Update September 29: The mailing that Regan received is from 2016, but it's not from ABM's federal PAC. Rather, it's from the Alliance for a Better Minnesota Action Fund, a state political fund. Here's the side of the card that includes the disclaimer as is required by state law:
It's not the text that Regan described in her letter and it's not from the federal fund. We've pointed out to Regan and in this post that it's a common practice of ideological non-profits like the Alliance for A Better Minnesota (on the left) and the Freedom Club (on the right) to establish legally separate political funds. Both organizations maintain legally separate state and federal PACs in accordance with Minnesota statutes. The Minnesota Jobs Coalition, also a non-profit, works only on the state level, and so its legislative fund PAC is registered only with the Minnesota campaign finance board.
It's worth noting that the new postcard isn't a negative attack on Representative Miller (an earlier letter writer claimed ABM had sent negative mail pieces about Miller beginning in 2014 through the present) but a positive independent expenditure urging voters to cast a ballot for Falk.
It's worth noting that Regan originally sent us only the address side of the postcard (we've obscured her address but left her name on it):
By originally sending only this side, Regan thought to bolster her published claim that the federal PAC--a legally separate fund--sent her the piece about Falk since the return addresses are the same and that all entities using that address are "one and the same."
But using the same mailing address is also an accepted and legal practice for separate political action funds. Witness the shared address for the Coalition of Minnesota Businesses' state PAC (Coalition of MN Businesses PAC ), its independent expenditure political fund (Coalition of Minnesota Businesses IEPC ), the Minn Business Partnership PAC and the Northstar Leadership Fund.
As for that national network to which ABM belongs, this too is not unusual. The Coalition of Minnesota Businesses appears to be part of the BIPAC national network that was established in 2001. (The CMB--not its legally separate PAC or legally separate IEPC--is sending "issue advocacy" postcards in MN17A) If Regan dislikes networking and organizations with PACs and IE funds, she can find plenty of targets. The other letter writer saw them as part of free speech, but claimed ABM had sent out "hate mailings" against Tim Miller.
Bluestem's household received its issue of the Clara City Herald in the mail today, and as with last week's edition, the letters-to-the-editor in the Opinions section did not disappoint.
We dealt with an early letter bashing the alleged handiwork of the Alliance for a Greater Minnesota in our post, Miller pal thinks imaginary ABM "hate mailings" as bad as real tracker pushing volunteers.
DeGraff resident Cindy Regan also has a bug up her bonnet about the Democratic front group, and like the earlier letter writer Mike Thein, her memory of the political mail she's received doesn't match campaign finance reports of spending. [See our update above; the 2016 mail piece doesn't match her description and was not sent by the federal PAC].
Nor does she have a grasp of how independent expenditures work. Regan writes in part:
Andrew Falk's campaign seems to center around telling us about Tim Miller's so called supporters such as the Jobs Coalition, Reynolds America, Blue Cross Blue Shield, Koch Industries, Las Vegas Sands, Exon [sic] Mobil, and Northern Oil and Gas. As of yet there hasn't been a single mailing from any of these organizations on Tim Miller's behalf.
We don't know if Regan deliberately gives a shortened, incorrect name for the MN Jobs Coalition, whose political fund received contributions directly or indirectly from the corporations she names. But she does misrepresent what Falk wrote.
Regan continues in her letter in the September 14 Herald (no online edition):
. . . However, I have received political mailings from Alliance for a Better Minnesota Federal PAC with Falk's picture and the words, "Andrew Falk Agrees!" . . .
[See our update above; the 2016 mail piece she provided doesn't match her description and was not sent by the federal PAC].
Had such a mail piece ever been sent by a federal PAC on behalf of a state candidate, former Minnesota Campaign Finance and Public Disclosure Board executive director Gary Goldsmith and his staff would be very cross indeed.That federal race spending needs to be spent on federal races--and indeed it was. We found no evidence of independent expenditure cash on mailings in the Minnesota House District 17A race.
Just like the Freedom Club, a conservative group which has both a state PAC and a federal PAC, ABM maintains federal and state PACs. Looking at the reports filed with the Federal Election Commission by ABM's federal PAC for 2014, 2015 and 2016, we learned that the committee didn't sending any mailings.
The only independent expenditures by ABM's Federal PAC were related to online ads against Republican United States Senate candidates from Minnesota: Mike McFadden and a couple of also-rans.
Even if Regan is mis-remembering the copy from an online ad as a mail piece, we're at a loss to figure out why the online ads would include Falk's photo and the copy "Andrew Falk Agrees!" since we're not sure about what, if anything, Falk and Mike McFadden would agree.
Perhaps it was some other group. [Update: it was sent by the state PAC, a legally separate entity]
Regan did discover another group that shares an office suite with ABM, America Votes, though its state-level PAC (the America Votes Action Fund - Minnesota) doesn't seem to have sent any mail at all in 2014, according to filings online at the campaign finance board. [Update: This state-level PAC has a $475.38 cash on hand balance and reports no activity].
An earlier PAC kept by America Votes, American Votes-Minnesota, was terminated in 2014.
Since the America Votes-Minnesota shares an office suite with ABM, Regan believes that these organizations are THE SAME! She continues:
I decided to do a little digging into this PAC [Alliance for a Better Minnesota Federal PAC], and they actually share the same address in St. Paul with an organization called America Votes. In my opinion, they are one and the same.
Regan then lists the national partners of America Votes, all found on the national group's website Our Partners.
Whatever the case, neither the ABM Federal PAC nor the America Votes Action Fund--Minnesota, sent any mail out in 2014 or since, to any state or federal race in Minnesota, much less House District 17A. It's puzzling that two Letters To The Editor attempt to pin their tales on these donkey allies without producing a copy of any mail piece or campaign finance report to support their claims.
One might even think they're trying to obscure the fact that the main thrust of the Falk letter that we discussed in MN Jobs Coalition tracker Kip Charles Christianson jostled parade volunteers at Raymond Harvest Fest Parade was about rude (and paid) behavior toward volunteers in a small-town parade.
Was there a mail piece with Falk's picture and copy about agreement? We don't have it in our collection of 2014 political junkmail, but someone might have sent it.
Just not ABM or America Votes.
Regan does switch over later in the letter to discuss votes that Falk took on abortion, child custody and daycare regulation. While the list appears to be drawn from a 2011-2012 cycle voting checklist (she doesn't mention which group put the key votes together nor chose the wording). While we don't share Regan's positions, Bluestem thinks this issues-based approach is much more grounded and legitimate than her forays about mis-remembered sources of the junkmail she may or may not have gotten.
For a fact-based discussion of spending, "negative campaign messages and a loud drum beat paid for largely by money from political action committees outside the district" and voter turnout in Minnesota House District 17A in 2014, we recommend Tom Cherveny's Andrew Falk in the aftermath of defeat, in the West Central Tribune.
Photo: Negative campaigning at its most simple.
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