March 12, 2024

VIA ELECTRONIC MAIL

Timothy Bechtold

Montanans Against Corruption in Congress

317 E Spruce Street

Missoula, MT 59802

abbey@abbeyleecook.com

Dear Mr. Bechtold:

RE: MUR 8088

On November 15, 2022, the Federal Election Commission notified Montanans Against 

Corruption in Congress and you in your official capacity as treasurer of a Complaint alleging 

violations of certain sections of the Federal Election Campaign Act of 1971, as amended. On 

March 6, 2024, based on the information provided in the Complaint, the Commission 

determined to exercise its prosecutorial discretion to dismiss the allegations contained in the 

Complaint. Accordingly, the Commission closed its file in this matter. A copy of the General 

Counsel’s Report, which more fully explains the Commission’s decision, is enclosed for your 

information.

Documents related to the case will be placed on the public record within 30 days. See 

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

(Aug. 2, 2016). If you have any questions, please contact Allen H. Coon, the attorney assigned 

to this matter, at (202) 694-1650.

Sincerely,

Lisa J. Stevenson 

Acting General Counsel

BY: Anne B. Robinson

Assistant General Counsel

Enclosure:

General Counsel’s Report

MUR808800009
1 BEFORE THE FEDERAL ELECTION COMMISSION

2

3 ENFORCEMENT PRIORITY SYSTEM

4 DISMISSAL REPORT

5

6 MUR 8088 Respondent: Montanans Against Corruption

7 in Congress and Timothy

8 Bechtold in his official 

9 capacity as treasurer 

10 Complaint Receipt Date: November 9, 2022

11 Response Date: N/A

12

13

14 Alleged Statutory and 52 U.S.C. § 30104(b), (g)(1)

15 Regulatory Violations: 11 C.F.R. § 104.4(c)

16

17

18 The Complaint alleges that Montanans Against Corruption in Congress and Timothy 

19 Bechtold in his official capacity as treasurer (the “Committee”), an independent expenditure-only 

20 political committee, failed to file a required 24-Hour Report to disclose independent expenditures 

21 aggregating $1,000 or more in the form of printed cards that were disseminated on October 30, 

22 2022, opposing Ryan Zinke and supporting John Lamb, both of whom were then-candidates for 

Montana’s 1st Congressional District.123 The election was held on November 8, 2022. Specifically, 

24 the Complaint alleges that the printed cards were left on the windshields of vehicles parked outside 

a church in Missoula, Montana.225 The Complaint further alleges that the Committee misappropriated 

the Montana Republican Party’s name and logo in its cards.

3

26 Finally, the Complaint alleges that, at 

27 the time that the Complaint was submitted, the Committee had failed to report any receipts or 

1 Compl. at 1-2 (Nov. 9, 2022).

2

Id. at 1.

3 The Complaint includes an image of the printed cards which shows bolded and large letters “MTGOP” in the 

upper left-hand corner. Id. at 1. The Complaint does not allege that the Committee misappropriated the Montana 

Republican Party’s name and logo for the purpose of solicitating contributions, and there does not appear to be any 

solicitation on the face of the printed card. See 52 U.S.C. § 30124(b) (prohibiting any person from fraudulently 

misrepresenting the person as speaking, writing, or otherwise acting for or on behalf of any candidate or political party 

or employee or agent thereof for the purpose of soliciting contributions or donations).

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MUR 8088 (Montanans Against Corruption in Congress)

EPS Dismissal Report

Page 2 of 3

disbursements since filing its Statement of Organization on July 14, 2022.

4

1 Prior to the Complaint, 

2 the Committee filed its first two reports, 2022 October Quarterly and Pre-General Election Reports, 

which showed zero dollars in total activity from its formation until October 19, 2022.53 After the 

4 Complaint, the Committee filed its 2022 Post-General Report, which disclosed one $10,000 

5 contribution on November 3, 2022, and an independent expenditure of $9,500 that same day for 

television ads.

6

6 None of the Committee’s reports show any disbursements apparently related to the 

7 printed cards. The Committee did not respond to the Complaint.

8 Based on its experience and expertise, the Commission has established an Enforcement 

9 Priority System using formal, pre-determined scoring criteria to allocate agency resources and 

10 assess whether particular matters warrant further administrative enforcement proceedings. These 

11 criteria include (1) the gravity of the alleged violation, taking into account both the type of activity 

12 and the amount in violation; (2) the apparent impact the alleged violation may have had on the 

13 electoral process; (3) the complexity of the legal issues raised in the matter; and (4) recent trends in 

14 potential violations and other developments in the law. This matter is rated as low priority for 

15 Commission action after application of these pre-established criteria. Given that low rating and the 

16 apparent low amount in violation, we recommend that the Commission dismiss the Complaint 

17 consistent with the Commission’s prosecutorial discretion to determine the proper ordering of its 

4 Compl. at 2; Montanans Against Corruption in Congress, Statement of Organization at 1 (July 14, 2022).

5 Montanans Against Corruption in Congress, 2022 October Quarterly Report at 2 (Oct. 15, 2022), 

https://docquery.fec.gov/pdf/529/202210159537490529/202210159537490529.pdf; Montanans Against Corruption in 

Congress, 2022 Pre-General Report at 2 (Oct. 27, 2022), https://docquery.fec.gov/pdf/859/202210279546523859/

202210279546523859.pdf.

6 Montanans Against Corruption in Congress, 2022 30-Day Post-General Report at 2, 6 ,7 (Dec. 8, 2022), 

https://docquery.fec.gov/pdf/981/202212089557503981/202212089557503981.pdf. The Committee also filed a 48-

Hour Report on November 4, 2022, reporting $9,500 in expenditures paid to “Plazby, LLC,” for television ads. 

Montanans Against Corruption in Congress, 48-Hour Report of Independent Expenditures at 1 (Nov. 4, 2022), 

https://docquery.fec.gov/pdf/517/202211049546711517/202211049546711517.pdf.

MUR808800011
MUR 8088 (Montanans Against Corruption in Congress)

EPS Dismissal Report

Page 3 of 3

priorities and use of agency resources.71 We also recommend that the Commission close the file as 

2 to all Respondents and send the appropriate letters.

3 Lisa J. Stevenson

4 Acting General Counsel

5

6 Charles Kitcher 

7 Associate General Counsel

8

9

10 ___________________ BY: ___________________

11 Date Claudio J. Pavia

12 Deputy Associate General Counsel 

13 for Enforcement

14

15

16 ___________________

17 Anne B. Robinson

18 Assistant General Counsel

19

20

21 ___________________

22 Wanda D. Brown

23 Assistant General Counsel

24

25

26 ___________________

27 Allen Coon

28 Attorney

7 Heckler v. Chaney, 470 U.S. 821, 831-32 (1985). 

02/22/2024

MUR808800012