This is the second complaint ECU has filed against Sam Brown for campaign finance violations
End Citizens United (ECU) filed a complaint with the Federal Election Commission (FEC) against Nevada U.S. Senate candidate Sam Brown. The complaint calls for an investigation over potential illegal coordination between Brown’s 2022 campaign and a super PAC that was set up by Brown’s top allies in his primary against Adam Laxalt. ECU alleges that Brown financed his 2022 super PAC exclusively through campaign donors, and then the PAC spent “soft money” promoting his campaign in violation of federal law.
“Sam Brown is a walking campaign finance violation. Throughout his failed runs, he repeatedly violated anti-corruption laws that are designed to prevent undue influence over his campaign by wealthy donors,” said End Citizens United President Tiffany Muller. “It appears that he organized a scheme to channel his big donors to a super PAC that supported his campaign in an effort to circumvent federal limits on campaign contributions. We urge the FEC to launch an investigation to hold Brown accountable and prevent him from engaging in any further illegal coordination this election cycle.”
This is the second complaint ECU has filed against Sam Brown for allegedly breaking campaign finance laws. In November 2023, ECU filed a complaint with the FEC against Brown for illegally using a political action committee that was marketed to help elect Republicans to Congress but instead was used to retire his old campaign debt.
The complaint:
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During the 2022 election, Citizens for Nevada (CFN) PAC was entirely funded by just four donors. Each donor had previously given the maximum permitted by law to Sam Brown’s campaign for the primary. Three of the four donors contributed to CFN in excess of the federal “hard money” limits to political committees.
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During the 2022 election, CFN supported Sam Brown through independent expenditure spending. This includes spending over $35,000 on a mailer distributed to Nevada voters in support of the Brown’s campaign. CFN only supported Brown; it did not support or oppose any other candidate.
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CFN paid just one vendor for fundraising consulting, a business called MWE Group LLC (MWE). MWE is a two-member LLC registered in Arizona. According to FEC records, MWE’s largest client in the 2021-2022 election cycle was the Brown campaign. The Brown campaign paid MWE over $150,000, almost twice the amount that MWE received from its next largest client during that cycle.
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Mr. Brown’s close association with MWE has continued beyond the 2022 election; one of MWE’s two members, Falicia Mandel, serves as Mr. Brown’s finance director in his current campaign.
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The evidence provides ample reason to believe that Mr. Brown, either directly or through his agent, financed CFN, which went on to spend soft money to influence his election in violation of federal law.
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Entities that are “directly or indirectly established, financed, maintained, or controlled by” a federal candidate or an agent of a federal candidate may not spend soft money in connection with a federal election. Therefore, federal law plainly prohibited CFN from spending soft money to influence Brown’s election while being financed by either him or agents of his campaign.
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In this case, the evidence strongly suggests that Brown financed CFN either directly (himself) or through his agent (MWE). Every single one of CFN’s donors—100% of its contributors—had previously contributed the maximum permitted amount to his campaign for the primary election.
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The logical explanation for how CFN’s donor base consisted entirely of Brown’s campaign donors is that either Mr. Brown or MWE provided donor names and contact information to CFN. This would mean that Mr. Brown, either directly or through his agent (MWE), caused or arranged for funds in a “significant amount or on an ongoing basis” to be provided to CFN. In fact, the funds attributable to Mr. Brown or his agent would appear to not only constitute CFN’s “seed money” but in fact all of the money CFN collected prior to the 2022 primary election.
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The close ties and ongoing relationship between Brown’s campaign, CFN, and MWE make the provision of donor information by Mr. Brown or his agent highly likely. First, the Brown campaign itself and its finance consultant are the primary keepers of data on campaign donors, including names and contact information. Further, CFN hired MWE as its sole fundraising consultant.
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Considering that Brown’s campaign was by far MWE’s largest client and the close ties between MWE personnel and Brown have continued through today, there is a strong likelihood that information passed from Brown’s campaign to CFN.
Click here to read the full complaint.
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