Bright Lines Project

Project of:

Public Citizen

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The Bright Lines Project is a left-of-center advocacy group that promotes increased government control over political and advocacy activity by nonprofit organizations. Bright Lines claims that its policy proposals to legislators, regulators, and the Internal Revenue Service (IRS) are “designed to clarify” existing laws. 1 However, right-of-center campaign speech advocacy groups such as the Institute for Free Speech (IFS) have criticized the Project’s proposed rules for further complicating political speech regulations and making them more restrictive. 2

Bright Lines is an initiative of Public Citizen, the left-of-center lobbying group created by former Green Party presidential candidate Ralph Nader. Public Citizen provides funding and staff for the Project. 3


Bright Lines was started in 2008 by the left-of-center OMB Watch (referring to the Office of Management and Budget). In 2012, OMB Watch transferred the Project over to Public Citizen. 4 OMB Watch itself went on to rebrand as the Center for Effective Government in 2013 and shut down in 2016. The Project on Government Oversight, a left-of-center watchdog group, absorbed the Center’s major initiatives. 5


Bright Lines argues that lack of clarity is the main problem with IRS rules on political spending by nonprofit organizations. The Project claims that new regulations and legislation would simplify the rules for nonprofits without discouraging civic engagement. 6

Following the 2013 IRS scandal, when an investigation revealed that the agency had singled out right-of-center organizations for additional audits and scrutiny, Bright Lines drafting committee vice chair Elizabeth Kingsley co-wrote an opinion piece on the incident for the Washington Post. The piece claimed that while the IRS’ selective enforcement “warrants investigation,” insufficient legislation and regulation were the “underlying problems” that enabled the agency’s conduct. 7

Bright Lines opposed President Donald Trump’s plan to repeal the Johnson Amendment, a tax code provision which prevents charitable organizations such as churches and foundations from supporting or opposing political candidates. The Project claims that repealing the amendment “jeopardizes the public’s confidence” that donations to charities would not be used for political purposes. 8

In 2019, Bright Lines endorsed Democratic Rep. Jason Crow’s (D-CO) proposed End Dark Money Act, which would make it harder for nonprofit organizations engaged in advocacy activities to maintain their tax-exempt status. The bill would also force greater disclosure of donors to political causes. 9

Institute for Free Speech, which opposes restrictions on political speech and spending, has pushed back on policy proposals by Bright Lines. Eric Wang, a senior fellow at the Institute, claims that the Project’s definition of direct (“per se”) political campaign activity is overly broad. According to Wang, IFS agrees with Bright Lines that the IRS’ current “facts and circumstances” standard for determining the extent of a nonprofit organization’s political activity overly subjective. However, Wang argues that the Project’s own proposals are too vague as well, and that they place an excessive burden on nonprofits to prove that their activities are not political. 10

Capital Research Center president Scott Walter has criticized Bright Lines’ claims about public support for nonprofit political spending restrictions. In an article for Philanthropy Daily, Walter claimed that the Project’s polling methods, such as asking respondents whether they support “more clear and fair rules,” allowed Bright Lines to exaggerate support for their cause by asking overly-vague questions. He also criticized the Project for using a 49 percent positive response as evidence that “voters are speaking with a unified voice” in favor of further regulations. Left-of-center political strategist Celinda Lake, whose firm assisted with the Bright Lines poll, acknowledged that Walter raised a “good point,” but claimed that “facts don’t matter that much” and that the poll measured “core values” instead. 11


Lisa Gilbert is the project director of Bright Lines and the director of Public Citizen’s “Congress Watch” program. She previously worked for another Ralph Nader-associated project, the U.S. Public Research Interest Group (US-PIRG.) She also worked for Environment Washington, a state chapter of Environment America, which separated from US-PIRG in 2007. 12

Attorneys Gregory Colvin and Elizabeth Kingsley sit as chair and vice chair of the Project’s drafting committee. 13


In 2016, the Public Citizen Foundation, which provides financial and administrative support to Public Citizen and its projects, received a $650,000 grant from the Open Society Foundations. The grant funded projects related to campaign finance and “corporate political spending disclosure.” 14

In 2011, the Bauman Foundation gave the Center for Effective Government a $75,000 grant, part of which was designated for Bright Lines. 15 The left-of-center Democracy Fund has also given multiple grants to the Project. 16


  1.    “About Us,” The Bright Lines Project. Accessed February 16, 2021.
  2.     Eric Wang, “Response to Recent Comments of The Bright Lines Project,” Institute for Free Speech, December 10, 2014. Accessed February 16, 2021.
  3.        “About Us,” The Bright Lines Project. Accessed February 16, 2021.
  4.      “History of the Bright Lines Project,” The Bright Lines Project. Accessed February 16, 2021.
  5.          “Center for Effective Government Closes Doors,” Philanthropy News Digest, March 21, 2016. Accessed February 16, 2021.
  6.        “Solutions,” The Bright Lines Project. Accessed February 16, 2021.
  7.            Gary D. Bass and Elizabeth J. Kingsley, “Nonprofits need better guidance on tax-exempt standards,” Washington Post, May 23, 2013. Accessed February 16, 2021.
  8.           “Bright Lines Project,” Public Citizen. Accessed February 16, 2021.
  9.      “In His First Bill, Crow Cracks Down on Dark Money Spending,” Jason Crow, Congressman for Colorado’s 6th District, January 30, 2019. Accessed February 16, 2021.
  10.     Eric Wang, “Response to Recent Comments of The Bright Lines Project,” Institute for Free Speech, December 10, 2014. Accessed February 16, 2021.
  11.        Scott Walter, “Lies, Damned Lies, and Polls,” Philanthropy Today, October 7, 2014. Accessed February 16, 2021.
  12.      “The Bright Lines Project Team,” The Bright Lines Project. Accessed February 16, 2021.
  13.             “The Bright Lines Project Team,” The Bright Lines Project. Accessed February 16, 2021.
  14.      “Grant: OR2016-29168,” Open Society Foundations. Accessed February 16, 2021.
  15.    “Center for Effective Government,” Bauman Foundation. Accessed February 16, 2021.
  16.       “Public Citizen Foundation, Inc.,” Democracy Fund. Accessed February 16, 2021.
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