[EL] Fwd: Democracy 21 and Campaign Legal Center ChallengeLegality of Pr...

JBoppjr at aol.com JBoppjr at aol.com
Tue May 17 14:53:58 PDT 2011


Now Trevor is weighing in on behalf of his clients  and co-PEW-money 
recipients to claim that "I’m sure he’ll next be  telling us that the new PAC has 
nothing to do with the RNC (of which he is a  leading Member)." Since when 
is control by one  organization of another determined by a participant being 
a "leading member" of  an organization.  I am a leading member of the 
Republican National Lawyers  Association, Federalist Society, Uniform Law 
Commission, James Madison Center  for Free Speech, National Right to Life 
Committee, National Legal Center for the  Medically Dependent and Disabled, Indiana 
Republican Party, etc.  Next  Trevor, who loves to throw arround that 
everyone else is a criminal who does  political spending he doesn't like, will "be 
telling us" that RSPAC is  controlled by all of these organizations that I 
am a "leading member" of.   Jim Bopp
 
 
In a message dated 5/17/2011 5:42:31 P.M. Eastern Daylight Time,  
tpotter at capdale.com writes:

 
I so respect these  measured, lawyerly, communications on the List Serve. “
Fred is so ignorant”,  Jim posts.  That’s right, Fred Wertheimer has no 
idea what’s in  McCain-Feingold, and is ignorant of federal  campaign finance 
law.  Of course, I can see why Jim feels this way—it’s only a federal 
statute  (with what Jim always reminds everyone is “criminal penalties”) —no one 
really  needs to look too closely. The fix is already in, after all! To 
quote Jim from  yesterday: 
"Who cares," Mr. Bopp  said of good government groups that may oppose his 
latest enterprise. "The  Supreme Court doesn't care, and I don't care, and 
the [Federal Election  Commission] doesn't care. No one that matters cares." 
_http://blogs.wsj.com/washwire/2011/05/16/super-pac-or-pack-of-trouble/_ 
(http://blogs.wsj.com/washwire/2011/05/16/super-pac-or-pack-of-trouble/)  
I’m sure he’ll next be  telling us that the new PAC has nothing to do with 
the RNC (of which he is a  leading Member) or the other national party 
committees (which are featured in  his press release). I personally expect this 
venture ends as well as the  attempt to get the federal courts to declare 
soft money legal after all in RNC  v FEC… 
Trevor  Potter 
 
 
From:  law-election-bounces at department-lists.uci.edu  
[mailto:law-election-bounces at department-lists.uci.edu] On Behalf Of  JBoppjr at aol.com
Sent: Tuesday, May 17, 2011 5:25  PM
To: rhasen at law.uci.edu; law-election at uci.edu
Subject:  Re: [EL] Fwd: Democracy 21 and Campaign Legal Center 
ChallengeLegality of  Pr...

 
Fred  is so ignorant.  The RSPAC is a federal PAC and therefore 
contributions  to it are HARD MONEY which political parties and candidates can solicit. 
  It is an IE-PAC which the FEC says and federal courts have required have 
not  source or amount limits on contributions.  And it is set up by Roger,  
Solomon and I and is not controlled by anyone but us.  More bluster from  
the guys that think all political spending is illegal.  Jim  Bopp
 

 
 
In a  message dated 5/17/2011 5:00:53 P.M. Eastern Daylight Time, 
rhasen at law.uci.edu  writes:

in  response to Steve Gold's post, see below (not yet up on the CLC or D21  
websites).


-------- Original Message --------       
Subject:    
Democracy 21 and Campaign Legal Center Challenge  Legality of Proposed Soft 
Money Activities by RNC Shadow Group Formed  by RNC Committeeman James Bopp 
  
Date:    
Tue, 17 May 2011 13:54:01  -0700   
From:    
_wertheimer at democracy21.org_ (mailto:wertheimer at democracy21.org)   
_<wertheimer at democracy21.org>_ (mailto:wertheimer at democracy21.org)    
Reply-To:    
_ekesler at democracy21.org_ (mailto:ekesler at democracy21.org)  
_<ekesler at democracy21.org>_ (mailto:ekesler at democracy21.org)    
To:    
Hasen, Richard _<rhasen at law.uci.edu>_ (mailto:rhasen at law.uci.edu)  

Democracy  21 - Campaign Legal Center
_________________________________________________________________ 
Press  Release, May 17, 2011, _www.democracy21.org_ 
(http://www.democracy21.org/) 
_________________________________________________________________ 
Democracy  21 and Campaign Legal Center Challenge Legality of Proposed Soft 
Money  Activities by RNC Shadow Group Formed by RNC Committeeman James  
Bopp 

Statement  of Fred Wertheimer, President of Democracy 21 and
Trevor Potter,  President of Campaign Legal Center and former FEC  Chairman 
Recent  press reports have revealed the formation of a new "Republican 
Super PAC"  whose planned operations would appear to violate multiple federal 
campaign  finance laws because of the involvement of members of the RNC in  
establishing and controlling the PAC and because of the planned use of  
federal officeholders and candidates to solicit unlimited contributions for  the 
PAC.  Such solicitations by federal officeholders and candidates  are 
explicitly prohibited by provisions of the Bipartisan Campaign Reform  Act that 
have been upheld by the Supreme Court.

According to recent  press reports, three members of the Republican 
National Committee - Indiana  RNC Committeeman James Bopp Jr, Oregon RNC 
Committeeman Solomon Yue and  Louisiana State party Chairman Roger Villere - have 
established a new  political committee called “Republican Super PAC.”

They have  indicated that the purpose of this PAC is to make independent 
expenditures  in federal elections and that it will use funds solicited in 
unlimited  amounts by, among others, federal candidates who will benefit from 
those  expenditures.  

In our view, the proposed efforts of this RNC  “shadow group” would 
violate multiple provisions of the federal campaign  finance laws.  

First, this constitutes an illegal scheme to  violate the ban on the 
raising or spending of soft money by national party  committees. Second, the 
proposed activities would violate the ban on federal  officeholders soliciting 
unlimited soft money donations in connection with a  federal election.  Each 
of these bans has been upheld by the Supreme  Court, and neither of them was 
affected by the Court’s decision in Citizens  United.

Indeed, in RNC v. FEC, Mr. Bopp  failed in his attempt to overturn the 
decision in McConnell v. FEC,  which upheld the constitutionality of  both the 
ban on political party  soft money and the ban on federal officeholders and 
candidates soliciting  unlimited contributions.  

Mr. Bopp urged a three-judge lower  court to declare provisions of the soft 
money ban unconstitutional but the  lower court unanimously rejected the 
argument and the Supreme Court last  year summarily affirmed the lower court 
decision. The party soft money ban  remains the law.

Mr. Bopp is now apparently attempting to ignore the  statutory ban on 
political party soft money and to overturn by fiat the  Supreme Court decision.

The soft money ban prohibits the RNC “or any  officer or agent acting on 
behalf of ” the RNC or “any entity that is  directly or indirectly 
established, financed, maintained or controlled” by  the RNC from soliciting, 
receiving, spending or directing to another person  any contributions that are not 
subject to the limitations, prohibitions and  reporting requirements of the 
law.

The “Republican Super PAC” has  been set up by three members of the RNC, 
including Mr. Bopp, who is,  according to press reports, unveiling the scheme 
in a presentation to all  RNC members tomorrow. 

Press reports also indicate that party  officials and agents will raise 
funds for the “Republican Super PAC,” in  unlimited amounts.  According to an 
article in POLITICO: 
“We  are not going to do any fundraising,” Bopp told POLITICO. “We are  
harnessing the fundraising operations of those entities, the RNC and all the  
state parties and federal candidates, who will be raising money first for  
themselves and then they would tell their donors, if they have extra money,  
to send it to the Republican Super PAC.” 
Given  these circumstances, this PAC is exactly the type of group that is 
described  by the law as an entity “that is directly or indirectly 
established,  financed, maintained or controlled” by a national party committee and 
that  is a group controlled by “agents” of the RNC who are acting on behalf 
of the  RNC.

As such, the soft money ban applies directly to “Republican  Super PAC” 
and the PAC is subject to the contribution limits that apply to  national 
party committees. It would be illegal for the PAC to accept, or for  any agent 
of the national party to solicit, a contribution in excess of the  limits 
that apply to contributions that can be accepted by the national  parties.

RNC Chairman Reince Priebus should be on notice that it  would be a 
violation of law for the RNC and “Republican Super PAC” to  solicit or receive any 
corporate or labor union contributions, and a  violation of the law for the 
RNC and "Republican SuperPac" to solicit or  receive contributions from an 
individual that in the aggregate exceed  $30,800 per year.

Mr. Bopp has also said that he intends to have  federal candidates solicit 
unlimited funds for “Republican Super  PAC.”

Every member of Congress and every federal candidate should be  on notice 
that it would be a violation of the law for them to solicit  unlimited 
contributions for “Republican Super PAC” or for any other Super  PAC.

According to press reports, “Republican Super PAC” is taking the  position 
that it is intending to make only “independent” expenditures, and  
therefore can accept contributions that are not subject to any limitations.  (The 
DC Circuit Court of Appeals held in SpeechNow v. FEC that  contributions to 
an independent expenditure-only PAC are not subject to  contribution limits). 
 

The federal campaign finance law  prohibits federal officeholders and 
candidates from soliciting or directing  any funds in connection with a federal 
election “unless the funds are  subject to the limitations, prohibitions and 
reporting requirements” of the  law.  

If “Republican Super PAC” raises unlimited contributions  under SpeechNow, 
it will be  raising funds that are not “subject to the limitations” of the 
 federal law.  

Even if it is permissible for “Republican Super  PAC” to accept such 
unlimited funds, it is not permissible for federal  candidates and officeholders 
to solicit such funds as they are not “subject  to the limitations” of the 
federal law.

Any contrary view would lead  to the absurd and obviously corrupting result 
that an incumbent federal  officeholder can solicit a $1 million or $5 
million donation to “Republican  Super PAC” with the understanding that the PAC 
will then spend the money on  “independent” expenditures to benefit that 
officeholder.

The D.C.  Circuit in the SpeechNow case found  that a PAC which makes only 
independent expenditures can accept unlimited  contributions on the grounds 
that such contributions do not pose any threat  of corruption. SpeechNow, 
however,  said it operated wholly independently of candidates and parties, and 
the  court did not consider a situation where the contributions raised by 
the PAC  are to be solicited by federal candidates. There is nothing in the 
court’s  opinion to suggest that it would permit solicitations of unlimited 
amounts  by federal candidates.

Federal law prohibits federal candidates and  officeholders from soliciting 
funds that are not subject to any contribution  limit.  That provision was 
upheld by the Supreme Court in the McConnell case and  even Justice Kennedy 
- who otherwise dissented in that case, and who  subsequently authored the 
Citizens United  decision-  said this solicitation ban was the one provision  
that “satisfies Buckley’s  anticorruption rationale and the First 
Amendment guarantee.”  

As Justice Kennedy wrote, “The making of a solicited gift is a  quid both 
to  the recipient of the money and to the one who solicits the payment (by  
granting his request).  Rules governing candidates’ or officeholders’  
solicitation of contributions are, therefore, regulations governing their  
receipt of quids. This regulation  fits under Buckley’s  anticorruption rationale.”

Any federal candidate or officeholder who  solicits unlimited contributions 
to the “Republican Super PAC” or any other  super PAC will be violating 
federal  law.



#  # # 
Released:  Tuesday, May 17, 2011 


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