A complaint filed February 24, 2026, with the Federal Election Commission alleges that Daniel Biss, his principal campaign committee (Biss for Congress), and his state committee (Friends of Daniel Biss) violated the Federal Election Campaign Act by using nonfederal funds in connection with a federal election. See Complaint, Fine v. Biss, FEC Complaint (Feb. 24, 2026).
The complainant, Carol Ronen, asserts that Biss is simultaneously a candidate for U.S. House in Illinois’s 9th Congressional District and for Democratic State Central Committeeman. According to the complaint, Friends of Daniel Biss, which is rasiing money for the state central committee race and may raise funds outside federal limits, sent a mailer that attacked Laura Fine by name. Laura Fine is Biss’s opponent in the congressional primary. Though, she is also a candidate for 9th District Central Committeeperson.
The mailer, juxtaposes Biss and Fine but includes detailed criticisms of Fine’s voting record and federal donors, including references to Trump donors, AIPAC, and alleged support from certain groups. The mailer discloses that it was “Paid for by Friends of Daniel Biss,” the nonfederal committee.
The legal theory rests on 52 U.S.C. § 30125(e), which prohibits a federal candidate, or an entity established, financed, maintained, or controlled by a federal candidate, from spending funds not subject to the Act’s limitations and reporting requirements in connection with a federal election. The complaint acknowledges that dual candidates may use nonfederal funds for state or local races, but contends that the exception applies only when the spending is solely in connection with the nonfederal election.
According to the filing, the state central committee race is structured so that voters elect one male and one female candidate from each congressional district. The complaint argues that because Biss (male) and Fine (female) are not competing against each other for the same state central committee seat, the mailer’s framing is misleading and cannot credibly be characterized as state-only advocacy.
The complainant requests that the FEC investigate and seek the highest penalties available under law.
As with any FEC matter, the filing of a complaint represents allegations, not findings. The Commission must determine whether there is “reason to believe” a violation occurred before proceeding to investigation or enforcement. The case presents a recurring issue for dual federal/state candidates: when state-level activity crosses the line into activity “in connection with” a federal election, triggering federal source restrictions.

