Bondi Donation: $25,000 Trump Foundation Gift to Florida Attorney General While Trump University Investigation Was Under Consideration
Tier 1Resolved2013-08-25 to 2019-11-07
Factual Summary
On September 17, 2013, the Donald J. Trump Foundation made a $25,000 donation to And Justice for All, a political committee supporting Florida Attorney General Pam Bondi. The donation was made during a period when Bondi's office was considering whether to join a multi-state investigation of Trump University, following New York Attorney General Eric Schneiderman's August 25, 2013 filing of a $40 million fraud lawsuit against Trump and Trump University.
The check was signed by Trump on September 9, 2013. Bondi's office had received complaints about Trump University from Florida consumers, and her spokeswoman later acknowledged that the office was reviewing the New York lawsuit at the time of the donation. Bondi had personally solicited the contribution from Trump. In mid-October 2013, Bondi's office announced it would not pursue its own investigation, stating that affected Florida consumers would be compensated if the New York lawsuit succeeded.
The donation violated federal tax law. Private foundations such as the Trump Foundation are prohibited under Section 501(c)(3) of the Internal Revenue Code from making political contributions to any candidate or campaign committee. The Trump Foundation initially attempted to disguise the donation by listing it on its IRS Form 990 as a contribution to an unrelated Kansas charity with a similar name, "Kansas Justice Institute." When the discrepancy was discovered by the Associated Press and Citizens for Responsibility and Ethics in Washington (CREW), the Trump Foundation acknowledged the error, filed amended tax returns, and paid a $2,500 excise tax penalty to the IRS.
The New York Attorney General cited the Bondi donation as part of the broader pattern of illegal conduct in the lawsuit against the Trump Foundation. Justice Saliann Scarpulla's November 2019 order dissolving the Foundation referenced the political contribution as one of several instances of the Foundation being used for purposes other than charitable activity.
A state prosecutor in Florida reviewed a bribery complaint related to the donation and concluded in 2016 that there was insufficient evidence to establish that Trump or Bondi violated Florida's bribery statute. Bondi has consistently denied that the donation influenced her office's decision not to investigate Trump University.
Primary Sources
1. Trump Foundation IRS Form 990-PF (2013), including the erroneous listing of the donation to "Kansas Justice Institute"
2. Amended Trump Foundation tax filing correcting the donation recipient
3. NY AG petition, People v. Trump Foundation, Index No. 451130/2018, citing the Bondi donation
4. IRS excise tax penalty of $2,500 assessed against the Trump Foundation
Corroborating Sources
1. CREW: "The Trump Foundation-Pam Bondi Scandal," ongoing investigation
2. ABC News: "What We Know About the Trump Foundation's Donation to Florida AG Pam Bondi's Fundraisers," September 2016
3. PolitiFact: "Donald Trump, Pam Bondi and $25K: Was Trump's donation pay to play?," September 2016
4. CBS News: "Florida AG Pam Bondi is cleared in complaint involving $25K donation from Trump," 2016
5. WUSF: "Florida Attorney General Pam Bondi Tried to Return Controversial $25,000 Donation from Trump," June 2016
Counterarguments and Context
Bondi and Trump both denied any connection between the donation and the decision not to investigate Trump University. Bondi stated that her office's decision was based on the merits and that the New York lawsuit would provide adequate relief for any affected Florida consumers. Bondi's office noted that it had received only one complaint about Trump University from a Florida resident. Trump's representatives argued that the donation was made because Bondi asked for it and that Trump routinely contributed to politicians of both parties. Bondi reportedly attempted to return the donation after the controversy became public, but the refund was never processed. The Florida prosecutor who reviewed the bribery complaint found insufficient evidence of a corrupt agreement, meaning no formal charge was brought against either party. The IRS penalty for the illegal charitable contribution was limited to the standard excise tax for first-time self-dealing violations.
Author's Note
This entry is classified as Tier 1 because the illegal nature of the Foundation's political contribution is an adjudicated fact: the IRS assessed a penalty, the Foundation filed amended returns acknowledging the violation, and the New York Supreme Court cited the donation in the Foundation dissolution order. The separate question of whether the donation constituted bribery was reviewed and closed without charges, a determination that this entry documents rather than disputes. The circumstantial timeline, in which a solicited donation preceded the decision not to investigate, is a matter of documented record regardless of whether corrupt intent is established.