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For months, Sen. Marsha Blackburn’s federal political operation has sent prospective donors incessant fundraising missives, many replete with false urgency and high pressure — tactics criticized by government agencies and elder advocacy groups. Sometimes, emails arrive multiple times a day.
They work: The Tennessee Republican’s operation has raised more than $9 million during the 2026 election cycle, according to Federal Election Commission records. Much of that money comes from tens of thousands of small-dollar contributions sent by individual donors who’ve responded to solicitations, records indicate.
Blackburn isn’t running for reelection to a federal office. She’s campaigning for state office — governor of Tennessee — where federal campaign dollars generally can’t get spent.
But some of that money is still wending its way toward her gubernatorial campaign. Federal and state campaign finance records indicate the senator’s federal joint fundraising committee, the Blackburn Tennessee Victory Fund, is helping seed a network of conservative Club for Growth super PACs with millions of dollars. And one of the network’s PACs is now spending millions of dollars to boost Blackburn’s gubernatorial campaign.
Blackburn’s novel financial machinations have alarmed some political ethics watchdogs, who say they blur lines between different campaigns and could skirt the spirit, if not the letter, of rules governing the intermingling of state and federal political cash.
“It raises red flags,” said Stuart McPhail, director of campaign finance litigation at Citizens for Responsibility and Ethics in Washington, which generally supports stronger campaign finance laws. “It’s fair to ask, ‘Why is a state-level candidate using a federal committee in this way?’”
Blackburn’s Senate office directed questions to Blackburn’s gubernatorial campaign, which did not respond to repeated requests for comment. The Club for Growth and several of its connected super PACs did not respond to inquiries.
Blackburn’s multi-step transfer of political wealth to Club for Growth’s political committee network began last year with the Blackburn Tennessee Victory Fund, which is composed of her Senate campaign, federal leadership PAC and a federal arm of the Tennessee Republican Party:
- The Blackburn Tennessee Victory Fund shifted about $2.1 million to Marsha for Senate, Blackburn’s dormant Senate campaign committee over the course of 15 months, from March 2025 to June 2026.
- Marsha for Senate contributed $4.8 million to the Club for Growth Action super PAC on May 8, as first reported by the Tennessee Lookout.
- Club for Growth Action contributed $3.55 million to School Freedom Fund Oklahoma, an affiliated state-level political committee established in April, between May 11 and June 8.
- The School Freedom Fund — a related political committee funded by billionaire businessman Jeff Yass, and which shares a Washington, D.C., address with the School Freedom Fund Oklahoma — contributed $4.81 million to the Tennessee Freedom Fund between May 7 and July 7.
- The Tennessee Freedom Fund spent nearly $1.8 million between June 10 and July 9 to advocate for Blackburn’s gubernatorial campaign.
State and federal campaign finance records covering the groups’ activity during August and September aren’t slated for public release until next month.
Bradley Smith, a former Republican chairman of the Federal Election Commission, said the Blackburn Tennessee Victory Fund is legally permitted to continue raising money, particularly since Blackburn hasn’t categorically ruled out running for Senate in the future. (Her current term expires in early 2031.)
The Blackburn Tennessee Victory Fund and Marsha for Senate committees can legally contribute money to super PACs, which may then independently choose how to use that money, including in state races, Smith added.
Tennessee state law prohibits a federal campaign committee from transferring funds to a state-level committee maintained by the same candidate, but does not address the kind of financial moves the Blackburn Tennessee Victory Fund has made.
“There are good reasons to keep raising money for the federal committee,” said Smith, who’s now chairman of the Institute for Free Speech, which generally opposes strong campaign finance laws.
The bipartisan FEC would typically investigate any complaint accusing the Blackburn Tennessee Victory Fund, or any federal committee, of not complying with federal campaign finance rules.
But the commission has been almost entirely out of commission since May 1, 2025, when it lost its legally required quorum of four commissioners needed to execute high-level business, such as formalizing investigations, conducting audits, interpreting statutes, penalizing scofflaws and even conducting public meetings.
President Donald Trump, who alone may float new commissioners to fill empty seats, waited until February to float the Senate two nominees for confirmation. Since then, the Senate has failed to even conduct a confirmation hearing for the pair of Republicans, Ashley Stow and Andrew Woodson.
The FEC declined to comment.
“This underscores how we need a functioning FEC to investigate these questions,” said Faith Williams, senior policy manager for anti-corruption and accountability at Common Cause. “The Senate can do something about it — wouldn’t that be nice — but isn’t.”
Recent polls show Blackburn with a sizable lead over her main gubernatorial race rival, Democrat Jerri Green. The Republican entered August with about $2.7 million in her state campaign account. Green’s campaign, in contrast, had about $118,000.
Meanwhile, back at the federal level, the Blackburn Tennessee Victory Fund keeps asking potential donors for money with aggressive pitches:
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