Reasonable Inference
The financial relationship between SVCF and Michigan Secretary of State Jocelyn Benson warrants scrutiny as a structural conflict of interest facilitated through multiple layers of nonprofit intermediaries. SVCF, as the donor-advised fund custodian for the Chan Zuckerberg Initiative, disbursed $69.5 million to the Center for Election Innovation and Research (CEIR). CEIR in turn awarded Michigan an approximately $12 million grant — routed not to the Secretary of State’s office but to MCELA, the Michigan Center for Election Law and Administration, a nonprofit founded by Benson that had reported minimal activity before 2020. At the time MCELA administered the grant, its president was Sally Marsh — simultaneously serving as Director of Special Projects in Benson’s own Secretary of State office and a veteran of Benson’s 2018 campaign, where she served as deputy campaign manager and finance director. MCELA disbursed approximately $11.9 million — nearly the entire grant — to two Democratic political consulting firms: Waterfront Strategies (a subsidiary of GMMB, described as the largest Democratic consulting firm in the United States) and Alper Strategies.
Citations
The Chan Zuckerberg Initiative maintained a donor-advised fund account at Silicon Valley Community Foundation (SVCF). According to Capital Research Center and InfluenceWatch reporting, SVCF disbursed $69.5 million from CZI to the Center for Election Innovation and Research ahead of the 2020 election cycle. See Capital Research Center, “Shining a Light on Zuck Bucks in Key States” (https://capitalresearch.org/article/shining-a-light-on-zuck-bucks-in-key-states/) ; InfluenceWatch, “Chan Zuckerberg Initiative” (https://www.influencewatch.org/for-profit/chan-zuckerberg-initiative/); InfluenceWatch, “Center for Election Innovation and Research” (https://www.influencewatch.org/non-profit/center-for-election-innovation-research/)
CEIR awarded $11,939,365 to MCELA (Michigan Center for Election Law and Administration) for Michigan voter education activities. See InfluenceWatch, “The Michigan Center for Election Law and Administration” (https://www.influencewatch.org/non-profit/the-michigan-center-for-election-law-and-administration/) (reporting $12,040,000 grant figure; CEIR grant table reflects $11,939,365). MCELA was founded in 2008 by Jocelyn Benson, then a Wayne State law professor, and reported no revenue exceeding the IRS $50,000 e-postcard threshold prior to 2020 — the first year a full Form 990 is publicly available. See also Michigan Enjoyer, “Jocelyn Benson Center for Election Law” (https://enjoyer.com/jocelyn-benson-center-for-election-law/) . The “every other state went directly to SOS offices” comparative claim is not independently confirmed by primary sources and is not asserted here. CEIR described its grant program as supporting “secretaries of state” generally, but its published grant report does not identify the recipient entity for each state on a comparative basis. See CEIR, “2020 Voter Education Grant Program” (https://electioninnovation.org/research/ceir-2020-voter-education-grant-program/).
Sally Marsh served as president of MCELA during the 2020 grant period while simultaneously holding the position of Director of Special Projects for Michigan Secretary of State Jocelyn Benson, where she was responsible for recruiting poll workers and leading youth voter outreach. Marsh previously served as deputy campaign manager and finance director for Benson’s 2018 Secretary of State campaign. See InfluenceWatch, “The Michigan Center for Election Law and Administration,” fn. 15, citing Sally Marsh LinkedIn profile (https://www.linkedin.com/in/sally-marsh/ ); see also Michigan Public Radio, “New Campaign Will Educate Citizens, Especially First-Time Voters, How to Vote” (Oct. 11, 2020) (https://www.michiganpublic.org/law/2020-10-11/new-campaign-will-educate-citizens-especially-first-time-voters-how-to-vote) (confirming Marsh’s role in the Benson SOS office during the MCELA campaign).
MCELA disbursed $9,799,407 to Waterfront Strategies — a subsidiary of GMMB, described as the largest Democratic political consulting firm in the United States — and $2,088,000 to Alper Strategies, also a Democratic consulting firm, for a combined total of $11,887,407 of the approximately $12 million grant. See InfluenceWatch, “The Michigan Center for Election Law and Administration” (https://www.influencewatch.org/non-profit/the-michigan-center-for-election-law-and-administration/ ); Star News Network (Miele, Aug. 5, 2021), “Zuckerberg-Funded Nonprofit Paid $11.8 Million to Democrat Political Consulting Firms for ‘Nonpartisan’ Voter Education in Michigan” (https://thestarnewsnetwork.com/2021/08/05/zuckerberg-funded-nonprofit-paid-11-8-million-to-democrat-political-consulting-firms-for-nonpartisan-voter-education-in-michigan-2020-election/ ); America First Policy Institute, “Big Tech May Be Canceling More Than Just Your Voice” (https://www.americafirstpolicy.com/issues/big-tech-may-be-canceling-more-than-just-your-voice ) (reporting that MCELA spent 99 percent of the grant on Democratic consulting firms).