LANSING – Michigan Attorney General Dana Nessel announced the findings of the Department’s investigation into Unlock Michigan. 

In May 2021, Robert LaBrant filed a complaint with the Michigan Department of State’s office alleging that former Senate Majority Leader Mike Shirkey, with the help of Heather Lombardini of Bright Sparks Strategies, used Michigan! My Michigan! (MMM) and the Michigan Citizens for Fiscal Responsibility (MCFR) to fund the Unlock Michigan ballot question initiative through what the complaints called a “dark money scheme.” The allegations included claims that MMM and MCFR, two 501(c)(4)s connected to former Senator Shirkey, together contributed over $2.4 million in funding to Unlock Michigan, amounting to “nearly 86% of Unlocks total funding.” 

The Department of State referred LaBrant’s complaint to the Department of Attorney General on June 3, 2022. The Department of Attorney General’s investigation found that not only was there extensive coordination between Unlock Michigan and the two 501(c)(4)s, but that Mike Shirkey and Heather Lombardini solicited and received contributions for the Unlock Michigan ballot initiative. Heather Lombardini then failed to file campaign finance statements disclosing the identity of the Unlock Michigan donors, violating the Michigan Campaign Finance Act. 

Heather Lombardini, 47, of Okemos, served as the treasurer for MMM and president of MCFR and has been charged with: 

• Two counts: Campaign Finance – Failing to File a Statement of Organization, a $1,000 Misdemeanor Fine.  
• One count: Campaign Finance – Ballot Committee – Failure to File a Campaign Statement, a 90-day misdemeanor; and 
• One count: Uttering and Publishing, a 14-year felony. 

Sandy Baxter, 63, of Caledonia, was also involved in the systematic fundraising of money for Unlock Michigan through MMM. The Department alleges that Baxter lied while under oath during testimony given during an investigative subpoena and therefore is charged with: 

• One count: Perjury, a 15-year felony. 

Under Michigan’s current campaign finance laws, a person must be the candidate, treasurer, or person responsible for record-keeping in order to be charged with failure to file campaign finance statements. The Department believes the evidence demonstrates that Mike Shirkey both coordinated with Unlock Michigan and directly solicited for the ballot initiative while directing donors to MMM and MCFR to avoid disclosure. However, because Mike Shirkey was not legally connected to either organization as a director, his actions did not violate the Michigan Campaign Finance Act. 

“Political staff and consultants are what keeps Michigan’s campaign fundraising machine moving, regardless of who is in office. They often have the expertise in Michigan’s campaign finance laws and connections to big-moneyed donors that allow this type of fundraising to continue through endless election cycles and candidates.  Without these hired guns, these dark money operations would never exist,” said Nessel in a press conference announcing the charges.  

“I want to make it clear that both elected officials and their staff should be held accountable under the full extent of the law when their actions arise to criminality,” Nessel Continued. “However, this is yet another example of how our current campaign finance laws lack the appropriate language and teeth necessary to hold all bad actors accountable.”

“Until we strengthen our campaign finance laws, the system is ripe for this kind of abuse. I’m glad to see some necessary accountability for breaking the law in this case, but the people of our state deserve more. It’s long past time to make campaigning and governing more open and transparent to the people of Michigan. Serious reform is long overdue, and I will continue my efforts with Attorney General Nessel to shine a light on dark money in Michigan politics and close the loopholes that lead to corruption,” said Michigan Secretary of State Jocelyn Benson. 

Lombardini and Baxter have both been charged in 54A District Court in Lansing. An arraignment date has not yet been set. 

An affidavit in support of the charges can be found here.