Today, new reporting from the New York Times revealed RFK Jr.’s campaign may have illegally coordinated with an allied Super PAC to submit signatures for ballot access in Arizona after volunteer efforts fell short and campaign funds ran dry. This follows an FEC complaint from the DNC and additional complaints from an allied organization for violating disclosure laws. 

In response, DNC Legal Counsel and Former FEC Chairman Robert Lenhard said: 

“This latest report on RFK Jr.’s signature gathering in Arizona raises serious legal questions. It appears that after the Kennedy campaign was unable to collect the required number of signatures for ballot access themselves, they simply submitted signatures collected earlier by a pro-Kennedy Super PAC – an action that amounts to a large and illegal in-kind contribution. The Times story describes facts that would amount to a knowing and willful violation of campaign finance law, and open his campaign up not only to enhanced FEC penalties, but also criminal prosecution. If true, this would be truly reckless behavior.” 

ICYMI: New York Times: A Desperate Kennedy Campaign, and the Mystery of 110,000 Signatures

By: Rebecca Davis O’Brien

• On Friday, a longtime friend of Robert F. Kennedy Jr., the independent candidate for president, delivered boxes carrying 110,000 signatures to election officials in Arizona, to secure ballot access in a critical battleground state.
• A vast majority of those signatures, according to two people closely involved with the campaign’s operations, were not gathered by local volunteers, or even by paid canvassers working for the campaign. Instead, the people said, they came from a super PAC backing Mr. Kennedy that gathered signatures in Arizona months ago but set them aside after their efforts prompted legal challenges.
• The issue of who collected the signatures is critical because coordination between super PACs and campaign committees is banned under federal law, though that rule — meant to limit the influence of megadonors on campaigns — has steadily eroded in recent years, as regulators have allowed exceptions and political groups have found workarounds. Among other prohibitions, super PACs are not allowed to give “in-kind” contributions to a campaign — basically, providing services free of charge.
• Top officials on the Kennedy campaign had discussed as recently as early August how they could use the signatures gathered by the super PAC, American Values 2024, to apply for ballot access in Arizona, according to the two people, who were granted anonymity to describe what they regarded as a potentially illegal arrangement.
• The campaign’s situation was dire: Volunteers in Arizona had been able to collect no more than 9,000 signatures, far short of the more than 42,000 valid signatures needed, according to the two people and a third person who has been briefed on the volunteers’ efforts. At the same time, the campaign was running short on cash that would be required to hire a canvassing company to gather more signatures — at the end of July, according to a campaign finance report filed on Monday, the campaign had $3.9 million on hand, and owed $3.5 million.
• Representatives for American Values 2024 did not respond to detailed requests for comment. 
• But Arizona has been a looming problem for months, according to several people involved in or briefed on internal campaign discussions […] 
• Volunteers were summoned, and the campaign also discussed paying a ballot-access firm to gather new signatures. But some in the campaign’s leadership were hesitant to spend money duplicating the PAC’s work, according to the two people involved in the campaign’s internal deliberations.
• As the volunteer effort appeared to be coming up short, in recent weeks campaign leadership discussed trying to buy a portion of the signatures from the super PAC, at a cost of about $700,000, the people said.
• Another plan discussed by senior campaign leaders was to have the super PAC’s signatures delivered, without payment or explanation, to Mr. Rink, they said. 
• On Friday, local news media in Arizona published a photograph of Mr. Rink wheeling the signatures into the secretary of state’s office in Phoenix. The next day, the campaign announced that “Kennedy supporters” — not “the campaign,” as most of their press notifications are worded — had submitted the signatures, and quoted Mr. Rink as an Arizona elector for Mr. Kennedy.