
(Georgia Recorder) — An influential conservative lobbying group has allegedly failed to file the proper disclosures in connection with advertisements for Gov. Brian Kemp and Lt. Gov. Burt Jones in the 2022 election, according to a complaint filed with the State Ethics Commission.
Frontline Policy Action is an evangelical 501(c)(4) organization that successfully lobbied during the 2025 Legislative session for bills including the so-called Religious Freedom Restoration Act and a ban on transgender women and girls playing on women’s school sports teams.
The complaint, submitted April 30 by attorney Bryan Sells, alleges that Frontline Policy Action violated multiple state laws in the runup to the 2022 election in which Kemp won a rematch against Democrat Stacey Abrams.
Failure to Report Advertising spending
According to the complaint, Frontline produced and distributed several advertisements in October and November 2022, including a 30-second video featuring a transgender swimmer winning a competition that appeared on Facebook and Instagram.
Sellers says Frontline did not file required disclosure reports containing the expenditures for those advertisements on the four dates required by the state, and he says that amounts to four separate violations.
Failure to Disclose Contributions and Expenditures
Between July 1, 2022 and June 30, 2023, Frontline reported bringing in $246,831 in contributions and spending $237,311 on its IRS filings, but the complaint alleges Frontline did not report either its income or its expenditures to the State Ethics Commission, which Sells alleges amounts to two more violations of the law.
Failure to include required statements
Under state law, any time an independent committee like Frontline pays for a political advertisement, the ad needs to clearly state that it was funded by the committee.
Sells found three advertisements he says does not contain that required statement, which he says equals three more violations.
Coordinated Campaign Contributions
State law forbids anybody from making contributions to any candidate for statewide elected office above certain inflation-adjusted limits. For the 2022 election, that limit was $7,600.
There are ways to get around that limit, but only under certain conditions, including that payments must not be made with the “cooperation or consent of, or in consultation with, or at the request or suggestion of any candidate or any of his or her agents or authorized committees.”
The complaint alleges that Frontline failed this test because a member of its board was also an agent of the governor.
According to Sells, Brad Hughes, director of field services at Kemp’s office since 2019, was also a member of the Board of Directors of Frontline Policy Action Inc. since 2021.
Previous allegations

Last November, the Southern Poverty Law Center, which designates Frontline as an anti-LGBTQ hate group, filed a complaint alleging that Frontline’s president and founder Cole Muzio and attorney Chelsea Thompson had been lobbying lawmakers under the Gold Dome without properly registering. According to that complaint, Muzio had not registered as a lobbyist since 2022 and Thompson had never registered.
A February open records request with the ethics commission for all documents related to that complaint yielded only the complaints themselves. The commission confirmed Monday that there was nothing new to report.
Thompson dismissed the complaint in a text message.
“This is a non-issue stemming from site technical issues. I’ve been in communication with the Commission and have exercised due diligence throughout the process, and expect the matter to be resolved soon.”
Thompson added that she is registered as a lobbyist but Muzio is not because that is not part of his role.
“It would be inaccurate to say ‘y’all/we’ registered as lobbyists,” she said. “I became the sole/lead lobbyist for our organization following the 2024 legislative session. Also, it would be false to suggest that we registered as lobbyists in response to the complaint, our registration reflects a change in role and responsibility, not a reaction to any complaint.”
Kemp’s office declined to comment on the matter.
“Our office has not received or read the complaint and it is not our practice to comment on complaints pending review or action,” said Kemp spokesperson Garrison Douglas.
During the session, it is common to see Frontline activists speaking with lawmakers around the Capitol.
Muzio and Thompson stood behind Speaker Jon Burns as he unveiled the House’s transgender sports ban bill and behind Acworth Republican Sen. Ed Setzler as he made his final pitch for his ultimately successful RFRA bill. Thompson is often seen sitting alongside lawmakers in committee meetings as they present red meat conservative bills.
The group’s considerable influence and legislative successes have made them a major pain for Democrats.
“I don’t think the general public has a real grasp of just how deeply embedded this Christian nationalist organization is in making policy for the state of Georgia,” said Rep. Karen Lupton, a Chamblee Democrat.
“Everybody down here knows exactly who’s with Frontline, who they’re talking to, who they have in their pockets, and it’s just kind of accepted as, ‘well this is the way we do business in Georgia,’ and that’s not acceptable to me,” she added.
Lupton, who was raised as an evangelical Christian and planned to major in Bible studies, said she thinks Frontline uses its significant influence to launder hateful ideology.
“If people can see past the quote-unquote issue that’s on the page whatever issue they’re bringing up and look past it to where it is coming from – those anti-trans bills, those quote-unquote ‘sports safety bills’ did not come from athletic organizations, they did not come from athletes, they did not come from coaches, they came from the Christian nationalist far-right, and people need to know that.”