The Campaign Legal Center is an advocacy group aligned with left-of-center interests that supports strict enforcement of campaign finance laws. Campaign Legal Center attorneys track and participate in a variety of cases around the country involving campaign finance law at the federal, state, and local levels.

The Campaign Legal Center is affiliated with Campaign Legal Center Action, a 501(c)(4).¹ Both groups received substantial funding from Sam Bankman-Fried from 2021-2022, with Business Insider reporting that Bankman-Fried gave more than $2.5 million to the Campaign Legal Center and its affiliates.²

Background

The CLC was founded in 2002 at the University of Utah with the purpose to advocate for the Bipartisan Campaign Reform Act, also known as McCain-Feingold. During that time, the CLC actively defended the legislation in court during the 2003 Supreme Court case McConnell v. FEC. ³ In the early years of the organization’s history, the CLC was mainly funded by Pew Charitable Trusts before later expanding its litigation practice to include other election-related activities and redistricting issues. ⁴

Activities

The CLC is focused on four overarching issues: campaign finance, ethics, redistricting, and voting and elections.⁵

After initial branding as a bipartisan organization, the CLC developed a Litigation Strategy Council for potential election-focused litigation. As of March 2019, the CLC has been involved in almost 70 cases and actions related to election activities. ⁶

As of March 2019, the CLC was involved in arguing against the practice of “partisan gerrymandering” in the Supreme Court case Gill v. Whitford. ⁷ Other cases that the CLC has advocated on include fighting against voter ID laws meant to protect elections from potential voter fraud, suffrage for released felons, and preventing the state of Texas from requiring potential voters provide proof of their citizenship.⁸

In September 2022, the CLC filed a complaint with the Federal Election Commission (FEC), alleging that the National Republican Senatorial Committee improperly spent funds that were earmarked for legal expenses on campaign advertisements. End Citizens Cited joined the CLC’s complaint, while the Democratic Senatorial Campaign Committee made a separate request to the FEC for an advisory ruling on whether the practice was legal.⁹

Leadership and Staff

Trevor Potter is president of the Campaign Legal Center (CLC). Potter previously served as general counsel for Sen. John McCain (R-AZ) in his 2000 and 2008 presidential campaigns. Prior to his work for the McCain campaign, Potter was a partner at Wiley Rein & Fielding and later served as a commissioner on the Federal Election Commission (FEC) from 1991-1996. ¹⁰

Adav Noti is executive director of the CLC. He previously worked in the general counsel’s office at the FEC, and was a special assistant U.S. attorney for the District of Columbia.¹¹

Sandhya Bathija is vice president, communications at the CLC. She previously worked for the Center for American Progress, the American Civil Liberties Union (ACLU), Asian Americans Advancing Justice, Americans United for Separation of Church and State, and the National Law Journal.¹²

Jo Deutsch is director, legislative strategy at the CLC. She was formerly president of the lobbying firm Deutsch Initiatives Group, and the federal director of Freedom to Marry. She has also worked with labor unions including the Association of Flight Attendants, the American Federation of State, County, and Municipal Employees (AFSCME), and the United Food and Commercial Workers.¹³

Brent Ferguson is senior legal counsel, voting rights at the CLC. He was previously senior counsel at the National Redistricting Foundation, and counsel at the Brennan Center for Justice.¹⁴

Mannal Haddad is senior communications manager, voting rights and redistricting at the CLC. She was previously communications director for U.S. Representative Salud Carbajal (D-CA), and press secretary for the Committee on House Administration.¹⁵

Alice Huling is senior legal counsel, voting rights at the CLC. She was previously counsel at the Campaign for Accountability from 2018 to 2020.¹⁶

Jason Jaffery was vice president, development at the CLC as of October 2023. He was previously the development director at the American Civil Liberties Union (ACLU) of Ohio, and at the Southern Poverty Law Center.¹⁷ He has also served as director of philanthropy at the Democracy Collaborative.¹⁸

Spencer Klein is senior legal counsel at the CLC. He was previously an attorney at the Elias Law Group.¹⁹

Kedric Payne is vice president, general counsel, and senior director, ethics at the CLC. He was previously deputy general counsel at the U.S. Department of Energy, deputy chief counsel at the Office of Congressional Ethics, and at attorney at the law firms of Skadden, Arps, Slate, Meagher & Flom and Cravath, Swaine & Moore.²⁰

Brendan Quinn is senior communications manager, campaign finance and ethics at the CLC. He previously served in editorial and press relations roles at OpenSecrets.²¹

Kelsey Rogers is senior manager, state advocacy at the CLC. She previously held communications and legal positions at the Brady Campaign to Prevent Gun Violence, and was involved in former President Barack Obama’s 2008 and 2012 presidential campaigns.²²

Jon Roux is manager, individual giving at the CLC. He was previously the corporate and major gifts office at the Center for American Progress, and has also held positions at the LGBTQ Victory Fund and the Human Rights Campaign.²³

Financials

In its 2022 tax filings, the Campaign Legal Center (CLC) reported total revenues of $25,659,692, total expenses of $13,166,031, and net assets of $39,338,308.²⁴

Notable Funders

The CLC was originally funded by Pew Charitable Trusts, but has over time received donations from more overtly left-of-center organizations. ²⁵

In recent years, notable funders of the Campaign Legal Center have included:

• Sherwood Foundation: $12,181,145 awarded from 2018-2022.²⁶
• Sandler Foundation: $7,750,000 awarded from 2016-2022.²⁷
• John D. and Catherine T. MacArthur Foundation: $5,050,000 awarded from 2012-2023.²⁸
• William and Flora Hewlett Foundation: $3,897,500 awarded from 2014-2022.²⁹
• Popplestone Foundation: $3,500,000 awarded in 2022.³⁰
• Democracy Fund: $3,475,000 awarded from 2014-2020.³¹
• Ford Foundation: $2,925,000 awarded from 2013-2024.³²
• Foundation to Promote Open Society: $1,035,000 awarded from 2016-2020.³³

The CLC has reported receiving donations from the Wyss Foundation, a private foundation established by Swiss billionaire Hansjorg Wyss.³⁴ In 2021, the right-of-center group Americans for Public Trust filed a complaint with the FEC, asking for an investigation into whether Wyss, as a foreign national, had improperly contributed to American political campaigns. The complaint argued that Wyss may have “indirectly funded federal electoral advocacy through his nonprofit organizations, the Wyss Foundation and the Berger Action Fund. The intended recipient of these funds was ultimately a variety of organizations whose primary purpose is to engage in electoral advocacy.”³⁵ In 2019, the CLC submitted testimony to the Internal Revenue Service (IRS) arguing against an IRS proposed rule that would stop requiring certain nonprofits, such as those organized under Section 501(c)(4), to disclose the identities of their donors on Schedule B of their Form 990. Among other things, the CLC argued that doing so “would effectively invite illegal foreign spending in U.S. elections.”³⁶

Donor Disclosure

On its website, the CLC claims to disclose “all donations of $200 or greater made within the past twelve months.”³⁷ As of March 2019, institutional donors included: ³⁸

• Actblue
• American Constitution Society
• Apple Employee Matching Gift Program
• Laura and John Arnold Foundation
• Atlantic Philanthropies
• Anne & Don Ayer Charitable Foundation
• The William Backer Foundation
• The Battery Foundation
• BayTree Fund
• Bessemer National Gift Fund
• The Blue Heron Charitable Fund
• BMO Charitable Fund Program
• Brach Family Fund of the Tides Foundation
• Brico Fund
• Bright Funds Foundation
• The Brokaw Family Foundation
• California Forward
• The Carroll and McNally Charitable Fund
• Center for Biological Diversity
• The Chase Family Philanthropic Fund
• Chockstone Fund of Marin Community Foundation
• Clark Philanthropic Fund
• Community Foundation of Louisville
• Common Concerns
• Cow Hollow Fund
• Democracy Fund
• Democracy Fund Voice
• The Eacho Family Foundation
• Edwards Family Fund at Silicon Valley Community Foundation
• The Evergreen II Fund of the Northern Trust
• FairVote
• Fidelity Charitable Gift Fund
• Ford Foundation
• Samuel Freeman Charitable Trust
• Georgetown Law Center
• Gilfoyle-Ma Charitable Fund
• Amy P. Goldman Foundation
• Horace Goldsmith Foundation
• Google Vouchers
• Grassroots Comedy
• The Green Street Foundation of San Francisco
• Harwood Family Fund
• William and Flora Hewlett Foundation
• Jonathan Holman Charitable Fund
• Charles Evans Hughes Memorial Foundation
• Impact Fund
• Institute of International Education
• Issue One
• The Jeffrey Family Fund of the Community Foundation of New Jersey
• Moritz Jenkins Charitable Fund
• Jewish Federation of Metropolitan Chicago
• Joyce Foundation
• David Kadish and Michael Norton Charitable Gift Fund
• The Kenswil/Holler Donor-Advised Fund
• Kirshenbaum/ Slater Family Charitable Fund
• The Klarman Family Foundation
• Paul H. Klingenstein and Kathleen R. Bole Family Fund
• The Kolar Foundation of Buckley Sandler LLC
• Leadership Conference Education Fund
• Leaves of Grass Fund
• Leon Fund II of the Community Foundation Serving Richmond and Central Virginia
• John D. and Catherine T. MacArthur Foundation
• The Robert Matlock Fund
• The McCullers Family Fund
• The Clement & Linda McGillicuddy Fund
• DJ McManus Foundation Inc.
• Mertz Gilmore Foundation
• Morgan Stanley Global Impact Funding Trust
• Network for Good
• New York Community Trust
• The Next Generation Foundation
• Open Society Foundations
• The Oran Kessler Family Charitable Fund
• The Polaner Family Charitable Fund
• Marc and Tracy Porosoff Charitable Fund
• Present Progressive Fund
• The Jerold J. and Majorie N. Principato Foundation
• Prudential Financial Inc
• Puri-Punian Family Charitable Fund
• Qualcomm Matching Grant Program
• Red House Fund
• Reed Family Foundation
• Renaissance Charitable Foundation Inc.
• Resources Legacy Fund
• Rockefeller Brothers Fund
• Rockefeller Family Fund
• The Samarth Foundation
• Sandler Foundation
• Scott Sandler Charitable Fund of the Jewish Communal Fund
• Schmeltzer MLJ Charitable Fund
• Schwab Charitable
• The Sedgwick Family Charitable Trust
• Shames Family Foundation
• The Shewood Foundation
• Shute, Mihaly, & Weinberger LLP
• Skadden Fellowship Foundation
• SLC Giving Fund
• Kevin W. Smith Charitable Fund
• Soltani-Plotz Charitable Fund
• Southern Poverty Law Center
• State Infrastructure Fund of NEO Philanthropies
• Susi and Dick Stoll Charitable Fund
• Stuart Family Foundation
• Sustainable Grantmaking Partners Fund
• Thornburg Foundation
• University of Guam
• University of Pennsylvania Law Review
• Vanguard Charitable
• Vmware Foundation
• The Adam J. Weissman Foundation
• Wellspring Philanthropic Fund
• The West Bend Matching Gift Program
• The Yentis Foundation
• The Susan Zappone and Mitchell Bacharach Fund

Sam Bankman-Fried’s Donations

Between 2021 and 2022, the CLC received over $2.5 million from crypto-based entrepreneur Sam Bankman-Fried, who was later charged with multiple fraud offenses after his crypto-currency company FTX filed for bankruptcy in November 2022. ^{39 40} According to CLC spokesperson Brendan Quinn, CLC was unable to return Bankman-Fried’s donations because the money had already been spent. ⁴¹ Quinn explained that the CLC would not consider sending back a similar amount that was donated because “when a campaign is asked to disgorge an already-spent contribution, it generally does so by giving an equivalent amount to a charity. CLC is a charity.” ⁴²

Quinn later released a statement which confirmed that on December 16, 2022, the CLC board had voted to place the $2.5 million in donations it had received from Bankman-Fried into a separate account “until instructions are received from bankruptcy courts.” ⁴³ Quinn’s statement further explained that the CLC had accepted the donations by Bankman-Fried “after careful vetting,” ⁴⁴ which included consulting and discussing the matter with similar nonprofit organizations that had “vouched for his apparent legitimacy at the time.” ⁴⁵ Quinn conceded that the allegations and charges against Bankman-Fried did “betray C.L.C.’s mission.” ⁴⁶

In December 2022, Business Insider reported that Sam Bankman-Fried “almost single-handedly funded” the Campaign Legal Center’s 501(c)(4) affiliate Campaign Legal Center Action in 2021. Bankman-Fried reportedly gave $760,000 to Campaign Legal Center Action that year, and tax filings reviewed by Business Insider revealed that this “amounted to more than 95% of CLC Action’s revenue for that year and roughly 94% of its expenses.” Bankman-Fried also reportedly gave $300,000 to Campaign Legal Center Action in 2022.⁴⁷

1. Return of Organization Exempt From Income Tax (Form 990). Campaign Legal Center. 2022. Schedule R.
2. Brent D. Griffiths and Dave Levinthal. “Sam Bankman-Fried Funded More than 90% of a Leading DC Ethics Group’s Political Arm in 2021.” Business Insider. December 29, 2022. Available at: https://www.businessinsider.com/sam-bankman-fried-funded-90-of-campaign-legal-centers-political-arm-2022-12
3. Rojc, Philip. “Litigating for Democracy: Who’s Backing the Lawyers Defending U.S. Electoral Institutions?” Inside Philanthropy. March 05, 2019. Accessed March 06, 2019. https://www.insidephilanthropy.com/home/2019/3/5/litigating-for-democracy-whos-backing-the-lawyers-defending-us-electoral-institutions.
4. “About CLC.” Campaign Legal Center. Accessed March 11, 2019. https://campaignlegal.org/about.
5. “Our Issues.” Campaign Legal Center. Accessed April 9, 2024. Available at: https://campaignlegal.org/issues
6. Rojc, Philip. “Litigating for Democracy: Who’s Backing the Lawyers Defending U.S. Electoral Institutions?” Inside Philanthropy. March 05, 2019. Accessed March 06, 2019. https://www.insidephilanthropy.com/home/2019/3/5/litigating-for-democracy-whos-backing-the-lawyers-defending-us-electoral-institutions
7. “About CLC.” Campaign Legal Center. Accessed March 11, 2019. https://campaignlegal.org/about.
8. “Cases & Actions.” Campaign Legal Center. Accessed March 11, 2019. https://campaignlegal.org/cases-actions.
9. Shane Goldmacher and Reid J. Epstein. “Watchdog Group Accuses Senate G.O.P. Campaign Arm of Breaking the Law.” The New York Times. September 21, 2022. Available at: https://www.nytimes.com/2022/09/21/us/politics/fec-complaint-republican-campaign-finance.html
10. “Trevor Potter.” LinkedIn. Accessed March 8, 2019. https://www.linkedin.com/in/trevor-potter-9336354.
11. “Adav Noti.” Campaign Legal Center. Accessed April 10, 2024. Available at: https://campaignlegal.org/staff/adav-noti
12. “Sandhya Bathija.” Campaign Legal Center. Accessed April 10, 2024. Available at: https://campaignlegal.org/staff/sandhya-bathija
13. “Jo Deutsch.” Campaign Legal Center. Accessed April 10, 2024. Available at: https://campaignlegal.org/staff/jo-deutsch
14. “Brent Ferguson.” Campaign Legal Center. Accessed April 10, 2024. Available at: https://campaignlegal.org/staff/brent-ferguson
15. “Mannal Haddad.” Campaign Legal Center. Accessed April 10, 2024. Available at: https://campaignlegal.org/staff/mannal-haddad
16. “Alice Huling.” Campaign Legal Center. Accessed April 10, 2024. Available at: https://campaignlegal.org/staff/alice-huling
17. “Jason Jaffery.” Campaign Legal Center. October 5, 2023 (accessed via WayBack Machine). Available at: https://web.archive.org/web/20231005202259/https://campaignlegal.org/staff/jason-jaffery
18. “Jason Jaffery.” Common Dreams. Accessed April 10, 2024. Available at: https://www.commondreams.org/author/jason-jaffery
19. “Spencer Klein.” Campaign Legal Center. Accessed April 10, 2024. Available at: https://campaignlegal.org/staff/spencer-klein
20. “Kedric Payne.” Campaign Legal Center. Accessed April 10, 2024. Available at: https://campaignlegal.org/staff/kedric-payne
21. “Brendan Quinn.” Campaign Legal Center. Accessed April 10, 2024. Available at: https://campaignlegal.org/staff/brendan-quinn
22. “Kelsey Rogers.” Campaign Legal Center. Accessed April 10, 2024. Available at: https://campaignlegal.org/staff/kelsey-rogers
23. “Jon Roux.” Campaign Legal Center. Accessed April 10, 2024. Available at: https://campaignlegal.org/staff/jon-roux
24. Return of Organization Exempt From Income Tax (Form 990). The Campaign Legal Center Inc. 2022. Part I.
25. Rojc, Philip. “Litigating for Democracy: Who’s Backing the Lawyers Defending U.S. Electoral Institutions?” Inside Philanthropy. March 05, 2019. Accessed March 06, 2019. https://www.insidephilanthropy.com/home/2019/3/5/litigating-for-democracy-whos-backing-the-lawyers-defending-us-electoral-institutions.
26. Return of Private Foundation (Form 990-PF). Sherwood Foundation. 2018-2022. Part XIV.
27. Return of Organization Exempt From Income Tax (Form 990). Sandler Foundation. 2016-2022. Schedule I.
28. “Grant Search.” MacArthur Foundation. Accessed April 9, 2024. Available at: https://www.macfound.org/grants/?q=%22campaign%20legal%20center%22
29. “Grants.” William and Flora Hewlett Foundation. Accessed April 9, 2024. Available at: https://hewlett.org/grants/?keyword=campaign%20legal%20center&sort=relevance&current_page=1
30. Return of Private Foundation (Form 990-PF). Popplestone Foundation. 2022. Part XIV.
31. “Grants Database.” Democracy Fund. Accessed April 9, 2024. Available at: https://democracyfund.org/for-partners/grants-database/?fwp_grants_search=%22campaign%20legal%20center%22
32. “Grants Database.” Ford Foundation. Accessed April 9, 2024. Available at: https://www.fordfoundation.org/work/our-grants/awarded-grants/grants-database/?search=campaign+legal+center
33. “Awarded Grants.” Open Society Foundations. Accessed April 9, 2024. Available at: https://www.opensocietyfoundations.org/grants/past?filter_keyword=%22campaign+legal+center%22
34. “Individual and Institutional Donors.” Campaign Legal Center. Accessed April 10, 2024. Available at: https://campaignlegal.org/about/support/individual-donations
35. Melissa Klein. “Watchdog Calls for Probe Into Swiss Billionaire’s US Political Spending.” New York Post. May 15, 2021. Available at: https://nypost.com/2021/05/15/watchdog-calls-for-probe-into-swiss-billionaires-political-spending/
36. “Comments on IRS Reg-102508-16: “Guidance Under Section 6033 Regarding the Reporting Requirements of Exempt Organizations.” Campaign Legal Center. December 5, 2019. Available at: https://campaignlegal.org/sites/default/files/2020-02/CLC%20comments%20IRS%20Reg-102508-16.pdf
37. “Individual and Institutional Donors.” Campaign Legal Center. Accessed April 9, 2024. Available at: https://campaignlegal.org/about/support/individual-donations
38. “Foundation & Institutional Donors.” Campaign Legal Center. March 29, 2019 (accessed via WayBack Machine) Available at: https://web.archive.org/web/20190329033232/https://campaignlegal.org/about/support/institutions.
39. Levinthal, Dave. “Sam Bankman-Fried gave $2.5 million to a leading political ethics watchdog. The group says it can’t give the money back because officials already spent it.” Insider, December 8, 2022. https://www.businessinsider.com/sam-bankman-fried-sbf-donation-contribution-charity-campaign-legal-center-2022-12 
40. Sundar, Sindhu. “The criminal charges against Sam Bankman-Fried carry big penalties and jail time if proven, legal experts say.” Business Insider, December 15, 2022. https://www.msn.com/en-us/news/crime/the-criminal-charges-against-sam-bankman-fried-carry-big-penalties-and-jail-time-if-proven-legal-experts-say/ar-AA15ko0C
41. Levinthal, Dave. “Sam Bankman-Fried gave $2.5 million to a leading political ethics watchdog. The group says it can’t give the money back because officials already spent it.” Insider, December 8, 2022. https://www.businessinsider.com/sam-bankman-fried-sbf-donation-contribution-charity-campaign-legal-center-2022-12 
42. Levinthal, Dave. “Sam Bankman-Fried gave $2.5 million to a leading political ethics watchdog. The group says it can’t give the money back because officials already spent it.” Insider, December 8, 2022. https://www.businessinsider.com/sam-bankman-fried-sbf-donation-contribution-charity-campaign-legal-center-2022-12 
43. Vogel, Kenneth P. and Ken Bensinger. “U.S. Scrutinizes Political Donations by Sam Bankman-Fried and Allies.” New York Times, December 17, 2022. https://www.nytimes.com/2022/12/17/us/politics/sam-bankman-fried-political-donations-doj.html
44. Vogel, Kenneth P. and Ken Bensinger. “U.S. Scrutinizes Political Donations by Sam Bankman-Fried and Allies.” New York Times, December 17, 2022. https://www.nytimes.com/2022/12/17/us/politics/sam-bankman-fried-political-donations-doj.html
45. Vogel, Kenneth P. and Ken Bensinger. “U.S. Scrutinizes Political Donations by Sam Bankman-Fried and Allies.” New York Times, December 17, 2022. https://www.nytimes.com/2022/12/17/us/politics/sam-bankman-fried-political-donations-doj.html
46. Vogel, Kenneth P. and Ken Bensinger. “U.S. Scrutinizes Political Donations by Sam Bankman-Fried and Allies.” New York Times, December 17, 2022. https://www.nytimes.com/2022/12/17/us/politics/sam-bankman-fried-political-donations-doj.html
47. Brent D. Griffiths and Dave Levinthal. “Sam Bankman-Fried Funded More Than 90% of a Leading DC Ethics Group’s Political Arm in 2021.” Business Insider. December 29, 2022. Available at: https://www.businessinsider.com/sam-bankman-fried-funded-90-of-campaign-legal-centers-political-arm-2022-12