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March 14, 2023

VIA CERTIFIED MAIL

Mr. Glenton Gilzean, Jr.

Chair, The Florida Commission on Ethics
P. O. Drawer 15709
Tallahassee, Florida 32317-5709

Re: Conduct Violations by Governor DeSantis.

Dear Mr. Gilzean:

There is strong evidence that Governor Ron DeSantis has engaged in illegal conduct pursuant to:

(1) Section 112.313(2) of the Florida Statutes (prohibition on solicitation and acceptance of
gifts);
(2) Article II, Section 8(h)(2) of the Florida Constitution with his wrongful intent evidenced
by his violations of the Federal Campaign Finance Act of 1971, Section 112.31485 of the
Florida Statutes (prohibition on gifts from political committees), and Section 112.3215 of the
Florida Statutes (prohibition on accepting illegal lobbying payments);
(3) Section 112.313(6) of the Florida Statutes (prohibition on misuse of public position); and
(4) Section 112.313(7) of the Florida Statutes (prohibition on conflicting employment or
contractual relationships).

This letter provides ample evidence to support a finding of probable cause1 by the Florida Commission
on Ethics (the “Commission”) that Governor DeSantis, in concert with certain associated political
committees, political consultants, and a 501(c)(4) organization, has solicited and received millions of
dollars’ worth of illegal gifts in violation of Florida State ethics laws and the Florida Constitution.
Absent immediate action by the Commission, Governor DeSantis will continue violating the law by
accepting additional gifts that are clearly intended by self-interested organizations to influence his
official judgment to submit an irrevocable resignation letter as required by Section 99.012(4)(a) of the
Florida Statutes.

INTRODUCTION

Certain activities related to Governor DeSantis’s ascension to the national stage, insofar as they are
funded by a vast network of political committees, non-profit organizations, and prominent political
operatives, are unlawful because they serve his personal political objectives, are in furtherance of his
personal financial gain at the expense of Florida taxpayers, and are intended to influence his official
decision to resign from office. It is no secret that Governor DeSantis aspires to national prominence.
In fact, and as detailed herein, Governor DeSantis is already a de facto candidate for President of the
United States under federal election laws. Governor DeSantis’s failure to declare his candidacy is no
mere oversight; it is a coordinated effort specifically designed for him to accept, as unethical gifts,
illegal campaign contributions and certain personal benefits that are necessarily intended to influence

1 See § 112.311(3), Fla. Stat. (2020).

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his official decision to resign from office under Florida’s resign to run law.2 Governor DeSantis’s ham-
handed maneuverings have rendered him irreparably conflicted and have left the statehouse vacant.3

Part II of Chapter 112 of the Florida Statutes contains standards of ethical conduct applicable to
Governor DeSantis. Specifically, the state legislature enacted the ethics laws to ensure that public
officials “hold their positions for the benefit of the public . . . regardless of personal considerations
[and that] [s]uch officers are bound to observe, in their official acts, the highest standards of ethics . .
. regardless of personal considerations.”4 Upon finding that Governor DeSantis has violated Florida
ethics laws and the State Constitution, the Commission should impose on him (and certain political
committees) the most severe penalties permitted by Section 112.317 and Section 112.31485 of the
Florida Statutes. This includes, without limitation, one or more of the following: (a) impeachment;
(b) removal from office; (c) public censure; (d) ballot disqualification; and (e) payment of fines, in
certain cases, equaling three times the value of the illegal gift.5

I. Governor DeSantis is Focused on his Shadow Presidential Campaign.

Like all Florida officials, Governor DeSantis is an “agent[] of the people” who must “hold [his]
position[] for the benefit of the people.”6 Unlike other Florida officials, Governor DeSantis is
leveraging his elected office and breaching his associated duties in a coordinated effort to develop his
national profile, enrich himself and his political allies, and influence the national electorate. A non-
comprehensive list of Governor DeSantis’s recent activities clearly indicates that he has abused his
office and abdicated his official duties in favor of pursuing his national political interests.

● Governor DeSantis has met with influential figures in early primary states;7
● Governor DeSantis’s team is vetting operatives in early primary states;8
● Governor DeSantis appeared on television and radio advertisements calling for a convention
to amend the United States Constitution;9
● People allied with Governor DeSantis launched a 501(c)(4) organization to support his
presidential candidacy by sponsoring his events in New York, Philadelphia, and Chicago;10

2 Virginia Chamlee, Florida Might Change a State Law So Ron DeSantis Can Run for President
and Be Governor at the Same Time, PEOPLE (Nov. 23, 2022, 2:13 PM),
https://people.com/politics/florida-may-change-state-law-for-ron-desantis-presidential-run/.
3 Claire Hansen, DeSantis Embarks on National Tour as Speculation Swirls About
His Future, U.S. NEWS (Feb. 28, 2023, 5:16 PM),
https://www.usnews.com/news/national-news/articles/2023-02-28/desantis-embarks-on-national-tour-as-
speculation-swirls-about-his-future.
4 See § 112.311(6), Fla. Stat. (2020).
5 See § 112.317, Fla. Stat. (2020); § 112.31485(3), Fla. Stat. (2013).
6 See § 112.331(6), Fla. Stat. (2020).
7 Alex Roarty, DeSantis meets with Iowa influencer ahead of book release as 2024 hopefuls make moves, MIAMI HERALD
(Feb. 24, 2023, 12:00 PM), https://www.aol.com/news/desantis-meets-iowa-influencer-ahead-
170059810.html.
8 Nancy Cook, DeSantis Preps 2024 Bid Behind Scenes While Waiting to Declare, BLOOMBERG (Feb. 10, 2023, 5:33
PM), https://www.bloomberg.com/news/articles/2023-02-10/desantis-preps-2024-bid-behind-scenes-while-
waiting-to-declare?srnd=premium#xj4y7vzkg&leadSource=uverify%20wall&leadSource=uverify%20wall.
9 Kirby Wilson, Ron DeSantis, appearing in Idaho ads, calls for a constitutional convention, TAMPA BAY TIMES (Feb. 23,
2023), https://www.tampabay.com/news/florida-politics/2023/01/24/ron-desantis-appearing-idaho-ads-calls-
constitutional-convention/.
10 Alex Isenstadt, A new nonprofit group is helping DeSantis go national, POLITICO (Feb. 20, 2023, 9:06 PM),
https://www.politico.com/news/2023/02/20/nonprofit-desantis-florida-00083692.

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● People close to Governor DeSantis are interviewing staff for a presidential campaign;11
● Allies of Governor DeSantis have formed and are raising soliciting dollar donations for a
federal draft PAC named Run, Ron, Run!;12
● Prominent Republican consultants are recruiting staffers for a DeSantis aligned federal PAC;13
● Governor DeSantis met with individuals who are likely to play key roles in his presidential
campaign; 14
● Governor DeSantis’s Florida political committee, Friends of Ron DeSantis, continues to
fundraise (despite him being term limited in the State of Florida)15 and has made, in violation
of state and federal campaign finance laws, inappropriate expenditures aimed at a national
audience;16 and
● Governor DeSantis has launched a personally lucrative book tour.17

II. Governor DeSantis Solicited and/or Received Millions of Dollars of Benefits in Connection
with his Shadow Presidential Campaign.

Governor DeSantis has solicited and accepted millions of dollars in benefits, each of which are
properly classified as gifts under Section 112.313(2) of the Florida Statutes. The gifts outlined in
Sections A and B below (referred to hereinafter as, the “Gifts List”) are made by organizations and
individuals that (a) are funded by donations from Governor DeSantis’s political supporters and,
therefore, (b) have a direct financial interest in his official decision to resign from office and run for
president. The gifts outlined in Section C below relate to his book tour, which he is using as cover for
his shadow presidential campaign. Furthermore, pursuant to Article II, Section 8 of the Florida
Constitution and Section 112.3144 of the Florida Statutes, Governor DeSantis must publicly report
each of the items contained in the Gifts List by July 1, 2023.

A. Gifts from Political Committees.

● Friends of Ron DeSantis, Governor DeSantis’s Florida political committee, has raised
approximately $12,000,000 and made expenditures in excess of $1,600,000 since January 1,
2023, to promote his presidential candidacy;18

11 Cook, supra note 8.

12 Paid Political Advertisement Paid for by Run, Ron, Run!, WINRED, https://secure.winred.com/never-back-
down-inc/20230308-launch-tag/?utm_medium=social&utm_source=tag&utm_term=nbd-us-
pac&utm_campaign=20230308-launch&utm_content=20230308-launch-tag-1 (last visited Mar. 10, 2023).
13 Brett Samuels, How outside groups are boosting DeSantis before a possible 2024 bid, THE HILL (Feb. 10, 2023, 6:00
AM), https://thehill.com/homenews/campaign/3851814-how-outside-groups-are-boosting-desantis-before-a-
possible-2024-bid/.
14 Aaron Navarro, DeSantis gathers donors, GOP politicians at event as he considers 2024
presidential run, CBS News (Feb. 27, 2023, 11:32 AM), https://www.cbsnews.com/news/desantis-donors-gop-
retreat-considers-2024-presidential-run/.
15 Paid Political Advertisement Paid for by Friends of Ron DeSantis, WINRED, https://secure.winred.com/ron-
desantis/the-freedom-blueprint-newsletter-feb-11 (last visited Mar. 10, 2023).
16 @WC_Elections, TWITTER (Feb. 26, 2023, 7:30 PM),
https://twitter.com/WC_Elections/status/1630002415868194816.
17 Zachary Basu, DeSantis readies de facto presidential campaign, AXIOS (Feb. 27, 2023),
https://www.axios.com/2023/02/28/desantis-campaign-launch-book-tour.
18 Friends of Ron DeSantis Contributions, FRIENDS OF RON DESANTIS,
https://friendsofrondesantis.com/wp-content/uploads/2023/02/fordcont-022423.pdf
(last visited Mar. 10, 2023).

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● According to the most recent data, Federal political committees, including Ready for Ron,
Ron to the Rescue, and Courageous Conservatives PAC, are actively raising money and
making expenditures advocating Ron DeSantis’s election as president;
o Ready for Ron made $281,405.21 in disbursements,19
o Ron to the Rescue made $1,273.00 in disbursements,20 and
o Courageous Conservatives PAC made $277,617.23 in disbursements;21
● The founder of Ron to the Rescue, a Federal Super PAC, says “he has 10 staffers and about
$20 million in commitments to support a DeSantis presidential campaign.”22
● The Republican State Leadership Committee, a federal political committee, has thrown its
financial support behind Governor DeSantis and has its own fundraising activities in support
of Governor DeSantis’s presidential run and has promoted his book;23
● Courageous Conservatives PAC has placed paid digital advertisements promoting Governor
DeSantis’s presidential run;24
● Federal political committees are reportedly making consulting payments for potential
presidential campaign staff;25
● Ron to the Rescue, a Federal Super PAC, had “a booth at the New Hampshire GOP meeting,
manned by staff from the super PAC and volunteers who are from New Hampshire, including
former state officials who are supporting the Florida governor[;]”26 and
● Attendees to the Lincoln Reagan Dinner 2023, sponsored by the Harris County Republican
Party, are reportedly paying $500 or more per ticket to receive a copy of Governor DeSantis’s
book.27

B. Gifts from Issue-Advocacy Organizations.

● A 501(c)(4) organization, formed on January 30, 2023, named And to the Republic (a) has
hosted three events featuring Governor DeSantis in New York, Philadelphia, and Chicago,28

19 Ready for Ron FEC Filings, FEDERAL ELECTION COMMISSION,

https://docquery.fec.gov/cgi-bin/forms/C00815928/1686534/ (last visited Mar. 10, 2023).
20 Ron to the Rescue FEC Filings, FEDERAL ELECTION COMMISSION,
https://docquery.fec.gov/cgi-bin/forms/C00828400/1679914/ (last visited Mar. 10, 2023).
21 Courageous Conservatives PAC FEC Filings, FEDERAL ELECTION COMMISSION,
https://docquery.fec.gov/cgi-bin/forms/C00587022/1674639/ (last visited Mar. 10, 2023).
22 Forrest Saunders, Gov. Ron DeSantis launches new book, ratcheting up 2024 speculation,
WPTV (Feb. 28, 2023, 7:15 PM), https://www.wptv.com/news/political/gov-ron-desantis-
launches-new-book-ratcheting-up-2024-speculation.
23 Republican State Leadership Committee, FACEBOOK (Feb. 24, 2023, 3:07 PM),
https://www.facebook.com/RepublicanFutureLeaders/videos/612622557368916/. See Fla. CEO No. 17-5
(Jun. 14, 2017) (holding that Section 112.313(2) prohibits a city commissioner from soliciting or accepting any
advertising revenue based on an understanding that the revenue contribution will influence their official
action).
24 @CourageousCPAC, TWITTER (Feb. 28, 2023, 9:24 AM),
https://twitter.com/CourageousCPAC/status/1630574591138512896.
25 Cook, supra note 8.
26 Brett Samuels, Pro-DeSantis group to launch ‘opening salvo' in New Hampshire at GOP
meeting, MSN (Jan. 27, 2023), https://www.msn.com/en-us/news/politics/pro-desantis-group-
to-launch-opening-salvo-in-new-hampshire-at-gop-meeting/ar-AA16NFfS.
27 Harris County Republican Party’s Lincoln Raegan Dinner 2023, Harris County GOP,
https://www.harriscountygop.com/wp-content/uploads/2023/02/LRD2023_2.21.pdf
(last visited Mar. 10, 2023).
28 Isenstadt, supra note 10.

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(b) reportedly intends to host future events featuring Governor DeSantis that will no doubt
involve the solicitation even more contributions in furtherance of his presidential run,29 and
(c) has paid for Facebook advertisements in Iowa and Nevada to promote Governor
DeSantis’s upcoming travel to these states;30 and
● Governor DeSantis has solicited and received other gifts associated with And to the Republic’s
activities, which likely include (a) the use of real property necessary for the book tour and
speaking events such as a speaking venue and hotel rooms, (b) air and ground transportation
necessary for the book tour, (c) services needed for the events, such as staffing requirements,
(d) products needed while attending the speaking events, such as food and beverage.

C. Gifts Related to His Book Tour.

● In the run-up to his presidential campaign, Governor DeSantis “has agreed to a lucrative book
deal with HarperCollins”;31
● Royalties, which have been increased by book sales and promotion by political committees, as
described above; and
● Governor DeSantis has solicited and received other gifts associated with the book tour, which
likely include (a) the use of real property necessary for the book tour and speaking events such
as a speaking venue and hotel rooms, (b) air and ground transportation necessary for the book
tour, (c) services needed for the events, such as staffing requirements, and (d) products needed
while on the book tour, such as food and beverage.

Despite millions of dollars in gifts that Governor DeSantis has directly and indirectly solicited and
received, he has improperly used state-funded resources to ensure that the gifts remain in the accounts
of the organizations that support his presidential aspirations. As reported by News 6 Orlando,
Governor DeSantis’s security detail has traveled with him in connection with certain out-of-state
events in furtherance of his presidential campaign.32

STANDARD OF REVIEW

The Commission shall undertake a preliminary investigation over any legally sufficient complaint.33
Upon conducting a preliminary investigation, the Commission needs to find that there is probable

29 Id. See also Fla. CEO No. 19-1 (Jan. 30, 2019) (holding that Section 112.313(2) prohibits a School Board
member is prohibited from soliciting contributions to a non-profit organization based on an understanding that
such contribution will influence an official act); Fla. CEO No. 19-13 (Sep. 13, 2019) (holding that a police chief
may solicit contributions for a non-profit unless those donations are used to purchase equipment for the police
department, in which case the donations would be an indirect gift to the police chief).
30 @FWIWnews, Twitter (Mar. 5, 2023),
https://twitter.com/fwiwnews/status/1632380447878414341?s=46&t=oagstSWB0qDew9p_
Ww6-Ew.
31 Rachael Bade, Politico Playbook: Operation ‘Stop Greitens’ Goes Awry, POLITICO (Feb. 17, 2022, 6:27 AM),
https://www.politico.com/newsletters/playbook/2022/02/17/operation-stop-greitens-goes-awry-00009720.
32 Erik Sandoval, Florida Gov. DeSantis travel expenses jump 50% as he prepares to begin next term, NEWS 6 ORLANDO
(Nov. 18, 2022, 5:00 PM), https://www.clickorlando.com/news/investigators/2022/11/18/florida-gov-
desantis-travel-expenses-jump-50-as-he-prepares-to-begin-next-term/. Governor DeSantis’ use of state
resources for these expenditures is in potential violation of Section 106.15 of the Florida Statutes. See § 106.15,
Fla. Stat. (2002).
33 § 112.324(3), Fla. Stat. (2018).

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cause that a violation of law occurred.34

ARGUMENT

Governor DeSantis’s national political activities breach the public trust because they are designed
(a) to enrich himself and certain organizations that support his presidential candidacy through an illegal
gifting scheme while (b) skirting federal campaign finance laws and (c) influencing his decision to
resign from office pursuant to Florida’s resign to run law. The Commission has an obligation to
investigate whether Governor DeSantis’s national political activities constitute an impermissible
conflict between his public duty and his private interests and/or a breach of public trust.

I. Governor DeSantis Violated Section 112.313(2).

Section 112.313(2) of the Florida Statues prohibits Governor DeSantis from soliciting or accepting
“anything of value . . . including a gift, loan, reward, promise of future employment, favor, or service,
based upon any understanding that the vote, official action, or judgment of [Governor DeSantis]
would be influenced thereby.”35

As will be described below, a Florida Governor’s decision to run for President of the United States
necessarily requires the exercise of his official duties. Therefore, anything of value solicited by or
provided to him with the understanding that he will run for president and resign as Governor of
Florida, pursuant to Section 99.012(4)(a) of the Florida Statutes, is illegal and must be investigated.

A. Governor DeSantis Solicited and Received Illegal Gifts.

The definition of a “gift,” which is a subcategory of “anything of value,” broadly includes, without
limitation, services, transportation, food and beverage, the use of real property, tangible or intangible
personal property, and any service or thing having an attributable value.36 A gift may be received
directly by the donee or indirectly by a third party. Governor DeSantis’s book tour and concurrent
speaking engagements, whether sponsored by a 501(c)(4) organization, political committees, or other
non-profit organizations, each undoubtedly include gifts solicited by him or his agents, directly,
indirectly, or implicitly37 or provided to him, directly or indirectly, by individuals seeking to influence
his official actions.38 These gifts are outlined in the Gifts List.

34 Id.
35 § 112.313(2), Fla. Stat. (2019).
36 § 112.312(12)(a), Fla. Stat. (2020).
37 See § 496.404(24)(c) defining “Solicitation” as “a request, directly or indirectly for money . . . or any other thing
of value . . . . [including by] [d]istributing, circulating, posting, or publishing any . . . written advertisement, or
other publication that directly or by implication seeks to obtain any contribution[.]” See, e.g., @clinkit_drinkit,
TWITTER (Mar. 1, 2023, 2:49 PM), https://twitter.com/clinkit_drinkit/status/1627025044579794948 (showing
that “Team DeSantis” distributed invitations to an event reportedly sponsored by And to the Republic, a
501(c)(4) organization. See supra note 12 (showing Governor DeSantis’s likeness being used in draft PAC ads).
38 The Commission’s determinations in analogous circumstances counsel in favor of an investigation into
Governor DeSantis’s recent activities. See Fla. CEO No. 19-13 (Sep. 13, 2019) (holding that a police chief may
solicit contributions for a non-profit unless those donations are used to purchase equipment for the police
department, in which case the donations would be an indirect gift to the police chief); CEO No. 19-17 (Oct.
30, 2019) (noting that a city official may not solicit contributions on behalf of a non-profit organization if the
donation is based upon the understanding that it will influence the city official’s official actions); Fla. CEO No.
13-2 (Mar. 13, 2013) (noting that that a charitable contribution could be used or offered as a quid pro quo for

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The primary purpose of this scheme is to benefit, directly and indirectly, Governor DeSantis by
elevating his national prominence and enriching organizations that support his federal candidacy.39
Not surprisingly, Governor DeSantis has not made substantial efforts to denounce these political
committees’ unauthorized use of his name, image, and likeness in their fundraising campaigns;
presumably, because these activities and expenditures finance his shadow campaign for president.
Governor DeSantis, through both his direct participation and inaction, has directly, indirectly, and
implicitly solicited40 and accepted millions of dollars of direct and indirect gifts.41

Abusing his office to solicit and receive illegal gifts is a critical component of Governor DeSantis’s
shadow presidential campaign. These events financially enrich, both directly and indirectly, Governor
DeSantis and the political committees that support his candidacy for president.42 As reported by CNN:

The seven-figure checks arrived ahead of what has amounted to a late-

February soft launch of DeSantis’ highly anticipated run for president.
On Monday, DeSantis held campaign-style rallies with police officers
in New York, Philadelphia, and Chicago, where he regaled the crowds
with stories of the culture wars. . . . And his memoir, “The Courage
to Be Free,” drops next Tuesday, with plans for a national book tour
and events scheduled with GOP activists in Texas, California, and
Alabama.43

Not only has Governor DeSantis personally solicited and accepted valuable gifts in connection with
his shadow presidential campaign, but he has also enriched himself through a lucrative book advance44
and associated royalties. The Commission must investigate.

B. The Gifts are Intended to Influence Mr. DeSantis’s Official Judgment.

The law and circumstances surrounding Governor DeSantis’s shadow presidential campaign show
that he is receiving gifts with the understanding that they will influence his official judgment. Under
Florida law, a sitting Governor’s decision to run for President of the United States is not primarily
personal; rather, it involves the exercise of an official act. Section 99.012(4)(a) of the Florida Statutes
requires that Governor DeSantis must submit a resignation letter in advance of his qualification for

official action); Fla. CEO No. 15-13 (Dec. 16, 2015) (noting that an opportunity to participate in a charitable
endeavor could be used or offered as a quid pro quo for official action).
39 See Fla. CEO No. 19-13 (Sep. 13, 2019) (holding that a police chief may solicit contributions for a non-profit
unless those donations are used to purchase equipment for the police department, in which case the donations
would be an indirect gift to the police chief).
40 See supra note 37.
41 See Fla. CEO No. 91-37 (Jul. 19, 1991).
42 Fla. CEO No. 19-17 (Oct. 30, 2019) (noting that a city official may not solicit contributions on behalf of a non-
profit organization if the donation is based upon the understanding that it will influence the city official’s
official actions); Fla. CEO No. 13-2 (Mar. 13, 2013) (noting that that a charitable contribution could be used or
offered as a quid pro quo for official action).
43 Steve Contorno, DeSantis gets 7-figure checks from top GOP donors as he soft launches presidential campaign, CNN (Feb.
22, 2023, 7:48 AM), https://www.cnn.com/2023/02/22/politics/ron-desantis-donors/index.html.
44 Rachael Bade, Politico Playbook: Operation ‘Stop Greitens’ Goes Awry, POLITICO (Feb. 17, 2022, 6:27 AM),
https://www.politico.com/newsletters/playbook/2022/02/17/operation-stop-greitens-goes-awry-00009720.

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candidacy.45 Even those close to Governor DeSantis have acknowledged that he is required to submit
a resignation letter prior to qualification for federal candidacy.46 Put plainly, only a sitting governor
can decide to resign his office and, because of the serious consequences associated with that decision,47
it necessarily involves the exercise of his official judgment. Governor DeSantis’s decision to resign
from office and run for president is a decision he can only make in his official capacity.

Florida law provides that an individual’s state of mind, such as their intent or understanding at a
particular time, can be established by circumstantial evidence.48 Based on the circumstances, Governor
DeSantis knew that the political committees and other organizations providing him with millions of
dollars of direct and indirect benefits are existentially motivated to ensure that he qualifies as a
candidate for federal office and exercise his official judgment to resign from office. Most importantly,
Run, Ron, Run!, which was formed on March 8, 2023,49 exists for the sole intent of enticing Governor
DeSantis to run for president and exercise his official judgment to submit an irrevocable resignation
pursuant to Florida’s resign to run law. The fundraising disclaimer contained on Run, Ron, Run!’s
contributions page makes its intent crystal clear: “Your contribution will be forwarded to Ron
DeSantis’ Presidential campaign committee in the event he publicly declares a campaign for U.S.
President in the 2024 election cycle no later than November 5, 2023.”50 Presidential politics is big
business. According to Open Secrets, a non-partisan, independent, non-profit research group that
tracks money in United States politics, the 2020 presidential election involved expenditures of
approximately $5.7 billion.51 The organizations giving gifts to Governor DeSantis, or receiving them
on his behalf, have a tremendous financial incentive to ensure that he run for president and resigns.
Neither Governor DeSantis nor the organizations that support him are blind to these realities.52

The gifts described in the Gifts List, whether provided to Governor DeSantis by a book publisher, a
federal or state political committee, an issue-advocacy organization, or another not-for-profit
organization, rest on the understanding that Governor DeSantis will choose to run for president and
resign from office under Section 99.012(4)(a) of the Florida Statutes. Because there is sufficient
circumstantial evidence that Governor DeSantis has solicited and received gifts as a quid pro quo for
his resignation, the Commission must conduct an immediate investigation. If the Commission finds a

45 Both the Florida ethics laws and the resign to run laws were enacted to ensure that Florida government officials
devote themselves to the good-faith performance of the duties delegated to them by the citizens of the State of
Florida.
46 Virginia Chamlee, Florida Might Change a State Law So Ron DeSantis Can Run for President
and Be Governor at the Same Time, PEOPLE (Nov. 23, 2022, 2:13 PM),
https://people.com/politics/florida-may-change-state-law-for-ron-desantis-presidential-run/.
47 The decision to resign would not give the people of Florida a say in their next governor; instead, it would result
in the Lieutenant Governor taking over. Even if Governor DeSantis were able to remain governor during his
presidential candidacy, it would effectively turn him into a lame-duck politician.
48 See Knight v. State, 107 So. 3d 449, 464 (Fla. 5th Dist. Ct. App. 2013).
49 Run, Ron, Run! FEC Filings, FEDERAL ELECTION COMMISSION,
https://docquery.fec.gov/pdf/813/202303089578977813/202303089578977813.pdf
(last visited Mar. 10, 2023).
50 Paid Political Advertisement Paid for by Run, Ron, Run!, WINRED, https://secure.winred.com/never-back-
down-inc/20230308-launch-tag/?utm_medium=social&utm_source=tag&utm_term=nbd-us-
pac&utm_campaign=20230308-launch&utm_content=20230308-launch-tag-1 (last visited Mar. 10, 2023).
51 Karl Evers-Hillstrom, Most Expensive Ever: 2020 election cost $14.4 billion, OPEN SECRETS (Feb. 11, 2021, 1:14
PM) https://www.opensecrets.org/news/2021/02/2020-cycle-cost-14p4-billion-doubling-16/.
52 See discussion supra Introduction.

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violation of law has occurred, the facts warrant penalties, up to and including removal from office and
ballot disqualification.53

II. Governor DeSantis Violated Article II, Section 8(h)(2) of the Florida Constitution.

Article II, Section 8(h)(2) of the Florida Constitution prohibits Governor DeSantis from abusing his
“public position in order to obtain a disproportionate benefit for himself.” The Commission defined
the term “disproportionate benefit” as “a benefit, privilege, exemption or result arising from an act or
omission by a public officer or public employee inconsistent with the proper performance of his or
her public duties.”54 The rule also specifies that the requisite intent necessary for finding a violation of
the disproportionate benefit prohibition is “that the public officer or public employee acted, or
refrained from acting, with a wrongful intent for the purpose of obtaining any benefit . . . which is
inconsistent with the proper performance of his or her public duties.”55

A. Governor DeSantis has Received a Disproportionate Benefit.

As more fully described in the Gifts List, Governor DeSantis has directly and indirectly received a
multitude of benefits in connection with his shadow presidential campaign and purported book tour.
Moreover, each of these benefits rests upon an understanding that he will submit his resignation. Rule
34-18.001(3) sets forth a six-factor test for determining whether a benefit is disproportionate.

● The number of persons, besides the public officer . . . who will experience the benefit,
privilege, exemption, or result;
● The nature of the interests involved;
● The degree to which the interests of all those who will experience the benefit, privilege,
exemption, or result are affected;
● The degree to which the public officer . . . receives a greater or more advantageous benefit,
privilege, exemption, or result when compared to others who will receive a benefit, privilege,
exemption, or result;
● The degree to which there is uncertainty at the time of the abuse of public position as to
whether there would be any benefit, privilege, exemption, or result, and, if so, the nature or
degree of the benefit, privilege, exemption, or result must also be considered; and
● The degree to which the benefit, privilege, exemption, or result is not available to similarly
situated persons. . . . .

Taking each factor in turn, it is clear that Governor DeSantis received a disproportionate benefit that
was intended to influence his decision to run for president and resign from office. First, the only
individuals and entities who benefit from Governor DeSantis’s illegal gift scheme are Governor
DeSantis and the organizations that gave gifts in furtherance of his shadow presidential campaign.
Second, the interests are significant: Governor DeSantis’s political organizations are reportedly raising
millions of dollars in support of his resignation as Governor and candidacy for president.56 Third,
Governor DeSantis’s and supporting political organizations’ interests in the benefit are wholly

53 See § 112.317, Fla. Stat. (2020).

54 Fla. Admin. Code R. 34-18.001(2)(a).
55 Id.
56 Contorno, supra note 43.

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dependent upon Governor DeSantis’s continued abuse of office, his federal candidacy, and required
resignation. Without a DeSantis presidential campaign, those organizations will be unable to finance
their operations or pay their vendors and employees. Fourth, there is no comparison to be made, as
only Governor DeSantis and his supporting organizations stand to benefit from his continued abuse
of office. These benefits are not available to, and at the expense of, the citizens of Florida. Fifth, there
was never uncertainty as to the existence of a benefit. With a DeSantis presidential campaign and his
resignation, the financial benefits are virtually unquantifiable, as the 2020 presidential election involved
billions of dollars.57 Moreover, and as noted above,58 there is ample circumstantial evidence that
Governor DeSantis knew these gifts were intended to induce him into running for president and
resigning from office prior to ballot qualification. The sixth factor is inapplicable under these
circumstances because there are no other individuals similarly situated to Governor DeSantis.
However, this lack of comparison should not provide Governor DeSantis with a free pass to abuse
his office in furtherance of an illegal gifting scheme that benefits his shadow presidential campaign
(and the organizations that support it) to the detriment of Florida citizens.

B. Governor DeSantis Acted with Wrongful Intent by Knowingly Violating Federal Campaign Finance Laws.

Governor DeSantis’s shadow presidential campaign, illegal gifting scheme, and the disproportionate
benefits derived therefrom, are in clear violation of federal campaign finance laws. An individual
becomes a “candidate” for purposes of the Federal Election Campaign Act of 1971 (as amended,
“FECA”) upon receiving contributions or making expenditures in excess of $5,000 to influence their
election for federal office, either directly or through third parties.59 Such individuals must file a
Statement of Candidacy within fifteen days of meeting this threshold.60

The Federal Election Commission (the “FEC”) has determined that once an individual “moved
beyond the deliberative process of deciding to become a candidate, and into the process of planning
and scheduling public activities designed to heighten his political appeal to the electorate, then . . . the
activity would cease to be within the exemption, and candidacy would arise.”61 Thus, even a candidate
who carefully crafts his public comments to avoid referring to himself as a candidate can trigger
candidacy by making expenditures to further his candidacy once a private decision has been made.

It is clear from Governor DeSantis’s activities that he has decided to run for president. As The New
York Times reported, Governor DeSantis is hitting the “traditional early primary states as he discusses
his new book.”62 Moreover, “[t]he people briefed on Mr. DeSantis’s schedule distinguished it from a
book tour,”63 as “Mr. DeSantis’s plans are said to include a collection of speaking engagements with
some connection to what he lays out in his book as a blueprint that his Florida record offers the

57 Amisa Ratliff, 12 numbers to know about the money in the 2020 presidential election, ISSUE
ONE (Dec. 14, 2020), https://issueone.org/articles/12-numbers-to-know-about-the-money-in-the-2020-
presidential-election/.
58 See supra note 48 and accompanying text.
59 See 52 U.S.C. § 30101(2); 11 C.F.R. § 100.3.
60 52 U.S.C. § 30102(e)(1); 11 C.F.R. § 101.1(a).
61 Fed. Elec. Comm. Advisory Op. 1981-32; see also, Isenstadt, supra note 10; Maggie Haberman, DeSantis Hits the
Trail. Just Don’t Call it a Campaign., NY TIMES (Feb. 28, 2023),
https://www.nytimes.com/2023/02/28/us/politics/desantis-primary-states.html.
62 Haberman, supra note 59.
63 Id.

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country.”64 Michael C. Bender of The New York Times accurately referred to DeSantis as “on the
campaign trail” before crossing out “campaign trail” and replacing it with “book tour.”65 Axios
recently reported that DeSantis is “aggressively testing the limits of running an unofficial presidential
campaign, ramping up national engagements that leave little doubt about his plans for 2024.”66
Governor DeSantis intends to use the book tour as an opportunity to meet with political donors and
solicit contributions to various political committees, as evidenced by his traveling to Iowa, New
Hampshire, Nevada, and South Carolina, the first four states to vote in the primary election.67 These
activities are for the purpose of heightening Governor DeSantis’s appeal to the national electorate.

Moreover, Governor DeSantis’s own words indicate he has made a private decision to run for
president. As reported by The Washington Post, “in recent conversations, DeSantis has described his
presidential plans without any caveats that would suggest he’s still deciding . . . .”68 When the hosts of
Fox & Friends questioned him about his intent to run, Governor DeSantis responded, “Wouldn’t you
guys like to have that announcement on Fox and Friends?”69 While only publicly teasing his private
decision to run for president, Friends of Ron DeSantis, Governor DeSantis’s Florida political
committee, has made Governor DeSantis’s intentions clear with a new advertising campaign ostensibly
promoting his book, stating, “that’s just the price you have to pay to be able to save this country.”70

Despite Governor DeSantis’ non-committal answers to public questions concerning his candidacy,
his donors know exactly what he meant: Friends of Ron DeSantis raised $11,969,560.83 since January
1, 2023.71 According to The Washington Post, “[t]he Governor’s advisors have been studying ways
to use that money to power a presidential campaign, since it was raised under different rules than ones
governing federal campaigns [and] transferring the money to a pro-DeSantis super PAC is seen as the
likeliest option . . . .”72

Governor DeSantis has violated FECA and FEC regulations by making expenditures in excess of
$5,000 for the purpose of advancing his own presidential campaign without publicly filing a statement
of candidacy with the FEC. Specifically, Governor DeSantis has been using Friends of Ron DeSantis,

64 Id.
65 @MichaelCBender, TWITTER (Mar. 1, 2023, 2:49 PM),
https://twitter.com/MichaelCBender/status/1631018933414232064?cxt=HHwWgIC8wYLFxaI
tAAAA
66 Basu, supra note 17.
67 Ryan King, DeSantis to barnstorm early primary states amid 2024 chatter, WASHINGTON
EXAMINER. Feb. 28, 2023, 3:45 PM), https://www.washingtonexaminer.com/news/campaigns/desantis-
barnstorm-battleground-states-2024-chatter.
68 Hannah Knowles, DeSantis indicates privately he intends to run in 2024 as allies prepare,
WASHINGTON POST (Mar. 10, 2023),
https://www.washingtonpost.com/politics/2023/03/09/ron-desantis-2024-president-iowa-nevada/.
69 Gary Fineout, The shadow DeSantis-Trump primary keeps getting closer, POLITICO (Feb. 21, 2023, 7:03 AM),
https://www.politico.com/newsletters/florida-playbook/2023/02/21/the-shadow-desantis-trump-primary-
keeps-getting-closer-00083723.
70 @RonDeSantisFL., Twitter (Mar. 3, 2023),
https://twitter.com/rondesantisfl/status/1631808459732578305?s=46&t=S3JdacLk4oyuy
B9vkOu9DA.
71 Friends of Ron DeSantis Contributions, FRIENDS OF RON DESANTIS,
https://friendsofrondesantis.com/wp-content/uploads/2023/02/fordcont-022423.pdf
(last visited Mar. 10, 2023). According to Section 106.025 of the Florida Statutes, because Governor DeSantis is
not a declared candidate for public office, this fundraising may be illegal under Florida law.
72 Knowles, supra note 68.

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ostensibly independent federal PACs, and a 501(c)(4) organization to spend money throughout the
country in excess of statutory limits, all of which is outlined in the Gifts List. By way of example,
Friends of Ron DeSantis, his Florida political committee, has made $1,657,503.83 in expenditures
through February 21, 2023.73 Likewise, the founder of Ron to the Rescue, a federal Super PAC, says
“he has 10 staffers and about $20 million in commitments [and that his] team had launched DeSantis
ads in key states and hoped to keep growing”.74 As described above, Governor DeSantis has also
attended, and plans to attend additional, public events in early primary states.75

Governor DeSantis triggered the requirement to file a Statement of Candidacy with the FEC. Yet
rather than complying with law, he is using his book tour, various state and federal PACs, and a
501(c)(4) organization to raise and spend exorbitant amounts to influence his own election, and to
enrich himself and his allied organizations, in knowing violation of FECA’s contribution limits.

C. Governor DeSantis Acted with Wrongful Intent by Knowingly Violating Laws Against Illegal Gifts from
Political Committees and Against Illegal Lobbying.

Section 112.31485(2)(a) of the Florida Statutes prohibits Governor DeSantis from “soliciting or
knowingly accepting, directly or indirectly, any gift from a political committee.” Likewise, Section
112.31485(2)(b) prohibits a political committee from “giving, directly or indirectly, any gift to
[Governor DeSantis].” For the purposes of Section 112.31485, the term “gift” means “any purchase,
payment, distribution . . . advance, transfer of funds, or disbursement of money or anything of value.”76

Governor DeSantis has solicited and received millions of dollars’ worth of gifts, as detailed in the
Gifts List, from political committees in violation of Section 112.31485(2)(a) of the Florida Statutes.
Section 112.31485(1)(a) provides a safe harbor if the gift from a political committee is “primarily
related to contributions, expenditures, or other political activities authorized pursuant to chapter 106.”
This safe harbor, however, does not apply under the current facts. As described herein, the gifts
provided by political committees are not primarily related to political activities; rather, they primarily
relate to purposes that are not permitted by Chapter 106: (a) the gifts are for the personal financial
benefit of Governor DeSantis through the promotion of his book;77 and (b) the gifts constitute illegal
lobbying “Expenditures” under Section 112.3215 of the Florida Statutes.

First, and as detailed in the Gifts List, the promotion of Governor DeSantis’s book by political
committees personally enriches Governor DeSantis, directly and indirectly, through a book advance
and payment of royalties. Other gifts from political committees, such as paid media, direct promotion
of his message, travel, accommodations, food and beverage, event staging, and other indirect benefits,
constitute illegal, excessive contributions to benefit his presidential campaign. Moreover, as noted

73 Friends of Ron DeSantis Expenditures, FRIENDS OF RON DESANTIS,

https://friendsofrondesantis.com/wp-content/uploads/2023/02/fordexp-022423.pdf
(last visited Mar. 10, 2023).
74 Forrest Saunders, Gov. Ron DeSantis launches new book, ratcheting up 2024 speculation,
WPTV (Feb. 28, 2023, 7:15 PM), https://www.wptv.com/news/political/gov-ron-desantis-
launches-new-book-ratcheting-up-2024-speculation.
75 See supra notes 62-67 and accompanying text.
76 § 112.31485(1)(a), Fla. Stat. (2013).
77 As described in the Gifts List, the promotion of Governor DeSantis’s book by political committees personally
enriches Governor DeSantis, directly and indirectly through the payment of royalties on book sales.

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above, continued spending by Friends of Ron DeSantis in furtherance of his shadow presidential
campaign violates state and federal campaign finance laws.

Second, Section 112.3215(6)(a) strictly prohibits Friends of Ron DeSantis, Ready for Ron, Ron to the
Rescue, Courageous Conservatives PAC, the Republican State Leadership Committee, And to the
Republic, Run, Ron, Run!, and any other issue-advocacy organization or political committee from
making, directly or indirectly, and Governor DeSantis from receiving, directly or indirectly, any
“Expenditure” by a lobbyist. Although Section 112.3215 provides a safe harbor similar to
112.31485(1)(a), the gifting scheme described herein does not qualify for the safe harbor for the
following reasons: (a) the aforementioned political committees are not registered lobbyists in
accordance with Florida law; (b) the aforementioned political committees have made “Expenditures”
in violation of campaign finance laws; and (c) the “Expenditures” are intended to “Lobby” Governor
DeSantis and were knowingly78 accepted by him.

A review of the Florida Lobbyist Registration database returns no registration information for any of
the aforementioned political committees.79 Because these entities are not registered lobbyists, they are
prohibited from making any lobbying expenditures. Section 112.3215(1)(d) defines “Expenditure” as
“a payment, distribution . . . advance, reimbursement, deposit, or anything of value made by a lobbyist
or principal for the purpose of lobbying.”80 Section 112.3215(1)(f) defines “Lobbies” as “seeking, on
behalf of another person, to influence [Governor DeSantis81] with respect to a decision . . . in the area
of policy . . . or an attempt to obtain the goodwill of an agency official or employee.”

For so long as Governor DeSantis remains both an undeclared candidate under FECA and a sitting
Governor subject to Florida’s resign to run law, any expenditures made by political committees in an
effort to influence Governor DeSantis’s decision to run for president constitute illegal gifts by political
committees and illegal lobbying payments. As described herein, the gifts provided to Governor
DeSantis are worth millions of dollars. Moreover, and as detailed specifically above, the gifts constitute
illegal, excessive contributions to his shadow presidential campaign and were made for the primary
purpose of seeking, on behalf of their donors, consultants, and other like-minded individuals,
Governor DeSantis’s goodwill in an effort to influence his policy decision to resign from office.

Governor DeSantis knows, or should know, that his shadow presidential campaign is illegal under
federal election law, Florida ethics laws prohibiting illegal gifts from political committees, and Florida
ethics laws prohibiting illegal lobbying payments. Given the foregoing, it is highly likely that Governor
DeSantis has violated Article II, Section 8(h)(2) of the Florida Constitution by failing to file a statement
of candidacy with the FEC for the specific purpose of continuing to solicit and accept illegal gifts
from political committees and unregistered lobbyists in furtherance of his shadow presidential
campaign. Thus, an investigation by the Commission is required82 and, if a violation is found,

78 See CEO No. 91-37, supra note 41.

79 Lobbyist Search, FLORIDA LOBBYIST, https://floridalobbyist.gov/LobbyistInformation/LobbyistSearch (last
visited Mar. 10, 2023).
80 § 112.3215(1)(d), Fla. Stat.(2014) contains an exception for political activities authorized under Chapter 106 of
the Florida Laws. This exception does not apply because the primary purpose of the gift is to obtain Governor
DeSantis’s goodwill and to influence his official decision to resign from office and pursue a presidential
campaign.
81 See § 112.3215(1)(a), Fla. Stat. (2014).
82 See § 112.317, Fla. Stat. (2020). Additionally, Section 112.3215(8)(a) provides that “the [C]ommission shall
investigate every sworn complaint that is filed with it alleging that a person covered by this section has failed to

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imposition of penalties up to and including ballot disqualification and treble damages are warranted.83

III. Governor DeSantis Violated Section 112.313(6).

Section 112.313(6) of the Florida Statutes prohibits Governor DeSantis from “corruptly us[ing] or
attempting to use his official position or any property or resource which may be within his . . . trust,
or perform his . . . official duties, to secure a special privilege, benefit, or exemption for himself . . . or
others.” Section 112.312(9) of the Florida Statutes defines “corruptly” as “done with a wrongful intent
and for the purpose of obtaining . . . any benefit resulting from some act or omission of a public
servant which is inconsistent with the proper performance of his or her public duties.”

The language of Section 112.313(6) differs from Article II, Section 8(h)(2) of the Florida Constitution
in that the statute is triggered not only when a “disproportionate benefit” results from misconduct by
a public officer or public employee, but when a “special privilege, benefit, or exemption” of “any
degree” results.84 Moreover, the language of the statute applies no matter who receives the “special
privilege, benefit, or exemption,” while the Constitutional amendment applies only when a
“disproportionate benefit” is received by the public officer.85

As detailed in the Gifts List, Governor DeSantis has directly and indirectly solicited and accepted a
multitude of gifts premised on the understanding that he will run for president and, as required by
law, ultimately submit his resignation as Governor of the State of Florida. Each of those gifts
undoubtedly constitutes a “special privilege” or “benefit,” as those terms are used in Section
112.313(6) of the Florida Statutes. Moreover, it is clear that Governor DeSantis is leveraging his office,
or as he calls himself, “America’s Governor,”86 to benefit himself through book sales and solicit gifts
to enrich organizations that will ultimately support his presidential campaign.

Troublingly, despite the millions of dollars being illegally gifted to Governor DeSantis and political
groups who support his candidacy for President, Governor DeSantis is corruptly availing himself of
Florida resources to ensure that those millions stay in his account and the accounts of those who
support his national ambitions. Over the last eighteen months, Governor DeSantis made
approximately fifteen out-of-state campaign trips accompanied by his official security detail.87

Because the benefits and savings arising from the illegal gifting scheme inure both to Governor
DeSantis and to the organizations that support his shadow presidential campaign, and the costs were

register, has failed to submit a compensation report, has made a prohibited expenditure, or has knowingly
submitted false information in any report or registration required in this section.” (emphasis added). In light of
the foregoing allegations, the Commission must thoroughly investigate the aforementioned political committees
and Governor DeSantis.
83 The Florida Legislature proscribed harsh punishment for violators of Section 112.31485. Section 112.31485(3)
provides for treble damages and personal liability for any entity or person (and their agents) that accept or
make a gift in violation of Section 112.31485. Given the strong public interest in ensuring that elected officials
do not receive gifts from political committees, the Commission should immediately investigate Governor
DeSantis and the aforementioned political committees.
84 See Fla. CEO No. 19-23 (Oct. 30, 2019) (emphasis added).
85 Id.
86 See discussion supra Argument Section 1, Part B.
87 Sandoval, supra note 32.

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apparently not reimbursed by the event sponsors,88 the Commission must investigate Governor
DeSantis’s corrupt misuse of official resources.89 Should the Commission find that a violation has
occurred, it should impose penalties that include removing Governor DeSantis from office and
disqualifying him from any future ballot in the State of Florida.90

IV. Governor DeSantis Violated Section 112.313(7).

Section 112.313(7) of the Florida Statutes prohibits Governor DeSantis from having “any . . .
contractual relationship that will create a continuing or frequently recurring conflict between his . . .
private interests and the performance of his . . . public duties or that would impede the full and faithful
discharge of his . . . public duties.”

Governor DeSantis’s book tour is conflicting with the exercise of his official duties. Governor
DeSantis will be on his book tour for much of Florida’s legislative session. With Governor DeSantis
absent from Florida due to his book tour and shadow presidential campaign, the Commission must
immediately investigate the terms of his contract with his publisher to ensure that such contractual
relationship will not further conflict with the full and faithful discharge of his public duties.91 If
appropriate, the Commission should void his contract with the publisher.92

CONCLUSION

An investigation by the Commission is mandated as soon as possible. This letter provides ample
evidence that Governor DeSantis’s and various political committees have engaged in conduct that
violates Florida Ethics laws. No person is above the law, not even the Governor.

Sincerely,

Taylor Budowich
Prepared with the Assistance of Counsel

88 See Fla. CEO No. 08-26 (Oct. 22, 2008) (implying that taxpayer expenses associated with a government
officer’s travel for non-official purposes are not impermissible gifts only if the government is reimbursed) (citing
Fla. CEO No. 92-12 (Mar. 6, 1992).
89 Id.
90 See § 112.317, Fla. Stat. (2020).
91 Ryan King, DeSantis to barnstorm early primary states amid 2024 chatter, WASHINGTON
EXAMINER. Feb. 28, 2023, 3:45 PM), https://www.washingtonexaminer.com/news/campaigns/desantis-
barnstorm-battleground-states-2024-chatter; Governor Ron DeSantis is Coming to Alabama, Alabama GOP,
https://algop.org/2023-algop-winter-dinner/ (last visited Mar. 10, 2023); Brianne Pfannenstiel, Ron DeSantis
makes his Iowa caucuses debut with stops March 10 in Des Moines, Davenport, Des Moines Register (Mar. 10, 2023,
10:23 AM), https://www.desmoinesregister.com/story/news/elections/presidential/caucus/2023/03/02/ron-
desantis-announces-first-iowa-trip-for-2024-presidential-caucuses/69959827007/; The Florida Blueprint, ft.
special guest Gov. Ron DeSantis in Las Vegas, NV, Eventbrite, https://www.eventbrite.com/e/the-florida-
blueprint-ft-special-guest-gov-ron-desantis-in-las-vegas-nv-tickets-570854149127 (last visited Mar. 10, 2023);
Speakers: Ron DeSantis, Pennsylvania Leadership Conference,
https://www.paleadershipconference.org/speakers-bios (last visited Mar. 5, 2023).
92 See § 112.31175(1)(b)(1), Fla. Stat. (2020).

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