One of our subscribers sent us a draft of what they are intending to send to the Federal Elections Commission (FEC) about the Minnesota’s Fourth Congressional District (CD4) Republicans. They cite some disturbing things about the FEC account opened more than a month after a campaign contribution was given to the endorsed Candidate Greg Ryan for Congress Campaign. We contacted the Greg Ryan Campaign and a spokesperson said that they assumed the CD4 Republicans had a FEC account when they took the contribution.
The name of the person who is filing the complaint has been withheld by request.
Office of the General Counsel:
I believe the filing for CD4-RPM has deliberate errors and there are a few disturbing things about the filings in the account C00621185.
The first problem is that James Carson is the Chair of this group he is not the Treasurer nor the acting treasurer. He lists himself as the Treasurer on the FEC acct opening file. His filings seem to suggest he acted alone on this FEC account. The actual Treasurer of this group is Mr John Rheinberger as the MN Campaign Finance Disclosures & Compliance Board lists.
The second problem is the opening of the account is dated 7/5/16. The PDF shows that Mr Carson sent it on 6/30/16 and due to the federal holiday it was opened on 7/5/16.
Mr Carson’s filings show CD4-RPM gave $4000 to Greg Ryan’s campaign (according to the Greg Ryan FEC account) on 5/14/16 and $1000 on 5/18/16. I’m puzzled why Mr Carson annotated it in his files as 5/24/16 and 6/1/16. Then he waits almost a month before he opens a FEC account.
To give money as a CD party unit one has to have a FEC account first. This $5000 was given to the Greg Ryan Campaign prior to the CD4-RPM FEC account was set up.
Another problem is the itemized contributions are not itemized. I looked at other accounts to see how things are itemized and on the Greg Ryan account ALL the contributors are listed thus the definition of “itemized”. It is odd that in a Presidential year they wouldn’t have more contributions to this organization.
Another problem is the lack of filings, he missed two periods. Before the CD4-RPM account was closed in April of 2013 Mr Carson had a problem filing FEC reports and thus CD4 fell into some sort of punishment by the FEC. I don’t know what the punishment was, but it seems they closed out the CD4 closed the account.
During the 39 months that CD4-RPM didn’t have a FEC acct people would talk about the account as if it still existed. We had an endorsed Candidate Sharna Wahlgren in 2014 and somehow people thought there was an account. I didn’t go to their meetings as I was no longer an officer in my house district.
I have to wonder if the appointed Treasurer Mr Rheinberger knew of this FEC account that was set up. The CD4 Republican Constitution says that the Treasurer’s job is to manage both the state account and the federal account. It seems that this didn’t happen.
******** (name withheld by request)
The FEC account mentioned is C00621185. It was filed by the Fourth Congressional District Republican, CD4-RPM Chair James “Jim” Carson on June 30, 2016 using Priority Mail. It was processed after the July 4th Independence Day Holiday. You can see the FEC Account Opening here.
This shows that CD4-RPM Chair Jim Carson allegedly made a contribution to the Greg Ryan Campaign almost a month before he opened the FEC account!
However if you go to Greg Ryan For Congress FEC account filing period from April 2016 to July 2016 (July Quarterly Report) you’ll see that the CD4-RPM Contributions came in on 5/14/16 ($4000) and 5/18/16 ($1000). Why did Mr Carson wait a few weeks to file them on 5/24/16 ($4000) and 6/1/16 ($1000)? By his own filing it allegedly shows that CD4-RPM gave money to their endorsed candidate Greg Ryan PRIOR TO the opening of the CD4-RPM FEC account.
Nowhere does it show Mr John Rheinberger on the FEC account. At some point the Treasurer should have found out about the federal account, but in the 2016 End of Year Report there is no amendment in C00621185, in fact Mr. Carson has made himself to be the Treasurer, not the acting Treasurer as the opening of the account states.
Where was the Oversight by Deputy Chair Michelle Manke?
Deputy Chairs are not listed as required to make filings to the Minnesota Campaign Finance Disclosures & Compliance Board (MNCFB) nor for FEC accounts, unless there is a need to as in a vacancy at Treasurer or Chair. The CD4 Constitution does mention the Treasurer and the Deputy Treasurer manage their funds, whether it be state or federal.
Where was the oversight by the Deputy Chair Michelle Manke?
She recently visited a number of Republican BPOU Conventions in CD4 talking about the positive messaging, and the number of parades they’ve taken their “float” adorned with numerous US Military Branch Flags, US Flags, and yet there is no mention of it being from CD4 Republicans!
Newsflash: Parades Don’t Win Elections!
A Deputy Chair’s job is to help out the chair, and the other officers on the Executive Committee. The Deputy Chair should be providing oversight on making sure the Chair and other officers are properly doing their jobs to the best of their abilities and to make sure there is no reason for the public to suspect any shenanigans going on. In some Republican BPOU Constitutions the Deputy Chair is also the Deputy Treasurer, unless there is a specific person elected into that position.
So why didn’t Michelle Manke provide proper oversight of the state account and the federal account? That’s a good question to ask her at the CD4 Convention on April 22, 2017 at the Roseville Oval.
A Conflict of Interest?
While it isn’t something that perhaps the FEC would look into, the selection of the Hennepin County Medical Center (HCMC) Food Shelf for catering at the CD4 Convention in 2016 and for some event in December 2016 might raise some concern about a conflict of interest. The Food Shelf at HCMC is a good thing, but Jim Carson’s wife helps out with the organization and the Deputy Chair Michelle Manke is the Project Manager for the HCMC Food Shelf from January 2014 to the present as her personal Facebook Page lists.
One would have to look into whether the CD4 Full Committee approved of this selection of the HCMC Food Shelf for catering. In 2014 Mrs Jim Carson was taking at-will donations from CD4 Convention Delegates and Alternates. One would have to question if the HCMC Food Shelf took at-will donations for the bag lunches they provided and also was paid what is listed. The first donation was prior to the creation of the FEC account on 5/11/16.
Payments Made Prior to the Creation of the FEC account
You can see in the Itemized Disbursements there is not only the payment to HCMC Food Shelf that Michelle Manke is the Project Manager for, but one to Century College for the rental of the auditorium for the 2016 CD4 Convention, on April 28, 2016 (almost a year ago). Maybe these payments should have went to the State Account.
Analyzing the draft of the letter to be sent to the Office of the General Counsel at the Federal Elections Commission and searching through the files; it is evident that the Chair the Deputy Chair and those on the Executive Committee for the Fourth Congressional District have not done their fiduciary duties to ensure the contributions are properly managed. Jim Carson and Michelle Manke are not to be trusted with leading anyone in the Fourth Congressional District of Minnesota (it isn’t too surprising that these two are both #NEVERTRUMPers). The people on the Executive Committee who knew about it and failed to alert the proper authorities ought to be ashamed of themselves…and they too should not be re-elected to any office ever again, nor be endorsed to run for an office.
How can we browbeat the DFL Party leaders, candidates, or sitting office holders with a standard we aren’t willing to follow ourselves?
It pains us to report this, but if Republicans can’t win elections on principles, and stay within the laws that govern elections, then they don’t deserve the trust of the voters. We hate it when we are told to, “Let it slide,” or, “Let it go, you’re not helping out the party.” Isn’t integrity a good thing? How can we browbeat the DFL Party leaders, candidates, or sitting office holders with a standard we aren’t following ourselves?
We need to elect leaders in our organization who lead with conscience, and speak loudly with proper action instead of just words.