Complaint alleges Josh Hawley received illegal almost $1 million contribution from NRA

A complaint filed Monday with the Federal Election Commission (FEC) alleges the campaigns of Republican Senate candidate Josh Hawley and the National Rifle Association PAC are coordinating illegally, which allowed the NRA to make an illegal in-kind contribution to Hawley of nearly $1 million.

Political action committees are allowed to spend unlimited amounts of money to support or oppose a candidate as long as they do not coordinate with the candidate's campaign.

The complaint, filed by the nonpartisan Campaign Legal Center and Giffords, a gun control group founded by former Sen. Gabby Giffords,  alleges the Hawley campaign and the NRA PAC both employed companies to produce ads for the campaign and for the PAC supporting Hawley with the ads being released on the same day.



There would be nothing wrong with that, except the ads were released by the same person, working for both companies.

The allegations are spelled out in the complaint,:

The NRA-PVF is the National Rifle Association of America’s lobbyist/registrant PAC.3 8. Josh Hawley is a candidate for U.S. Senate in Missouri. Josh Hawley for Senate is his authorized campaign committee. Bradley “Brad” Todd—a partner at the consulting firms OnMessage and Starboard Strategic is Hawley’s campaign consultant.

On October 9, 2018, The Trace reported that the NRA-PVF had been routing its independent expenditures supporting Hawley through Starboard, while Josh Hawley for Senate had been contracting with OnMessage.

OnMessage is a political consulting firm that has performed contracting work for dozens of campaigns and political committees. The Washington Post recently called OnMessage “a powerhouse GOP consulting firm." 

OnMessage was registered in Virginia on April 13, 2005, and was incorporated in Maryland on April 20, 2006. Its website provides detailed information about its staff, past clients, and portfolio of work. In the 2010 election cycle, the NRA-PVF reported paying OnMessage over $4.5 million, primarily for television and radio ad production, including approximately $3.2 million for federal independent expenditures, according to reports filed with the Commission.

In the 2012 election cycle, the NRA-PVF reported paying OnMessage $7.7 million for independent expenditures and $42,866 in other disbursements. All of the independent expenditure payments were for “Advertising Expenses,” and the other disbursements were also for television and radio advertising expenses. 

Also in the 2012 election cycle, the NRA-ILA—a tax-exempt organization under Section 501(c)(4) of the Internal Revenue Code that describes itself as “the lobbying arm of the NRA,” and which reports independent expenditures to the Commission under ID C9001330117—reported paying OnMessage over $3.5 million for independent expenditures described as “Advertising Expenses.” 




On March 22, 2013, Starboard was incorporated in Virginia by OnMessage officials. The incorporation certificate lists five directors: Brad Todd, Curtis Anderson, Wesley Anderson, Graham Shafer, and Timothy Teepell. At the time, three of those directors—Anderson, Anderson, and Todd—were also directors at OnMessage.

By the following year, 2014, Shafer and Teepell had been added to OnMessage’s board, as was Orrin “Guy” Harrison. Harrison, in turn, was added to Starboard’s board the year after, in 2015. Both Starboard’s and OnMessage’s boards still consist of these same six directors (Anderson, Anderson, Todd, Shafer, Teepell, and Harrison).

Starboard’s registered agent, Craig M. Palik, is also the registered agent for OnMessage Holdings, Inc. According to a recent POLITICO article, “[i]nternal emails indicate executives toggled between roles” at both Starboard and OnMessage, and that “none of Starboard’s partners has publicly affiliated himself with the company; four of them have LinkedIn pages, for instance, and their profiles only mention OnMessage.”

In the 2014 election cycle, the NRA-PVF and the NRA-ILA paid Starboard approximately $20.5 million combined: the NRA-PVF paid Starboard $12.54 million for independent expenditures, and $1.38 million in other disbursements, and the NRA-ILA paid Starboard $6.6 million for independent expenditures.

Neither the NRA-PVF nor NRA-ILA reported any payments to OnMessage during the 2014 cycle. The NRA-PVF reported paying Starboard for expenses related to television, radio, and digital advertising in the 2014 cycle. The address reported for each Starboard disbursement was 705 Melvin Avenue #105 in Annapolis, Maryland, the same address and suite number as OnMessage’s Maryland office.

The NRA-ILA also reported paying Starboard for “Advertising Expenses” in the 2014 cycle. The address reported for each Starboard disbursement was 817 Slaters Lane in Alexandria, Virginia, the same address as OnMessage’s Virginia office. The NRA’s 2014 “focus” included “three major Senate races,” and was aimed at “boosting Republican Senate challengers in Arkansas, Colorado and North Carolina,” according to published reports. Reports filed with the Commission show that the NRA-PVF supported candidates in these U.S. Senate races—Tom Cotton, Cory Gardner, and Thom Tillis—with independent expenditures contracted through Starboard. The NRA-ILA also supported two of these candidates—Gardner and Tillis—with independent expenditures contracted through Starboard. At or around the same time, these same three candidates were contracting with OnMessage for advertising and media consulting.

THE The complaint details how the same methods were used to support those candidates that was allegedly used to support the Josh Hawley campaign and that Starboard did not work for any companies other than the ones that were being supported by the NRA.

Politico articles are quoted that indicate there was nothing to suggest that Starboard really exists (as a separate entity) other than some thumb drives with Starboard material.

So far in the 2018 election cycle—specifically, on October 5, 2018 and October 19, 2018— the NRA-PVF has reported $973,411 in payments to Starboard for independent expenditures either supporting Hawley or opposing Claire McCaskill. The NRA-PVF reported paying Starboard at the address 705 Melvin Ave., #105, Annapolis, Maryland, 21401, the same address and suite number as OnMessage’s Maryland office.

Also on October 5, 2018, the date of the NRA-PVF’s first report of independent expenditures to Starboard in the 2018 Missouri U.S. Senate race, the NRA’s lobbying arm, the NRA-ILA, issued a press release announcing the start of a seven-figure ad campaign in the Missouri U.S. Senate race by the NRA-PVF.

The press release included a quote from Cox, who said, “If you value your constitutional right to self-defense, vote Josh Hawley for U.S. Senate,” and a link to the ad itself. As of September 30, 2018, the close of books for the 2018 October quarterly report, Josh Hawley for Senate had reported paying $2.2 million to OnMessage for purposes including “media production,” “web ads,” “political strategy consulting/travel,” and “survey research,”100 at the address 705 Melvin Ave., #105, Annapolis, Maryland, 21401.

Additionally, as of September 30, 2018, Josh Hawley for Senate reported paying $98,967 to an entity called “First Tuesday” for “Communications Consulting,” “Communications Consulting/Travel,” or “Travel,” at the same address as OnMessage, 705 Melvin Ave.Annapolis, Maryland, 21404.

Maryland corporate records do not show any results for registered corporations under the name “First Tuesday,” but Virginia State Corporation Commission records show that an entity called “First Tuesday: The Ballot Initiative Group” is located at 817 Slaters Lane, Alexandria Virginia, the same address as OnMessage’s Virginia office. Its articles of incorporation, dated August 2, 2016, listed the following individuals as directors: Bradley A Todd, Gail Gitcho, Wesley Anderson, Curtis Anderson, and Graham Shafer.

The ads were placed through a company called Red Eagle Media, which has no website,but not surprisingly, has the same address as the other entities.

The complaint alleges the NRA, by coordinating its advertising with the Hawley campaign, is making an in-kind contribution that far exceeds the $2,700 federal limit, appearing to be at least $973,411.