Rule of Law Defense Fund

The Rule of Law Defense Fund is the 501(c)(4) dark money fundraising arm of the Republican Attorneys General Association.

Key Takeaways

● Political and fundraising arm of the Republican Attorneys General Association
● Helped organize the “March to Save America” rally on January 6, 2021 that preceded the attack on the Capitol
● Heavily funded by groups in conservative legal activist Leonard Leo’s dark money network

Top Leadership

● Steve Marshall, Board Chair
● Lee Russell, Treasurer
● Pete Bisbee, Former Executive Director
● Samantha Dravis, Former President

Tax Status

501(c)(4)

EIN

46-5130903

Year Formed

2014

Location

Washington, DC

Total Revenue In Most Recent Tax Year

$3,065,892

Total Expenses In Most Recent Tax Year

$2,695,896

Total Assets In Most Recent Tax Year

$458,363
About Rule of Law Defense Fund

The Dark Money Fundraising Arm of the Republican Attorneys General Association is Connected to Efforts to Overturn the 2020 Election

The Rule of Law Defense Fund is the 501(c)(4) political and fundraising arm of the Republican Attorneys General Association. Together, the organizations help coordinate between GOP attorneys general and aid legal challenges to federal programs and protections. The Rule of Law Defense Fund and the Republican Attorneys General Association count the Leonard Leo-connected Concord Fund among their major funders.

  • RLDF and RAGA are heavily funded by groups in Leonard Leo’s network: the Concord Fund, a dark money operation formerly known as the Judicial Crisis Network led by Leo’s close associate Carrie Severino, has given RLDF nearly $1.6 million. The Concord Fund has also given at least $13.7 million to RAGA, donating $1 million to the group in 2022 alone. 
  • The organization has been a major supporter of efforts led by Republican attorneys general to chip away at climate policies: RLDF was founded during the Obama administration to support GOP attorneys general in their fight against the administration’s climate initiatives and the group’s leadership has included former EPA Administrator Scott Pruitt and other individuals who supported actions to undermine the EPA.
  • The power wielded by RLDF and RAGA through state attorneys general has massive implications for abortion rights following the overturning of Roe v. Wade: the two groups work with — and, in RAGA’s case, help elect — GOP attorneys general who will be “on the front lines of the abortion fight” as they choose how to enforce restrictive abortion laws at the state level.

Steve Marshall, Board Chair

Alabama Attorney General Steve Marshall began serving as chair of RLDF’s board in November 2020. Marshall had been serving as board chair for three months when RLDF sent robocalls on January 6, 2021, urging “patriots” to “call on Congress to stop the steal.” Marshall later claimed that the calls were sent without his knowledge. Marshall’s office refused to disclose his whereabouts during the week before and the week after Jan. 6 and denied reporters’ requests for his calendar records. 

Lee Russell, Treasurer

RLDF Treasurer Lee Russell has also served as The Republican Attorneys General Association’s (RAGA) chief financial officer since 2015, and she has worked in numerous other roles for the Republican Party since 2010. She previously served as director of operations for the Mississippi Republican Party, office manager of the Republican State Leadership Committee, and assistant to the chief counsel at the National Republican Senatorial Committee.

Pete Bisbee, Former Executive Director

Pete Bisbee was RLDF’s executive director until April 2021, when he was promoted to a leadership position at RAGA.

  • Bisbee previously served as director of state courts and director of membership at the Federalist Society.

Samantha Dravis, Former President

Samantha Dravis served as president of RLDF from 2015 to 2017. She also served as general counsel for RAGA and as an attorney at the Koch-funded organization Freedom Partners, which has advocated for eliminating environmental regulations relating to clean-water protections and greenhouse gas emissions.

RLDF is a dark money operation funding the Republican Attorneys General Association. RAGA is a 527 political organization that can receive unlimited contributions from wealthy individuals and corporations, which the group then spends to elect GOP state attorneys general. RLDF and RAGA work alongside Republican attorneys general to mount legal challenges aimed at undermining the 2020 election, environmental protections, and other policies of interest to conservatives and corporations.

In 2020, RLDF gave RAGA over $800,000 — the third largest donation that RAGA received that year. RLDF also regularly reimburses RAGA for work done by RAGA employees. 

RAGA has come under scrutiny as a “vehicle for corporate donors to gain the credibility and expertise of state attorneys general in fighting federal regulations.” 

  • With funding from fossil fuel interest groups like the American Petroleum Institute, ConocoPhillips, and Alpha Natural Resources, the group devotes considerable attention to defeating environmental initiatives.

Role In Organizing Jan. 6 Protest

RLDF came into the spotlight in 2021 for its key role in organizing the “March to Save America” protest that preceded the violent attack on the Capitol on January 6, 2021.

“War Games” Meetings With Attorneys General Around The 2020 Election

Between July 2020 and mid-January of 2021, RLDF and RAGA held at least thirty meetings for senior staff members of attorneys general to plan and execute a response if Donald Trump lost his re-election bid.

AP News reported that in the four months before the November 2020 election, RLDF held more than twenty meetings for senior aides to Republican state attorneys general. The group’s events included weekly calls for senior staffers and a “virtual roundtable” with corporate attorneys. 

  • Most notably, in September 2020, RLDF held a private two-day conference in Atlanta to discuss how the party would respond if Trump lost the election. RAGA’s executive director described the event as “war games” and said there would be a “series of conversations planning for what could come if we lose the White House.”
  • Over thirty attorneys general staff members were in attendance at the Atlanta event. Two of Kansas Attorney General Derek Schmidt’s senior staffers attended the event — all expenses paid for by RLDF — and Schmidt’s chief of staff registered for online sessions. Schmidt later joined a lawsuit with other state attorneys general aiming to overturn the results of the election.  

After Trump’s defeat, Republican AGs associated with RAGA and RLDF mounted baseless legal challenges to keep Trump in office.

  • Missouri Solicitor General John Sauer, who attended RLDF’s “war games” meetings, became the counsel of record on the amicus brief filed by the seventeen attorneys general. The lawsuit, which the Supreme Court quickly dismissed, was reportedly drafted by Trump’s legal team. 

Of the six of the attorneys general listed as board directors on RLDF’s 2020 tax filings, four signed on to a brief supporting Paxton’s lawsuit. 

  • RLDF board director Austin Knudsen had not yet assumed office as Attorney General of Montana when Paxton’s lawsuit was filed, but in November 2021, Knudsen’s staff reportedly met with MyPillow founder and election conspiracy theorist Mike Lindell. At the time, Lindell was trying to garner support from AGs to file a federal lawsuit challenging the election results.

Efforts To Undermine Environmental Regulations

RLDF was founded in 2014 to challenge the Obama administration’s efforts to tighten regulations on greenhouse gas emissions and water pollution. A RAGA spokesperson said in 2018 that, “from day one, RLDF has been consistently focused on regulatory overreach as well as promoting and defending the rule of law.” 

Two of RLDF’s former leaders went on to work at the Environmental Protection Agency under the Trump administration: former RLDF Board Chair Scott Pruitt was Trump’s pick for EPA administrator, and former RLDF President Samantha Dravis was appointed as the head of the EPA’s Office of Policy in 2017.

  • Pruitt served on the RLDF board from 2014 until December 2016, when President-elect Donald Trump announced his intention to nominate Pruitt as the administrator of the Environmental Protection Agency. Pruitt also served RLDF’s board chair from November 2015 until November 2016.
  • During his tenure as Oklahoma AG, Pruitt sued the EPA fourteen times in unsuccessful attempts to block the Obama administration’s climate agenda. According to the New York Times, “in all but one of these 14 cases, regulated industry players also were parties,” and the “companies or trade associations in 13 of these cases were also financial contributors to Mr. Pruitt’s political causes.”

RLDF staunchly opposed Obama’s Clean Power Plan, which aimed to reduce greenhouse gas emissions from fossil fuel companies. 

  • In August 2015, GOP attorneys general discussed their opposition to the Clean Power Plan with fossil fuel giants Murray Energy and Southern Company at a RAGA summit, which CMD described as an “opportunity to meet with GOP attorneys general in exchange for financial donations to help reelect the Republican state prosecutors.” Two weeks later, fifteen attorneys general filed a court petition to try to block the climate proposal. Then-Oklahoma Attorney General Scott Pruitt spoke at the event.

Republicans’ efforts to undermine the Clean Power Plan and chip away at other environmental protections carried into 2022. Provisions in Obama’s plan — which never went into effect — were brought before the Supreme Court in June 2022, when the court’s 6-3 conservative supermajority ruled to strip the EPA of its power to regulate power plants’ greenhouse gas emissions and, in turn, restrict the agency’s ability to combat climate change.

Opposition To Workers’ And Consumers’ Rights

In addition to fighting environmental regulations, RLDF has tried to undermine workers’ and consumers’ rights by:

Coordination With State Attorneys General

RLDF works to undermine federal programs and protections by “fostering communication” with conservative state attorneys general, wealthy donors, and corporations, which the group describes as “convening stakeholders around their interests.” 

RLDF’s 2020 tax filings show that its board of directors includes six state attorneys general: Alabama Attorney General Steve Marshall, Mississippi Attorney General Lynn Fitch, Montana Attorney General Austin Knudsen, Utah Attorney General Sean Reyes, South Carolina Attorney General Alan Wilson, and Kentucky Attorney General Daniel Cameron.

The Center for Media and Democracy released emails between then-President of RLDF Samantha Dravis and attorneys general staff in 2016, showing that RLDF helped compile officials’ signatures to oppose the numerous fraud investigations into ExxonMobil. 

  • Reports released in 2015 showed that ExxonMobil began conducting research into climate change and discovered that fossil fuels were a primary cause of global warming in the 1970s. 
  • Internal documents showed that a senior scientist at the company warned Exxon executives in 1977 about the potentially catastrophic effects of fossil fuels on the climate, but Exxon did not publicly admit that it knew of the link between carbon emissions and climate change until the mid-2000s.
  • In May 2016, RLDF drafted and encouraged Republican attorneys general to sign a letter to express their opposition to the investigations. The letter was riddled with disinformation about climate science and cast doubt on humans’ role in causing climate change. 

RLDF and RAGA have also coordinated meetings and events for attorneys general and lobbyists. For example, American Oversight released email records showing that officials from South Carolina Attorney General Alan Wilson’s office attended numerous RLDF board meetings and met with lobbyists at RAGA’s request in 2018 and 2019. 

  • Email records from 2021 show that Wilson, who was voted as chair of RAGA in May 2021, met with two lobbyists from UPS at RAGA’s request. The briefing for that call laid out UPS’ giving history to RLDF and RAGA, as well as the company’s public policy interests. Those interests included lawsuits filed against UPS for circumventing state tax laws and allegedly discriminating against an employee with a disability, and a proposed SEC rule that would require increased “climate change-related disclosures.” 

Paying For Attorneys General To Mingle With Donors At Lavish Events 

RLDF spends hundreds of thousands of dollars annually putting on luxury events and funding travel for Republican attorneys general and their staff. 

  • Tax filings show that RLDF spent over $614,000 in 2020 on “travel, workshops, roundtables, and seminars on federal and state policy matters,” which served to “facilitate further education of attorneys general staff and other stakeholders on policy and legal development in the states and in Washington, D.C.”

“Aggregating Support” For Trump’s Supreme Court Nominees

RLDF supported all three of Trump’s Supreme Court nominees and coordinated with Republican attorneys general to urge the Senate to confirm Brett Kavanaugh and Amy Coney Barrett. 

  • The night before Donald Trump nominated Amy Coney Barrett to fill the Supreme Court vacancy left by Justice Ruth Bader Ginsburg’s death, RLDF Executive Director Adam Piper sent an email to staff saying, “we have video compilations ready for tomorrow’s announcement and will aggregate statements from AGs as well.” Piper also said that “when Justice Kavanaugh was nominated, twenty-six Republican AGs signed a letter,” and he expressed his hope to “replicate such a feat.”
  • Following Justice Antonin Scalia’s death in February 2016, the organization held a “senior staff retreat” called “Supreme Court Review: The Legacy of Justice Antonin Scalia, Implications of the Court Vacancy and What to Expect.”

Coordination With The Trump Administration

In 2018, MapLight obtained emails showing that RLDF formed a “working group” in partnership with the Trump administration. The “invitation only” group was formed to “work with the administration on the promotion, protection, and preservation of the rule of law.” Email records show that Trump White House Counsel Mike McGinley attended at least one of the “working group calls” in September 2017.

American Principles Project

RLDF’s robocall and its website were promoted in a text sent by the American Principles Project, a far-right group that fiercely opposes LGBTQ rights, abortion access, and anti-racism curriculum in schools. APP’s text called on Trump supporters to join the president and Texas Attorney General Ken Paxton, who spoke at the rally, in D.C. to “fight for the integrity of our elections!” 

Freedom Partners

RLDF’s former president Samantha Dravis also served as an attorney at the Koch-funded organization Freedom Partners. 

Federalist Society

RLDF’s former executive director Pete Bisbee served as the Federalist Society’s director of state courts and director of membership. RLDF has also received significant funding from the Concord Fund, a group associated with longtime Federalist Society vice president Leonard Leo.

RLDF has relied on funding from dark money groups since its inception. According to MapLight, “at least 40 percent of RLDF’s funding in 2014-15 came from dark money organizations like the Judicial Crisis Network, the Rule of Law Project and Freedom Partners.” Freedom Partners, a dark money operation backed by the Koch family, has given RLDF at least $175,000

RLDF has also received at least $50,000 from the Edison Electric Institute, the trade association for electric utility companies.

Funding From Leonard Leo’s Network

Groups tied to conservative activist Leonard Leo’s network have donated huge sums to RLDF since its founding.

RLDF has reportedly received nearly $1.6 million from the Concord Fund, a dark money operation formerly known as the Judicial Crisis Network led by Leo’s close associate Carrie Severino. The Concord Fund has given millions more to RAGA, donating $1 million to the group in 2022 alone. 

  • The Concord Fund is the public face of Leonard Leo’s nonprofit network and supports his efforts to transform the courts, having spent nearly $40 million to help confirm Donald Trump’s Supreme Court nominees. The group also played a significant role in helping George W. Bush’s nominees get confirmed and opposing Barack Obama’s nominees.
  • Leo has used the Concord Fund’s immense war chest to bombard the airwaves to influence public opinion and pressure senators and presidential administrations who select individuals for the federal judiciary. The organization’s campaigns have been criticized by opponents of dark money who see the group as a vehicle for conservative donors to influence the courts without accountability. 

In 2014, RLDF received $145,000 from a nonprofit called the Rule of Law Project, which Leo was a director of at the time

Funding For Jan. 6 Protest

  • The Washington Post reported that Julie Jenkins Fancelli, daughter of the founder of the Publix grocery store chain, gave RLDF roughly $150,000 on December 29, 2020. RLDF’s robocall instructing Trump supporters to gather in D.C. and march on the Capitol was reportedly purchased “in order to satisfy the conditions” of Fancelli’s donation.
  • On the same day, Fancelli gave $300,000 to Women for America First, the “Stop the Steal” group that obtained a permit for the Jan. 6th rally.

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