On April 30, the day Nathan Willett’s state Senate campaign committee declared itself dissolved, it sent $165,384.46 — most of its remaining campaign cash — to a small Georgia nonprofit.
Seven weeks later, that nonprofit, Grassroots America Inc., contributed $160,384.46 to Conservative Future Fund, a super PAC that has reported spending more than $207,000 in Missouri’s 6th Congressional District race, nearly all of it supporting Willett or opposing his principal rival in the Republican primary, radio host Chris Stigall.
The nonprofit and Willett’s federal campaign share a treasurer, Jason D. Boles, whose compliance firm was also paid $5,500 by Willett’s campaign during the same period, according to filings with the Federal Election Commission, the Missouri Ethics Commission and the IRS.
The chain of transactions is now the subject of state and federal complaints filed Monday by Liberty Alliance USA, a conservative nonprofit with longstanding ties to the political network surrounding retiring U.S. Rep. Sam Graves, who endorsed Stigall as his hopeful successor in the Aug. 4 Republican primary.
The complaints landed on the last day Missouri law allows a campaign-finance complaint against a candidate before an election — 15 days out. Neither the Missouri Ethics Commission nor the FEC is likely to resolve them before voting ends.
But they immediately provided Graves and his allies a new line of attack against Willett in the campaign’s final two weeks. And Graves quickly delivered that attack himself.
The transfers were “absolutely illegal,” Graves said in an interview with KCMO radio host Pete Mundo on Tuesday, adding that he had personally reviewed the evidence and found it “pretty convincing.”
The complaints allege violations and ask regulators to investigate, but acknowledge they lack direct evidence of who ordered the transfer or what those involved intended. Liberty Alliance wants those questions answered through bank records, contracts and communications.
Willett’s campaign dismissed the complaints without addressing the transactions they describe.
“This is a baseless attack from a flailing campaign desperate to talk about anything other than Chris Stigall’s history of repeated betrayals and attacks on President Trump,” the campaign said in a statement to The Independent. “It’s no coincidence this frivolous complaint was launched the same day we launched philadelphiastigall.com detailing Stigall’s horrible attacks on President Trump.”
Boles did not respond to questions submitted through his firm, which said it was passing them along to him. Stigall’s campaign did not respond to a request for comment.
Andy Bakker, Liberty Alliance’s executive director, said in a statement that the transactions showed a candidate using “a shell of a nonprofit” that shares a treasurer with his campaign to move money from his old state account into a super PAC built to elect him to Congress.
Money trail
Willett, a Kansas City councilman and high school math teacher, entered the congressional race March 30, days after Graves announced he would not seek another term after 26 years in office. Willett abandoned a campaign for an open state Senate seat to run for Congress.
A month later, Nathan Willett for Missouri filed its termination report with the Missouri Ethics Commission.
The report certified, over the electronic signatures of Willett and committee treasurer James Hall, that the committee had been dissolved and that no surplus remained upon termination.
The accompanying disclosure showed the committee sent $165,384.46 to Grassroots America that same day, listing the transaction as a “contribution made.” It represented the overwhelming majority of the committee’s remaining money.
Grassroots America used an Alpharetta, Georgia, address that matches its federal tax filings.
The nonprofit’s most recent full tax return, covering 2022, reported $9,784 in revenue and $790 in assets. For 2023 and 2024, it filed abbreviated IRS notices showing its gross receipts did not exceed $50,000 in either year.
On June 18, Grassroots America contributed $160,384.46 to Conservative Future Fund, an independent-expenditure-only committee registered in Alabama. It was the largest contribution the super PAC reported receiving during the quarter.
The amount was exactly $5,000 less than the sum Grassroots America had received from Willett’s state committee seven weeks earlier.
Conservative Future Fund reported more than $207,000 in independent expenditures during the period. Nearly all of it — about $198,000 paid to the political media firm OnMessage — went toward advertising supporting Willett or opposing Stigall.
At the center of the transactions is Jason D. Boles.
Boles is treasurer of Nathan Willett for Congress, the candidate’s federal campaign committee, and signed its most recent report to the FEC.
IRS records also identify Boles as the treasurer and principal officer of Grassroots America, the nonprofit that received the state committee’s money and later made the contribution to Conservative Future Fund. Boles is also president and CEO of Tabularius Compliance LLC, a company that provides political-finance and campaign-compliance services.
Willett’s congressional campaign reported paying Tabularius $5,500 in May and June for “compliance and ethics consulting” and regulatory reporting. Grassroots America and Tabularius list matching mailing addresses in Washington, D.C., and Alpharetta.
There is no payment to Boles or Tabularius listed in the state committee’s filings before Willett began his congressional campaign.
The overlapping roles are central to Liberty Alliance’s complaints. The group argues they support an inference that Grassroots America was not an unrelated recipient making an independent decision about how to use the state committee’s money.
Holding multiple financial roles is not itself illegal, however, and the public filings do not reveal what Boles knew about the intended use of the money or what communications occurred among Willett, Grassroots America and Conservative Future Fund.
What the law requires
Federal law prohibits a federal candidate, or anyone acting on the candidate’s behalf, from directing, transferring or spending money in connection with a federal election unless it complies with federal contribution limits, source restrictions and disclosure requirements.
Money raised for a state campaign is collected under Missouri’s rules, not federal ones, making it off-limits for a federal candidate to direct toward his own election. The prohibition, enacted as part of the 2002 Bipartisan Campaign Reform Act, extends to funds raised or spent through an entity a candidate “established, financed, maintained or controlled,” according to the Campaign Legal Center, a Washington nonprofit that advocates for stronger enforcement of campaign-finance laws.
The federal complaint alleges Willett directed his state committee’s money toward his congressional race by sending it to Grassroots America, whose treasurer also managed his federal campaign’s finances, before the nonprofit made the nearly matching contribution to a super PAC supporting him. It also alleges the transaction amounted to a contribution made in the name of another and an impermissible transfer from a candidate’s nonfederal committee.
Regulators have reached different results in cases involving state campaign money transferred to super PACs supporting the same candidates’ federal campaigns, according to FEC records and the Campaign Legal Center, which filed the complaints that prompted several of those cases.
In 2024, the FEC settled with former Tennessee legislator and congressional candidate Beth Harwell and her state committees, which paid a $16,000 civil penalty after two committees she had used for state office transferred $47,000 to a super PAC that spent roughly $113,000 supporting her or attacking a primary opponent.
The FEC has declined to impose penalties in other cases. In one cited by Liberty Alliance, then-Arizona state Sen. Debbie Lesko moved $50,000 from a state committee she continued to chair to a super PAC formed days earlier that spent all its money supporting her congressional campaign. The FEC agreed to investigate but ultimately closed the matter without penalties against Lesko, her committee or the super PAC.
Missouri law presents a different question.
State statute allows a dissolving campaign committee to return money to contributors, transfer it in certain circumstances to political committees or make an unconditional gift to a charitable, fraternal or civic organization — provided the candidate or the candidate’s immediate family receives no direct financial benefit.
Willett could argue that the payment to Grassroots America was a permissible gift to a nonprofit. His campaign did not respond when asked whether that is its position.
The state complaint contends it was not an arm’s-length gift because nearly the same amount reached a super
PAC spending to elect Willett within seven weeks, and because the nonprofit’s treasurer simultaneously managed the finances of Willett’s federal campaign. Whether political support from a super PAC is the kind of “direct financial benefit” state law prohibits is a question the filings do not resolve — and one the Missouri Ethics Commission will not answer before the primary.
The political operation behind the complaints
Liberty Alliance is not a neutral observer in the 6th District primary — and neither is the apparatus that amplified its complaints.
Liberty Alliance USA is a registered name of a nonprofit called Cornerstone 179. Its leadership overlaps with Stanley M. Herzog Charitable Foundation, a conservative Christian education organization near Kansas City with a web of influence in Missouri politics. Businesses and political entities connected to the late Stanley Herzog have spent around $4 million on state campaigns since his death in 2019.
Liberty Alliance shares an address with Graves Garrett, the Kansas City law firm of Todd Graves, the congressman’s brother and a former chairman of the Missouri Republican Party.
Todd Graves also chairs the Herzog Foundation. And Stigall works for the foundation, serving as a part-time content creator, according to his show’s biography.
The first news coverage of the complaints appeared Monday in The Heartlander, a news outlet published by the Herzog Foundation. The Heartlander’s story, carrying a staff byline, described Liberty Alliance as “a conservative watchdog group” but did not mention the group’s ties to Graves’ political allies or the Herzog Foundation’s relationships with both Todd Graves and Stigall.
Bakker told the Kansas City Star that Liberty Alliance had “zero communication with the Stigall campaign” about the complaints.
This story was originally published by the Missouri Independent.
