FEDERAL ELECTION COMMISSION

 WASHINGTON, D.C.

 

 

April 11, 2024 

VIA EMAIL

Christopher M. Marston

2652 Group LLC 

P.O. Box 26141 

Alexandria, VA 22313

chris@2652group.com 

 RE: MUR 8091 (Beth Harwell, et al.) 

 

Dear Mr. Marston: 

On March 12, 2024, the Federal Election Commission (the “Commission”) accepted the 

signed conciliation agreement submitted on your clients’ behalf in settlement of a violation of 

52 U.S.C. § 30125(e)(1)(A), a provision of the Federal Election Campaign Act of 1971, as 

amended (the “Act”). Accordingly, the file has been closed in this matter, effective today. 

Documents related to the case will be placed on the public record today. See Disclosure 

of Certain Documents in Enforcement and Other Matters, 81 Fed. Reg. 50,702 

(Aug. 2, 2016). Information derived in connection with any conciliation attempt will not 

become public without the written consent of the respondent and the Commission. See

52 U.S.C. § 30109(a)(4)(B). 

Enclosed you will find a copy of the fully executed conciliation agreement for your files. 

Please note that the civil penalty is due within 30 days of the conciliation agreement’s effective 

date. If you have any questions, please contact me at (202) 694-1362. 

 

Sincerely, 

 

Christopher S. Curran

 Attorney 

MUR809100144
 

BEFORE THE FEDERAL ELECTION COMMISSION 

In the matter of ) 

 ) 

 Beth Harwell ) MUR 8091 

Beth Harwell (House 18) ) 

Tennesseans for Good State ) 

Government ) 

CONCILIATION AGREEMENT 

The Commission found reason to believe that Beth Harwell, Beth Harwell (House 18) 

(the “State Committee”), and Tennesseans for Good State Government (the “State PAC”) 

(collectively “Respondents”), violated 52 U.S.C. § 30125(e)(1)(A) by transferring funds that 

were not subject to the limitations, prohibitions, and reporting requirements of the Federal 

Election Campaign Act of 1971, as amended (the “Act”) in connection with an election to 

Federal office. 

NOW, THEREFORE, the Commission and the Respondents, having participated in 

informal methods of conciliation, prior to a finding of probable cause to believe, do hereby agree 

as follows: 

I. The Commission has jurisdiction over the Respondents and the subject matter of 

this proceeding, and this agreement has the effect of an agreement entered pursuant to 52 U.S.C. 

§ 30109(a)(4)(A)(i). 

II. Respondents have had a reasonable opportunity to demonstrate that no action 

should be taken in this matter. 

III. Respondents enter voluntarily into this agreement with the Commission. 

IV. The pertinent facts in this matter are as follows: 

1. Beth Harwell is a former member of the Tennessee House of Representatives. 

   	
	

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MUR 8091 (Beth Harwell, et al.) 

Conciliation Agreement 

Page 2 of 5 

2. Harwell established the State Committee in January 2017 and Harwell 

maintains the authority or ability to direct or participate in the governance of the State 

Committee and has the authority to hire, appoint, demote, or otherwise control the officers of the 

State Committee. 

3. Harwell established the State PAC in September 2006 and Harwell maintains 

the authority or ability to direct or participate in the governance of the State Committee and has 

the authority to hire, appoint, demote, or otherwise control the officers of the State Committee. 

4. The State Committee and State PAC received contributions that were not 

subject to the limitations, prohibitions, and reporting requirements of the Act. 

5. On February 24, 2022, Beth Harwell filed a Statement of Candidacy to run for 

Tennessee’s newly-drawn 5th Congressional District and became a federal candidate. 

6. On July 22, 2022, the State Committee contributed $35,000 to the independent 

expenditure-only political committee Government of the People. 

7. On July 22, 2022, the State PAC contributed $12,000 to Government of the 

People. 

8. On July 28, 2022, Government of the People spent $90,084 on independent 

expenditures either supporting Harwell or opposing her Republican primary election opponent 

Andy Ogles. 

9. On August 2, 2022 and August 4, 2022, Government of the People made 

additional independent expenditures of $19,475 and $3,580, again in support of Harwell or 

opposing Ogles. Government of the People did not make any more independent expenditures 

that election cycle. 

   	
	

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MUR 8091 (Beth Harwell, et al.) 

Conciliation Agreement 

Page 3 of 5 

10. The State Committee’s and State PAC’s combined contributions amounted to 

60.8% of Government of the People’s receipts at the time they were made. 

11. The State Committee’s and State PAC’s combined contributions represent 

Government of the People’s largest contributions. 

12. The Act prohibits federal candidates and officeholders, their agents and 

entities directly or indirectly established, financed, maintained or controlled by or acting on 

behalf of one or more candidates or individuals holding office from receiving or spending funds 

in connection with an election for Federal office unless the funds are subject to the limitations, 

prohibitions, and reporting requirements of the Act. 52 U.S.C. § 30125(e)(1)(A). 

13. To determine whether a sponsor directly or indirectly established, finances, 

maintains, or controls an entity, the factors described in 11 C.F.R. § 300(c)(2)(i) through (x) are 

examined in the context of the overall relationship between the sponsor and the entity. 11 C.F.R. 

§ 300.2(c)(2). 

14. The State Committee and State PAC were entities established, financed, 

maintained, or controlled by Harwell, a federal candidate, and acted on her behalf. 

15. Respondents contend that Harwell was not personally involved in the decision 

by the State Committee and the State PAC to contribute to Government of the People. 

 V. Respondents violated 52 U.S.C. § 30125(e)(1)(A) by transferring a total of 

$47,000 to Government of the People in connection with an election for Federal office that were 

not subject to the limitations, prohibitions, and reporting requirements of the Act. 

 VI. Respondents will take the following actions: 

 1. Respondents will pay a combined civil penalty to the Commission in the 

amount of Sixteen Thousand ($16,000), pursuant to 52 U.S.C. § 30109(a)(5)(A). 

   	
	

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MUR 8091 (Beth Harwell, et al.) 

Conciliation Agreement 

Page 4 of 5 

2. Respondents will cease and desist from committing violations of 52 U.S.C. 

§ 30125(e)(1)(A). 

 VII. The Commission, on request of anyone filing a complaint under 52 U.S.C. 

§ 30109(a)(1) concerning the matters at issue herein or on its own motion, may review 

compliance with this agreement. If the Commission believes that this agreement or any 

requirement thereof has been violated, it may institute a civil action for relief in the United States 

District Court for the District of Columbia. 

 VIII. This agreement shall become effective as of the date that all parties hereto have 

executed the same and the Commission has approved the entire agreement. 

 IX. Respondents shall have no more than 30 days from the date this agreement 

becomes effective to comply with and implement the requirements contained in this agreement 

and to so notify the Commission. 

 X. This Conciliation Agreement constitutes the entire agreement between the parties 

on the matters raised herein, and no other statement, promise, or agreement, either written or 

 

   	
	

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MUR 8091 (Beth Harwell, et al.) 

Conciliation Agreement 

Page 5 of 5 

oral, made by either party or by agents of either party, that is not contained within this written 

agreement shall be enforceable. 

FOR THE COMMISSION: 

Lisa J. Stevenson 

Acting General Counsel 

BY: __________________________ _____________ 

 Charles Kitcher Date 

 Associate General Counsel 

 for Enforcement 

FOR THE RESPONDENT: 

 _ __________ _____________ 

 (Name) Date 

 (Position) 

   	
	




	



	  


Charles 

Kitcher

Digitally signed by 

Charles Kitcher 

Date: 2024.03.14 

14:02:30 -04'00'

MUR809100149