A nonprofit government watchdog organization filed a complaint with the Federal Election Commission last week against a brand new Wyoming-based limited liability company that made a $50,000 donation to a super PAC working to unseat Rep. Liz Cheney. 

The complaint alleges that Snow Goose LLC’s donation to a pro-Harriet Hageman super PAC, Wyoming Values, is in violation of the “straw donor” rule, which prohibits companies and individuals from giving someone else money to make a political donation on their behalf. 

LLCs are legally allowed to donate to super PACs even if the true recipient of the cash is unknown, but Campaign Legal Center argues that because Snow Goose is so new and has little financial activity outside of this donation, it is in violation of the straw donor ban. 

In other words, it argues that the LLC was created for the sole purpose of a political donation to Wyoming Values. 

“Basically [Snow Goose] has no activity, no commercial enterprise that would generate any income and no assets,” said Saurav Ghosh, director of federal reform at Campaign Legal Center. “Within 10 weeks of being organized it’s making a $50,000 contribution. This says to us that they didn’t have the means to make a $50,0000 contribution until someone donated to it. And that’s pretty much a textbook straw donor scheme.” 

This complaint is another inflection point in the ongoing conversation about political donations from unknown but legal sources — referred to as “dark money” — in Wyoming and national politics. 

While Campaign Legal Center argues that it expressly violates the straw donor ban, others aren’t as convinced.

“I’m not certain [the expenditure] was illegal. I think what happened might be legal,” said Ken Chestek, a law professor at the University of Wyoming and the chair of Wyoming Promise, a cross-partisan group working to reduce the political influence of big money. “If it was legal, it should not be.” 

Michael Beckel, the research director for Issue One, a nonpartisan nonprofit organization that aims to increase public awareness of the campaign finance system, called it a “violation of the spirit of the law.” 

But the FEC has an inconsistent history of going after shadowy LLCs. 

“We try to file complaints in any situation where we see straw donor schemes,” Ghosh said. “Whether the FEC moves forward or not isn’t really the measure if we file or not.” 

Super PACs are prohibited from donating money or communicating directly with political candidates, and the complaint is not against Wyoming Values, but Snow Goose itself. 

Snow Goose was formed in December of 2021 and made a donation only a few weeks later, in February of this year. 

The party listed on the LLC’s filing is a Jackson-based corporate lawyer, Matthew Kim-Miller, who often helps clients set up entities. 

Kim-Miller did not respond to the Star-Tribune’s request for comment. 

Snow Goose also lists a “virtual office address” in Casper, meaning it does not have a physical location. 

Super PACs are defined in the fact that they can receive huge donations  — unlike campaign committees where donations have caps in the low thousands. 

Along with raising major sums of money, super PACs stand out in another way — through them, it’s easy to conceal who and where the money is coming from. 

The single Snow Goose donation isn’t a monumental donation when looking at the full picture. 

As of March 31, the end of the first fundraising quarter of 2022, Wyoming Values had raised just over $700,000 and had roughly $590,000 left in the bank. 

That said, $50,000 is in a three-way tie for the third largest donation to the super PAC so far. 

“In the grand scheme of super PAC spending hundreds of thousands, $50,000 in and of itself might not sound like a lot, but I think this is a practice that is unfortunately very common,” Ghosh said. 

Even if the donation isn’t the biggest of the bunch, Ghosh and others say that dark money donations “undermine voters’ ability to meaningfully participate in our election system.” 

“It dilutes the voice of ordinary people. It makes individual donors essentially powerless,” Chestek said. “These big donors can shout down the rest of us and we don’t even know who’s talking and that’s very dangerous for democracy.” 

Super PACS are an important — but new — part of the dark money and big donor conversations in Wyoming politics; they appear to not have existed in the Cowboy State until the 2022 House race. 

“This complaint from Liz Cheney’s liberal friends at CLC doesn’t even allege any wrongdoing by our PAC. Wyoming Values has always fully complied with the law and will continue to do so,” said James Blair, Strategist for Wyoming Values. 

When PACs and committees receive donations, there are a few boxes donors need to check, like age and citizenship. But when it comes to LLCs and Super PACs, things get murkier. 

“There’s nothing to verify,” said Paul Kilgore, treasurer for Wyoming Values. “Super PACs can accept LLC money.” 

After Cheney voted to impeach Trump and continually criticized him, the former president sought a challenger and ended up selecting Hageman who entered the race on Sept. 9, 2021 with Trump’s endorsement in tow. 

Since then, national interest groups have flocked to Wyoming in all sides of the race. 

In many respects, Wyoming’s 2022 House race is one of the most important in the nation as it’s being viewed as the ultimate referendum on Trump and his grip on the Republican Party.