News & Insights

In-Compliance: Holtzman Vogel's September 2025 Political Law Update

By: Michael Bayes, Joseph T. Burns, Matthew Petersen, Andrew D. Watkins, Rebecca Layne, Alexandria J. Saquella, Jared Bauman, Austin Graham, Drew C. Marvel, and Maryanna Mitchell

In this In-Compliance September 2025 Political Law Update, we cover the following topics:

President Trump Orders Investigation into Impermissible Use of Federal Grant Funds for Lobbying

President Trump issued a Presidential Memorandum directing U.S. Attorney General Pam Bondi to investigate whether federal grant funds are being improperly used to support lobbying activities or political candidates and parties. The directive was prompted by “[f]ederal funding reviews by my Administration [that] have revealed that taxpayer funds are being spent on grants with highly political overtones" and related concerns about "the possible use of Federal grants as slush funds for political and legislative advocacy.” 

Trump Administration Announces Plans to Investigate Nonprofit Groups and Funding Sources Allegedly Connected to Domestic Political Violence

In the wake of the politically motivated assassination of conservative activist and Turning Point USA leader Charlie Kirk, Vice President JD Vance announced that the Trump Administration would “work to dismantle the institutions that promote violence and terrorism in our own country . . . in the months to come.” On September 25, President Trump took a significant step forward in formalizing this plan in a memorandum on “Countering Domestic Terrorism and Organized Political Violence.” The memorandum explains that “[t]he United States requires a national strategy to investigate and disrupt networks, entities, and organizations that foment political violence so that law enforcement can intervene in criminal conspiracies before they result in violent political acts. 

U.S. House and Senate Announce Measures to Provide Additional Funding for Member Security

In the aftermath of Charlie Kirk’s assassination on September 10, 2025, both the U.S. House of Representatives and Senate took swift action to provide Members with additional resources to bolster their personal security. 

FEC Vice Chairman Trey Trainor Resigns Effective October 3; Agency Down to Two Commissioners

Federal Election Commission (FEC) Vice Chairman Trey Trainor announced his resignation from the agency on September 25, to be effective October 3. Trainor’s departure will leave the FEC with only two Commissioners, both Democrat appointees. The agency has been without a four-member quorum since Allen Dickerson departed in late April.

Jimmy Kimmel Prevails in Copyright Dispute with George Santos

On September 15, the Second Circuit Court of Appeals issued a ruling in favor of late-night host Jimmy Kimmel in a lawsuit brought by former Congressman George Santos, who accused Kimmel of copyright infringement, along with several state law causes of action. 

New York State Ethics Commission Undertakes Review of Ethics and Lobbying Laws, Seeks Written Comments from Public

New York State’s Commission on Ethics and Lobbying in Government (COELIG) is undertaking a comprehensive review of the state’s ethics laws, regulations, and advisory opinions. As part of this review, COELIG held a public hearing on September 25, 2025, and the Commission is accepting written comments via email through October 2, 2025. COELIG’s review is required by the 2022 Ethics Commission Reform Act (ECRA), the legislation that created COELIG.

Florida Ban on Charitable Fundraising from 'Foreign Sources of Concern' Now in Effect

Earlier this year, the Florida Legislature enacted SB 700, which introduced a broad prohibition against charitable organizations receiving money or other support from hostile foreign powers. Under the new law, which took effect on July 1, a charitable organization registered in Florida may not solicit or accept contributions or anything else of value from a “foreign source of concern,” which includes an individual, government, or group from China, Russia, Iran, North Korea, Cuba, Venezuela, and Syria. 

11th Circuit Upholds Florida Law Barring Noncitizens and Nonresidents from Gathering Signatures for Constitutional Initiative Petitions

The Eleventh Circuit Court of Appeals issued a 2-1 decision staying a lower court's preliminary injunction and allowing Florida's H.B. 1205 to take effect, concluding that citizenship and residency requirements for petition signature collectors likely do not violate the First Amendment since Florida's substantial interest in preventing voter fraud would be achieved less effectively without them.

Federal District Court Upholds Georgia Restrictions on Absentee Ballot Application Distribution

A federal district court upheld two provisions of Georgia law adopted in 2021 relating to the distribution of absentee ballot applications. The provisions at issue prohibit sending a voter an absentee ballot application that is prefilled with the voter’s required information and requires that absentee ballot applications may only be sent to individuals who have not already requested, received, or voted an absentee ballot in the primary, general, or runoff election.

South Carolina Supreme Court Rejects Partisan Gerrymandering Claims

On September 17, the Supreme Court of South Carolina issued an opinion in League of Women Voters of South Carolina v. Alexander upholding the State’s congressional redistricting plan while finding partisan gerrymandering claims to be non-justiciable political questions under the South Carolina Constitution. 

Andy Gould & Jon Riches - Disclosure Laws Put Targets on the Backs of Nonprofit Donors

In an age of doxxing, violent threats, and professional retribution for people’s policy positions, exposing donors creates real risks. Andy Gould and Jon Riches write for the National Review.

Supreme Court to Hear Direct Challenge to Humphrey's Executor; Will Reconsider Congressional Authority to Restrict President's Ability to Remove Independent Agency Commissioners

The Supreme Court may be on the cusp of overturning a 90-year-old precedent that has long served as one of the cornerstones of the modern administrative state. On September 22, 2025, the Court issued an order staying the lower court’s decision blocking President Trump’s attempted removal of Rebecca Slaughter from the Federal Trade Commission (FTC), effectively allowing her removal from the agency pending the outcome of her case. In addition, the Court announced it would hear Ms. Slaughter’s challenge to her removal and asked the parties to address two questions: (1) Whether the statutory removal protections for members of the FTC violate the separation of powers, and, if so, whether Humphrey’s Executor should be overruled; and (2) Whether a federal court may prevent a person’s removal from public office, either through relief at equity or at law.

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