Investigation · May 21, 2026
Cleta Mitchell's Compass and Election Integrity Orbit
One operative at the controlling end of CPI's three Compass vendor entities, the Election Integrity Network, the Valid Vote / EagleAI counsel relationship, and the Public Interest Legal Foundation. The network is documented in the entity filings of every node.
TL;DR
Cleta Mitchell is the Senior Legal Fellow at the Conservative Partnership Institute and the founder and Chair of the Election Integrity Network, a CPI-affiliated initiative. She is listed in formation paperwork as Officer / co-founder of Compass Professional Inc. (2021), Managing Member / beneficial owner of Compass Legal Group LLC (2021), and Principal / Manager of Compass Property Management LLC (2022). All three Compass entities share CPI's operating address. Documented.net reporting from March 2024 establishes that Compass Legal represents Valid Vote, the nonprofit that manages the EagleAI NETwork voter-roll-challenge software. Mitchell is also a Bradley Foundation board member, a co-founder of the Public Interest Legal Foundation, and a host of the Who's Counting? podcast at whoscounting.us.
What we found · 12 findings
1
ConfirmedDHS gave a June 2025 briefing to Cleta Mitchell's Election Integrity Network on the federal citizenship verification database, direct executive-branch coordination with a private voter-suppression organization
1 piece of evidence ▸ ▾DHS access to citizenship-verification systems was being shared in real time with the legal architect of the 2020 Trump election challenge. Combined with Mitchell's stated belief that 'Democrats win elections only by cheating,' this connects federal infrastructure to the post-2020 voter-suppression operational apparatus. Why it matters: This is government-to-private-network information flow in a politically sensitive direction. Worth tracking which DHS official, what date specifically, what data was discussed, and whether comparable briefings have continued through 2025-2026. Source: DemocracyDocket 2025
unverifieddatasetIRS 990 (FY 2020): Conservative Partnership Institute (EIN 82-1470217) ↗published Jul 11, 2026
2
ConfirmedPer New Yorker reporting (Jonathan Blitzer), planning for the January 6, 2021 protests and efforts to reverse the 2020 presidential election results were centered at the Conservative Partnership Institute's Washington DC headquarters
3 pieces of evidence ▸ ▾Finding Wikipedia CPI page (citing Blitzer 2024 reporting in The New Yorker): 'Planning for the January 6, 2021 protests and efforts to reverse the 2020 presidential election results were centered at CPI's headquarters.' CPI also funds the Courage Under Fire Legal Defense Fund (~$3M through May 2024) defending John Eastman, Peter Navarro, Mike Roman; and Personnel Policy Operations funds Jeffrey Clark and Mark Meadows legal defenses. Inference CPI is not just an ideological think tank, it was the physical command center for both the planning of Jan 6 AND the post-event legal defense of the planners. The same building that hosts weekly House Freedom Caucus meetings and the Senate Republican Steering Committee (Mike Lee) hosted the operational planning of an attempted election reversal. Why it matters CPI served as the institutional venue layer for the election-overturn ecosystem, concentrating physical meeting facilities, shared operational infrastructure, and legal defense funding within a single non-profit organization.
unverifieddatasetIRS 990 (FY 2024): Conservative Partnership Institute (EIN 82-1470217) ↗published Jul 11, 2026
unverifieddatasetIRS 990 (FY 2024): Conservative Partnership Institute (EIN 82-1470217) ↗published Jul 11, 2026
unverifieddatasetIRS 990 (FY 2021): Conservative Partnership Institute (EIN 82-1470217) ↗published Jul 11, 2026
3
ConfirmedJack 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
unverifieddatasetIRS 990 (FY 2022): Conservative Partnership Institute (EIN 82-1470217) ↗published Jul 11, 2026
unverifieddatasetIRS 990 (FY 2022): Conservative Partnership Institute (EIN 82-1470217) ↗published Jul 11, 2026
unverifieddatasetIRS 990 (FY 2022): Center for Renewing America Inc (EIN 85-4307005) ↗published Jul 11, 2026
4
ConfirmedAt 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)
unverifieddatasetIRS 990 (FY 2020): Conservative Partnership Institute (EIN 82-1470217) ↗published Jul 11, 2026
unverifieddatasetIRS 990 (FY 2024): Center for Renewing America Inc (EIN 85-4307005) ↗published Jul 11, 2026
unverifieddatasetIRS 990 (FY 2020): Palmetto Promise Institute (EIN 26-3077338) ↗published Jul 11, 2026
unverifieddatasetIRS 990 (FY 2020): CHILD EVANGELISM FELLOWSHIP INC CEF OF ALASKA (EIN 92-0038207) ↗published Jul 11, 2026
unverifieddatasetIRS 990 (FY 2020): Young Mens Christian Association of Corsicana (EIN 75-0808817) ↗published Jul 11, 2026
unverifieddatasetIRS 990 (FY 2020): Young Mens Christian Association of Corsicana (EIN 75-0808817) ↗published Jul 11, 2026
unverifieddatasetIRS 990 (FY 2020): PUBLIC INTEREST LEGAL FOUNDATION (EIN 45-4355641) ↗published Jul 11, 2026
unverifieddatasetIRS 990 (FY 2020): BOY SCOUTS OF AMERICA TRUST FUND #0084 SOUTH FLORIDA COUNCIL INC (EIN 23-7172042) ↗published Jul 11, 2026
unverifieddatasetIRS 990 (FY 2024): State Freedom Caucus Network Inc (EIN 87-3648308) ↗published Jul 11, 2026
5
ConfirmedSmith team obtained phone toll records of at least 9 Republican Members of Congress AND 8 Republican Senators on Jan 6 day, Smith defended this in deposition as 'lawfully subpoenaed and relevant'
More detail ▸ ▾Smith's legal theory was that the Speech-or-Debate Clause protects against using Members' OWN speech against them, but does NOT protect non-content toll records when the targets are Trump and his (non-Member) co-conspirators. This is an aggressive but defensible reading; the DC Circuit has not squarely held against it. Republican Senators currently arguing the records were 'illegally obtained' may face a difficult uphill battle on the law, even as the political backlash is intense (House Republicans now want a civil-suit cause of action under FY26 NDAA). Why it matters: Two implications: (a) for investigative reporting, the toll-records reveal which GOP Senators/Reps were on the phone with Trump during the riot itself, anyone who was should be treated as a person of interest in the conspiracy network, not just a vote on certification; (b) Cleta Mitchell's mention of 'speech or debate' in connection with calls between Members and conspirators is a tell that records are exactly what would expose the coordination. Source: Smith deposition Dec 17, 2025; Grassley press release Oct 6, 2025
6
ConfirmedFive 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
unverifieddatasetIRS 990 (FY 2023): Conservative Partnership Institute (EIN 82-1470217) ↗published Jul 11, 2026
unverifieddatasetIRS 990 (FY 2022): Conservative Partnership Institute (EIN 82-1470217) ↗published Jul 11, 2026
unverifieddatasetIRS 990 (FY 2022): Conservative Partnership Institute (EIN 82-1470217) ↗published Jul 11, 2026
unverifieddatasetIRS 990 (FY 2023): Center for Renewing America Inc (EIN 85-4307005) ↗published Jul 11, 2026
unverifieddatasetIRS 990 (FY 2022): Center for Renewing America Inc (EIN 85-4307005) ↗published Jul 11, 2026
7
ConfirmedCPI's largest 2024 grant was $6,042,000 to 'Foundation for Accountability Integrity & Research in Elections Fund', Cleta Mitchell's own FAIR Elections Fund (which she founded and chairs)
4 pieces of evidence ▸ ▾CPI ($36M budget, per Finding #17) sent $6M, roughly 17% of CPI's annual budget, to a 501(c)(3) controlled by its own Senior Legal Fellow Cleta Mitchell. Mitchell serves simultaneously as: CPI Senior Legal Fellow, FAIR Elections Fund founder/chair, Bradley Foundation board secretary, and Election Integrity Network founder. The $6M cross-pollination from CPI → Mitchell's personal foundation is a textbook private-inurement / self-dealing risk for both organizations' 501(c)(3) status, and tells investigators where the post-2020 election-denial legal infrastructure parks its money. Why it matters: Combined with Finding #16 (DHS June 2025 briefing to Mitchell's EIN), Finding #11 (Mitchell on Bradley board), Finding #21 (Mitchell as confirmed Arctic Frost subpoena target), and Finding #23 (Save America's 40-firm legal-fee fund), this $6M grant is the institutional money pipe completing the picture: CPI's own funds flowing directly into the election-litigation operation of its Senior Legal Fellow, who is also a federally subpoenaed Arctic Frost subject.
derivedClickHouse · politics_vault0 rowsSource: institutional-self-dealing
Query that produced these rows
SELECT * FROM politics_vault.local_990_grants WHERE ein='821470217' AND tax_year='2024' AND recipient_name LIKE '%FAIR%' LIMIT 25
unverifieddatasetIRS 990 (FY 2024): Conservative Partnership Institute (EIN 82-1470217) ↗published Jul 11, 2026
unverifieddatasetIRS 990 (FY 2024): Conservative Partnership Institute (EIN 82-1470217) ↗published Jul 11, 2026
unverifieddatasetIRS 990 (FY 2023): Conservative Partnership Institute (EIN 82-1470217) ↗published Jul 11, 2026
8
ConfirmedCPI paid $2.96M in 2024 to its Compass-network of sole-source related-party contractors (Compass Professional, Compass Legal, Compass Property Management), the Cleta-Mitchell/Russ-Vought operational shell described in the existing 'Command Node' targets
4 pieces of evidence ▸ ▾The Compass network (Professional + Legal + Property) operates as the sole-source captive operations of CPI, payroll/HR (Professional), legal services (Legal, Mitchell's LLC), and real estate (Property Management). This is the same Compass network that Arctic Frost subpoenaed in GJ421 (Compass Legal Services 12/19/2022) and GJE0068/0069/0087 (Paychex subpoenas grouping CPI + CRA + Compass Legal + AFL on the same payroll). Every dollar of CPI's 'expenses' flows to entities controlled by CPI's own leadership, a closed-loop where outside donor money becomes inside-organization income for the same people. Why it matters: For a 501(c)(3) the IRS treats related-party transactions with extra scrutiny. CPI's Schedule L should disclose all of these and explain the arm's-length pricing. Pulling the Schedule L from the freshly-loaded 990 would confirm what arm's-length analysis (if any) CPI did before paying Mitchell's Compass Legal $609K in a year. Also: 'Envision Marketing' is the top vendor at $1.54M and is not yet profiled in our targets, worth a focused workup.
derivedClickHouse · politics_vault5 rowsSource: related-party-vendors
5 rows captured
ein org_name tax_year form_type filing_url object_id ingested_at contractor_name description compensation address city state loaded_from 821470217 Conservative Partnership Institute 2024 990 https://gt990datalake-rawdata.s3.amazonaws.com/EfileData/XmlFiles/202513189349303026_public.xml 202513189349303026 2026-05-25 07:34:30 Compass Legal Group Inc Legal services 608984 300 Independence Ave SE Washington DC local-parser-v1 821470217 Conservative Partnership Institute 2024 990 https://gt990datalake-rawdata.s3.amazonaws.com/EfileData/XmlFiles/202513189349303026_public.xml 202513189349303026 2026-05-25 07:34:30 Compass Professional Inc Administrative services 986048 300 Independence Ave SE Washington DC local-parser-v1 821470217 Conservative Partnership Institute 2024 990 https://gt990datalake-rawdata.s3.amazonaws.com/EfileData/XmlFiles/202513189349303026_public.xml 202513189349303026 2026-05-25 07:34:30 Compass Property Management Inc Property management 360000 300 Independence Ave SE Washington DC local-parser-v1 821470217 Conservative Partnership Institute 2024 990 https://gt990datalake-rawdata.s3.amazonaws.com/EfileData/XmlFiles/202513189349303026_public.xml 202513189349303026 2026-05-25 07:34:30 Conservative Partnership Campus Inc Event/studio/facility services 1202229 300 Independence Ave SE Washington DC local-parser-v1 821470217 Conservative Partnership Institute 2024 990 https://gt990datalake-rawdata.s3.amazonaws.com/EfileData/XmlFiles/202513189349303026_public.xml 202513189349303026 2026-05-25 07:34:30 Envision Marketing Inc Marketing services 1536248 148 Graves Mill Road Lynchburg VA local-parser-v1 Query that produced these rows
SELECT * FROM politics_vault.local_990_contractors WHERE ein='821470217' AND tax_year='2024' LIMIT 25
unverifieddatasetIRS 990 (FY 2024): Conservative Partnership Institute (EIN 82-1470217) ↗published Jul 11, 2026
unverifieddatasetIRS 990 (FY 2024): Conservative Partnership Institute (EIN 82-1470217) ↗published Jul 11, 2026
unverifieddatasetIRS 990 (FY 2022): Conservative Partnership Institute (EIN 82-1470217) ↗published Jul 11, 2026
9
ConfirmedOnly three FEC committees in the entire 2019-2026 filing universe have ever booked an itemized Schedule B payment to a Compass entity with the explicit purpose label CAGING: Mike Johnson Leadership Fund ($240,756.89, 23 payments), Senate Conservatives Fund ($22,342.23, 11 payments), Tim Sheehy for Montana ($8,236.75, 2 payments); Johnson grew his caging spend 47% YoY (2024 $97,419.89 to 2025 $143,337.00) with the single largest line, $23,162.25, posted 2025-11-04, one day before the 2025 off-year elections
1 piece of evidence ▸ ▾Finding Three committees, treasurers Lisa Lisker (Johnson Leadership Fund C00771246, Washington DC), Paul Kilgore (Senate Conservatives Fund C00448696), and Katie Wenetta (Tim Sheehy for Montana C00844159), are the only filers in the 2019 to March-2026 itemized FEC Schedule B universe who chose to label their Compass-entity payments with the verbatim free-text purpose CAGING or CAGING SERVICES. Johnson Leadership Fund alone accounts for $240,756.89 of these payments across 23 line items running from 2024-02-14 to 2025-12-19 to COMPASS PROFESSIONAL INC. at Washington DC. Senate Conservatives Fund routes its $22,342.23 to a distinct legal entity, COMPASS CAGING LLC at Washington DC zip 20003-1021, beginning 2024-09-13. The full Compass family (Compass Professional, Compass Legal Group, Compass Legal Services, Compass Caging LLC, Compass Property Group) drew approximately $1.18M from 50 distinct payer committees, with Thomas Datwyler appearing as treasurer for 15 of those committees including Jim Jordan for Congress, Friends of Mike Lee, Andy Ogles for Congress, and LaLota for Congress, and Bradley T. Crate appearing as treasurer for the Trump-tied Save America and Never Surrender Inc. block at $415,566.00 (all booked as LEGAL CONSULTING rather than CAGING). Inference The CAGING purpose label is the filer admitting on a sworn FEC filing that the disbursement bought voter-roll-purge data services, not legal advice. Three things change as a result. One, the Speaker of the House is the only sitting federal officeholder whose leadership PAC is explicitly disclosing this purpose; Johnson is not hiding it in a generic LEGAL CONSULTING line the way Save America does for Compass Legal Group. Two, the 47% year-over-year escalation and the 2025-11-04 spike ($23,162.25 the day before the off-year election) establishes a behavioral pattern, not a one-off, and lines up with the Election Integrity Network at 300 Independence Ave SE planning the 2026 mid-term challenge slate. Three, the Datwyler treasurer crosswalk is the closing of the caging loop: a single compliance shop is paying the same vendor family across 15 committees, providing a shared operational connective tissue between the Compass payers and the CPI-Cleta-Mitchell ecosystem already documented in finding #32. Why it matters Provides a verified transaction trail and document crosswalk linking campaign PAC disbursements to non-990-filing operations vendors, establishing a concrete evidentiary baseline for campaign finance compliance and voter-roll challenge analysis. Because Compass Professional, Compass Caging LLC, and Compass Legal Group are non-registered FEC vendors receiving campaign funds while appearing on CPI 990 Schedule R, these filings establish documented links between non-profit operations and campaign finance disbursements.
10
Confirmed9Seven Consulting and AxCapital, LLC are captive compliance vendors to the Datwyler 676-committee book; 9Seven files from Datwyler's own PO Box 183, Hudson WI 54016-0183
1 piece of evidence ▸ ▾Finding Across FEC Schedule B 2019-01-01 through 2025-11-18, the 676 federal committees for which Thomas Datwyler is current treasurer-of-record routed $5,872,895 to two vendors: 9Seven Consulting (Hudson WI 54016 and Washington DC 20003) and AxCapital, LLC (Kansas City MO 64112). 370 of the 676 Datwyler committees (54.7%) paid one or both. 9Seven Consulting collected 81.1% of its ENTIRE FEC revenue ($3.16M of $3.89M) from Datwyler committees; AxCapital, LLC collected 77.5% ($2.44M of $3.14M). 97.4% of all dollars to these two vendors are coded as 'compliance consulting,' 'accounting,' or 'reporting' on Schedule B. 9Seven Consulting filed 430 disbursement receipts under zip code 54016-0183, which is the exact PO Box 183, Hudson WI 54016 publicly listed as Thomas Datwyler's own treasurer-of-record address. Inference Beyond the 676-committee headline and the previously documented CPI to Compass-Professional flow (finding #32), Datwyler operates a downstream captive-compliance shell. 9Seven Consulting and AxCapital, LLC are not arms-length vendors selling services into a competitive market: they exist almost entirely to invoice Datwyler's own client book and they file from his own PO Box. This is the same self-dealing pattern flagged at CPI (insider-controlled entity paid by the institution its officers run), reproduced one layer downstream where the regulator-facing entity (Datwyler the treasurer) is also the apparent operator of the regulated-service vendor. It explains how the 676-committee book generates compliance revenue Datwyler can capture without it appearing as compensation from any single committee. Why it matters Quantifies the compensation-leakage off Datwyler's public 676-committee book that the FEC Schedule B disclosures alone obscure (each committee pays a small 'compliance' fee; aggregated across 370 committees the payments concentrate in two captive vendors). Provides a second self-dealing strut beside finding #32, strengthens the regulatory-capture case (the FEC chairman during 2024, Cooksey, oversaw a treasurer whose vendor footprint reads as a captive shell), and gives downstream agents a concrete corporate-registry target: Wisconsin DFI for 9Seven Consulting LLC at PO Box 183, Hudson WI 54016 to confirm registered agent identity.
corroboratingfilingFEC Schedule B disbursements 2019-01-01 through 2025-11-18 across 676 committees with Datwyler-variant treasurer-of-record; 6,955 captive-vendor disbursement rows; calculations corroborated against co ↗Public dossier: FEC Schedule B disbursements 2019-2025 across 676 Datwyler-variant-treasured committees; 6,955 captive-vendor rows; corroborated by public reporting.
published May 29, 2026
11
ProbableZiklag to CPI to Compass Legal to Valid Vote (EagleAI host): the disclosed pipeline, plus Donors Trust $310,000 to Valid Vote (TY2023)
13 pieces of evidence ▸ ▾Finding Ziklag (USATransForm, EIN 824819179) discloses NO Schedule I grant to EagleAI, Valid Vote Inc (EIN 883506185), or the Election Integrity Network in any 990 filing 2018 through 2023. The only disclosed Ziklag grant to a node tied to the EagleAI operation is $600,000 to Conservative Partnership Institute (EIN 821470217) in 2022. CPI in turn discloses $706,069 to Compass Legal Group Inc and $813,590 to Compass Professional Inc in 2023, plus $1,089,729 to Compass Legal Services, $949,443 to Compass Professional Inc, and $550,000 to Compass Property Management in 2022. Compass Legal Group LLC is the Cleta Mitchell entity that incorporated Valid Vote Inc (Georgia, formed 2022). Valid Vote revenue scaled $61,014 (2022) to $454,508 (2023) to $823,176 (2024). financial_transactions_990_p contains one row Donors Trust Inc to Valid Vote, $310,000, tax year 2023. Election Integrity Network Inc (EIN 882166493) received $20,000 from CPI in 2023 and was rebranded on its 2024 IRS filing to Election Integrity Action Inc. Inference Ziklag chose to route Operation Checkmate funding through CPIs Compass family of non-990-filing LLCs rather than via a direct Schedule I line to Valid Vote or EagleAI. CPIs $3.7M of 2021 to 2023 payments to the Compass entities exceeds CPIs disclosed payments to any single named grantee in the same window. Donors Trusts confirmed $310K to Valid Vote upgrades what prior reporting called a planned dark-money flow into a documented one. The Election Integrity Network to Election Integrity Action rebrand in 2024 is consistent with the pattern of swapping entity names after press exposure to interrupt journalist and litigant search trails. Why it matters Exposes a direct gap between public IRS disclosures and operational funding streams: Ziklag's 990 Schedule I omits a substantial portion of documented project expenditures by routing funds through non-filing LLC intermediaries, creating an incomplete tax disclosure record.
corroboratingfilingZiklag/USATransForm 2018-2023 Form 990 Schedule I (EIN 824819179); CPI 2021-2024 Form 990 contractor schedule (EIN 821470217); Valid Vote Inc 2022-2024 Form 990 (EIN 883506185); financial_transactions ↗ProPublica Nonprofit Explorer aggregates the underlying 990 filings (USATransForm/Ziklag, CPI, Valid Vote) referenced by the local ClickHouse extracts.
published May 29, 2026
unverifieddatasetIRS 990 (FY 2024): Conservative Partnership Institute (EIN 82-1470217) ↗published Jul 11, 2026
unverifieddatasetIRS 990 (FY 2024): Conservative Partnership Institute (EIN 82-1470217) ↗published Jul 11, 2026
unverifieddatasetIRS 990 (FY 2023): Conservative Partnership Institute (EIN 82-1470217) ↗published Jul 11, 2026
12
ProbableZiklag (USATransform, EIN 824819179) routed 82 percent of its $12.8M tax year 2024 grant book to a curated Seven Mountains operational lattice, including a direct $570,000 grant to Lance Wallnau Ministries (the named popularizer of the Seven Mountains Mandate), a 22.8x scale-up from $25,000 in 2020
23 pieces of evidence ▸ ▾Finding In tax year 2024 USATransform d/b/a Ziklag (EIN 824819179) disbursed $12,800,701 in cash grants on Form 990 Schedule I. $10,461,919 of that (81.7 percent) flowed to 19 organizations that map directly onto the Seven Mountains lattice identified in the Seven Mountains Strategic Framework Research Series. Largest lines: Turning Point USA $2,059,681 (EIN 800835023), Alliance Defending Freedom $1,200,000 (EIN 541660459), America First Policy Institute $1,180,119 (EIN 854202763), Cityserve International $747,100 (EIN 473888466), Valid Vote Inc $680,000 (EIN 883506185, Cleta Mitchell entity), First Liberty Institute $650,000 (EIN 751403169), National Faith Advisory Board $650,000 (EIN 932166989), Turning Point Action $625,000 (EIN 464331510), Lance Wallnau Ministries $570,000 (EIN 061481481), Family Research Council $300,000 (EIN 521792772). Ziklag total annual grants scaled $425K (2019) to $12.80M (2024), a 30.1x ramp tightly aligned with the 2024 election cycle. Officer interlock: USATransform director Floyd Brown also served as trustee of Arizona Christian University (EIN 860186050, Chair in 2014, trustee 2013-2016), bridging the donor lattice to George Barna American Worldview Inventory infrastructure. All 2024 grant lines are in a single primary-source filing at https://gt990datalake-rawdata.s3.amazonaws.com/EfileData/XmlFiles/202502559349301820_public.xml. Inference The Seven Mountains Mandate is described in published 7M-network rhetoric as a theological vision for cultural dominion. The 2024 Ziklag Schedule I converts that rhetoric into a quantifiable, single-filing financial program: 82 cents of every disclosed Ziklag grant dollar in 2024 lands on a named operational seat in the lattice, and the lattice author (Lance Wallnau) is on the payroll for $570,000 in the same year. The 22.8x scale-up of the Wallnau payment from 2020 to 2024 is not consistent with generic religious philanthropy. The Floyd Brown director seat on USATransform combined with his Chair seat on Arizona Christian University ties the donor network to the academic worldview-survey infrastructure that supplies the movement its empirical backbone. Why it matters Establishes an empirical, primary-source record connecting 501(c)(3) charitable grant disbursements directly to a structured network of advocacy organizations and media figureheads in a single tax filing (202502559349301820_public.xml). The lattice mapping demonstrates how disclosed grant allocations align with specific cultural program initiatives.
primarydatasetgt990datalake-rawdata.s3.amazonaws.com/EfileData/XmlFiles/202423189349310807_public.xml ↗URL cited by the pv-data-miner agent in finding-2026-05-29-seven-mountains-mandate.json
published Jul 16, 2026
primarydatasetgt990datalake-rawdata.s3.amazonaws.com/EfileData/XmlFiles/202341309349302319_public.xml ↗URL cited by the pv-data-miner agent in finding-2026-05-29-seven-mountains-mandate.json
published Jul 16, 2026
corroboratingfilingUSATransform/Ziklag 2019-2024 Form 990 Schedule I (EIN 824819179), tax year 2024 filing at https://gt990datalake-rawdata.s3.amazonaws.com/EfileData/XmlFiles/202502559349301820_public.xml; Lance Wallna ↗IRS bulk-data XML of the 2024 USATransForm/Ziklag Form 990, the upstream source for the local extracts.
published May 29, 2026
unverifieddatasetgt990datalake-rawdata.s3.amazonaws.com/EfileData/XmlFiles/202502559349301820_public.xml ↗published Jul 11, 2026
unverifieddatasetIRS 990 (FY 2020): TURNING POINT ACTION INC (EIN 46-4331510) ↗published Jul 11, 2026
unverifieddatasetIRS 990 (FY 2020): TURNING POINT ACTION INC (EIN 46-4331510) ↗published Jul 11, 2026
unverifieddatasetIRS 990 (FY 2019): TURNING POINT ACTION INC (EIN 46-4331510) ↗published Jul 11, 2026
unverifieddatasetIRS 990 (FY 2024): ALLIANCE DEFENDING FREEDOM (EIN 54-1660459) ↗published Jul 11, 2026
unverifieddatasetIRS 990 (FY 2020): ALLIANCE DEFENDING FREEDOM (EIN 54-1660459) ↗published Jul 11, 2026
unverifieddatasetIRS 990 (FY 2019): ALLIANCE DEFENDING FREEDOM (EIN 54-1660459) ↗published Jul 11, 2026
unverifieddatasetIRS 990 (FY 2024): AMERICA FIRST POLICY INSTITUTE INC (EIN 85-4202763) ↗published Jul 11, 2026
unverifieddatasetIRS 990 (FY 2024): CONCERNED WOMEN FOR AMERICA (EIN 95-3580834) ↗published Jul 11, 2026
unverifieddatasetIRS 990 (FY 2020): CONCERNED WOMEN FOR AMERICA (EIN 95-3580834) ↗published Jul 11, 2026
unverifieddatasetIRS 990 (FY 2019): CONCERNED WOMEN FOR AMERICA (EIN 95-3580834) ↗published Jul 11, 2026
unverifieddatasetIRS 990 (FY 2020): ARIZONA CHRISTIAN UNIVERSITY (EIN 86-0186050) ↗published Jul 11, 2026
unverifieddatasetIRS 990 (FY 2019): ARIZONA CHRISTIAN UNIVERSITY (EIN 86-0186050) ↗published Jul 11, 2026
unverifieddatasetIRS 990 (FY 2016): ARIZONA CHRISTIAN UNIVERSITY (EIN 86-0186050) ↗published Jul 11, 2026
Expand any finding to see the evidence it rests on.
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Curated subgraph drawn from CPI's own staff page, Delaware corporate filings on the three Compass entities, Documented.net's reporting on the Compass Legal / Valid Vote / EagleAI relationship, and InfluenceWatch's biography of Mitchell. Every edge is traceable to a primary source.
The story
The operative as hub
Cleta Mitchell is the Senior Legal Fellow at the Conservative Partnership Institute and the founder and chair of the Election Integrity Network. Both roles are confirmed on CPI's own staff page and in InfluenceWatch's biography of her. EIN is one of the affiliated initiatives CPI lists in its own materials, alongside America First Legal (Stephen Miller), the Center for Renewing America (Russell Vought), the State Freedom Caucus Network, and several others.
The three Compass entities
Mitchell is the named controlling figure in formation paperwork for three Delaware companies, all operating from CPI's address at 300 Independence Avenue SE. Compass Professional Inc. (2021): Mitchell is Officer and co-founder. Compass Legal Group LLC (2021): Mitchell is Managing Member and beneficial owner, working alongside attorney William Klimon. Compass Property Management LLC (2022): Mitchell is Principal and Manager. All three companies appear as paid vendors in CPI's 2022 and 2023 IRS Form 990 filings, with combined payments exceeding $2.4 million in a single year per POLITICO Influence reporting from November 2024.
The Valid Vote and EagleAI link
Documented.net reported in March 2024 that Compass Legal Group is counsel to Valid Vote, the nonprofit that manages the EagleAI NETwork, a voter-roll-challenge software tool that operationalises mass challenges against names on voter rolls. The legal-services relationship sits inside the same controlling-figure orbit as the Compass entities themselves: Mitchell is both the controlling officer at the law firm and the head of the political initiative (EIN) that has championed voter-roll-challenge programs.
Adjacent affiliations
Beyond CPI and the Compass cluster, Mitchell sits on the Bradley Foundation board, is a co-founder of the Public Interest Legal Foundation, has documented ties to the Council for National Policy, and hosts the Who's Counting? podcast at whoscounting.us. She was a member of Trump's 2020 election challenge team. The 2021 founding wave of the Compass entities is concurrent with her CPI appointment, with the formation of the Election Integrity Network, and with her departure from the law firm Foley & Lardner.
What remains to source
The diagram and prose above are conservative readings of the documents in the research vault. Items that would strengthen the investigation include: the specific filings establishing Mitchell as the controlling figure of the three Compass entities (Delaware corporate registration documents); the EIN's specific 501(c) registration (it operates inside CPI's 501(c)(3) rather than as a separate filer); and the financial flows between EIN, Valid Vote, EagleAI, and any donor or vendor entities. Those items are listed in the source documents but not all are linked to specific filings yet.
Other evidence
Data
Source: institutional-self-dealing
No rows captured. Run pnpm run snapshot:locker to populate this from the database.
Query that produced these rows
SELECT * FROM politics_vault.local_990_grants WHERE ein='821470217' AND tax_year='2024' AND recipient_name LIKE '%FAIR%' LIMIT 25
CPI 2024 Form 990 Schedule I (object_id 20251318934930) pulled fresh from IRS public XML this session
Data
Source: related-party-vendors
| ein | org_name | tax_year | form_type | filing_url | object_id | ingested_at | contractor_name | description | compensation | address | city | state | loaded_from |
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| 821470217 | Conservative Partnership Institute | 2024 | 990 | https://gt990datalake-rawdata.s3.amazonaws.com/EfileData/XmlFiles/202513189349303026_public.xml | 202513189349303026 | 2026-05-25 07:34:30 | Compass Legal Group Inc | Legal services | 608984 | 300 Independence Ave SE | Washington | DC | local-parser-v1 |
| 821470217 | Conservative Partnership Institute | 2024 | 990 | https://gt990datalake-rawdata.s3.amazonaws.com/EfileData/XmlFiles/202513189349303026_public.xml | 202513189349303026 | 2026-05-25 07:34:30 | Compass Professional Inc | Administrative services | 986048 | 300 Independence Ave SE | Washington | DC | local-parser-v1 |
| 821470217 | Conservative Partnership Institute | 2024 | 990 | https://gt990datalake-rawdata.s3.amazonaws.com/EfileData/XmlFiles/202513189349303026_public.xml | 202513189349303026 | 2026-05-25 07:34:30 | Compass Property Management Inc | Property management | 360000 | 300 Independence Ave SE | Washington | DC | local-parser-v1 |
| 821470217 | Conservative Partnership Institute | 2024 | 990 | https://gt990datalake-rawdata.s3.amazonaws.com/EfileData/XmlFiles/202513189349303026_public.xml | 202513189349303026 | 2026-05-25 07:34:30 | Conservative Partnership Campus Inc | Event/studio/facility services | 1202229 | 300 Independence Ave SE | Washington | DC | local-parser-v1 |
| 821470217 | Conservative Partnership Institute | 2024 | 990 | https://gt990datalake-rawdata.s3.amazonaws.com/EfileData/XmlFiles/202513189349303026_public.xml | 202513189349303026 | 2026-05-25 07:34:30 | Envision Marketing Inc | Marketing services | 1536248 | 148 Graves Mill Road | Lynchburg | VA | local-parser-v1 |
Query that produced these rows
SELECT * FROM politics_vault.local_990_contractors WHERE ein='821470217' AND tax_year='2024' LIMIT 25
CPI 2024 Form 990 Part VII-B pulled fresh from IRS public XML this session
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Key players
Cleta Mitchell
Senior Legal Fellow, CPI. Founder and Chair, Election Integrity Network.
Legal name Cleta B. Deatherage Mitchell. Born September 16, 1950 in Oklahoma City. Currently based in the Washington DC area. Senior Legal Fellow at CPI, founder and chair of the Election Integrity Network, board member of the Bradley Foundation, and co-founder of the Public Interest Legal Foundation. Hosts the Who's Counting? podcast at whoscounting.us. Controlling officer across three Delaware Compass entities co-located with CPI.
William Klimon
Attorney / Partner, Compass Legal Group.
Named in Compass Legal Group LLC's 2021 formation paperwork as Attorney and Partner. Listed as counsel for CPI-aligned entities including the Frontier Foundation.
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.
10Reportscorroborating18.3 KB · markdownretrieved Mar 14, 2026Cleta Mitchell - Personal Investigation Brief
Personal-level brief on Cleta Mitchell's institutional roles, including Senior Legal Fellow at CPI and officer of the three Compass entities.
Read full document ▸Collapse ▾download raw .md ↗
Cleta Mitchell: A sourced investigative biography
Cleta B. Deatherage Mitchell (born September 16, 1950, Oklahoma City) is a conservative attorney and election activist whose career arc — from feminist Democratic legislator to MAGA legal strategist — represents one of American politics' most dramatic ideological transformations. Every claim below is sourced from credible, named publications; items with evidentiary gaps are flagged.
From ERA champion to conservative power broker
Mitchell was born Cleta Deatherage in Oklahoma City and attended Classen High School. She earned both a B.A. (1973, high honors) and J.D. (1975) from the University of Oklahoma. As a student, she co-founded the Oklahoma Women's Political Caucus in 1971 and campaigned for the Equal Rights Amendment and legal recognition of homemakers' contributions to marital estates. She considered U.S. Senator Margaret Chase Smith her political role model.
Elected in 1976 as a Democrat to the Oklahoma House of Representatives from District 44 (Norman), Mitchell served four two-year terms until 1984. During her second term, she became the first woman in the United States to chair a state house appropriations and budget committee — a milestone confirmed by the Encyclopedia of Oklahoma History and Culture, RNLA, the Washington Post (Jan. 4, 2021), and the Bradley Foundation's own biography of Mitchell.
Her legislative record was distinctly progressive:
- She was the architect of Oklahoma's Open Meetings Act, requiring public bodies to conduct business openly (BatesLine, Oct. 7, 2011, citing OSU oral history transcript).
- She authored a universal preschool proposal, making Oklahoma one of the first states to adopt one. In her own words from an Oklahoma State University oral history: "I insisted that it couldn't be means-based. It had to be universal… It wasn't just some other people who were poor kids" (Washington Post, Jan. 4, 2021).
- She championed the Equal Rights Amendment in Oklahoma. Former Oklahoma legislator Cal Hobson recalled: "She was very intense and determined to pass the Equal Rights amendment. I would say that was her number one priority" (The Guardian, July 2, 2024).
- She ended unrecorded votes in the legislature, computerized voter records, and created "displaced homemaker" training programs (BatesLine, Oct. 7, 2011, summarizing OSU oral history).
Mitchell was named one of ten outstanding young women in America by Redbook magazine in 1979, a fellow at Harvard's Kennedy School Institute of Politics in 1981, and one of the most promising Democratic women by Time in 1984 (Encyclopedia of Oklahoma History; Wikipedia).
Her first husband, Duane Draper, and AIDS
Mitchell married Duane Draper, a fellow Oklahoman from Norman, in 1973. In 1980, Draper took a teaching fellowship at Harvard's Kennedy School of Government and moved to Massachusetts. The couple divorced in July 1982 on grounds of "incompatibility."
Draper later came out as a gay man. In 1988, he became the director of AIDS programming at the Massachusetts Department of Public Health. He died of AIDS on February 11, 1991, at his home in Brookline, Massachusetts, at age 43. This is confirmed by a contemporaneous obituary in the Orlando Sentinel (Feb. 14, 1991), which states: "Draper, the director of AIDS programs for the state Department of Public Health, died Monday of AIDS in Boston. He was 43. He died at his home in Brookline. In 1990, Draper visited first lady Barbara Bush at the White House and received a Victory Award at the Kennedy Center. His story was featured last year on NBC's Today show."
Multiple additional sources corroborate this: Wikipedia (citing The Atlantic, The Oklahoman, and other primary sources); Above the Law (David Lat, April 2013); NRA On the Record database; and The Atlantic's profile by Jonathan Krohn (April 4, 2013). Krohn's Atlantic profile noted Draper's sexuality and death in the context of Mitchell's subsequent anti-gay activism. When Krohn emailed Mitchell about Draper, she reportedly responded: "I think I'm finished talking about this with you — it is a hit piece as I suspected from the start" (The Atlantic, April 4, 2013; Oklahoma Gazette summary).
Important clarification: Draper was Mitchell's ex-husband at the time of his death. They had been divorced for nearly nine years when he died in 1991.
Dale Mitchell's bank fraud conviction and its ideological aftermath
In 1984, Mitchell married Dale E. Mitchell, the son of 1940s–50s All-Star Cleveland Indians outfielder (Loren) Dale Mitchell. Dale Mitchell served as CEO and Chairman of Citizens National Bank and Trust Co. in Oklahoma City. They have one daughter. After leaving the legislature, Cleta Mitchell became vice president at Citizens National Bank (The Guardian, July 2, 2024).
The criminal case. In 1986, the FBI began investigating Dale Mitchell for banking malpractice. Citizens National Bank was declared insolvent that same year. In 1988, Mitchell agreed to permanent removal from the banking industry at the request of the U.S. Comptroller of the Currency. He was convicted in approximately late 1991 or early 1992 on five felony counts: conspiracy to defraud, willful misapplication of bank funds (18 U.S.C. § 656), and making false statements to banks (18 U.S.C. § 1014). The specific conduct included forcing a borrower to purchase stock in his bank holding company as a condition of a loan, misapplying monies of Citizens National Bank, and pledging the same $1.387 million promissory note as collateral to multiple banks without disclosure. The full appellate record is available at United States v. Dale E. Mitchell, 15 F.3d 953 (10th Cir. 1994).
Sentencing. Dale Mitchell received a suspended sentence of five years (probation, no prison time) and was ordered to perform community service. The trial judge was U.S. District Judge Lee R. West (W.D. Oklahoma). Multiple sources note the judge "suggested that Dale had lucked out by avoiding prison time" (Salon, Feb. 23, 2021; Raw Story, July 2, 2024).
Restitution. The district court originally ordered $3,039,740 in restitution. However, the 10th Circuit vacated the restitution order and remanded for further proceedings, noting that Mitchell's pre-sentence investigation report showed him as unemployed with a negative net worth of $4,148,346. The government conceded that $370,852.22 related to a victim not connected to any conviction count, plus $101,000 in attorney fees, needed to be eliminated. The final post-remand restitution amount is not confirmed in available sources. ⚠️ Flag: Salon (2021) cites $1.3 million; most other sources cite approximately $3 million — likely the pre-appeal figure. One conviction (Count 6) was reversed on appeal, leaving four affirmed convictions.
Mitchell's explicit ideological connection. Cleta Mitchell has directly and publicly attributed her political transformation, at least in part, to her husband's prosecution. She is quoted as saying the conviction convinced her that "overreaching government regulation is one of the great scandals of our times." This quote appears in the Washington Post (Kranish and Hamburger, Jan. 4, 2021), Salon (Sollenberger, Feb. 23, 2021), SourceWatch, and is attributed originally to Jane Mayer's 1996 New Yorker profile. The Washington Post reported: "In 1992, Dale Mitchell was convicted of bank fraud, an experience that Cleta Mitchell later said was the result of 'overreaching government regulation.' She became increasingly disenchanted with the social liberal policies she had supported." The Guardian's 2024 profile further reported that "people who had known her in college and in the legislature say that her husband's politics, and the wealth they earned as bankers, had an influence on her politics, pushing her to the right."
The political transformation: Democrat to Republican, 1984–1996
Mitchell's ideological shift was gradual, spanning roughly a decade. Multiple factors contributed, with varying weight depending on the source:
1986: Failed lieutenant governor campaign. Mitchell ran as a Democrat for Oklahoma lieutenant governor but lost the primary to Robert S. Kerr III. Former Oklahoma Governor David Walters said this loss "precipitated a real turn on her part" (The Guardian, July 2, 2024; Wikipedia).
1986–1991: Banking crisis and FBI investigation. The FBI investigation of Dale Mitchell began in 1986. Citizens National Bank was declared insolvent that year. This period coincided with Mitchell's drift away from the Democratic Party.
1991: Moved to Washington, D.C. Mitchell became executive director of the Term Limits Legal Institute — a predominantly conservative cause. She was co-counsel in U.S. Term Limits, Inc. v. Thornton (1995) before the Supreme Court. The Encyclopedia of Oklahoma History states: "After leaving politics, Mitchell decided that politicians are essentially out of touch with the people they represent. Turning her back on her past, she began to work for the movement to limit the number of terms in office."
1992: Husband convicted. The conviction cemented her anti-government views.
1996: Registered Republican. Mitchell formally switched her party affiliation, first to independent, then to Republican (Wikipedia's "List of party switchers"; Urban Milwaukee, Jan. 4, 2021; CNN, Oct. 13, 2021).
Former colleagues' counter-narrative. Multiple former colleagues described the transition as career-driven rather than principled. The Guardian (July 2, 2024) reported: "Former colleagues and classmates described a gifted, ambitious, but self-interested attorney willing to attach herself to whatever cause might propel her career." Robert S. Kerr III told The Guardian: "Cleta has always been, in my opinion, my experience, first foremost and always for whatever is best for what she perceived to be best for herself." Joe Lunn, a University of Oklahoma classmate, described her as "an opportunist." At some point in the 1990s, Mitchell returned to the University of Oklahoma and told former ERA supporters she was glad the amendment had failed. Cal Hobson recalled: "She just gleefully told all these ladies that had supported her and the Equal Rights amendment how happy she was that it had failed and that she was wrong back then" (The Guardian, July 2, 2024).
Board positions and organizational affiliations
The following roles are confirmed with sources:
Lynde and Harry Bradley Foundation — Board member and currently Secretary. She has served since at least 2013 (Urban Milwaukee, June 7, 2022). Confirmed by the Bradley Foundation's own website (bradleyfdn.org/our-people/cleta-mitchell), the Federalist Society, and IRS filings cited by SourceWatch. She remained on the board after the January 6 controversy.
American Conservative Union (ACU) — Board member since approximately May 2005 (C-SPAN database). Also served as Chairman of the ACU Foundation (the 501(c)(3) arm), per the Federalist Society biography. She played a central role in banning the gay Republican group GOProud from CPAC in 2011 (The Atlantic, April 4, 2013; LGBTQ Nation, Jan. 2021). GOProud co-founder Chris Barron publicly called her "just a nasty bigot" (LGBTQ Nation).
Institute for Free Speech (formerly Center for Competitive Politics) — Board member. Confirmed by SourceWatch ("as of August 2017") and GuideStar (Form 990, charity #20-3676886), which listed her with her Foley & Lardner title.
Public Interest Legal Foundation (PILF) — Board Chair from approximately 2020 (C-SPAN database). Confirmed by SourceWatch, Votebeat (Nov. 2021), and Issue One. ⚠️ Flag: EXPOSEDbyCMD (March 2026) refers to her as "longtime board chair through 2022," suggesting she may no longer hold the chairmanship, but other sources still list her as chairman based on the most recent IRS filings.
National Rifle Association (NRA) — Mitchell served as both an NRA board member (now former, per NRA On the Record database) and as outside counsel — not General Counsel. ⚠️ Correction: Her role was outside counsel, not general counsel. Her own Election Integrity Network biography states: "Cleta has served as outside counsel to the NRCC, NRSC, NRA, and numerous Republican members of Congress." Her most prominent NRA legal work was serving as co-counsel in McConnell v. FEC, the Supreme Court challenge to the 2002 Bipartisan Campaign Reform Act (McCain-Feingold). The ABA Journal (Jan. 5, 2021) confirmed this. CNBC (June 2019) described her as "a longtime lawyer for the NRA."
Foley & Lardner LLP — Partner in the Washington, D.C., office from 2001 to January 5, 2021. She resigned after the Washington Post published audio of her participation in the Trump-Raffensperger phone call (Jan. 2, 2021). Foley & Lardner stated: "Cleta Mitchell has informed firm management of her decision to resign from Foley & Lardner effective immediately." Mitchell blamed "a massive pressure campaign mounted by leftist groups via social media" (NPR, Jan. 6, 2021; ABA Journal, Jan. 5, 2021).
Conservative Partnership Institute (CPI) — Senior Legal Fellow and Secretary, from 2021 to present. CPI was founded by former Sen. Jim DeMint; former White House Chief of Staff Mark Meadows is also a senior member. CPI received funding from Trump's Save America PAC (multiple sources).
Election Integrity Network (EIN) — Founder and Chair, launched 2021 under CPI. In 2023, EIN moved to be administered by the Virginia Institute for Public Policy. The New York Times obtained over 400 hours of recordings from EIN's weekly video calls, finding Mitchell's network had "done more than any other group to take Mr. Trump's falsehoods about corruption in the democratic system and turn them into action" (NYT, Berzon et al., Oct. 2024).
Other confirmed affiliations: Council for National Policy, Board of Governors (SourceWatch, as of Sept. 2020); Republican National Lawyers Association, former president (RNLA bio); International Foundation for Electoral Systems, board member (Persagen); U.S. Election Assistance Commission, Board of Advisors (Nov. 2021–Nov. 2023); American Law Institute, elected member (2016, per Bradley Foundation bio); trustee of EPA Administrator Scott Pruitt's legal defense fund (Wikipedia); National Organization for Marriage, attorney (2011); and officer of Steve Bannon's Citizens of the American Republic nonprofit (CNBC, June 2019).
Key profiles and long-form journalism
The following major investigative profiles cover Mitchell's full biography:
Jane Mayer, "The Outsider," The New Yorker (Oct. 21 & 28, 1996). The earliest major national profile. Source of the "overreaching government regulation" quote. Covers her political transformation, husband's conviction, and party switch. Behind the New Yorker paywall; referenced in the Oklahoma Historical Society bibliography and Salon (2021).
Jane Mayer, "The Big Money Behind the Big Lie," The New Yorker (Aug. 9, 2021). Major investigative piece on dark money funding election denial. Mitchell is a central figure. Details her Bradley Foundation role and election integrity activities. Won the Sidney Award from the Hillman Foundation.
Jonathan Krohn, "Meet Cleta Mitchell, the Conservative Movement's Anti-Gay Eminence Grise," The Atlantic (April 4, 2013). The most detailed profile of her personal transformation and first marriage. Covers GOProud ban, Duane Draper's sexuality and death, and Mitchell's refusal to discuss the topic.
Michael Kranish and Tom Hamburger, "Cleta Mitchell, a key figure in president's phone call, was an early backer of Trump's voter fraud claims," Washington Post (Jan. 4, 2021). Breaking profile after the Raffensperger call. Extensive biographical details, Grover Norquist quotes, and Dale Mitchell conviction narrative.
Roger Sollenberger, "One phone call with Donald Trump destroyed this Republican lawyer's career," Salon (Feb. 23, 2021). Detailed investigative profile covering her full arc from Oklahoma to Trump's Georgia call.
Peter Stone, The Guardian (July 2, 2024). Extended profile with original interviews from former colleagues including Cal Hobson, Robert S. Kerr III, Joe Lunn, and David Walters. Published as an interactive feature. Covers the "opportunism" counter-narrative in depth.
Alexandra Berzon, Nick Corasaniti, et al., "Inside the Movement Behind Trump's Election Lies," New York Times (Oct. 2024). Based on 400+ hours of EIN meeting recordings. Focuses on Mitchell's post-2020 organizing infrastructure.
Christine Pappas, "Mitchell, Cleta Deatherage," Encyclopedia of Oklahoma History and Culture (published Jan. 15, 2010; updated Sept. 27, 2022). Authoritative encyclopedic entry from the Oklahoma Historical Society.
Additional profiles: Above the Law (David Lat, April 2013); Urban Milwaukee (Bruce Murphy, Jan. 4, 2021 and July 27, 2022); The Intercept (Andrew Donohue, Sept. 13, 2023, on her escape from Georgia indictment); The New Republic (Peter Stone, 2022); NPR/Fresh Air (Terry Gross interview with Jane Mayer, Aug. 5, 2021); Law & Crime (Jan. 2021). A former NRA official was quoted in The New Republic: "You tell Cleta where you want to end up, and she will come up with a way to get you there, whether it's legal or not."
Conclusion: What remains uncertain
Three factual points carry genuine ambiguity and should be flagged in any published account. First, the final restitution figure in the Dale Mitchell case: the 10th Circuit vacated the original $3,039,740 order and remanded for reconsideration; whether the post-remand amount was closer to $1.3 million (Salon's figure) or remained near $3 million is unresolvable from available sources. Second, the precise timeline of Mitchell's independent registration — whether she registered as independent before or simultaneously with her 1996 Republican registration is reported inconsistently. Third, her current status on several boards (PILF chairmanship, ACU board, Institute for Free Speech) may have changed since the most recent IRS filings available. Finally, her role with the NRA was as outside counsel, not General Counsel — a distinction worth noting precisely in any published piece. The primary source for Mitchell's own voice on many biographical matters is her Oklahoma State University oral history interview (Women of the Oklahoma Legislature project), which has been quoted extensively in secondary sources but was not directly accessible online during this research.
10Reportscorroborating13.9 KB · markdownretrieved Mar 14, 2026Mitchell Financial Network - Red Flags (Analysis)
Issue-by-issue red flags pulled from the Mitchell-aligned financial network.
Read full document ▸Collapse ▾download raw .md ↗
Mitchell Financial Network — Red Flags Investigation
Classification: Active Investigation Date Initiated: 2026-02-16 Primary Target Entities: [[1792 Exchange]], [[Conservative Partnership Institute]], [[State Freedom Caucus Network]], [[Lynde and Harry Bradley Foundation]] Key Individual: [[Cleta Mitchell]]
Executive Summary
Analysis of 1792 Exchange's 2023 Form 990 (EIN 27-3707886), State Freedom Caucus Network filings, vault intelligence, and ProPublica financial data reveals a network of interlocking conservative organizations with six significant financial anomalies. Cleta Mitchell sits at the nexus — simultaneously serving as Secretary of 1792 Exchange, Senior Legal Fellow at [[Conservative Partnership Institute|CPI]], Bradley Foundation Board Member, and founder of the [[Election Integrity Network]].
Key Finding: Multiple structural red flags suggest this network may function as a coordinated dark money pipeline, with anonymous donors funding entities that share leadership, addresses, and operational infrastructure while maintaining minimal public transparency.
Red Flag #1: Explosive, Unexplained Revenue Growth
| Year | Revenue | YoY Growth |
|---|---|---|
| 2021 | $225,296 | — |
| 2022 | $2,321,653 | +930% |
| 2023 | $5,818,826 | +150% |
26x revenue growth in 2 years — from a small advocacy outfit to a $5.8M operation. This growth pattern is consistent with a coordinated funding injection rather than organic donor development.
Source: ProPublica Nonprofit Explorer, EIN 83-2470389 filings.
Red Flag #2: Extreme Donor Concentration & Anonymity
1792 Exchange's $5.8M in 2023 revenue came from only 6 donors, all anonymous:
| Donor | Contribution | % of Total |
|---|---|---|
| Donor A | $1,750,000 | 30.1% |
| Donor B | $1,300,000 | 22.3% |
| Donor C | $1,193,576 | 20.5% |
| Donor D | $800,000 | 13.7% |
| Donor E | $350,000 | 6.0% |
| Donor F | $250,000 | 4.3% |
| Total (6 donors) | $5,643,576 | 97.0% |
Schedule O of the 990 confirms: "No documents are available to the public."
Source: 1792 Exchange 2023 Form 990, Schedule B.
Red Flag #3: Suspicious Compensation Practices
Officer Compensation (2023)
| Officer | Title | Base Comp | Other Comp | Total |
|---|---|---|---|---|
| [[Katharine Sullivan]] | General Counsel & SVP | $270,128 | $19,764 | $289,892 |
| [[Paul Fitzpatrick]] | President | $270,128 | $16,308 | $286,436 |
| [[Erica Moshtahedian]] | Vice President | $150,000 | $16,308 | $166,308 |
| Total | $742,636 |
Schedule J Disclosure (ALL answered "Yes")
| Item | Response | Significance |
|---|---|---|
| 4a: Severance/change-of-control payments | Yes | Golden parachute provisions at a 501(c)(3) |
| 4b: Supplemental nonqualified retirement | Yes | Deferred comp arrangements — unusual for nonprofits |
| 4c: Equity-based compensation | Yes | Equity comp at a tax-exempt org — very unusual |
| 5a: Compensation contingent on revenue | Yes | Officers paid more if org raises more |
| 5b: Compensation contingent on net earnings | Yes | Profit-sharing at a nonprofit — extreme red flag |
| 6a: Non-fixed payments to non-officers | Yes | Variable pay throughout org |
| 6b: Bonus/incentive comp to non-officers | Yes | Performance bonuses across the organization |
Revenue-contingent and earnings-contingent compensation (5a, 5b) at a 501(c)(3) is a major IRS compliance concern. This structure incentivizes officers to maximize revenue rather than fulfill charitable mission.
Source: 1792 Exchange 2023 Form 990, Schedule J.
Red Flag #4: "Care-of" Address & Phantom Office
1792 Exchange is filed "care-of Cleta Mitchell" at an Ohio address, despite:
- Reporting 14 employees (W-2s)
- Paying $742K+ in executive compensation
- Operating a $5.8M budget
An organization of this size operating out of someone else's care-of address suggests either: shared infrastructure with another entity, minimal actual operations, or deliberate address obfuscation.
Source: 1792 Exchange 2023 Form 990, Part I.
Red Flag #5: Negligible Grantmaking Despite Charitable Status
Despite $5.8M in revenue, 1792 Exchange made exactly one grant in 2023:
| Recipient | EIN | Amount | Purpose |
|---|---|---|---|
| [[United Charitable]] | 20-4286082 | $7,190 | Educational |
$7,190 in grants on $5.8M in revenue = 0.12% grant rate.
The remaining funds were allocated:
- ~$1.2M → Compensation & benefits
- ~$4.9M → "Program expenses" (vague categories)
- ~$330K → Operating deficit
Investigation needed: Where did $4.9M in "program expenses" go? The 990 does not break this down sufficiently. [[United Charitable]] requires investigation as a potential pass-through.
Source: 1792 Exchange 2023 Form 990, Schedule I.
Red Flag #6: SFOF ↔ [[Conservative Partnership Institute|CPI]] Hidden Financial Relationship
The State Freedom Caucus Network 2023 Form 990 reveals:
"Due from [[Conservative Partnership Institute]], Inc. — $244,944"
This balance sheet entry shows [[Conservative Partnership Institute|CPI]] owes SFOF $244,944 — indicating either:
- A fiscal sponsorship arrangement ([[Conservative Partnership Institute|CPI]] hosting SFOF operations)
- An inter-organizational loan
- Shared vendor payments flowing through [[Conservative Partnership Institute|CPI]]
Ed Corrigan ([[Conservative Partnership Institute|CPI]] President & CEO) signed the anti-ESG letter organized by SFOF alongside [[Paul Fitzpatrick]] of 1792 Exchange.
Source: State Freedom Caucus Network 2023 Form 990, Schedule D/Balance Sheet.
Red Flag #7: CPI Revenue Explosion Post-January 6
CPI EIN: 82-1470217 — Also filed "care-of Cleta Mitchell" at 300 Independence Ave SE, Washington DC.
[[Conservative Partnership Institute|CPI]] Revenue Trajectory (ProPublica)
| Year | Revenue | Contributions | Officer Comp | Assets | YoY Growth |
|---|---|---|---|---|---|
| 2017 | $1,787,723 | $1,787,723 | $0 | $852,189 | — |
| 2018 | $4,328,406 | $4,204,160 | $864,087 | $1,072,033 | +142% |
| 2019 | $5,322,860 | $5,689,725 | $1,008,647 | $1,247,549 | +23% |
| 2020 | $6,202,407 | $7,106,027 | $2,249,705 | $2,629,044 | +17% |
| 2021 | $45,707,730 | $45,027,954 | $1,538,824 | $31,688,292 | +637% |
| 2022 | $36,397,454 | $35,715,410 | $1,996,625 | $63,471,958 | -20% |
| 2023 | $19,498,478 | $19,647,346 | $1,655,980 | $71,058,890 | -46% |
Critical CPI Findings
Post-Jan 6 Revenue Spike: [[Conservative Partnership Institute|CPI]]'s revenue exploded from $6.2M (2020) to $45.7M (2021) — a 637% increase in the year following January 6th, when [[Conservative Partnership Institute|CPI]] provided office space and support to members of Congress who objected to the 2020 election certification.
$72M in Assets: Despite declining revenue, [[Conservative Partnership Institute|CPI]]'s total assets grew from $31.7M (2021) to $71.1M (2022) to $72.3M (2023) — suggesting investment/real estate accumulation.
$27.3M in Secured Mortgages (2023): [[Conservative Partnership Institute|CPI]] holds $27.3M in secured mortgage debt, up from $1.07M (2021) — a massive real estate acquisition financed with debt.
Officer Comp Anomaly (2020): Officers received $2.25M on only $6.2M in revenue (36% of revenue!) — before the 2021 donation flood.
Filed "Care-of Cleta Mitchell": Just like 1792 Exchange, [[Conservative Partnership Institute|CPI]]'s ProPublica record shows the organization is filed care-of Cleta Mitchell — confirming she controls the address/mail for both organizations.
Revenue Mirror Pattern: As [[Conservative Partnership Institute|CPI]] revenue declined ($45.7M → $36.4M → $19.5M), 1792 Exchange revenue surged ($225K → $2.3M → $5.8M) — suggesting funds may be shifting from [[Conservative Partnership Institute|CPI]] to 1792 Exchange over time.
The Interlocking Network
Cleta Mitchell's Simultaneous Positions
| Organization | Role | Start |
|---|---|---|
| [[1792 Exchange]] | Secretary | 2021 |
| [[Conservative Partnership Institute]] | Senior Legal Fellow | 2021 |
| [[Conservative Partnership Institute]] | Board Secretary | 2019–2020 |
| [[Lynde and Harry Bradley Foundation]] | Board of Directors | Active |
| [[Election Integrity Network]] | Founder & Chairman | 2022 |
| [[FAIR Elections Fund]] | Founder & Chairman | 2023 |
Key Personnel Overlap Matrix
| Person | 1792 Exchange | CPI | SFOF | Bradley Fdn |
|---|---|---|---|---|
| [[Cleta Mitchell]] | Secretary | Senior Fellow + Former Board Sec | — | Board Member |
| [[Paul Fitzpatrick]] | President/CEO | — | Panel speaker | — |
| [[Ed Corrigan]] | Anti-ESG letter signer | President & CEO | Anti-ESG letter organizer | — |
| [[The Honorable Jim DeMint]] | — | Chairman | — | — |
Mitchell Family Financial History
Cleta Mitchell's husband, Dale Mitchell, was convicted in 1992 on five felony counts:
- Conspiracy to defraud
- Misapplying bank funds
- Making false statements to banks
- Ordered to pay $3 million in restitution
- Received suspended 5-year sentence
Mitchell has stated this conviction convinced her that "overreaching government regulation is one of the great scandals of our times" — suggesting personal financial crimes motivated her anti-regulatory ideology.
Source: Wikipedia/Oklahoma historical records, confirmed in vault profile.
Open Investigation Threads
Priority 1 — Immediate
- Identify the 6 anonymous donors — FOIA requests, state-level Schedule B filings
- Analyze "program expenses" — $4.9M in vague spending needs itemization
- Investigate [[United Charitable]] (EIN 20-4286082) — sole grant recipient, potential pass-through
- Determine if [[Lynde and Harry Bradley Foundation]] is one of the 6 anonymous donors
- Trace CPI ↔ SFOF $244,944 intercompany balance
Priority 2 — Follow-Up
- Pull CPI 990 (need EIN) — examine for Bradley Foundation grants
- Cross-reference officer compensation across all network entities
- Track Cleta Mitchell's total compensation across all orgs she serves
- Investigate equity-based compensation structure — what "equity" exists at a 501(c)(3)?
- Compare anti-ESG letter signatories against donor/grantee relationships
Priority 3 — Data Quality
- Fix BigQuery dataset location config (us-central1 not found)
- Locate CPI EIN for ProPublica data pull
- Obtain Bradley Foundation 990 Schedule I
- Pull 1792 Exchange 2021 and 2022 990s for compensation trajectory
EINs Referenced
| Organization | EIN | Status |
|---|---|---|
| 1792 Exchange | 27-3707886 / 83-2470389 | Confirmed |
| United Charitable | 20-4286082 | Confirmed — sole grant recipient |
| State Freedom Caucus Network | See 2023 990 | Confirmed |
| Conservative Partnership Institute | 82-1470217 | Confirmed — $72M assets |
| Lynde and Harry Bradley Foundation | 39-6037928 | Confirmed — $987M assets |
Sources
- 1792 Exchange 2023 Form 990 —
/14DocsandFiles/SFOFExposed/25489765-1792-exchange-2023-990.md - State Freedom Caucus Network 2023 Form 990 —
/14DocsandFiles/SFOFExposed/25871656-state-freedom-caucus-network-2023.md - ProPublica Nonprofit Explorer API — EIN 83-2470389
- Cleta Mitchell profile —
/01People/Cleta Mitchell.md - Bradley Foundation dossier —
/04FinancialFlows/Lynde and Harry Bradley Foundation.md - Ed Corrigan profile —
/01People/Ed Corrigan.md - 1792 Exchange "What is ESG" —
/14DocsandFiles/SFOFExposed/23588850-1792-exchanges-what-is-esg.md - Open Letter to Larry Fink —
/14DocsandFiles/SFOFExposed/23742868-open-letter-to-larry-fink.md
Sources
- PRIMARYFECFEC Schedule B: Johnson Leadership Fund (C00771246) to Compass Professional Inc., purpose "CAGING"· 25 itemized disbursements totaling $286,696.79, 2024-02-14 to 2026-03-22, purpose field literally "CAGING" on every line. Committee treasurer of record: Lisa Lisker. Compass Professional Inc. is the same Delaware entity Mitchell is listed as Officer / co-founder of in its 2021 formation paperwork. Note: FEC "caging" purpose codes conventionally describe donor-mail response processing, a standard PAC back-office service; this record does not by itself establish the payments relate to voter-roll list challenges rather than routine contribution-mail handling.
- PRIMARYFECFEC Schedule B: Senate Conservatives Fund (C00448696) to Compass Caging LLC, purpose "PAC CAGING SERVICES"· 13 itemized disbursements totaling $24,698.73, 2024-09-13 to 2026-04-02. Vendor is registered under the name "Compass Caging LLC", distinct from but sharing the Compass branding of the other Mitchell-linked Compass entities. Committee treasurer of record: Paul Kilgore. Same caveat as above on the meaning of "caging" in FEC purpose codes.
- PRIMARYFECFEC Schedule B: Tim Sheehy for Montana (C00844159) to Compass Caging, LLC, purpose "CAGING SERVICES"· 2 itemized disbursements totaling $8,236.75, 2024-10-10 and 2024-10-25. Committee treasurer of record: Katie Wenetta.
- PRIMARYIRS 990CPI Form 990, tax year 2023 (EIN 82-1470217), IRS public e-file XML· IRS-published raw e-file XML for CPI's FY2023 Form 990, pulled via the standard GuideStar/Candid public data lake mirror used elsewhere in this pipeline (see ein_990_filings).
- SECONDARYPressCPI staff page: Cleta Mitchell· CPI's own confirmation of Mitchell's Senior Legal Fellow role and EIN leadership.
- SECONDARYPressInfluenceWatch: Conservative Partnership Institute· Confirms Mitchell as Senior Legal Fellow / Secretary / Chair of EIN. Identifies her as a co-founder of the Public Interest Legal Foundation.
- SECONDARYPressBradley Foundation: People (Cleta Mitchell)
- SECONDARYPressDocumented.net: Compass Legal Group's association with EagleAI· Established Compass Legal as counsel to Valid Vote, the entity managing EagleAI.
- SECONDARYPressDocumented.net: Meet EagleAI (Mar 2024)
- SECONDARYPressExposedByCMD: Cleta Mitchell's new dark money elections group raised $3.9M
- SECONDARYPressPOLITICO Influence (Nov 21, 2024): CPI 2023 990 vendor payments· Documents $2.4M+ in CPI payments to the Compass affiliated vendors.
- SECONDARYPressWikipedia: EagleAI NETwork
- SECONDARYPressJacob Silverman: Charter cities advocates find hope (Apr 2025)· Describes Compass Legal Group as a CPI spinoff helping conservative nonprofits with incorporation, tax compliance, and election law.
Data Provenance & Pipeline Integrity