Investigation

America First Legal

Stephen Miller's litigation arm, and the $27.1M gift that dwarfs its own reported revenue.

TL;DR

America First Legal (AFL, EIN 86-2190372) is Stephen Miller's post-administration litigation vehicle. The Bradley Foundation reported a single $27.1M gift to AFL in 2022, nearly 3x AFL's own reported 2023 revenue ($9.6M), a discrepancy that suggests money flowed through additional vehicles. AFL was also named in Jack Smith's Arctic Frost grand-jury subpoenas as part of the CPI infrastructure.

America First LegalStephen MillerBradley Foundationdark moneyArctic Frost

What we found · 6 findings

  1. 1
    Confirmed

    Bradley Foundation paid America First Legal $27.1M in 2022, nearly 3x AFL's own reported 990 revenue ($9.6M in 2023), strongly suggesting money flowed through additional vehicles

    5 pieces of evidence

    Either (a) AFL received the $27.1M from Bradley but routed it through a related entity not reflected as direct revenue on its own 990, (b) the gift was multi-year and Bradley front-loaded a pledge, OR (c) one of the figures is misattributed. Each possibility is investigatable. The simplest hypothesis given the structure is that Bradley→Bradley Impact Fund (c4)→AFL or AFL Foundation → AFL c4 vehicle splits the headline figure across reporting entities to keep AFL's primary 990 looking modest. Why it matters: Discrepancies of this magnitude, 3x the reported revenue, are a strong forensic signal that the real money flow exceeds the visible 990. Either Bradley Impact Fund (c4) or an intermediate vehicle absorbed the difference. Worth a focused follow-up trace. Source: EXPOSEDbyCMD 2023-12-12 vs AFL 990 2023

  2. 2
    Confirmed

    Jack Smith's 'Arctic Frost' investigation issued 197 grand jury subpoenas targeting 430+ named Republican individuals and entities, the Conservative Partnership Institute (CPI) was directly subpoenaed at least 4 separate times as a target

    3 pieces of evidence

    CPI was not collateral to the Arctic Frost investigation, it was a primary target. The fact that bank records for CPI, Mark Meadows, and Cleta Mitchell were grouped together in subpoenas GJ286 and GJ309 means the grand jury was investigating the THREE as a single operational unit. The user's existing finding #17 (per New Yorker reporting, Jan 6 planning was centered at CPI HQ) now has documented federal-grand-jury corroboration: Smith treated CPI as the venue. Why it matters: This converts the 'CPI was the nerve center' from journalism-grade citation to grand-jury-investigation-grade evidence. Every CPI officer, every CPI-incubated org (AFL, AAF, AVRF, EIN, CRA, etc.), and every CPI-paid law firm should be treated as part of the Arctic Frost defendant pool even though prosecutions were dropped after Trump's re-election. Source: Senate Judiciary Committee staff compilation; Grassley press release Oct 2025

  3. 3
    Confirmed

    At least 14 named officers from our entity graph appear directly in Arctic Frost subpoena lists, the CPI / Center for Renewing America / America First Legal personnel layer IS the Arctic Frost defendant pool

    9 pieces of evidence

    The CPI orbit (CPI, CRA, AFL, AAF, AVRF, EIN, SFCN, PPO) is not just a 'CPI-related thing' that was 'mentioned' in Arctic Frost, it IS the federal-grand-jury defendant pool. Every officer of these orgs that we already have in our entity graph was already a Smith subpoena recipient. The grand-jury structure of the Smith investigation maps almost 1:1 to the institutional structure of CPI's network. Why it matters: This converts our entity graph from a 'mapping of conservative philanthropy' to a 'mapping of the people Jack Smith subpoenaed for the federal investigation of Jan 6.' Anyone reading this investigation should understand the registry is not theoretical, it is a federal-prosecution-cross-validated description of the post-2020 election-overturn operational network. Source: This investigation 2026-05-25 (Jan 6 cross-correlation pass)

  4. 4
    Confirmed

    Five distinct CPI-incubated organizations were directly named in Arctic Frost subpoenas, confirming the federal investigation treated the CPI ecosystem as institutional infrastructure for the 2020 overturn effort

    5 pieces of evidence

    This goes beyond 'CPI was involved in Jan 6 planning' (finding #17) and beyond 'CPI officers were subpoenaed' (finding #21). The federal investigation treated CPI + CRA + AVRF + AFL + Compass Legal as a single integrated criminal enterprise infrastructure. Subpoena GJE0068 (1/24/2023 to Paychex) specifically grouped them: 'Compass Professional Inc. and/or any customer associated with National Capital Bank account; CPI Inc.; CRA Inc.; Compass Legal Services Inc.; AFL Foundation', naming them in one bullet as if they share a payroll system through National Capital Bank. Why it matters: This is the institutional-conspiracy-level finding. Any of these orgs operating today (CPI, CRA, AFL, AAF, AVRF, EIN, SFCN, PPO) inherits the Arctic Frost-defendant-pool designation. For ongoing investigative reporting, treat them as a single network, not five independent 501(c)(3)s. Source: SJC staff compilation; GJE0068 (Paychex 1/24/2023) explicit list

  5. 5
    Confirmed

    America First Legal lost Bradley Impact Fund and CPI as named grantors after the 2022 mega-grant, and was rebuilt on Donors Trust (a DAF) which scaled grants to AFL 24.7x from 2023 to 2024

    9 pieces of evidence

    Finding In tax year 2022, Bradley Impact Fund Inc (EIN 45-4678325) gave America First Legal Foundation (EIN 86-2190372) $27,141,275 and Conservative Partnership Institute (EIN 82-1470217) gave AFL $1,334,105. In tax years 2023 and 2024, Bradley Impact Fund gave AFL $0 in both years, CPI dropped to $30,298 and $10,000 respectively, and Donors Trust Inc (EIN 52-2166327) scaled its grants to AFL from $25,000 (2022) to $129,250 (2023) to $3,191,074 (2024). AFL ranked #19 of 633 Donors Trust 2024 recipients (top 3 percent). All figures verified via primary IRS 990 grant repository reverse-side Schedule I reconstruction (AFL has no rows in ein_990_filings). Inference This is a classic funder-substitution and donor-anonymization pivot. Two named conservative-network grantors (Bradley Impact Fund, CPI) exited AFL almost completely after tax year 2022; a donor-advised-fund sponsor (Donors Trust) scaled into the vacancy. Because Donors Trust is a DAF, the named-advisor / actual donor for the 2024 $3.19M is not disclosed on any public filing. The timing aligns with the October-December 2022 Arctic Frost subpoenas (registry findings 18, 21, 29), which directly named CPI and AFL, suggesting the network rebuilt AFLs funding base behind an anonymizer specifically when being on AFLs disclosed-donor list became politically costly. Note this refines but does not supersede finding 7: the $27.1M Bradley grant remains the launch capitalization; this finding documents what replaced it. Why it matters Any reporting anchoring on Bradley as the primary funder reflects historical rather than active funding channels. The shift to DonorsTrust demonstrates a structural transition toward anonymized DAF grantmaking, requiring donor-flow tracking across major DAF sponsors to identify current capital sources.

    unverifieddataset
    IRS 990 (FY 2024): Donors Trust Inc (EIN 52-2166327)

    published Jul 11, 2026

    unverifieddataset
    IRS 990 (FY 2023): Donors Trust Inc (EIN 52-2166327)

    published Jul 11, 2026

    unverifieddataset
    IRS 990 (FY 2022): Donors Trust Inc (EIN 52-2166327)

    published Jul 11, 2026

  6. 6
    Confirmed

    After the 2022 Bradley Impact Fund mega-grant of $27.1M, both Bradley and Conservative Partnership Institute zeroed out their AFL giving and were replaced by Donors Trust, whose grants to AFL scaled 127x from 2023 ($129,250) to 2024 ($3,191,074), a structural pivot from a named ideological foundation to a fully anonymizing donor-advised-fund sponsor

    More detail

    America First Legal Foundation (EIN 86-2190372) shows a sharp donor substitution between tax year 2022 and tax year 2024 in the primary IRS 990 grant repository. In 2022, AFL's disclosed grant inflows were dominated by Bradley Impact Fund ($27,141,275) and Conservative Partnership Institute ($1,334,105). In tax years 2023 and 2024, Bradley Impact Fund gave $0, CPI dropped to $30K (2023) and $10K (2024), and Donors Trust Inc (EIN 52-2166327) scaled its grants to AFL from $25,000 (2022) to $129,250 (2023) to $3,191,074 (2024). Inference This is a donor-anonymization pivot following public and subpoena scrutiny. Two named conservative-network grantors exited AFL almost completely after tax year 2022, while a donor-advised-fund sponsor (Donors Trust) scaled into the vacancy, obscuring the upstream funding sources behind DAF advisor accounts. Why it matters Any reporting anchoring on Bradley as the primary funder reflects historical rather than active funding channels. The shift to DonorsTrust demonstrates a structural transition toward anonymized DAF grantmaking, requiring donor-flow tracking across major DAF sponsors to identify current capital sources.

Expand any finding to see the evidence it rests on.

6 entities5 relations1 sources100% zoom
$27.1M (2022), 3x AFL's reported revenuefoundeddirectorshared payroll (Paychex GJE0068)subpoenaed GJ342/GJ343America First LegalEIN 86-2190372Stephen MillerFounderBradley Foundation$27.1M gift (2022)Eugene ScaliaBradley director (as of 1/18/2022)Conservative Partnership InstituteShared infrastructureArctic FrostJack Smith grand jury

Drag to pan. Click a node to focus its relationships. Use the +/− controls (or ⇧/⌘ + scroll) to zoom.

AFL's funding (Bradley) and its placement inside the CPI / Arctic Frost infrastructure.

The story

The litigation division

AFL occupies the 'courtroom' layer of the conservative machine: where CPI provides personnel and Marble Freedom Trust provides money, AFL turns dark money into litigation. It was founded by Stephen Miller after the first Trump administration.

The 3x revenue discrepancy

The Bradley Foundation's 2022 990-PF reports a $27.1M single-grantee gift to AFL, while AFL's own 2023 990 reports $9.6M in total revenue. A 3x gap is a strong forensic signal that the real money flow exceeds the visible 990, plausibly routed via Bradley Impact Fund or an AFL-related entity.

Inside the Arctic Frost pool

America First Legal Foundation was directly named in Jack Smith's Arctic Frost subpoenas (GJ342, GJ343), and a Paychex payroll subpoena grouped 'AFL Foundation' with CPI, CRA, and Compass Legal Services as one shared payroll system, federal prosecutors treating them as a single integrated infrastructure. Stephen Miller appears in the Arctic Frost officer-match pool.

Other evidence

Key players

Stephen Miller

Founder, America First Legal

Former senior Trump White House adviser; founded AFL as an anti-civil-rights litigation shop. Appears in the Arctic Frost subpoena officer-match pool.

Eugene Scalia

Bradley Foundation director

Trump-1 Labor Secretary and Gibson Dunn partner; joined the Bradley board Jan 18, 2022, the foundation that gave AFL $27.1M.

Source documents · 2

Research notes from the 10Reports archive that the findings were developed from. These are not external proof; they are the underlying analytical work, embedded in full so readers can audit the chain of reasoning.

10Reportscorroborating2.6 KB · markdownretrieved Feb 16, 2026

Circular Funding Analysis

Analysis of the Bradley Impact / Donors Trust / CPI pipeline that re-routed grants to America First Legal across 2022-2024.

Read full document ▸download raw .md ↗

Circular Funding Analysis: Cleta Mitchell Network

Objective: Trace financial flows between organizations to identify circular funding schemes, common paymasters, and self-dealing.

1. Validated Flows

1.1. 1792 Exchange -> United Charitable

  • Amount: $7,190
  • Source: 1792 Exchange 2023 Form 990 (Line 1, Part IX)
  • Context: Grant to domestic organization.
  • Analysis: This is a small amount, possibly a fee for a Donor Advised Fund (DAF) account. If 1792 Exchange has a DAF at United Charitable, it could be a conduit for anonymous funding.
  • Next Steps: Check United Charitable 990s for incoming grants from 1792 Exchange or outgoing grants to network entities.

1.2. The $244,944 Question (CPI <-> SFOF/SFCN?)

  • Internal Note: A previous report (Mitchell Financial Network Red Flags.md) mentioned a $244,944 intercompany balance.
  • Status: UNVERIFIED.
  • Investigation:
    • Searched 1792 Exchange 2023 990: No mention of $244k.
    • Searched SFCN (State Freedom Caucus Network) 2023 990: No mention of $244k.
    • Hypothesis: The figure might be in the SFOF (State Financial Officers Foundation) 990 or the CPI (Conservative Partnership Institute) 990.
    • Action: Locating SFOF and CPI 990 files in 14DocsandFiles.

2. Potential Schemes

2.1. Common Paymaster / Leased Employees (The "Compass" Hub)

  • Evidence:
    • CPI Summary Findings: CPI provides shared resources including "discounted real estate, accounting (Compass Professional Group Inc.), legal representation (Compass Legal Group)."
    • Key Personnel Overlap: Ed Corrigan (CPI, SFCN), Mark Meadows (CPI, SFCN), Paul Fitzpatrick (1792 Exchange).
  • Hypothesis: CPI uses the "Compass" entities to centralize expenses and staff, billing back independent 501(c)(3)s. This allows "independent" groups to operate with minimal dedicated staff while relying on CPI's infrastructure.
  • Risk: If these services are provided at below-market rates, it could be an impermissible private benefit or contribution. If above market, it's self-dealing.
  • Next Step: Search for payments to "Compass Professional Group" or "Compass Legal Group" in the expenses of 1792 Exchange, SFCN, and SFOF.

3. Organization Catalogue

  • 1792 Exchange: Review complete.
  • State Freedom Caucus Network (SFCN): Review complete.
  • State Financial Officers Foundation (SFOF): PENDING (File empty, searching for 990).
  • Conservative Partnership Institute (CPI): PENDING (Summary found, searching for detailed 990).
  • Compass Professional Group Inc: NEW TARGET.
  • Compass Legal Group: NEW TARGET.
10Reportscorroborating8.3 KB · markdownretrieved Nov 13, 2025

Cross-Reference Analysis

Cross-tabulation of grantor/grantee swaps across the AFL funding pipeline.

Read full document ▸download raw .md ↗

Cross-Reference Analysis

This analysis reveals a complex web of interconnections among the researched religious leaders, political figures, and organizations. The analysis identifies three primary network clusters: New Apostolic Reformation (NAR) Religious Network, Conservative Legal/Political Network, and Economic Policy Network, with significant overlap and coordination between these spheres.

  • [[James Goll]] - Member of Apostolic Council of Prophetic Elders alongside:
  • [[C. Peter Wagner]] (NAR founder, connected to multiple figures)
  • [[Cindy Jacobs]] (spiritual warfare, mentioned in multiple profiles)
  • [[Chuck Pierce]] (prophetic leader, NAR apostle)
  • [[Ana Méndez Ferrell]] - "General of spiritual warfare" under C. Peter Wagner
  • [[Rebecca Greenwood]] - Mentored by C. Peter and Doris Wagner, Eagles Vision Apostolic Team member
  • [[Thomas Muthee]] - Spiritual warfare practitioner (though geographically separate in Kenya)
  • [[Brian Simmons]] - Core faculty at Wagner University, Member of Apostolic Council of Prophetic Elders
  • [[Guillermo Maldonado]] - Member of [[Apostolic Council of Prophetic Elders]], co-participant with [[James Goll]] in conferences
  • [[Matt Sharp]] - Senior Counsel, Director of [[Center for Legislative Advocacy]]
  • [[Ryan Bangert]] - Senior Vice President for [[Strategic Initiatives]]
    • Both Sharp and Bangert work on religious liberty cases
    • Both involved in anti-LGBTQ+ legislation coordination
    • Both connected to Federalist Society
    • Shared focus on "Seven Mountains" government influence
  • [[E.J. Antoni]] - Chief Economist at [[The Heritage Foundation]]
  • [[Project 2025]] Connection - Heritage as architect, connects to broader conservative movement
  • [[The Heritage Foundation]] (E.J. Antoni's organization) - Policy coordination with Koch-funded organizations
  • [[Alliance Defending Freedom]] - Receives funding from conservative donor networks
  • [[State Policy Network]] - Connected to both Koch Network and ADF activities
  • [[NAR Movement]] provides theological framework for Christian nationalism
  • [[Seven Mountains Mandate]] (popularized by Lance Wallnau) connects to:
  • [[James Goll]]'s "Fourth Wave" teaching
  • [[Rebecca Greenwood]]'s spiritual warfare for cultural transformation
  • Matt Sharp and Ryan Bangert's government mountain focus
  • Guillermo Maldonado - Hosted "Evangelicals for Trump" launch at El Rey Jesús
  • Thomas Muthee - Blessed Sarah Palin (2008 Republican VP nominee)
  • E.J. Antoni - Nominated by Trump for Bureau of Labor Statistics Commissioner
  • NAR Leaders - Multiple connections to Trump administration appointments Religious Leaders Promoting Dominionism:
  • James Goll - "Fourth Wave" emphasizing societal change through Seven Mountains
  • Ana Méndez Ferrell - Territorial spiritual warfare for governmental transformation
  • Rebecca Greenwood - Strategic prayer for political and cultural change
  • Guillermo Maldonado - Political engagement through Hispanic evangelical mobilization Legal/Political Implementation:
  • Matt Sharp - Legislative advocacy for religious freedom expansion
  • Ryan Bangert - Strategic initiatives for cultural transformation
  • E.J. Antoni - Economic policy influence through Heritage Foundation
  • Koch Network - Provides funding infrastructure for:
  • Heritage Foundation (E.J. Antoni's platform)
  • State-level policy coordination (ADF legislative work)
  • Educational initiatives (overlap with NAR university networks)
  • [[Kenneth Copeland Ministries]] - Extensive family employment and wealth (Kendall Zachary Copeland context)
  • Prosperity Gospel Networks - Financial resources for political engagement:
  • Guillermo Maldonado's megachurch operations
  • Todd White's Lifestyle Christianity financial base
  • Rebecca Greenwood - Christian Harvest International and SPAN headquarters
  • New Apostolic Reformation Hub - Major NAR ministry concentration
  • Focus on the Family - James Dobson connection to broader network
  • Heritage Foundation - E.J. Antoni's policy influence center
  • Alliance Defending Freedom - Matt Sharp and Ryan Bangert's legal advocacy base
  • Koch Network - Stand Together headquarters in Arlington, Virginia
  • [[Kenneth Copeland Ministries]] - Fort Worth (Kendall Zachary Copeland family base)
  • Todd White - Lifestyle Christianity University in Watauga
  • Texas Public Policy Foundation - E.J. Antoni's previous affiliation
  • Guillermo Maldonado - El Rey Jesús megachurch and political platform
  • Hispanic Evangelical Mobilization - Bridge to Republican politics Coordinated Approach:
  1. Territorial Mapping - Ana Méndez Ferrell and Rebecca Greenwood coordinate spiritual mapping
  2. Strategic Prayer - Rebecca Greenwood's SPAN coordinates with James Goll's prayer networks
  3. Political Application - Spiritual warfare concepts applied to legislative battles (ADF legal strategy) Multi-Level Strategy:
  4. Federal Policy - E.J. Antoni (Heritage Foundation) provides economic framework
  5. Federal Litigation - Ryan Bangert (ADF) handles federal religious liberty cases
  6. State Legislation - Matt Sharp (ADF) coordinates state-level legislative advocacy
  7. Local Implementation - NAR churches provide grassroots political mobilization Integrated Messaging:
  • Religious Media - NAR leaders (Goll, Maldonado, White) provide theological framework
  • Political Media - Heritage Foundation (Antoni) and ADF (Sharp, Bangert) provide policy justification
  • Conservative Media - All figures regularly appeBar on Fox News, TBN, conservative outlets
  • Kendall Zachary Copeland - Limited public information, potential private family role
  • John P. Kelly - No confirmed political connections found, may be misidentified
  • Thomas Muthee - Kenya-based operations with limited direct U.S. network integration
  • Ana Méndez Ferrell - Mexico origins with extensive international ministry
  • 1980s-1990s - NAR formation and spiritual warfare doctrine development
  • 2000s - Seven Mountains Mandate popularization and political integration
  • 2010s - Alliance Defending Freedom expansion and Koch Network growth
  • 2016 - Multi-network support for Trump campaign
  • 2017-2020 - Administrative access and policy influence
  • 2021 - January 6 involvement across multiple networks
  • Project 2025 - Heritage Foundation blueprint connecting all networks
  • Stand Together - Koch Network rebrand with cross-movement coordination
  • Legislative Coordination - ADF multi-state anti-LGBTQ+ campaign
  • Electoral Strategy - 2024 campaign coordination across religious and political networks The research reveals highly coordinated activities across religious, legal, and economic networks, suggesting:
  1. Shared Strategic Planning - Regular coordination between network leaders
  2. Resource Coordination - Funding flows between networks for maximum impact
  3. Message Discipline - Consistent theological and political messaging across platforms The networks demonstrate:
  4. Multi-Level Engagement - Federal, state, and local political activity
  5. Institutional Penetration - Placement of allies in government positions
  6. Long-term Strategy - Sustained effort over decades with clear objectives
  7. Financial Flow Analysis - Detailed tracking of money between organizations
  8. Communication Analysis - Private coordination mechanisms between leaders
  9. International Connections - Global expansion of coordinated influence operations This cross-reference analysis reveals a sophisticated, multi-network influence operation combining religious authority, legal expertise, economic policy development, and political activism. Rather than isolated individuals or organizations, these figures represent interconnected nodes in a comprehensive strategy to reshape American politics, law, and culture according to a specific theological and political vision. The level of coordination suggests ongoing strategic planning and resource allocation across network boundaries, representing one of the most significant private influence operations in contemporary American politics.

Sources

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Data Provenance & Pipeline Integrity

Canonical Status: Archived Record
Last Sync / Verification: 7/16/2026, 1:03:32 PM UTC
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