Page 1 of 2

FEDERAL ELECTION COMMISSION

WASHINGTON, D.C. 20463

STATEMENT OF REASONS OF 

COMMISSIONERS ELLEN L. WEINTRAUB AND STEVEN T. WALTHER

This matter involved two individual donors who used the Hawaii Republican Party (“HRP”) 

as a conduit to make excessive contributions to the Cavasso Committee. Each donor made the 

maximum contribution to the Cavasso Committee. Then, Melba Cavasso and Mikio Izuka contributed 

$2,500 and $7,320, respectively, to HRP. While the contributions were made to HRP, the available 

record demonstrates that they were impermissibly earmarked for the Cavasso Committee. One of the 

donors stated that he was simply following the candidate’s instruction, which was to send two checks, 

one for $2,700 for the Cavasso Committee and another for $7,300 to HRP. During the 2018 election 

cycle, the contribution limit for individuals was $2,700 per election.1 It was made clear to the donor 

that any amount given to HRP would pass through to the Committee.2

To ensure that contributors do not circumvent their individual contribution limits, the Federal 

Election Campaign Act and Commission regulations prohibit persons from using intermediaries to

skirt the contribution limits. Specifically, “all contributions made by a person, either directly or 

indirectly, on behalf of a particular candidate, including contributions which are in any way 

earmarked or otherwise directed through an intermediary or conduit to such candidate, shall be treated 

as contributions from such person to such candidate.”3 Contributions earmarked for a candidate 

1 See Fed. Election Comm’n, Archive of Contribution Limits, available at 

https://transition.fec.gov/info/contriblimitschart1718.pdf. 2 First. Gen. Counsels Rpt., MUR 7572, at 4 (citing Izuka Resp. at 1.). While the donor indicates that he was asked to 

make a $7,300 contribution, HRP states that it received a contribution for $7,320. Party Resp. at 3-6. 3 52 U.S.C. § 30116(a)(8).

BEFORE THE FEDERAL ELECTION COMMISSION

In the Matter of

Hawaii Republican Party and Mary Smart, in 

her official capacity as treasurer; Cam 

Cavasso 4 Congress and Sandra Lee Ahn, in 

her official capacity as treasurer; Melba 

Cavasso; Mikio Izuka; Shirlene Ostrov; 

Miriam Hellreich; Celyn Chong Kee; Greg 

Lussier; David Ross; Steve Yoder; Gary 

Grimmer; Andresen Blom; Pam Smith

)

 ) 

 ) 

 ) 

 ) 

 ) 

 ) 

 ) 

 ) 

 ) 

 ) 

 ) 

 

 

 

 MUR 7572 

 

 

MUR757200274
MUR 7572 (Hawaii Republican Party, et al.)

Statement of Commissioners Ellen L. Weintraub and Steven T. Walther 

Page 2 of 2 

through a conduit or intermediary are treated as contributions from the original contributor to that 

candidate, and are reportable as such.

4

 

HRP claimed payments to the Cavasso Committee’s vendors by HRP were coordinated party 

expenditures.5 Reviewing this record, the Office of General Counsel concluded: “On balance, the 

available information suggests that the donors may have implicitly or explicitly directed that their 

contributions to HRP be earmarked for the Cavasso Committee.”6 The complaint and responses 

provided sufficient information to find reason to believe that the donors, campaign, and state party 

committee violated the law. We so voted.7 Although the amount in violation was not large, state party 

committees are not unsophisticated or small-time participants in our political system. The federal 

campaign finance system depends on such major players upholding the highest standards and 

rigorously complying with the law. The Commission should ensure that they do so. 

 December 10, 2021 __________________________ 

Date Ellen L. Weintraub 

 Commissioner 

 December 10, 2021 __________________________ 

Date Steven T. Walther 

 Commissioner 

4 See 52 U.S.C. § 30116(a)(8); 11 C.F.R. § 110.6(a). 5 Id. at 4 (citing Cavasso Joint Resp. at 1-2.) 6 Id. at 11. 7 See Certification, MUR 7572 (Hawaii Republican Party, et al.), dated Nov. 2, 2021. We also voted to take no action at 

this time on allegations that HRP failed to maintain records relating to this matter and to the allegations that the 

Executive Committee members violated the Act. Id. 

MUR757200275