The Ohio Elections Commission determined a political action committee and a limited liability company — both run by Republican political consultant Regina McManus — violated state campaign finance laws and will refer the matter to the Trumbull County Prosecutor’s Office to decide on any criminal charges.

“It’s up to the prosecutor’s office to decide whether to pursue it based on what we will send,” said Philip Richter, the commission’s executive director.

The case was heard Oct. 30 by the commission with its recommendations going to the Trumbull prosecutor either late this week or early next week, Richter said.

After an initial 3-3 vote on taking action against McManus, the TCR Grassroots PAC and the Trumbull County Presidential Cigar Club, a second vote resulted in a 6-0 decision by the commission that determines she and the two groups violated election law by failing to file campaign finance reports with the Trumbull County Board of Elections, Richter said.

The Federal Election Commission investigated the same claims against McManus and the PAC, voting April 9 to dismiss the matter, effective May 12, according to a May 15 letter sent by Aaron Rabinowitz, the FEC’s assistant general counsel.

The complaints were filed in early 2024 with the FEC, OEC and Ohio Secretary of State’s Office by the Trumbull County Republican Party and by the county board of elections.

Marleah Campbell, the GOP’s secretary who also sits on the board of elections, is listed in the OEC complaint as the lead plaintiff with McManus as the lead defendant.

McManus said: “The individuals who filed this complaint have no merit and only seek to stifle the progress we’ve made in electing Republican candidates to office.”

She added: “These accusations are nothing more than a desperate attempt to execute a personal vendetta against me. I am not interested in playing such trivial games. We’ve got real work to do in electing Republicans on all levels of the ballot.”

Campbell said, “I’m looking for fair elections. Whatever the fine or consequences of her actions, I’d like to see this stop. I’d like to see a strong message that this can’t go on. She improperly spent money and there’s no accounting for the money.”

A May 7, 2024, letter from the elections board read: “While we are not an investigative agency, after review of the complaints received, a review of documents and our own cursory research, we have determined that there appears to be possible improprieties involving persons / PAC and an LLC operating as a PCE (political contributing entity) that may have been attempting to influence elections (federal, state and local), while at the time, operating as an unregistered PAC and other entities. Further, documentation shows several possible campaign finance violations and lack of reporting.”

FINANCE REPORTS

The board complaint states that between Feb. 20 and March 12, 2024, the PAC mailed 1,140 slate cards to absentee voters, worth at least $1,000 in postage costs, and the PAC wasn’t registered with any entity for virtually that entire time.

A statement of organization, signed by McManus, on March 11, 2024, and filed with the FEC, lists her as the PAC’s treasurer, designated agent and custodian of records.

The PAC filed a statement of organization with the Ohio secretary of state on March 29, 2024, and filed a finance report with the secretary on April 15, 2024, showing it raised and spent no money. It hasn’t filed another finance report with the secretary of state.

A 2024 first quarter report that was supposed to be filed by the PAC by April 15, 2024, with the FEC was submitted June 3, 2024, showing McManus gave $1,480.63 in in-kind contributions and paid her the same amount on the same two days: Feb. 19 and 20, 2024.

The PAC on June 3, 2024, wrote the FEC that it raised no money and the $1,543 for the slate card came from a McManus in-kind contribution.

Since then, the PAC has missed three straight filing deadlines and received letters for each of them from the FEC warning of possible civil penalties, an audit or legal enforcement action.

The FEC sends similar letters to PACs and candidate campaigns when they fail to file.

The only document filed by the PAC this year was a new statement of organization on Aug. 18 naming Jason Miner as its treasurer and McManus still as designated agent and custodian of records.

McManus said the PAC doesn’t have to file finance reports with the Trumbull County Board of Elections — something the OEC said it had to do.

The state Legislature voted earlier this year to eliminate the OEC at the end of this year with the secretary of state creating the Ohio Election Integrity Commission, which will investigate campaign finance complaints.

McManus said the OEC’s decision in her case to refer it to the county prosecutor “is a clear attempt by the (OEC) to kick the can down the road, far beyond their existence.”

The Trumbull elections board met five times and voted May 7, 2024, to send a letter to the FEC, OEC and the Ohio Secretary of State’s Office to investigate the PAC.

The board had requested the county prosecutor on March 19, 2024, file complaints with the various agencies on behalf of the board. The prosecutor’s office subsequently told the board it doesn’t file complaints for its clients, but agreed April 1, 2024, to offer assistance in identifying the proper entities for review.

The investigation will soon be in the hands of the prosecutor’s office.

The county Republican Party’s officers agreed March 21, 2024, to use up to $2,000 from the chairman’s fund — the party was led at the time by Mike Bollas — to hire an attorney to file complaints against the PAC.

After Bollas’ resignation after the Nov. 5, 2024, election, the party selected Julia Shutt on Dec. 3, 2024, as its chairwoman. Shutt beat Campbell by one vote on a second ballot.

At a Jan. 27 GOP executive committee meeting, Shutt said the attorney hired for the McManus matter was never paid and the complaint should be dismissed because the executive committee never voted to file it.

At that same meeting, the executive committee voted 28-11 to continue with the complaint.

Despite the vote, Shutt sent a May 9 letter to Richter telling him the party was “no longer interested in pursuing the complaint against Regina McManus. Upon my review of our corporate records and meeting minutes I found there was never a formal resolution taken to pursue the aforementioned complaint.”

Shutt wrote: “This was a complaint brought by a party officer (Campbell) against a private citizen (McManus) who had the temerity to support Republicans in the 2024 Republican primary. Citizens have the right to free speech. Again, we are requesting that this matter be dismissed immediately.”

In a May 20 letter to Richter, Campbell wrote that Shutt’s statement about the party seeking to dismiss the complaint “is a knowingly false statement!”

Campbell wrote that Shutt’s “false statements were no mere mistake. Clearly, Ms. Shutt lied with the clear intention of misleading the election commission. Such conduct is a clear criminal act” because she “knowingly made a false statement” with “the purpose to mislead a public official in performing the public official’s function.”