* The Tribune story is here. From DPI…

For months, the People Who Play By The Rules PAC, run by one-time failed candidate and Florida resident Dan Proft, has been running ads funded by Dick Uihlein to support Darren Bailey’s run for governor. By law, PACs cannot coordinate with individual campaigns, but new reporting sheds light on Proft and Bailey’s relationship that begs the question: What is Dan Proft doing for the Bailey campaign and why?

Read highlights from The Chicago Tribune’s bombshell story below.

• The political committee is an independent expenditure PAC and, by law, is not supposed to coordinate its spending activities with Bailey’s campaign. But the apparent efforts by Proft — who also co-hosts a conservative radio show for which Bailey has been a frequent guest — to try to intercede in a potential legal matter involving Bailey indicate he may be playing a larger role than previously acknowledged.

• Proft also is involved in political mailers disguised as newspapers that have been sent to thousands of homes across the state, disseminating disinformation to disparage Pritzker. In 2016, a similar mailing effort funded by a former Proft independent expenditure PAC was cited by the Illinois State Board of Elections for illegal coordination with candidates.

• An internal dispute between Republican governor candidate Darren Bailey’s campaign and a recently departed Bailey political worker has raised questions about the level of involvement the conservative leader of a Bailey-aligned political action committee has had with the Bailey campaign.

• During those negotiations, Proft weighed in, apparently in an effort to quash the filing of a possible lawsuit in the matter that could become public and hurt Bailey’s chances.

• Asked to clarify, the campaign did not respond.

With hundreds of thousands of Illinoisans already casting their ballots and thousands more headed to the polls this weekend, Darren Bailey’s campaign must answer about his relationship with Dan Proft. With just four days to go, voters deserve to know: Why did Bailey fire Brett Corrigan and why was Dan Proft involved in an internal HR dispute?

* This is an odd story all around…

Corrigan declined to comment and referred all questions to his attorney, Scott Kaspar of Orland Park. Kaspar said Corrigan attended Bailey’s private Full Armor Christian Academy in downstate Louisville, Illinois, and lived with Bailey’s family on their farm in nearby Xenia. Corrigan on the campaign trail served largely as a “body man” for the Republican governor candidate, who is also a state senator, closely following Bailey at events and assisting Bailey as he needed. Since June 2021, state campaign finance records show, he was paid $18,861 by Bailey’s campaign.

But around mid-September, Corrigan left Bailey’s campaign — whether he was fired or left on his own is a matter of dispute, his attorney said. Corrigan now serves a similar role for GOP attorney general candidate Tom DeVore, whose campaign Corrigan joined almost immediately after leaving Bailey’s.

In an interview, DeVore said he was aware of a dispute between Corrigan and Bailey’s campaign and that the two sides were trying to reconcile their differences. DeVore had no comment when asked about any involvement by Proft.

The penalty appears to be a fine.

*** UPDATE 1 *** Pritzker campaign…

The best read of the law suggests the State Board of Elections could impose a fine of as much as $28,083,000 on the [Proft] PAC should they find a violation. We haven’t found examples of fines that large, but that amount should be possible under the IE statute, as described in more detail below.

If an independent expenditure committee (in this case, People Who Play By The Rules PAC) makes a contribution to candidate committee, the State Board of Elections assesses a fine on the committee equal to the amount of any contribution received in the preceding 2 years by the independent expenditure committee that exceeded the limits a [normal, non-independent] PAC may accept in an election cycle. 10 Ill. Comp. Stat. 5/9-8.6(d). For background, a normal PAC in IL may accept $12,000 per year from individuals, $24,000 per year from corporations, unions, or associations, $59,900 per year from candidate committees, $24,000 per year from party committees, and $59,900 per year from other PACS. Id. 5/9-8.5; see also IL State Board of Elections, Contribution Limits Per Election Cycle (Jan. 1, 2021), https://www.elections.il.gov/downloads/campaigndisclosure/pdf/contributionsummary.pdf. So, any contribution the PAC received in excess of those limits could be imposed against them as a fine in the event of a violation.

Because PACs may accept $12,000 per year from individuals, the excess of any individual contribution over $12k will count towards the fine. 10 Ill. Comp. Stat. 5/9-8.5; see also IL State Board of Elections, Contribution Limits Per Election Cycle (Jan. 1, 2021), https://www.elections.il.gov/downloads/campaigndisclosure/pdf/contributionsummary.pdf.

Since the People Who Play By The Rules PAC was formed in March 2022, it has reported $28,095,000 in contributions from Richard Uihlein—which is $28,083,000 above the limit Uihlein could give to a normal PAC as an individual. See generally People Who Play By The Rules PAC, Committee Details, https://www.elections.il.gov/CampaignDisclosure/CommitteeDetail.aspx?ID=meYU8YumQ1UjlydtIJRv9w%3d%3d (last visited Nov. 4, 2022). Should the State Board of Elections find that the PAC illegality coordinated with the Bailey Campaign, its fine could therefore exceed $28 million.

A $28 million fine? Whew.

*** UPDATE 2 *** The Democratic Party of Illinois has filed a complaint with the State Board of Elections, according to the Tribune, and the Dems have revised the possible penalty upwards to $42 million…

We’ve updated the figures to include all of Uihlein’s contributions to the PAC, including the one on the October A-1. Based on all contributions, the fine could exceed $42 million. Revised version below.

he best read of the law suggests the State Board of Elections could impose a fine of as much as $42,018,000 on the PAC should they find a violation. We haven’t found examples of fines that large, but that amount should be possible under the IE statute, as described in more detail below.

If an independent expenditure committee (in this case, People Who Play By The Rules PAC) makes a contribution to candidate committee, the State Board of Elections assesses a fine on the committee equal to the amount of any contribution received in the preceding 2 years by the independent expenditure committee that exceeded the limits a [normal, non-independent] PAC may accept in an election cycle. 10 Ill. Comp. Stat. 5/9-8.6(d). For background, a normal PAC in IL may accept $12,000 per year from individuals, $24,000 per year from corporations, unions, or associations, $59,900 per year from candidate committees, $24,000 per year from party committees, and $59,900 per year from other PACS. Id. 5/9-8.5; see also IL State Board of Elections, Contribution Limits Per Election Cycle (Jan. 1, 2021), https://www.elections.il.gov/downloads/campaigndisclosure/pdf/contributionsummary.pdf. So, any contribution the PAC received in excess of those limits could be imposed against them as a fine in the event of a violation.

Because PACs may accept $12,000 per year from individuals, the excess of any individual contribution over $12k will count towards the fine. 10 Ill. Comp. Stat. 5/9-8.5; see also IL State Board of Elections, Contribution Limits Per Election Cycle (Jan. 1, 2021), https://www.elections.il.gov/downloads/campaigndisclosure/pdf/contributionsummary.pdf.

Since the People Who Play By The Rules PAC was formed in March 2022, it has reported $42,018,000 in contributions from Richard Uihlein—which is $42,006,000 above the limit Uihlein could give to a normal PAC as an individual. See generally People Who Play By The Rules PAC, Committee Details, https://www.elections.il.gov/CampaignDisclosure/CommitteeDetail.aspx?ID=meYU8YumQ1UjlydtIJRv9w%3d%3d (last visited Nov. 4, 2022). Should the State Board of Elections find that the PAC illegality coordinated with the Bailey Campaign, its fine could therefore exceed $42 million.

*** UPDATE 3 *** From DPI’s filed complaint…

Mr. Proft has consistently acted in “cooperation, consultation, or concert” with the Bailey Campaign. The examples are endless. For example, Mr. Proft co-hosts a conservative radio show in which Mr. Bailey has been a frequent guest. In one instance, Mr. Proft talks about the millions he has spent supporting the Bailey Campaign, with Mr. Bailey on the line, saying that he “supported Darren Bailey through the super PAC that I run in the primary. And I’m supporting him through the super PAC that I run into the general too.”

From the Bailey campaign’s statement to the Tribune…

“The campaign hasn’t spoken to Dan since their general election efforts started,” Bailey campaign spokesman Joe DeBose said in a text

That answer begs the question about what the campaign did with Proft during the primary.