for Giving to Trump Super PAC in Violation of Government Contractor Contribution Ban

In November 2016, CLC filed a complaint with the FEC alleging that one of the nation’s largest private prison companies had contributed to a pro-Trump super PAC in violation of the 75-year old ban on government contractors making contributions in connection with elections. Brendan Fischer told VICE, “GEO Group and GEO Corrections Holdings Inc. really seem indistinguishable, and their corporate interests are the same. Their goal is to influence the federal contracting process, which is exactly what the contractor ban is designed to prevent.”

FEC Complaint Filed Against Trump Super Pac for Illegally Soliciting Foreign Contributions

In October 2016, CLC filed a complaint with the FEC alleging that a super PAC supporting Trump, Great America PAC, violated FECA when it solicited a donation from what it believed was a foreign national CLC’s Larry Noble told the Lexington Herald Leader, “The solicitation of the contribution in and of itself is illegal, even if money never changes hands. So it’s illegal to ask a foreign donor or to help a foreign donor make contributions. If you look at the videotape, I think it clearly falls in the definition of solicitation.”

Legal Brief Filed In Supreme Court Case Regarding Virginia Gov. Bob McDonnell’s Acceptance of Gifts in Exchanges for Favors

In April 2016, CLC filed a friend-of-the-court brief stating that the Supreme Court should reject former Virginia Governor Bob McDonnell’s claim that the First Amendment protects political quid pro quos. McDonnell accepted up to $175,000 in gifts and loans from a wealthy businessman in exchange for favors from the governor’s office. CLC argued in its brief that if the Supreme Court bought into former Gov. McDonnell’s arguments, politicians face no penalty for freely accepting gifts and favors from America’s wealthiest who are trying to buy influence. Public officials should not be permitted to engage in public business for private gain, while pretending to represent the interests of their constituencies. It would undercut the very basic principles of our democracy and the integrity of our political system.

Legal Brief Filed in Case Involving Republican National Committee’s Challenge to “Soft Money” Restrictions

In March 2016, CLC filed a friend-of-the-court brief in the case RNC v. FEC, arguing against the Republican National Committee’s challenge to the restrictions on “soft money” that were instituted by the Bipartisan Campaign Reform Act (BCRA) barring national parties from raising or spending soft money. In a press release, CLC’s Larry Noble stated, “What the party committees are seeking is nothing short of permission to violate the laws passed by Congress.”

FEC Complaint Filed Calling for Investigation into Ted Cruz’s Failure to Report Loans in Compliance with the Law

In January 2016, CLC filed a complaint with the FEC asking for an investigation into Republican Senator Ted Cruz’s loans from two banks which were not reported in compliance with campaign finance law and may have exceeded contribution limits. Paul S. Ryan told The Hill, “The failure to report these loans is a clear cut violation of the law and kept voters in the dark about the money behind the Cruz campaign. If he also used his wife’s assets to obtain these unreported loans, he caused his committee to accept illegal excessive contributions from his wife.”

Letter Sent to DOJ Urging Agency to Investigate Jeb Bush’s Possible Violation of Contribution Limits

In May 2015, CLC sent a letter to the DOJ urging them to exercise its authority and investigate whether Republican presidential candidate Jeb Bush and a super PAC operating on his behalf knowingly violated candidate contribution limits and raised tens of millions of dollars in ‘soft money’ for his campaign before officially declaring as a candidate. CLC’s Gerry Hebert told McClatchy DC“If the FEC will not do its job, then it falls to DOJ to enforce the law and investigate these apparent knowing and willful pattern of violations of the law by the individuals and groups associated with Jeb Bush’s shadow campaign.”

FEC Complaint Urges Investigation of Jeb Bush, Rick Santorum and Scott Walker’s Presidential Campaigns

In March 2015, CLC filed a complaint with the FEC urging it to investigate Jeb Bush, Rick Santorum and Scott Walker’s 2016 presidential campaigns for violating candidate registration and reporting requirements, contribution limits and restrictions, as well as federal “soft money” prohibitions, by claiming they were not yet “candidates.” Paul S. Ryan told CBS News , “Jeb Bush is reportedly aiming to raise more than $50 million for his super PAC. Wisconsin Governor Scott Walker has opened an office in Iowa and is raising millions for a political group he created in January. Rick Santorum's own aide is referring to him as a 'candidate.' These individuals are 'candidates' under the law."

Letter Sent to Senate Candidate Mitch McConnell Urging Campaign to Discontinue Ads Violating Campaign Finance Laws

In March 2014, CLC wrote a letter to the Kentucky Opportunity Coalition and the McConnell Senate Committee asking them to discontinue ads that violated campaign finance laws, by KOC republishing “b-roll” produced by the McConnell campaign.

FEC Complaint Filed Against U.S. Senator David Vitter for Soliciting Contributions to the Fund for Louisiana’s Future in Excess of Federal Contribution Limits

In March 2014, CLC filed a complaint with the FEC urging them to investigate U.S. Senator David Vitter and the Fund for Louisiana’s Future based on information suggesting that Vitter and his agents had solicited contributions to the super PAC in excess of federal contribution limits and from prohibited sources. 

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