FEDERAL ELECTION COMMISSION 

WASHINGTON, D.C. 20463 

BEFORE THE FEDERAL ELECTION COMMISSION 

H 

01) 

CP 

In the Matter of 

Chris Nwasike for Congress and Marcus Brooks, in his 

oflicial capacity as Treasurer 

Biblical Concepts Ministries, Inc. 

Chukwuemeka Christian Nwasike 

Marianne '"Jorgine" Fields 

Joseph "Jay" Fields 

MUR 6345 

STATEMENT OF REASONS 

Chair Cynthia L. Bauerly and Commissioner Steven Waitfaer 

This matter concems allegations that Chukwuemeka Christian Nwasike C'Mr. Nwasike"), 

a former Congressional candidate in Florida's 3"* Congressional district, instructed Josqph 

Fields, the treasurer of a rally organized by Biblical Concepts Ministries, Inc. ("BCM"), to 

transfer $2,000 from BCM to his wife, Marianne "Jorgine" Fields, so that Mrs. Fields could 

make a contribution to Mr. Nwasike's campaign committee.* 

On February 16, 2011, the Commission considered the General Counsel's 

recommendations to find reason to believe that Mr. Nwasike and Chris Nwasike for Congress 

and Marcus Brooks, in his ofGcial capacity as treasurer ("Nwasike Comimttee") knowingly 

accepted a corporate contribution made in the name of another and that Mr. Nwasike also 

knowingly assisted in the making of a corporate contribution in the name of another in violation 

of Sections §§ 441b and 441f of the Federal Election Campaign Act of 1971. Although we 

supported the General Coxmsel's recommendations, a motion to adopt these recommendations 

failed by a vote of 3-3.^ Following that first vote, we then joined our colleagues in voting 5-1 to 

^See MUR 6345 (Nwasike), Complaint at 2. 

^Chair Bauerly and Commissioners Waldier and Weintraub voted in &vor ofthe motion. Vice Chair Hunter and 

Commissioners McGahn and Petersen opposed the motion. MUR 634S (Nwasike), Amended Certification dated 

March4.20n. 
MUR 634S (Nwasike) 

Statement of Reasons 

Page 2 of2 

exercise prosecutorial discretion and dismiss the allegations as to Mr. Nwasike and his 

committee.^ 

We first voted with our colleague, Commissioner Weintraub, to find reason to believe 

that Mr. Nwasike assisted in the making of a corporate contribution in the name of another and 

that he and his committee accepted a coiporate contribution made in the name of another. We 

share the view that § 44 If violations are particularly troubling because they can represent 

circumvention of contribution limits and can undermine the important focus of the Act on 

disclosure/ Given the serious nature of § 44 If violations and ^e weight of the information in 

favor of these recommendations, reason to believe was warranted in this matter. 

H As explained in the Statement of Reasons regarding the Commission's dismissal, we 

Cjn next voted to dismiss this matter under Heckler v. Chaney, 470 U.S. 821, based on the unique 

circumstances presented here, including that there was only one contribution at issue, the 

^ relatively small amount of money involved ($2,000), and the refund of the entire contribution by 

0 the Nwasike Committee prior to the filing of the complaint. Although we take seriously all 

*H allegations of violations stemming fix)m contributions made m the name of another ^ hence our 

<H vote to find reason to believe - here we viewed a Heckler dismissal appropriate in light of the 

unique facts and circumstances present in this matter. 

Date Cynthia L. Bauerly 

Chair 

Date Steven Walther 

Commissioner 

Chair Bauerly, Vice Chair Hunter, Commissioner McGahn, Commissioner Petersen, and Commissioner Walther 

voted in fiivor ofa motion to dismiss with respect to the allegation that Mr. Nwasike violated 2 U.S.C. §§ 441b(a), 

441f, and 11 C.F.R. § 110.4(b)(l)(iii), and that the Nwasike Committee violated 2 U.S.C. §§ 441b and 441f. 

Commissioner Weintraub voted against the motion. 

^ See Statement of Reasons in MUR 634S of Commissioner Ellen L. Weinliaub, dated March 24,2011. 

^See Statement of Reasons in MUR 6345 of Chav Cynthia L. Bauerly, Vice Chair Caroline C. Hunter, and 

Commissioners Donald F. McGahn II, Matthew S. Petersen and Steven Walther, dated March 28,2011.