Judicial Commission of Wisconsin March 13, 2025
110 E Main St, Unit 700
Madison, WI 53703
I, Julie Saunders-Seegers, allege for this Judicial Commission complaint the following:
The Susan Crawford of Wisconsin (“SCW”) registered campaign committee is using fictitious names to fund its campaign. In this fraudulent scheme, 1,397 real citizens' names are being used without their knowledge or permission. The total amount is $63,903.63 and is comprised of over 2,179 transactions. This allegation is conservative and not exhaustive. The Code violations are listed at the end of this complaint.
I request a full investigation be conducted on SCW. Several Wisconsin campaign finance statutes have been violated including, but not limited to:
1) 11.1303(1) No disbursement may be made anonymously and no contribution or disbursement may be made in a fictitious name or by one person or organization in the name of another.
2) 11.1204 Unlawful political contributions.
(1) Subject to sub. (2), no person may, directly or indirectly, make any contribution other than from funds or property belonging to the person. No person may, directly or indirectly, give funds or property to another person for the purpose of making a contribution in other than the first person's name.
(3) No person may intentionally receive or accept any contribution made in violation of this chapter.
3) 11.1201 False reports and statements. No person may prepare or submit a false report or statement to a filing officer under this chapter.
There is more than enough reasonable suspicion that justifies opening a full investigation into SCW. Evidence in this complaint strongly shows that the recorded donors may not be the actual sources of these funds. These people are known as Smurfs, and the scheme is known as Smurfing. See https://www.investopedia.com/terms/s/s/smurf.asp for a concise explanation. The SCW campaign must ensure that every suspicious donation listed is legitimate and originates from the stated donor. Per Chapter 11 ignorance cannot be a defense for accepting illegal donations. § 11.1400(7),(8).
Smurfs are a) over the age of 65, b) largely have occupations recorded as: unemployed, not employed, retired, unknown, or none, c) have extraordinarily high number of contributions. These transactions are being electronically executed using computer bots. Bots are a kind of computer algorithm.
See “Exhibit A, Crawford Potential Smurf Sample” a sampling of SCW identified Smurfs (using real people’s names and addresses without their knowledge). Part of their scheme is to mix legitimate contributions with fictitious ones.
David J Mahoney, the SCW treasurer listed on the CF-1 form and Park Bank, 33 E Main St., Madison, WI is the financial institution listed under “depository information”. The financial platforms used to deposit funds into the SCW campaign are in question. SCW uses ActBlue Express as a contribution processor, see https://www.crawfordforwi.com/ . Another platform SCW is using is also ActBlue but on a different platform: 1
https://secure.actblue.com/donate/sc-ads-240611-search?
refcode=SC_ATA_ADS_Search_D2D_240612_Launch_Keywords_Wisconsin_Contextual_Headline_Text&ga d_source=1&gclid=CjwKCAiAm67BhBlEiwAEVftNrnhTkepYmNtWfbV6tMD0_YECOUDQpULsJEQZWpAhjwPFrqBbvkjxoCLL4QAvD_BwE
ActBlue is under investigation by The House Administration Committee headed by US Congressman Brian Steil for not having adequate financial controls. Twenty (20) U.S. Attorneys General are also investigating ActBlue for not verifying that the merchant card(s) used to make donations are legally tracked back to the legal owner of the name and address. ActBlue has only recently required CVV codes, but only for new donors, which is the 3-digit number on the back of the credit or debit card. It is one security measure to prevent fraudulent activity. This leaves the over 300,000 Smurfed names used at the FEC and state levels still unchecked to make sure the names and the addresses used are tied back to legitimate bank accounts.
ActBlue, which Susan Crawford uses for funding her campaign, is collapsing due to criminal money laundering where 20 State Attorney Generals have opened an investigation into them. An article came out on this new development just days ago:
https://www.nytimes.com/2025/03/05/us/politics/actblue-democrat-fundraising-resignations.html
Following is just one example of over 1,000 Smurfs used to boost the Crawford campaign. His name is Mark Jennerjohn, Appleton, WI (age 66). Recorded at the FEC since 1/1/2019 is 7,313 transactions, and 764 to various state of WI politicians and PACS, to total 8,077 in a six-year period.
“Exhibit C, Jennerjohn Compilation of State & Federal Donations" shows 196 combined state and federal contributions made by Mark Jennerjohn to various state and federal politicians and PACs since 6/1/2024 (the date Crawford announced her Candidacy for Supreme Court). The total is $25,379. That would be $2,819 per month (nine-month period). Please note the transactions dates; many on the same day and consecutive days in a row.
- Breaking down the state and federal donations even further,
o Mark Jennerjohn supposedly made 21 donations to Democratic Party of WI Federal PAC between 6/1/24 and 1/29/25 to total $1,199.
o Mark Jennerjohn supposedly made 33 donations directly to Susan Crawford to total $3,135. See “Exhibit B JennerJohn Donations to Crawford”. The daily donation patterns with same day and many consecutive days in a row show a computer bot is doing these transactions, not a human being.
- Donations to WI politicians include 29 times to Janet for Justice, also a Supreme Court race in 2024, to total $2,960. 47 donations were made to Josh Kaul in 2018 to total $527.
- On Thursday, April 6, 2023, a Private Investigator was hired by ElectionWatch, visited Mr. Jennerjohn. This is an excerpt from the PI report: “The subject stated he is disabled, not clothed, but would speak to the investigator at the front door. Upon speaking to the subject regarding his political donation history, he denied making 7,878 donations as well as the dollar amount reported, $93,168. 2
The subject scoffed at the amount and stated, “look where I’m living!” The subject referred to the modest, run-down, small apartment on the second floor of a modest converted home. He stated he donates $5 at times but could never afford to donate over $90,000 in the last 7 years.” This report along with recorded video of Mr. Jennerjohn is available.
- Wisconsin 915 donations attributed to Mr. Jennerjohn between 7/14/2016 and 6/30/2023 total $24,714.28. The daily patterns show a computer bot is doing these transactions, not a human being.
-Federal 5,659 transactions (that don’t include blank transaction lines) attributed to Mr. Jennerjohn between 6/3/2017 to 12/30/2022 total $90,772.
The data on the attached excel spreadsheet(s) includes information from official open sources. An email from Open Secrets who reports heavily on campaign contributions, reported to me that the average number of contributions, for a person making such political contributions, is 4.2 donations per donor per candidate per election cycle (two years). Or thus 2.1 per year. In support, per the FEC contributors who are making political contributions make on average 1.4 contributions per year. This means it is unusual to have 1,397 unique donors
contribute to SCW in excess of two times and also contribute to the Federal campaigns more than 1.4 contributions per year. This is one fact showing a reasonable suspicion.
SCW has 21,681 unique donors comprised of 30,287 donations. 43% of the unique donors are from out of state. It is common to see Smurfs’ who live in other states being used in local Wisconsin elections as there are 300,000 Smufs to choose from according our estimations. Compare the 42% out of state to her Republican opponent’s 3% out of state donations.
Individual Contributions Between 6/10/24 and 2/17/2025
I respectfully submit this complaint to the Wisconsin Judicial Commission concerning serious violations of the Wisconsin Code of Judicial Conduct (SCR Chapter 60) by Judge Susan Crawford, currently serving in the Wisconsin judiciary. The alleged conduct severely undermines public confidence in the impartiality, integrity, and independence of the judiciary and warrants formal investigation and disciplinary proceedings.
This complaint arises from a widespread campaign finance scheme involving the Susan Crawford for Wisconsin (SCW) campaign committee, in which over 1,397 individual names were allegedly used without consent to process over 2,179 campaign contributions totaling approximately $63,903.63. The scale and characteristics of these contributions strongly suggest a fraudulent scheme known as “Smurfing,” where real individuals’ identities are misused to make fictitious political donations through automated means such as bots and proxy financial channels. Smurfing is clearly described in this short article by Investopedia:
https://www.investopedia.com/terms/s/smurf.asp
Judge Crawford’s campaign appears to have facilitated or at minimum failed to prevent this conduct, violating multiple provisions of SCR Chapter 60:
I. Violations of SCR Chapter 60 – Judicial Conduct Code
SCR 60.02 – Integrity and Independence of the Judiciary. Judge Crawford, by engaging in or benefiting from fraudulent campaign financing activity, has severely compromised the perceived integrity and independence of her judicial office.
SCR 60.03 – Impropriety and the Appearance of Impropriety. The use of fictitious names and donor identities, even if not directly orchestrated by Judge Crawford, creates an undeniable appearance of impropriety that erodes public trust in the judiciary.
SCR 60.03(2) – Use of Judicial Prestige for Private Interests. Judge Crawford’s campaign fundraised under the name and image of a sitting judge. To the extent the campaign enabled or failed to prevent misconduct, the judicial office's prestige was misused for personal political benefit.
SCR 60.04(1)(e) – Judicial Duties Without Bias or Prejudice. A judge’s campaign must be held to the highest ethical standards. Improper financial transactions conducted under Judge Crawford’s name raise concerns of bias and preferential influence inconsistent with judicial impartiality.
SCR 60.04(2)(a–c) – Administrative Responsibilities. Judge Crawford had a responsibility to ensure that campaign staff and agents operated in accordance with legal and ethical standards. Her failure to prevent or detect the widespread misuse of donor identities constitutes a breach of administrative responsibility.
SCR 60.04(3)(a–c) – Disciplinary Responsibilities. Under these provisions, a judge must take appropriate action upon learning of unethical behavior. Judge Crawford was aware or should have been aware (although the law states she is guilty no matter if she did or not know) of the suspicious donation patterns and failed to act, she failed her disciplinary duty.
SCR 60.05(1)(a–c) – Extrajudicial Conduct Affecting Impartiality or Performance. Conduct related to campaign activities must not cast doubt on the judge’s ability to be impartial or interfere with judicial duties. The scope of the alleged financial irregularities and public controversy surrounding the campaign directly impact her capacity to serve credibly on the bench.
SCR 60.05(4)(a–e) – Financial Activities Judge Crawford’s campaign finance practices appear to conflict with this section by engaging in improper transactions and benefiting from contributions that could reasonably be perceived as exploiting her judicial position.
SCR 60.06 – Political Activity by Judges. Judge Crawford’s participation in a campaign that accepted contributions from fictitious or improperly verified sources constitutes inappropriate political activity under the code. The high percentage of out-of-state donors and excessive transaction patterns also raise red flags about the integrity of campaign practices.
II. Supporting Evidence
A. Statistical anomalies indicating computer-automated transactions and fictitious donors. B. Private investigator affidavit confirming denial of donations by key donor (Mark Jennerjohn). C. Reference to ongoing federal and state investigations into ActBlue, the platform used by SCW. D. Donation volume analysis showing far above-average contribution activity per individual.
III. Conclusion and Request for Action
The conduct outlined above constitutes substantial violations of Wisconsin’s Code of Judicial Conduct and raises serious concerns about Judge Susan Crawford’s fitness for judicial office. It is respectfully requested that the Judicial Commission undertake a full investigation into these allegations and consider appropriate disciplinary actions up to and including formal reprimand, suspension, or recommendation of removal from judicial office.
Julie Saunders-Seegers
Electronically Signed By: Julie Saunders-Seegers March 13, 2025
Enclosures: Crawford Exhibit A (Crawford Potential Smurfs Sample), Exhibit B (JennerJohn Donations to Crawford), and Exhibit C (JennerJohn Complilation of State and Federal Donations)
References: https://www.fec.gov , https://ethics.wi.gov/Pages/CampaignFinance/CampaignFinance.aspx , https://electionwatch.info/