MUR #7654
AMERICA FIRST ACTION, INC.Summary
RESPONDENTS: America First Action, Inc.; Josh Hawley for Senate; Matt Rosendale for Montana; Pete Sessions for Congress; Galt, Errol; Hargrove, Steve; National Media Research and Placement, LLC; OnMessage, Inc.; Proch, Jon; Purpura, Salvatore A.; Starboard Strategic, Inc.
COMPLAINANTS: Campaign Legal Center (1); Muller, Tiffany; End Citizens United; Christ, Margaret; Fischer (CLC), Brendan M.
SUBJECT: Committees; Contributions; Expenditures; Reporting
DISPOSITION: The Commission decided by a vote of 4-1 to close the file and send the appropriate letters, as recommended in the Memorandum from Chairman Dickerson dated September 6, 2022.
The Commission decided by a vote of 5-0 to approve the appropriate letters acknowledging waivers by Respondents (to be sent to counsel of record), as recommended in the Memorandum to the Commission dated November 9, 2021.
The Commission failed by a vote of 2-1 to approve the appropriate letters acknowledging waivers by Respondents (to be sent to counsel of record), as recommended in the Memorandum to the Commission dated November 9, 2021.
The Commission failed by a vote of 3-2 to take the following actions in MURs 7654 and 7660:
1. Merge MUR 7660 into MUR 7427.
2. Find reason to believe that America First Action, Inc. and Jon Proch, in his official capacity as treasurer violated 52 U.S.C. §§ 30104(b), 30116(a) and 30118(a) by making and failing to report excessive and prohibited in-kind contributions to Josh Hawley for Senate and Salvatore and Purpura in his official capacity as treasurer by coordinating communications through National Media.
3. Find reason to believe that America First Action, Inc. and Jon Proch, in his official capacity as treasurer violated 52 U.S.C. §§ 30104(b), 30116(a) and 30118(a) by making and failing to report excessive and prohibited in-kind contributions to Matt Rosendale for Montana and Errol Galt in his official capacity as treasurer by coordinating communications through National Media.
4. Find reason to believe that America First Action, Inc. and Jon Proch, in his official capacity as treasurer violated 52 U.S.C. §§ 30104(b), 30116(a) and 30118(a) by making and failing to report excessive and prohibited in-kind contributions to Pete Sessions for Congress and Steve Hargrove in his official capacity as treasurer by coordinating communications through National Media.
5. Find reason to believe that Hawley for Senate and Salvatore Purpura in his official capacity as treasurer, Rosendale for Montana and Errol Galt in his official capacity as treasurer, Pete Sessions for Congress and Steve Hargrove in his official capacity as treasurer violated 52 U.S.C. §§ 30104(b), 30116(f), and 30118(a).
6. Direct the Office of General Counsel to draft corresponding Factual and Legal Analyses and send the appropriate letters.
7. Approve the Factual and Legal Analysis, as recommended in the First General Counsel’s Report dated August 7, 2020, subject to the edits circulated by Commissioner Weintraub’s Office on January 25, 2021 at 5:57 p.m.
8. Authorize the use of compulsory process, including the issuance of appropriate interrogatories, document subpoenas, and deposition subpoenas, as necessary.
9. Approve the appropriate letter.
The Commission failed by a vote of 2-3 to take the following actions in MURs 7427, 7497, 7524, 7553, 7558, 7560, 7621, 7654, and 7660:
1. Close the files.
2. Send the appropriate letters.
The Commission failed by a vote of 2-3 to find no reason to believe in MURs 7427, 7497, 7560, 7621, 7654, and 7660.
Disposition
| Disposition | Penalty | Respondent | Citation |
|---|---|---|---|
| Dismissed-Other | Pete Sessions for Congress |
52
U.S.C.
§30104(b)
52 U.S.C. §30116(f) 52 U.S.C. §30118(a) |
|
| Purpura, Salvatore A. |
52
U.S.C.
§30104(b)
52 U.S.C. §30116(f) 52 U.S.C. §30118(a) |
||
| Galt, Errol |
52
U.S.C.
§30104(b)
52 U.S.C. §30116(f) 52 U.S.C. §30118(a) |
||
| National Media Research and Placement, LLC | |||
| Josh Hawley for Senate |
52
U.S.C.
§30104(b)
52 U.S.C. §30116(f) 52 U.S.C. §30118(a) |
||
| OnMessage, Inc. | |||
| Matt Rosendale for Montana |
52
U.S.C.
§30104(b)
52 U.S.C. §30116(f) 52 U.S.C. §30118(a) |
||
| Proch, Jon |
52
U.S.C.
§30104(b)
52 U.S.C. §30116(a) 52 U.S.C. §30118(a) |
||
| Starboard Strategic, Inc. | |||
| America First Action, Inc. |
52
U.S.C.
§30104(b)
52 U.S.C. §30116(a) 52 U.S.C. §30118(a) |
||
| Hargrove, Steve |
52
U.S.C.
§30104(b)
52 U.S.C. §30116(f) 52 U.S.C. §30118(a) |
Documents
Participants
| Relationship | Name |
|---|---|
| Primary respondent | America First Action, Inc. |
| Respondent | Josh Hawley for Senate |
| Matt Rosendale for Montana | |
| Pete Sessions for Congress | |
| Previous respondent | Galt, Errol |
| Hargrove, Steve | |
| National Media Research and Placement, LLC | |
| OnMessage, Inc. | |
| Proch, Jon | |
| Purpura, Salvatore A. | |
| Starboard Strategic, Inc. | |
| Complainant | Campaign Legal Center (1) |
| Christ, Margaret | |
| End Citizens United | |
| Fischer (CLC), Brendan M. | |
| Muller, Tiffany | |
| Respondent's counsel | Anderson, Tucker |
| Holtzman Vogel Baran Torchinsky & Josefiak, PLLC | |
| Jones Day | |
| Lex Politica (formerly Gober Group LLC/Vantage Legal PLLC) | |
| Sowards Newton, Megan |