FEDERAL ELECTION COMMISSION

Washington, DC 20463 

BEFORE THE FEDERAL ELECTION COMMISSION

In the Matter of ) 

 ) 

Honor and Principles PAC and Lisa Lisker ) MUR 7464

 as treasurer, et al. ) 

 ) 

STATEMENT OF REASONS OF CHAIR DARA LINDENBAUM

AND COMMISSIONER SHANA M. BROUSSARD

This matter arose from a Complaint and Amended Complaint alleging that Honor and

Principles PAC and Lisa Lisker in her official capacity as treasurer (“Honor PAC”) violated

52 U.S.C. § 30122, a provision of the Federal Election Campaign Act of 1971, as amended (the 

“Act”), when Independence and Freedom Network, Inc. (“IFN”), made a series of contributions 

to Honor PAC in 2018 in the name of LZP, LLC.1 On May 20, 2021, the Commission found 

reason to believe that IFN and LZP made or allowed their names to be used to make 

contributions in the name of another, and that Honor PAC knowingly accepted contributions in 

the name of another, in violation of 52 U.S.C. § 30122.2 Following an investigation, the Office 

of General Counsel (“OGC”) recommended that the Commission find probable cause to believe 

that IFN made contributions in the name of another, LZP allowed its name to be used to make 

contributions in the name of another, and Honor PAC knowingly accepted a contribution in the 

name of another, in violation of 52 U.S.C. § 30122.3 We agreed with OGC’s first two 

recommendations, but we voted to reject OGC’s recommendation to find probable cause to 

believe that Honor PAC knowingly accepted a contribution in the name of another.4 This 

Statement explains the reasons for our Honor PAC vote. 

IFN was a social welfare non-profit organized under section 501(c)(4) of the tax code.5 

Although Raymond McVeigh was the President of IFN on paper, McVeigh testified at his 

1 Compl. (Aug. 9, 2018); Am. Compl. (May 29, 2020).

2 Certification at 1-2 (May 20, 2021). The Commission also found reason to believe that respondents failed to 

provide attribution information for a $35,000 contribution. Id.

3 OGC’s Notice to the Commission Following the Submission of Probable Cause Brief (Honor PAC) (Apr. 3, 2023); 

OGC’s Notice to the Commission Following the Submission of Probable Cause Brief (LZP, et al.) (Apr. 3, 2023).

4 See Certification (“Cert.”) at 1 ⁋ 1, MUR 7464 (Honor PAC) (Apr. 6, 2023) (reflecting the Commission’s 1-to-5 

vote against a motion to find probable cause to believe). In the subsequent vote, Chair Lindenbaum voted to 

approve a motion to find no probable cause to believe while Commissioner Broussard joined a vote against the 

motion. See id. at ⁋ 2. 

5 Gen. Counsel’s Br. at 1 (Honor PAC) (Mar. 1, 2023). 

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Statement of Reasons

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deposition that Tom Norris and Joel Riter ran its operations and did not communicate with him 

about what IFN was doing.6

 LZP was an LLC registered in Ohio on March 27, 2018. Honor 

PAC was an independent-expenditure-only committee (“IEOPC”) that registered with the 

Commission on March 26, 2018, naming Lisa Lisker as treasurer.7 Lisker testified that Riter 

instructed her to form Honor PAC to make independent expenditures in non-federal elections in 

Ohio.

8

The investigation revealed a compelling paper trail. Days after LZP and Honor PAC 

were created, IFN transferred $271,000 to LZP that, in turn, contributed nearly all of the funds to 

Honor PAC.9

 LZP did not have any other reported activity – its sole apparent purpose was to be 

a conduit for the funds from IFN to Honor PAC.10 Honor PAC reported receiving the 

contributions from LZP, not IFN.11 Honor PAC did not report receiving contributions from any 

other source.12 Respondents did not deny that LZP was a conduit, but instead characterized it as 

a “disregarded entity” for the purpose of “simplifying [IFN’s] accounting procedures.”13 

Respondents argued that IFN did not act for the “purpose of making a contribution to Honor 

PAC or to disguise its own identity.”14 

The Act prohibits a person from making a contribution in the name of another person, 

knowingly permitting his or her name to be used to effect such a contribution, or knowingly 

accepting such a contribution.15 Because the evidence was sufficient to establish that IFN made 

a contribution in the name of LZP and that LZP allowed its name to be used to effect a 

contribution in name of another, we voted to find probable cause to believe as to them.

16

However, we did not believe the record was sufficient to find probable cause to believe 

that Honor PAC knowingly accepted the contribution. As a threshold matter, the information in 

the record did not support imputing to Honor PAC, under principles of agency law, the 

knowledge required to establish a violation of § 30122. Nor did the record support identifying 

who – whether an agent of Honor PAC or not – had the requisite knowledge that the 

contributions were made in the name of another. Because the available information could not 

6 Id. 5-6.

7 Id. at 6.

8 Id. at 7. While the Commission would not ordinarily have jurisdiction over this state level activity, Honor PAC 

voluntarily registered with the Commission and submitted to its jurisdiction.

9 Id. at 1. LZP retained $1,000. Id.

10 Id. at 6-7. 

11 Id. at 1. 

12 Id.

13 Reply to Gen. Counsel’s Br. at 4 (LZP, et al.) (Mar. 16, 2023); Reply to Gen. Counsel’s Br. at 1 (Honor PAC) 

(Mar. 16, 2023) (adopting arguments from the LZP reply).

14 Id. at 5. 

15 52 U.S.C. § 30122.

16 Cert. at 1 ⁋ 1, MUR 7464 (LZP, LLC Inc.), dated April 6, 2023 (reflecting the votes of Chair Lindenbaum and 

Commissioners Broussard and Weintraub to find probable cause to believe against Respondents). 

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Statement of Reasons

Page 3 of 3 

establish the knowledge element of the violation, Respondents did not have notice or an 

opportunity to respond. In any event, we were unable to independently identify sufficient 

evidence in the record to establish that Honor PAC knowingly accepted a contribution in the 

name of another. Lisker, the treasurer and agent of Honor PAC as a matter of law, testified that 

she did not have any personal knowledge that LZP was “not the original source or the true 

source” of the contributions.17 McVeigh had no apparent relationship with Honor PAC.18 While 

Norris and Riter arguably had the requisite knowledge as the day-to-day managers of IFN, there 

was insufficient information in the record to establish that they were agents of Honor PAC.19

For these reasons, we voted to reject OGC’s recommendation to find probable cause to 

believe that Honor PAC knowingly accepted a contribution in the name of another. 

__________________ ___________________ 

Date Dara Lindenbaum 

Chair 

__________________ ___________________ 

Date Shana M. Broussard 

Commissioner

17 Lisa Lisker Dep. at 23:13–19 (Dec. 19, 2022). 

18 Gen. Counsel’s Br. at 14 (Honor PAC).

19 The Commission voted not to consider the unrecorded interviews of Norris and Riter in considering probable 

cause in this matter. Cert. at 1 (Mar. 28, 2023).

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