1

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

CAMPAIGN LEGAL CENTER

1101 14th Street NW, Ste. 400

Washington, DC 20005

DEMOCRACY 21

2000 Massachusetts Avenue, NW

Washington, DC 20036

 Civil Action No. __________ Plaintiffs,

v.

FEDERAL ELECTION COMMISSION

1050 First Street, NE

Washington, DC 20463

Defendant.

COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF

1. This is an action under the Federal Election Campaign Act (“FECA” or “Act”), 52 

U.S.C. § 30109(a)(8)(A), and the Administrative Procedure Act (“APA”), 5 U.S.C. § 706(1), for 

illegal agency delay. 

2. Plaintiffs seek injunctive and declaratory relief to compel defendant Federal 

Election Commission (“FEC” or “Commission”) to take action on plaintiffs’ administrative 

complaint alleging violations of 52 U.S.C. § 30125(e), a FECA provision that prohibits any entity 

“established, financed, maintained or controlled by or acting on behalf of” a federal candidate from 

raising and spending funds that do not comply with the “limitations, prohibitions, and reporting 

requirements” of the Act, 52 U.S.C. § 30125(e)(1), i.e., “soft money.”

3. Section 30125(e) strictly circumscribes a federal candidate’s involvement with 

soft-money groups—such as federal independent expenditure-only political committees known as 

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“super PACs” that can raise funds outside FECA’s contribution limitations—and prevents

candidates from establishing or operating such groups as slush funds to support their campaigns.

4. Plaintiffs filed an administrative complaint with the FEC on May 27, 2015—

supplementing an earlier administrative complaint they filed March 31, 20151—alleging that

former Florida Governor John Elias “Jeb” Bush had violated 52 U.S.C. § 30125(e) by 

“establish[ing],” “financ[ing],” “maintain[ing],” and “controll[ing],” both directly and indirectly 

through his agents, the Right to Rise Super PAC, Inc.,

2 which “act[ed] on his behalf” by raising 

and spending soft money to promote Bush’s presidential campaign. Ex. A, Admin. Compl. ¶ 1.

5. The May 27 administrative complaint asked the Commission to find reason to 

believe that Bush violated section 30125(e) by raising and spending soft money for and through 

Right to Rise Super PAC, and that Right to Rise Super PAC violated section 30125(e) by raising 

and spending soft money on behalf of Bush, and to conduct an investigation to determine whether 

a violation had occurred or was continuing to occur. Ex. A, Admin. Compl. ¶¶ 1-2.

6. FECA provides administrative complainants with a right of action against the FEC 

if the Commission fails to act on a complaint within 120 days. 52 U.S.C. § 30109(a)(8)(A).

7. Four and a half years after plaintiffs filed their administrative complaints, there is 

no indication that the FEC has taken any action on them.

8. This prolonged inaction has fostered a Wild West atmosphere in the financing of

campaigns for federal office, allowing wealthy donors, including corporations and unions, to 

sidestep FECA’s contribution limits and disclosure requirements by making unlimited 

 1 The May 27, 2015 and March 31, 2015 administrative complaints are attached hereto as 

Exhibits A and B, respectively.

2 Shortly thereafter, Right to Rise Super PAC filed an amended Statement of Organization 

changing its name to Right to Rise USA. See Right to Rise USA Statement of Organization, FEC 

(Jun. 12, 2015), https://docquery.fec.gov/pdf/367/15951468367/15951468367.pdf. 

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contributions to super PACs established, financed, maintained, or controlled by their favored

federal candidates. Without enforcement of FECA provisions, such as section 30125(e), designed 

to prevent such circumvention of the contribution limits, “the integrity of our system of 

representative democracy is undermined.” Buckley v. Valeo, 424 U.S. 1, 26-27 (1976) (per 

curiam). 

9. Plaintiffs have also suffered, because they, as well as the public, have been deprived 

of full disclosure about the activities undertaken by Bush and his agents to establish Right to Rise 

Super PAC, as well as the nature of the ongoing relationship between the super PAC and the Bush 

campaign. Plaintiffs lack information, for instance, about whether Right to Rise’s expenditures 

should be deemed “coordinated” with the Bush campaign, or whether its contributors “earmarked” 

their money specifically for support of the Bush campaign. This is information to which plaintiffs

are legally entitled under FECA.

10. There is also reason to believe that Bush did not fully disclose his campaign 

activities as required by law, see 52 U.S.C. §§ 30102(e), 30103, 30104, and 11 C.F.R. § 101.3, 

both during the “testing the waters” phase of his campaign and after there was reason to believe 

Bush had moved beyond “testing the waters” to become a “candidate” under FECA. Ex. B, March 

Admin. Compl. ¶¶ 34-36, 49.

11. By failing to act on plaintiffs’ complaints, and exceeding by over four years the 

120-day period prescribed by FECA for such action, the Commission has encouraged the use of 

candidate-controlled super PACs like Right to Rise as vehicles for the wholesale evasion of the 

contribution limits enacted to prevent quid pro quo corruption and its appearance.

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Jurisdiction and Venue

12. This Court has both subject matter jurisdiction over this action and personal 

jurisdiction over the parties pursuant to 52 U.S.C. § 30109(a)(8)(A) and 5 U.S.C. § 702. This Court 

also has jurisdiction over this action pursuant to 28 U.S.C. § 1331. 

13. Venue lies in this district under 52 U.S.C. § 30109(a)(8)(A) and 5 U.S.C. § 703.

The Parties

14. Plaintiff Campaign Legal Center (“CLC”) is a nonpartisan, nonprofit organization 

that works to strengthen American democracy through, among other activities, local, state, and 

federal efforts to ensure that the public has access to information regarding the financing of U.S.

election campaigns. 

15. As part of this effort, CLC conducts research, authors reports and articles, and 

regularly provides expert analysis to the media. CLC also litigates throughout the country 

regarding campaign finance matters; files FEC complaints requesting that enforcement actions be 

taken against individuals or organizations that violate the law; participates in rulemaking and 

advisory opinion proceedings before the FEC to ensure that the agency is properly interpreting and 

enforcing federal election laws; and engages in legislative advocacy for reform measures at the 

federal, state, and local level.

16. CLC relies on the accurate and complete reporting of campaign finance information 

to carry out activities central to its mission, including the production of reports and other materials 

to educate the public about campaign spending and the true sources and scope of candidates’ 

financial support. 

17. CLC expends significant resources assisting reporters and other members of the 

media in their investigative research into candidates’ financial support and relationships with 

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donors, to ensure that the public is equipped with the information necessary to evaluate different 

candidates and messages and to cast informed votes. 

18. CLC also uses its analyses of federal campaign finance disclosure information to 

support its administrative practice at the FEC and before state and local campaign finance agencies, 

and to defend campaign finance laws in its active docket of cases in federal and state courts.

19. When inadequate disclosure of federal campaign finance activity makes it difficult

to ascertain the origin or nature of a candidate’s financial support, as occurs when a candidate’s 

fundraising and other operations are illegally outsourced to an “independent” super PAC without 

full disclosure, reporters often contact CLC for guidance as to whether or where they can find the 

campaign finance information that is not being properly reported. This work requires CLC to divert 

resources and funds from other organizational needs.

20. Plaintiff Democracy 21 is a nonprofit, nonpartisan organization dedicated to 

making democracy work for all Americans through support of campaign finance and other political 

reforms. To accomplish these goals, it conducts public education efforts, participates in litigation 

involving the constitutionality and interpretation of campaign finance laws, and engages in efforts 

to help ensure that campaign finance laws are properly enforced and implemented. It also 

participates in rulemaking and advisory opinion proceedings, and other administrative matters, at 

the FEC. 

21. Like CLC, Democracy 21 relies on the accurate and complete reporting of 

campaign finance information to carry out activities central to its mission, including its public 

education efforts, reports, and statements about campaign spending and the sources and scope of 

candidates’ financial support. Democracy 21 also expends significant resources to assist members 

of the media with research into issues of campaign financing and the relationships between 

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candidates and donors to ensure the public is broadly and accurately informed on these matters. 

Democracy 21 also uses its analyses of federal campaign finance disclosure information to support 

its administrative efforts at the FEC, including its participation in advisory opinion and rulemaking 

proceedings, as well as the filing of administrative complaints, and also uses such disclosure 

information in litigation to defend the constitutionality of the campaign finance laws in court. 

22. When such disclosure information is unavailable, inadequate, or inaccurate, such

as when candidates are allowed to use supposedly “independent” outside spending groups as de 

facto coordinated arms of their campaigns, it impedes the ability of Democracy 21 to fulfill its 

mission and causes Democracy 21 to divert resources and funds from other organizational needs 

in order to provide the public with accurate information about the facts and implications of how 

the financing of federal campaigns is occurring. 

23. Defendant FEC is an independent federal agency charged with the administration 

and civil enforcement of FECA. 52 U.S.C. § 30106(b).

Background

24. On May 27, 2015, CLC and Democracy 21 filed a complaint with the FEC against 

respondents Jeb Bush and Right to Rise Super PAC, urging that the Commission find reason to 

believe a violation of 52 U.S.C. § 30125(e) had occurred and commence an investigation. The 

May 27 complaint supplemented an earlier complaint plaintiffs filed with the FEC on March 31, 

2015, alleging that Bush had not complied with applicable contribution restrictions and disclosure 

requirements while “testing the waters” prior to officially announcing his candidacy. See infra 

¶ 32.

25. Plaintiffs’ May 27 administrative complaint alleged that Bush, while holding 

himself out as a candidate for the Republican nomination for U.S. President, and Bush’s agents,

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established Right to Rise Super PAC in January 2015,

3 and thereafter both directly and indirectly 

financed, maintained, and controlled Right to Rise Super PAC in violation of 52 U.S.C. 

§ 30125(e).

26. Citing news reports, the administrative complaint detailed the involvement of Bush

and his close advisors in “establishing” the super PAC. See Ex. A, Admin. Compl. ¶¶ 11-19. For 

example, Bush and his agents reportedly took a direct role in recruiting high-level staff for Right 

to Rise Super PAC, such as by installing Mike Murphy, one of Bush’s top advisers, at its helm.

4

 

27. The administrative complaint also alleged that Jeb Bush directly or indirectly 

“controlled” and “maintained” the super PAC while a candidate for office, citing reports that, 

among other things, Bush’s advisers were “overseeing the operations of” Right to Rise Super 

PAC,

5 that Bush attempted to delay a formal announcement of his candidacy to maximize his soft-

 3 See, e.g., Ex. A, Admin. Compl. ¶¶ 1, 9, 11 (citing Richard Costa, Jeb Bush and His Allies 

Form Leadership PAC and Super PAC, both dubbed Right to Rise, Wash. Post (Jan. 6, 2015),

https://www.washingtonpost.com/news/post-politics/wp/2015/01/06/jeb-bush-forms-new-pacright-to-rise; Peter Overby, 5 Years After ‘Citizens United,’ Super PACs Continue to Grow, NPR

(Jan. 13, 2015), https://www.npr.org/2015/01/13/377024687/five-years-after-citizens-unitedsuperpacs-continue-to-grow; Alex Isenstadt, Jeb Bush’s $100M May, Politico (May 8, 2015),

https://www.politico.com/story/2015/05/jeb-bush-right-to-rise-super-pac-campaign-117753; 

Philip Rucker & Matea Gold, Top Republican Strategists in Talks to Join Jeb Bush’s Super PAC, 

Wash. Post (Mar. 17, 2015), https://www.washingtonpost.com/news/post-politics/wp/2015/03/17/

top-republican-strategists-in-talks-to-join-jeb-bushs-super-pac).

4 See Ex. A, Admin. Compl. ¶ 12 (citing Michael C. Bender, Jeb Bush Promises 2016 Decision 

in ‘Few Months,’ Bloomberg Politics (Mar. 18, 2015), https://www.bloomberg.com/news/articles/

2015-03-18/jeb-bush-promises-2016-decision-in-next-few-months-; Rucker & Gold, supra; 

Maggie Haberman, Bush Advisor May Skip Campaign to Work for ‘Super PAC,’ N.Y. Times (Feb. 

18, 2015), https://www.nytimes.com/politics/first-draft/2015/02/18/bush-adviser-may-skip-cam

paign-to-work-for-super-pac; Jim Rutenberg, The Next Era of Campaign-Finance Craziness Is 

Already Underway, N.Y. Times (Apr. 21, 2015), https://www.nytimes.com/2015/04/21/magazine/

the-next-era-of-campaign-finance-craziness-is-already-underway.html; Thomas Beaumont, Bush 

Preparing to Delegate Many Campaign Tasks to Super PAC, Miami Herald (Apr. 21, 2015),

https://www.miamiherald.com/news/nation-world/national/article19123962.html).

5 Ex. A, Admin. Compl. ¶ 11 (citing Rucker & Gold, supra). See also id. ¶¶ 12-15.

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money fundraising for the super PAC,6 and that Bush and Right to Rise Super PAC developed a 

division of labor between his official authorized committee and the super PAC to operate as a 

unified campaign effort.

7

28. The administrative complaint also alleged Bush and his agents “financed” Right to

Rise Super PAC, and that Bush himself,8 his advisors,9 and members of his family10 personally 

conducted fundraising for the super PAC.

29. For example, Bush was reportedly the “Special Guest” at the “Right to Rise 

National Team Meeting” held in Miami at the end of April 2015. The invitation for that event 

established four tiers of supporters, with the highest tier reserved for those who contributed or 

 6 See, e.g., Ex. A, Admin. Compl. ¶¶ 12, 16-18 (citing Beaumont, Bender, and Isenstadt, supra).

7 See Ex. A, Admin. Compl. ¶¶ 16-18 (citing Beaumont and Isenstadt, supra).

8 See, e.g., Ex. A, Admin. Compl. ¶ 20 (citing Nicholas Confessore, Lines are Blurred in Donor 

Event for Jeb Bush ‘Super PAC,’ N.Y. Times (Mar. 12, 2015), https://www.nytimes.com/politics/

first-draft/2015/03/12/lines-are-blurred-in-a-jeb-bush-super-pac-donor-event; Maggie Haberman, 

Hillary Clinton to Jump Start Fund-Raising Efforts, N.Y. Times (Apr. 29, 2015), https://www.

nytimes.com/politics/first-draft/2015/04/29/hillary-clinton-to-jump-start-fund-raising-efforts; 

Matea Gold & Ed O’Keefe, Never Before Have So Many People with So Much Money Run for 

President, Wash. Post (Apr. 27, 2015), https://www.washingtonpost.com/politics/why-the-2016-

gop-race-may-be-more-like-2012-than-the-party-hoped/2015/04/26/fff662c8-e9f9-11e4-9767-

6276fc9b0ada_story.html). See also id. ¶ 23.

9 See, e.g., Ex. A, Admin. Compl. ¶ 24 (citing Ben White, Jeb Bush’s $100 Million Problem, 

Politico (Mar. 16, 2015), https://www.politico.com/story/2015/03/jeb-bush-fundraising-right-torise-116108).

10 See, e.g., Ex. A, Admin. Compl. ¶ 26 (citing Patrick Svitek, George P. Bush to Help Raise 

Cash for Dad’s Super PAC, Tex. Trib. (Mar. 9, 2015), https://www.texastribune.org/2015/03/09/

george-p-bush-attend-fundraiser-dads-super-pac; Matea Gold & Ed O’Keefe, George W. and 

Laura Bush to Appear at Fundraiser for Jeb Bush, Wash. Post (Mar. 23, 2015), https://www.wash

ingtonpost.com/news/post-politics/wp/2015/03/23/george-w-and-laura-bush-to-appear-at-fund

raiser-for-jeb-bush; Ed O’Keefe, In Fundraising E-Mail, Barbara Bush Says Jeb Bush ‘Is Our Best 

Chance of Taking Back the White House in 2016,’ Wash. Post (Mar. 18, 2015), https://www.

washingtonpost.com/news/post-politics/wp/2015/03/18/in-fundraising-e-mail-barbara-bush-saysjeb-bush-is-our-best-chance-of-taking-back-the-white-house-in-2016).

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raised $500,000 by April 17, 2015. Bush reportedly told donors at the event that he had already

“raised tens of millions of dollars for his allied super PAC.”11

30. Over the course of the 2015-2016 election cycle, the Right to Rise Super PAC spent 

over $86 million on behalf of Jeb Bush’s presidential run.12

31. With the exception of a single $108 expenditure, all of that spending occurred after 

the filing of the May 27, 2015 administrative complaint.13

Administrative Proceedings

32. CLC and Democracy 21 first filed an FEC complaint against Bush on March 31, 

2015, alleging that Bush failed to comply with the requirement that activities to “test the waters” 

for an eventual campaign for federal office be paid for with funds that comply with applicable 

FECA contribution limits and source restrictions, as per 11 C.F.R. §§ 100.72 and 100.131. The 

March 31 complaint further alleged that there was reason to believe Bush had moved beyond 

“testing the waters” to become a “candidate” under FECA, but failed to comply with the candidate 

registration and disclosure requirements established by 52 U.S.C. §§ 30102(e), 30103, and 30104, 

and 11 C.F.R. § 101.3. Ex. B, March Admin. Compl. ¶ 49.

33. The FEC responded to the March 31, 2015 complaint with a letter of 

acknowledgement dated April 3, 2015 informing plaintiffs that the proceeding would be 

designated Matter Under Review (“MUR”) 6927.

 11 Ex. A, Admin. Compl. ¶ 20 (citing Confessore; Gold & O’Keefe, Never Before; and

Haberman, Clinton to Jump Start Fund-Raising, supra).

12 See Right to Rise USA: Targeted Candidates, 2016 Cycle, Ctr. for Responsive Politics, https://

www.opensecrets.org/outsidespending/recips.php?cmte=C00571372&cycle=2016 (last visited 

Mar. 11, 2020).

13 See Independent Expenditures: Right to Rise USA (2015-2016), FEC, https://www.fec.gov/

data/independent-expenditures/?committee_id=C00571372&two_year_transaction_period=2016

&cycle=2016&data_type=processed&is_notice=true (last visited Mar. 11, 2020).

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34. CLC and Democracy 21 then filed the May 27 administrative complaint described 

in paragraphs 24-29 supra, alleging violations of 52 U.S.C. § 30125(e) by Bush and Right to Rise

Super PAC. The FEC sent plaintiffs another acknowledgement letter, dated June 4, 2015,

indicating that the May 27 complaint would be treated as a supplement to the March 31 complaint.

35. Upon information and belief, the Commission has failed to act on plaintiffs’ May 

27, 2015 administrative complaint, or the March 31 complaint it supplemented, since it was filed 

more than four and a half years ago. The Commission’s inaction has thus persisted well beyond 

the statutorily allotted 120-day response period, as indeed, it has failed to take action over a period 

more than ten times that length.

CAUSES OF ACTION

Count I: FECA, 52 U.S.C. § 30109(a)(8)(A)

36. Plaintiffs repeat and reallege paragraphs 1-35.

37. Defendant’s failure to act on plaintiffs’ administrative complaints within 120 days 

of their filing was contrary to law under 52 U.S.C. § 30109(a)(8)(A), which provides plaintiffs a

cause of action for “a failure of the Commission to act on such complaint during the 120-day period 

beginning on the date the complaint is filed.” 

Count II: APA, 5 U.S.C. § 706(1)

38. Plaintiffs repeat and reallege paragraphs 1-37.

39. By failing to act on plaintiffs’ administrative complaints within 120 days of their

filing, the FEC unlawfully withheld and unreasonably delayed agency action under 5 U.S.C. 

§ 706(1).

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REQUESTED RELIEF

WHEREFORE, plaintiffs request that this Court:

(1) Declare that the FEC’s failure to act on plaintiffs’ administrative complaints was 

contrary to law under 52 U.S.C. § 30109(a)(8)(A);

(2) Declare that the FEC has unlawfully withheld and unreasonably delayed agency 

action on plaintiffs’ administrative complaints under 5 U.S.C. § 706(1);

(3) Order the FEC to conform with this declaration within 30 days pursuant to 52 

U.S.C. § 30109(a)(8)(C);

(4) Award plaintiffs their costs and reasonable attorneys’ fees incurred in this action; 

and

(5) Grant such other relief the Court may deem just and proper.

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Dated: March 13, 2020 Respectfully submitted,

/s/ Tara Malloy

Paul M. Smith (DC Bar No. 358870)

Tara Malloy (DC Bar No. 988280)

Megan P. McAllen (DC Bar No. 1020509)

CAMPAIGN LEGAL CENTER

1101 14TH ST. NW, SUITE 400

WASHINGTON, D.C. 20005

(202) 736-2200

Fred Wertheimer (DC Bar No. 154211)

DEMOCRACY 21

2000 Massachusetts Avenue N.W.

Washington, DC 20036

(202) 355-9600

Donald J. Simon (DC Bar No. 256388)

SONOSKY, CHAMBERS, SACHSE,

ENDRESON & PERRY, LLP

1425 K Street N.W., Suite 600

Washington, DC 20005

(202) 682-0240

Attorneys for Plaintiffs

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EXHIBIT A

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EXHIBIT B

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Campaign Legal Center 

215 E Street, NE 

Washington, DC 20002 

(202) 736-2200

Democracy 21 

BEFORE THE UNITED STATES 

FEDERAL ELECTION coMMissION 21; � 1;c� Ji PH 1: 06

2000 Massachusetts A venue, NW 

Washington, DC 20036 

(202) 355-9600

V. 

John Ellis "Jeb" Bush 

c/o Right to Rise PAC 

P.O. Box 14349 

Tallahassee, FL 32317 

MURNo. 

COMPLAINT 

1. This complaint is filed pursuant to 52 U.S.C. § 30109(a)(l) and is based on information

providing reason to believe that John Ellis "Jeb" Bush has been "testing the waters" of a

2016 presidential campaign and has not complied with and will not comply with the

requirement that "testing the waters" activities be paid for with funds that comply with

the Federal Election Campaign Act's ("FECA") candidate contribution limits and

restrictions, in violation of FECA provisions, 52 U.S.C. § 30101, et seq., and

Commission regulations.

2. Additionally, this complaint is based on information providing reason to believe that Jeb

Bush moved beyond "testing the waters" to become a "candidate" under FECA and

violated the candidate registration and reporting requirements, contribution limits and

restrictions, and "soft money" prohibitions of FECA, 52 U.S.C. § 30101, et seq., and

Commission regulations.

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CIVIL COVER SHEET

JS-44 (Rev. 6/17 DC)

I. (a) PLAINTIFFS

(b) COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF _____________________

(EXCEPT IN U.S. PLAINTIFF CASES)

DEFENDANTS

COUNTY OF RESIDENCE OF FIRST LISTED DEFENDANT _____________________

(IN U.S. PLAINTIFF CASES ONLY) NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE TRACT OF LAND INVOLVED

(c) ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER) ATTORNEYS (IF KNOWN)

II. BASIS OF JURISDICTION

 (PLACE AN x IN ONE BOX ONLY)

III. CITIZENSHIP OF PRINCIPAL PARTIES (PLACE AN x IN ONE BOX FOR 

PLAINTIFF AND ONE BOX FOR DEFENDANT) FOR DIVERSITY CASES ONLY!

o 1 U.S. Government 

Plaintiff

o 2 U.S. Government 

Defendant

o 3 Federal Question

 (U.S. Government Not a Party)

o 4 Diversity

 (Indicate Citizenship of 

 Parties in item III)

Citizen of this State

Citizen of Another State

Citizen or Subject of a 

Foreign Country

PTF

o 1

o 2

o 3

DFT

o 1

o 2

o 3

Incorporated or Principal Place 

of Business in This State

Incorporated and Principal Place 

of Business in Another State

Foreign Nation

PTF

o 4

o 5

o 6

DFT

o 4

o 5

o 6

IV. CASE ASSIGNMENT AND NATURE OF SUIT

(Place an X in one category, A-N, that best represents your Cause of Action and one in a corresponding Nature of Suit)

o A. Antitrust

410 Antitrust

o B. Personal Injury/ 

 Malpractice

310 Airplane

315 Airplane Product Liability

320 Assault, Libel & Slander

330 Federal Employers Liability

340 Marine

345 Marine Product Liability

350 Motor Vehicle

355 Motor Vehicle Product Liability

360 Other Personal Injury

362 Medical Malpractice

365 Product Liability

367 Health Care/Pharmaceutical 

 Personal Injury Product Liability 

368 Asbestos Product Liability

o C. Administrative Agency 

 Review

151 Medicare Act

Social Security

861 HIA (1395ff)

862 Black Lung (923)

863 DIWC/DIWW (405(g))

864 SSID Title XVI

865 RSI (405(g))

Other Statutes

891 Agricultural Acts

893 Environmental Matters

890 Other Statutory Actions (If 

 Administrative Agency is

 Involved)

o D. Temporary Restraining 

 Order/Preliminary 

 Injunction

Any nature of suit from any category 

may be selected for this category of 

case assignment. 

*(If Antitrust, then A governs)*

o E. General Civil (Other) OR o F. Pro Se General Civil

Real Property

210 Land Condemnation

220 Foreclosure

230 Rent, Lease & Ejectment

240 Torts to Land

245 Tort Product Liability

290 All Other Real Property

Personal Property

370 Other Fraud

371 Truth in Lending

380 Other Personal Property 

 Damage

385 Property Damage 

 Product Liability

Bankruptcy

422 Appeal 27 USC 158

423 Withdrawal 28 USC 157

Prisoner Petitions

535 Death Penalty

540 Mandamus & Other

550 Civil Rights

555 Prison Conditions

560 Civil Detainee – Conditions 

 of Confinement

Property Rights

820 Copyrights

830 Patent

835 Patent – Abbreviated New 

 Drug Application

840 Trademark

Federal Tax Suits

870 Taxes (US plaintiff or 

 defendant)

871 IRS-Third Party 26 USC 

 7609

Forfeiture/Penalty

625 Drug Related Seizure of 

 Property 21 USC 881

690 Other

Other Statutes

375 False Claims Act

376 Qui Tam (31 USC 

3729(a))

400 State Reapportionment

430 Banks & Banking

450 Commerce/ICC 

 Rates/etc.

460 Deportation

462 Naturalization 

 Application

465 Other Immigration 

 Actions

470 Racketeer Influenced 

 & Corrupt Organization

480 Consumer Credit

490 Cable/Satellite TV

850 Securities/Commodities/

 Exchange

896 Arbitration

899 Administrative Procedure 

 Act/Review or Appeal of 

 Agency Decision

950 Constitutionality of State 

 Statutes

890 Other Statutory Actions 

 (if not administrative agency 

 review or Privacy Act)

CAMPAIGN LEGAL CENTER and

DEMOCRACY 21

FEDERAL ELECTION COMMISSION

DC DC

Tara Malloy, Campaign Legal Center

1101 14th St. NW, Ste. 400

Washington D.C., 20005

(202) 736-2200

Office of the General Counsel

Federal Election Commission

1050 First Street, NE

Washington, D.C. 20463

Case 1:20-cv-00730-CRC Document 1-3 Filed 03/13/20 Page 1 of 2
o G. Habeas Corpus/

 2255

530 Habeas Corpus – General 

510 Motion/Vacate Sentence

463 Habeas Corpus – Alien

 Detainee

o H. Employment 

Discrimination 

442 Civil Rights – Employment 

 (criteria: race, gender/sex, 

 national origin,

 discrimination, disability, age, 

 religion, retaliation)

*(If pro se, select this deck)*

o I. FOIA/Privacy Act

895 Freedom of Information Act

890 Other Statutory Actions 

 (if Privacy Act)

*(If pro se, select this deck)*

o J. Student Loan

152 Recovery of Defaulted 

 Student Loan

 (excluding veterans)

o K. Labor/ERISA 

 (non-employment)

710 Fair Labor Standards Act

720 Labor/Mgmt. Relations

740 Labor Railway Act

751 Family and Medical 

 Leave Act

790 Other Labor Litigation 

791 Empl. Ret. Inc. Security Act

o L. Other Civil Rights

 (non-employment)

441 Voting (if not Voting Rights 

 Act)

443 Housing/Accommodations

440 Other Civil Rights

445 Americans w/Disabilities –

 Employment 

446 Americans w/Disabilities –

 Other

448 Education 

o M. Contract

110 Insurance

120 Marine

130 Miller Act

140 Negotiable Instrument

150 Recovery of Overpayment 

 & Enforcement of 

 Judgment

153 Recovery of Overpayment 

 of Veteran’s Benefits

160 Stockholder’s Suits

190 Other Contracts 

195 Contract Product Liability

196 Franchise

o N. Three-Judge 

Court

441 Civil Rights – Voting 

 (if Voting Rights Act) 

V. ORIGIN

o 1 Original 

Proceeding

o 2 Removed

 from State 

 Court

o 3 Remanded 

from Appellate 

Court

o4 Reinstated 

or Reopened

o5 Transferred 

from another 

district (specify) 

o 6 Multi-district 

Litigation

o7 Appeal to 

District Judge 

from Mag. 

Judge

o8 Multi-district 

Litigation –

Direct File

VI. CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE.)

VII. REQUESTED IN

 COMPLAINT

CHECK IF THIS IS A CLASS 

ACTION UNDER F.R.C.P. 23

DEMAND $ 

 JURY DEMAND: 

Check YES only if demanded in complaint

YES NO

VIII. RELATED CASE(S)

 IF ANY

(See instruction) YES NO If yes, please complete related case form

DATE: _________________________ SIGNATURE OF ATTORNEY OF RECORD _________________________________________________________

INSTRUCTIONS FOR COMPLETING CIVIL COVER SHEET JS-44

Authority for Civil Cover Sheet

The JS-44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and services of pleadings or other papers as required 

by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the 

Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of Court for each civil complaint filed. 

Listed below are tips for completing the civil cover sheet. These tips coincide with the Roman Numerals on the cover sheet. 

I. COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF/DEFENDANT (b) County of residence: Use 11001 to indicate plaintiff if resident 

of Washington, DC, 88888 if plaintiff is resident of United States but not Washington, DC, and 99999 if plaintiff is outside the United States.

III. CITIZENSHIP OF PRINCIPAL PARTIES: This section is completed only if diversity of citizenship was selected as the Basis of Jurisdiction 

under Section II.

IV. CASE ASSIGNMENT AND NATURE OF SUIT: The assignment of a judge to your case will depend on the category you select that best 

represents the primary cause of action found in your complaint. You may select only one category. You must also select one corresponding 

nature of suit found under the category of the case. 

VI. CAUSE OF ACTION: Cite the U.S. Civil Statute under which you are filing and write a brief statement of the primary cause. 

VIII. RELATED CASE(S), IF ANY: If you indicated that there is a related case, you must complete a related case form, which may be obtained from 

the Clerk’s Office.

Because of the need for accurate and complete information, you should ensure the accuracy of the information provided prior to signing the form. 

Action for declaratory and injunctive relief under 52 U.S.C. § 30109(a)(8) against Federal Election Commission.

✘

✘

March 13, 2020 /s/ Tara Malloy

Case 1:20-cv-00730-CRC Document 1-3 Filed 03/13/20 Page 2 of 2
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CAMPAIGN LEGAL CENTER and

DEMOCRACY 21

1:20-cv-730

FEDERAL ELECTION COMMISSION

Attorney General of the United States

U.S. Department of Justice

950 Pennsylvania Avenue, NW

Washington, DC 20530-0001

Tara Malloy

Campaign Legal Center

1101 14th St. NW, Ste. 400

Washington D.C. 20005

Case 1:20-cv-00730-CRC Document 1-4 Filed 03/13/20 Page 1 of 2
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CAMPAIGN LEGAL CENTER and

DEMOCRACY 21

1:20-cv-730

FEDERAL ELECTION COMMISSION

Federal Election Commission

1050 First Street, NE

Washington, D.C. 20463

Tara Malloy

Campaign Legal Center

1101 14th St. NW, Ste. 400

Washington D.C. 20005

Case 1:20-cv-00730-CRC Document 1-5 Filed 03/13/20 Page 1 of 2
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CAMPAIGN LEGAL CENTER and

DEMOCRACY 21

1:20-cv-730

FEDERAL ELECTION COMMISSION

United States Attorney for the District of Columbia

Judiciary Center Building

555 4th Street, NW

Washington, DC 20530

Tara Malloy

Campaign Legal Center

1101 14th St. NW, Ste. 400

Washington D.C. 20005

Case 1:20-cv-00730-CRC Document 1-6 Filed 03/13/20 Page 1 of 2
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