Spencer M.

Ritchie
Spencer.Ritchie@formanwatkins.com
Direct Dial: 601-960-3172
March 2, 2023

VIA ELECTRONIC MAIL

Hon. Michael Watson
Mississippi Secretary of State
125 S. Congress Street
Jackson, MS 39201
c/o Kyle Kirkpatrick
Assistant Secretary of State
Elections Division
Kyle.Kirkpatrick@sos.ms.gov

Dear Secretary Watson:

I represent the Delbert Hosemann Campaign. As you may know, Mr. Hosemann
recently qualified to run for re-election as the Republican nominee for Lieutenant Governor
of Mississippi. State Senator Chris McDaniel also qualified for the Republican primary
election for Lieutenant Governor.

A Mississippi political action committee (PAC) entitled Hold The Line recently
reported on its 2022 annual campaign finance report that on August 23, 2022, it received a
contribution in the amount of $237,500 from a corporation entitled the American
Exceptionalism Institute. See Exhibit A (copy of the report filed on January 31, 2023). Chris
McDaniel is the contact person and director of the Hold The Line PAC. See Exhibit B (copy of
Hold the Line’s statement of organization); see also Miss. Att’y General Op. No. 94-0546, 1994
WL 732921 (Miss. A.G. Dec. 1, 1994) (“A candidate or political committee may not lawfully
conceal contributions . . . by forming a separate account and diverting some or all of those
political contributions to the separate account.”).

Mr. McDaniel reported that in January of this year he received a total of $465,000
from the Hold The Line PAC. See Exhibit C (copy of Mr. McDaniel’s campaign finance report
filed on January 31, 2023).

As you are aware, Mississippi law prohibits corporations from contributing more
than $1,000 per calendar year, directly or indirectly, to a candidate for office or PAC. Miss.
Code Ann. § 97-13-15. Given that corporate contributions are limited in Mississippi to
$1,000, the Hold The Line PAC and Mr. McDaniel received directly and indirectly $236,500
in illegal campaign contributions from a corporation. See Miss. Att’y General Op. 1979 WL
40628 (Miss. A.G. Feb. 8, 1979) (“[T]he funds held by a political action committee continue
to possess their corporate status and any collected funds would be disbursed to a candidate
as an indirect corporate contribution and thus must conform to the required limitation of
One Thousand Dollars ($1,000.00) either directly or indirectly”).
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Additionally, on its original 2022 annual report, the Hold The Line PAC reported a
cash on hand balance at the end of 2021 of $473,962.38. See Exhibit A. On February 3, 2023,
the PAC filed an amended annual report showing $236,981.19 as its cash on hand balance at
the end of 2021. See Exhibit D. Regardless of which dollar amount is correct, if either, the PAC
never reported the source(s) of those funds. In fact, the PAC did not make its first filing, i.e.,
its statement of organization, until June 10, 2022. See Exhibit B.
As you are aware, as soon as a PAC receives in excess of $200 in the aggregate during
a calendar year, Mississippi law requires that the PAC must file a statement of organization
within forty-eight hours of receiving that amount and must begin filing periodic campaign
finance reports in accordance with the applicable reporting schedule. Miss. Code Ann. §§ 23-
15-803 et seq.

We respectfully request that your office promptly investigate these clear violations of
Mississippi law and ensure compliance with State law. We further request that this
investigation receive expedited attention because it relates to an upcoming election and out
of interests for a fully informed electorate. Finally, as other state agencies may be involved
in this review, we are copying them with this correspondence and make the same request.
Please do not hesitate to contact me if you have any questions or need additional
information.
Sincerely,
Forman Watkins & Krutz LLP

__________________________________
Spencer M. Ritchie

Cc: Hon. Lynn Fitch

Mississippi Attorney General
550 High Street
Jackson MS 39201
c/o Michelle Williams
Chief of Staff
Michelle.Williams@ago.ms.gov

Tom Hood
Executive Director
Mississippi Ethics Commission
660 North St, Ste 100-C
Jackson, MS 39202
THood@ethics.state.ms.us
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