Reasonable Inference
The five Democratic-plurality “Zuckerberg 5” cities — Milwaukee, Madison, Green Bay, Racine, and Kenosha — received a total of $8.8 million in CTCL grants, all conditioned on implementation of the “Wisconsin Safe Voting Plan,” a joint election operations framework developed by those cities at CTCL’s direction. Grant funds were contractually bound to that plan: the agreements specified that funds “must be used exclusively for the public purpose of planning and operationalizing safe and secure election administration … in accordance with the Wisconsin Safe Voting Plan 2020,” and clawback provisions required return of any funds if CTCL determined the cities had not complied with its requirements. The funded activities extended well beyond pandemic safety measures. Green Bay’s WSVP application called for bilingual “voter navigators” to help residents complete ballots and meet certification requirements, geo-fenced digital advertising, and partnership with “organizations serving African immigrants, ‘LatinX’ residents, and African Americans.” Milwaukee’s funded communications plan “focused on appealing to … historically underrepresented communities such as LatinX and African Americans,” and Madison allocated $100,000 to advertising on Spanish-language radio, hip-hop radio, and in “publications run by and for our communities of color.” Of the Green Bay grant, less than one percent was spent on PPE; Milwaukee spent less than six percent of its total grant on pandemic safety equipment. The Wisconsin Office of Special Counsel concluded that the CTCL agreement “facially violates the election bribery prohibition of Wis. Stat. § 12.11,” because participating cities and officials received private money — which the statute defines as “anything of value” — to facilitate voting in ways specified by a private contractor rather than by neutral government administration. That conclusion is the opinion of the OSC, a Republican-appointed investigative body, and no Wisconsin court issued a merits ruling affirming it.
Citations
Wisconsin Institute for Law & Liberty, “Finger on the Scale: How CTCL Grants to Wisconsin Municipalities Boosted Turnout for Joe Biden in 2020” (p. 5: “$8.8 million” figure and Wisconsin Safe Voting Plan obligation; p. 11, Table 3: per-city grant amounts): https://will-law.org/wp-content/uploads/2021/06/WillLawFINGER-ON-THE-SCALE.6.pdf
Center for Tech and Civic Life, Wisconsin Safe Voting Plan announcement (July 6, 2020) (confirming initial $6.3M grant to five cities conditioned on WSVP implementation; per-city amounts; use categories): https://www.techandciviclife.org/wisconsin-safe-voting-plan/
Wisconsin Office of Special Counsel, Second Interim Investigative Report (March 1, 2022) (p. 17: “The CTCL agreement facially violates the election bribery prohibition of Wis. Stat. § 12.11”; p. 18: “anything of value” definition; pp. 26–27: verbatim clawback language — “Any amount reduced or not provided in contravention of this paragraph shall be repaid to CTCL up to the total amount of this grant”; pp. 19, 34–35: communities-of-color and demographic targeting documentation): https://bloximages.chicago2.vip.townnews.com/madison.com/content/tncms/assets/v3/editorial/6/49/64989810-acbc-5ce7-bdc1-f56d37e7c923/621e4cdc386e7.pdf.pdf
Krumberger et al. v. Wisconsin Elections Commission (Complaint, Sept. 10, 2020) (pp. 9–11: verbatim Green Bay WSVP application: bilingual “voter navigators” $45,000; “geo-fencing” $100,000 multi-channel outreach; “organizations serving African immigrants, ‘LatinX’ residents, and African Americans” $15,000; pp. 14–15: Madison Spanish-language and African American-focused advertising; pp. 15–16: Milwaukee “LatinX and African Americans” communications focus): https://mma.prnewswire.com/media/1252440/Wisconsin_Elections_Commission_Complaint.pdf?p=pdf
Foundation for Government Accountability, “The Wisconsin ‘Zuckerbucks’ Problem” (documenting Milwaukee spent less than 6% of grant on PPE; Green Bay spent less than 1% on PPE; Green Bay purchased two Ford trucks and paid a PR firm nearly $150,000 for voter outreach): https://thefga.org/research/the-wisconsin-zuckerbucks-problem/
WILL, “Finger on the Scale” (p. 5: clawback and plan-compliance conditions); see also OSC Second Interim Report, Chapter 1 title: “The Center for Tech and Civic Life’s $8,800,000 Zuckerberg Plan Grant with the Cities of Milwaukee, Madison, Racine, Kenosha and Green Bay (the Zuckerberg 5 Cities) Facially Violates Wisconsin Law Prohibiting Election Bribery.” Note: No Wisconsin court issued a merits ruling affirming the § 12.11 violation; challenges were dismissed on standing or justiciability grounds: https://will-law.org/wp-content/uploads/2021/06/WillLawFINGER-ON-THE-SCALE.6.pdf | Wisconsin Institute for Law & Liberty