An examination by CREW of campaign finance and tax filings suggests that a $1 million contribution made by former President Donald Trump’s political action committee in 2021 may have ended up supporting an effort to audit the 2020 election in Georgia. The trail of contributions that appears to stem from Trump’s PAC resembles the path that another $1 million was recently revealed to have taken from the PAC to a discredited audit in Arizona. 

Last month, The Guardian and the investigative watchdog group Documented reported that Trump’s political operation secretly backed the flawed partisan audit of the 2020 presidential election in Arizona’s Maricopa County by funneling $1 million from Trump’s PAC through a nonprofit run by his allies. Leveraging emails and text messages made public by American Oversight, Documented traced the money from Save America through the Conservative Partnership Institute to an entity called the American Voting Rights Foundation that ultimately gave $1 million to contractors working on the Arizona audit. 

Though similar internal messages are not available to precisely tie together all the connections, the curious line of identically-sized contributions disclosed in FEC reports and tax filings paints a plausible picture of a path for lawyers working in Georgia to have received similar funds from Trump’s PAC. 

On June 15, 2021, a little over a month before its Conservative Partnership Institute donation, Trump’s Save America committee contributed $1 million to America First Policy Institute, a nonprofit think tank that has been described as “the largest pro-Trump operation launched after his presidency.” The contribution was the single largest expenditure that Save America made in the first half of 2021.  

save america contribution

Save America’s contribution to America First Policy Institute attracted attention from the press as well as the House select committee that investigated Trump’s efforts to overturn the 2020 election, which noted in an appendix to its final report that the nonprofit is “home to several former Trump officials and witnesses subpoenaed to testify before the Committee.” But little to nothing has been reported about why Save America made the contribution or how the think tank used the funds. 

America First Policy Institute’s 2021 tax return may contain a clue. According to the return, in its first year of existence, America First Policy Institute raised nearly $15 million and spent close to $11 million. One of the largest line items in its expenditures was $1 million – the exact amount the group received from Save America – that America First Policy Institute provided to Citizens United Foundation as a grant. 

America First Policy Institute’s 2021 tax return

On its own 2021 tax return, Citizens United Foundation also reported making a $1 million grant, but it didn’t go to a nonprofit group. Instead, Citizens United Foundation gave $1 million to the Georgia-based Cheeley Law Group, LLC for “election integrity litigation.” Citizens United Foundation also reported giving $300,000 to Conservative Partnership Institute for “election integrity programs.”  

Citizens United Foundation 2021 tax return

The Cheeley Law Group describes itself as a “personal injury law firm,” but in 2021 its managing partner, Bob Cheeley, represented clients seeking to examine absentee ballots in Georgia’s Fulton County in search of fraud in the 2020 election. If Save America’s mid-June 2021 contribution to America First Policy Institute did ultimately flow into the Georgia audit push, which has previously been described as being funded exclusively by small donors, it could have come during a pivotal period for the Fulton County effort. 

In late May 2021, the judge in the case ruled in favor of the plaintiffs, opening the door for them to hire a firm to conduct a ballot review. But the review was soon put on hold when the Fulton County elections board challenged the lawsuit. Cheeley argued for the plaintiffs in a June 21, 2021 hearing on the board’s request to dismiss the case. Despite asserting that the lawsuit was not actually about contesting the 2020 election, Cheeley told the judge there were “unlawful acts at Fulton County on the night of the election.” Ultimately, however, Superior Court Judge Brian Amero dismissed the case in October 2021, finding that the plaintiffs lacked the standing to sue. 

Cheeley has subsequently popped up in other episodes related to challenges to the 2020 election. In December 2021, Cheeley represented former Sen. David Perdue (R-GA) in an effort to inspect Fulton County absentee ballots that the Atlanta Journal Constitution said echoed the prior Fulton County case. A judge dismissed Perdue’s lawsuit in May 2022. Cheeley has also appeared as a lawyer representing Cathy Latham, who CNN described as “a former GOP chairwoman of Coffee County who is under criminal investigation for posing as a fake elector in 2020.”

It’s certainly possible that Save America’s $1 million contribution to America First Policy Institute supported other activities, such as Trump’s July 2021 lawsuit against social media companies. In his announcement of the lawsuit, which quickly served as a fundraising tool for both his PAC and America First Policy Institute, Trump claimed he was working “in conjunction” with the think tank. 

But the outlines of a money trail from Save America to America First Policy Institute and beyond fit the model of how money now clearly appears to have flowed from the PAC through the Conservative Partnership Institute to the Arizona audit. Trump’s representatives have previously denied that funds from his political committees went to audit efforts in Arizona or Georgia. As The Guardian made a point of noting, Trump “officials” had earlier denied that the former president had contributed to the Arizona effort too. 

Read More in Investigations