2023 - 2024 LEGISLATURE
November 2, 2023 - Introduced by Representatives Brandtjen, Allen, Behnke,
Bodden and Wichgers. Referred to Committee on Government Accountability
and Oversight.
AR18,1,3 1Relating to: the impeachment of Meagan Wolfe, the Administrator of the Wisconsin
2Elections Commission, citing allegations of maladministration in office and
3potential violations of election laws.
AR18,1,54 Whereas, the following articles of impeachment are presented to the Wisconsin
5State Assembly and Senate:
AR18,1,7 6Article 1. Administrator Wolfe's Maladministration During the 2020
7Presidential Election
AR18,2,28 Administrator Wolfe promoted and encouraged illegal alterations of absentee
9ballot applications during the administration of the 2020 presidential election in
10Wisconsin. It is important to note that absentee voting, in contrast to in-person
11voting, is regarded as a privilege rather than a right, primarily due to legislative
12concerns regarding potential fraudulent activities associated with absentee voting
13that are not as prevalent in in-person voting. This perspective on absentee voting
14has been acknowledged since former President Carter's review of the 2000

1presidential election identified absentee voting as a significant source of potential
2election fraud.
AR18,2,113 To address the perceived vulnerabilities of absentee voting, the legislature
4established a series of safeguards, with one of the primary requirements being that
5absentee ballots must be witnessed by a third party who provides their name,
6signature, and address. Unfortunately, some Wisconsin Elections Commission
7(WEC) members, with whom Administrator Wolfe concurred, criticized these
8security measures as “vote suppressors" and employed derogatory characterizations.
9As the chief elections official in Wisconsin, Administrator Wolfe was responsible for
10advocating for adherence to the laws set by the legislature and advising
11commissioners while publicly supporting adherence to the law.
AR18,2,2412 Throughout the relevant period, Administrator Wolfe was aware, or should
13have been aware, that absentee ballots failing to meet legal requirements, such as
14missing witness signatures or addresses, should not be counted. Despite this
15knowledge, Administrator Wolfe approved and endorsed specific instructions within
16the Election Administration Manual for Wisconsin Municipal Clerks, which stated
17that clerks “may add a missing witness address using whatever means are
18available." This so-called “ballot curing" procedure violated the legislative intent for
19strict compliance with absentee ballot requirements and did not guarantee accurate
20corrections. This maladministration of “curing," promoted and encouraged by
21Administrator Wolfe, created disparities in how voters were treated, allowing some
22deficient ballots to be “cured" while others were not. The decision on which votes
23would count was left to the municipal clerk, whereas the legislature had previously
24determined it.
1Wisconsin Statute § 6.87 (6d) explicitly states, “If a certificate is missing the
2address of a witness, the ballot may not be counted." However, the law does provide
3a lawful method to correct missing absentee ballot information under Wis. Stat. §
46.87 (9). According to this law, if a municipal clerk receives an absentee ballot with
5an improperly completed certificate or no certificate, the clerk may return the ballot
6to the elector inside the sealed envelope if available, along with a new envelope if
7necessary, allowing the elector to correct the defect and return the ballot within the
8authorized period under subsection (6). Contrary to Administrator Wolfe's directive
9to clerks, it was the voter's responsibility to correct absentee ballot errors, not the
10clerks' responsibility.
AR18,3,2011 During the investigation into this matter, the Wisconsin Institute of Law and
12Liberty (WILL) discovered high rates of cured ballots in Green Bay and Racine.
13Nonprofit partners of the Center for Tech and Civic Life (CTCL), such as US Digital
14Response (USDR), Elections Group, and National Vote at Home Institute (NVAHI),
15played an active role in curing ballots in these locations. These partners offered
16services to streamline and automate the ballot curing process in several cities.
17Administrator Wolfe, as with the SVD issue outlined in Article 5, failed to fulfill her
18duty to take reasonable steps to ensure that essential election laws concerning the
19receipt of deficient and ineligible absentee ballots were adhered to during the 2020
20presidential election in Wisconsin.
AR18,3,22 21Article 2. Administrator Wolfe's Neglect of Duty in Safeguarding
22Wisconsinites' Personal Data
AR18,4,823 Administrator Wolfe committed maladministration by unlawfully failing to
24protect Wisconsin citizens' confidential and personal information as mandated by
25state statutes. These statutes require the Administrator to enter into a contract with

1the Electronic Registration Information Center (ERIC), a private nonprofit, of which
2Administrator Wolfe was the Chairman until recently. ERIC's stated purpose is to
3assist states in maintaining accurate voter rolls. Yet, it has proven to be ineffective,
4evident in the fact that Wisconsin, with approximately 4.5 million eligible voters, has
5over 7 million names on its voter rolls—a situation that Administrator Wolfe has
6actively contributed to. Furthermore, in the calendar year 2023, eight states have
7terminated their relationships with ERIC, casting doubt on its ability to achieve its
8stated objectives.
AR18,4,219 Notably, Kevin Kennedy, the then-chief legal counsel for the Government
10Accountability Board, signed a contract with WEC shortly after the statutes
11authorizing WEC's creation were enacted. The Government Accountability Board
12was dissolved by statute due to its perceived dishonest and partisan activities.
13Despite this, Administrator Wolfe has never signed a contract with ERIC. It is
14crucial to underline that the duty to sign such a contract is explicitly laid out in the
15statute to protect the confidential information of all Wisconsin citizens.
16Administrator Wolfe was well aware of this duty through her four-year term as
17Administrator of the WEC or her concurrent role as Chairman of ERIC. Her failure
18to uphold this vital statutory duty has left ERIC, an organization with partisan
19implications if not in name, with unrestricted access to sell, distribute, or share
20confidential data. Administrator Wolfe's neglect of this straightforward and
21essential duty is indefensible.
AR18,4,23 22Article 3. Administrator Wolfe's Maladministration in Ensuring
23Safeguards Against Fraudulent Voting
AR18,5,824 Administrator Wolfe unlawfully failed to establish the minimum required
25safeguards to prevent fraudulent voting in Wisconsin. Under Wisconsin law,

1residents temporarily residing overseas can cast ballots in Wisconsin's elections. It
2is also incumbent upon Administrator Wolfe to establish, implement, and maintain
3a comprehensive database containing the names of these individuals. This database
4serves as a crucial tool for municipal clerks to cross-reference voter requests with the
5overseas voter list, thereby ensuring the legitimacy of such requests. This safeguard
6is especially significant because, unlike military overseas absentee voters,
7non-military overseas voters are not required to provide a photo ID when requesting
8an absentee ballot.
AR18,5,209 Regrettably, Administrator Wolfe's maladministration unfulfilled her
10responsibility to create, implement, and maintain this reference database for our
11clerks. Consequently, this method of ballot gathering is left vulnerable to fraudulent
12activity, akin to the vulnerabilities seen in the military overseas voting system. In
13other words, just as demonstrated by the case of Kim Zapata, who fabricated three
14fictitious names and addresses of non-existent military absentee ballot requesters
15and had all three ballots sent to Representative Brandtjen's home, anyone, from
16anywhere, at any time, can similarly obtain an unlimited number of non-military
17absentee ballots. Much like the ballots sent to Representative Brandtjen's home,
18there is no mechanism to verify the authenticity of non-military overseas absentee
19ballots obtained through this process. This lack of verification results directly from
20Administrator Wolfe's complete and inexcusable failure to fulfill her duties.
AR18,5,22 21Article 4. Administrator Wolfe's Unlawful Advocacy for Ballot Drop
AR18,6,423 Administrator Wolfe unlawfully promoted maladministration with the use of
24ballot drop boxes. In her role as Wisconsin's chief elections official, Administrator
25Wolfe was responsible for guiding clerks regarding the procedures outlined in the

1state's elections law. However, there have been instances where Administrator Wolfe
2acted as if she, and not the legislature, had the authority to establish rules for
3Wisconsin's elections. One such instance was her purported authorization of ballot
4drop boxes.
AR18,6,95 Ballot drop boxes were unfamiliar in Wisconsin before the 2020 presidential
6election cycle. Their use was mandated for the state's five largest cities through
7contracts signed with the “Center for Tech and Civic Life" (CTCL), a private
8corporation funded by Mark Zuckerberg to conduct partisan Get Out the Vote
9(GOTV) campaigns in Wisconsin and other swing states.
AR18,6,1710 Under the guise of her official role, Administrator Wolfe fully supported and
11promoted the use of these unauthorized drop boxes by issuing a series of memoranda
12(prepared by WEC staff under her supervision) to municipal clerks. This
13endorsement and promotion of ballot drop boxes ran counter to Wisconsin law, as
14highlighted in the Teigen case, which concluded that WEC's staff erred by
15authorizing a voting method not sanctioned by law. The memos created a ballot drop
16box system entirely absent from Wisconsin's election code, as the legislature's
17procedures for absentee voting do not allow for voting via ballot drop boxes.
AR18,6,2518 Ballot drop boxes present opportunities for election fraud by reducing the
19likelihood of detection, and their maladministration use, as endorsed and promoted
20by Administrator Wolfe, likely had a significant and unfair impact on the outcome
21of the November 2020 presidential election in Wisconsin. The cities of Green Bay,
22Kenosha, Madison, Milwaukee, and Racine received $216,000 from CTCL
23specifically to purchase and utilize 44 ballot drop boxes in Wisconsin's five largest
24metropolitan areas. The exact number of ballots deposited in these unlawful drop
25boxes during the 2020 election remains unknown.
1Article 5. Administrator Wolfe's Role in Enabling Unlawful Absentee
2Voting in Long-Term Care Facilities Without Special Voting Deputie
AR18,7,123 Administrator Wolfe was involved in facilitating illegal absentee voting in
4long-term care facilities without the presence of Special Voting Deputies (SVDs), as
5required by Wisconsin law. According to Wisconsin law, when absentee voting is
6conducted in long-term care facilities such as nursing homes, each municipal clerk
7or their designated representatives must be accompanied by two SVDs, one from
8each of the two major political parties. These SVDs receive specialized training and
9take an oath to ensure that absentee voting is conducted strictly with the law. One
10of their essential functions is to challenge the competency of potential voters in
11nursing homes and other long-term care facilities, as outlined in Wis. Stat. § 6.875
AR18,7,2413 Administrator Wolfe caused maladministration by assisting five out of the six
14WEC commissioners in consistently voting to unlawfully direct Wisconsin's clerks to
15disregard the statutorily mandated SVD procedure. This disregard for the law
16occurred in 2020 during the administration of three separate elections, including the
17presidential election. Several authorities, including the Racine County Sheriff's
18Department, the Racine County District Attorney, Wisconsin's Legislative Audit
19Bureau (LAB), and the Wisconsin Assembly's Special Counsel to Investigate the
202020 presidential election, all reached the conclusion that WEC violated Wisconsin
21election law each time it permitted absentee voting in long-term care facilities
22without requiring the presence of at least two special voting deputies. It is
23indisputable that the actions of those five commissioners and Administrator Wolfe
24were illegal.
1Throughout the relevant period, Administrator Wolfe publicly and privately
2supported this illegal scheme and encouraged Wisconsin's clerks to participate in it.
AR18,8,4 3Article 6. Administrator Wolfe's Neglect in Safeguarding the Votes of
4Overseas Military Voters
AR18,8,105 Administrator Wolfe is charged with maladministration for failing to protect
6overseas military voters' votes, as Wisconsin Statutes require. These statutes assign
7to WEC and its Administrator, Meagan Wolfe, the responsibility to establish,
8implement, and maintain a process through which the identities of Wisconsin
9residents serving in the military and stationed overseas can be made available to
10municipal clerks.
AR18,8,1611 Upon receiving an application for a ballot from a purported serviceman or
12woman, the municipal clerk is then statutorily obligated to refer to the identification
13list created, implemented, and maintained by WEC to verify the individual's military
14service status. This verification process is especially crucial because military service
15personnel are exempt from the statutory requirement to present photo identification
16before voting.
AR18,9,517 The significance of the system that WEC is mandated to create, implement, and
18maintain cannot be overstated; it serves as the protective barrier between access to
19military ballots and those who may attempt to fraudulently obtain them by falsely
20claiming eligibility. The need for such a verification system was unequivocally
21demonstrated in October 2022 when Kim Zapata, then employed as the Deputy
22Director of the Milwaukee Election Commission, intentionally fabricated three
23fictitious names with non-existent home addresses and submitted them online to
24generate three fraudulent ballots, which were subsequently mailed to the residence
25of Representative Janel Brandtjen, who was serving as the Chairman of the

1Assembly Committee on Campaigns and Elections at the time. These fraudulent
2ballots were indeed delivered to Representative Brandtjen's home, prompting her to
3turn them over to law enforcement. Kim Zapata later admitted her actions,
4explaining that she did so to illustrate to Representative Brandtjen and others the
5“true" vulnerability to fraud in Wisconsin elections.
AR18,9,96 Crucially, due to Administrator Wolfe's negligence, if anyone had cast the three
7fraudulent ballots created by Kim Zapata, there would have been no means to detect
8the fraudulent activity or the resulting disenfranchisement of three legitimate
9military absentee ballots.
AR18,9,1210 When a lawsuit sought declaratory and injunctive relief to compel
11Administrator Wolfe to address this dereliction, she engaged the services of a private
12law firm, the Mark Elias Law Group, in an attempt to avoid remedying the situation.
AR18,9,14 13Article 7. Administrator Wolfe's Involvement in the Employment of
14Partisan, Out-of-State Residents for Election Administration in 202
AR18,9,2415 Administrator Wolfe facilitated, promoted, and encouraged the employment of
16partisan, out-of-state residents to administer Wisconsin's elections in 2020. In this
17maladministration, Mark Zuckerberg's stated objective in 2020 was to aid in the
18defeat of President Donald Trump. Zuckerberg enlisted the services of David Plouffe,
19one of former President Obama's principal political advisors and the author of “The
20Citizen's Guide to Beating Donald Trump," to oversee a plan aimed at staffing the
21offices of the largest cities in swing states with partisan employees and agents to
22administer the elections in those cities. An essential aspect of this plan, called
23“block-by-block political warfare," was directed at cities like Detroit, Milwaukee,
24and Philadelphia.
1David Becker, a highly partisan individual employed by George Soros and the
2administrator of the partisan Electronic Registration Information Center (ERIC),
3played a central role in executing this scheme. It is noteworthy that while
4Administrator Wolfe was the Chairman of ERIC, David Becker was in charge. In this
5context, Zuckerberg, Plouffe, and Becker arranged for the Center for Tech and Civic
6Life (CTCL) to distribute payments totaling $8.8 million to the five largest cities in
7Wisconsin, namely Milwaukee, Madison, Racine, Kenosha, and Green Bay (referred
8to as the “Zuckerberg Five" or the “Cities"). The contracts governing the transfer of
9these funds required the Cities to perform various services for Zuckerberg, with a
10primary obligation being the installation of illegal ballot drop boxes in unmonitored
11locations. Additionally, the Cities were required to “cooperate" with Zuckerberg's
12directives and follow the instructions of CTCL's designated personnel in
13administering the elections.
AR18,10,2214 One of the individuals involved in this scheme was Michael
15Spitzer-Rubenstein, a Brooklyn, New York resident and known partisan. In an
16email to the clerks of the Zuckerberg Five Cities, Administrator Wolfe provided her
17authorization to utilize Michael Spitzer-Rubenstein as part of their election
18administration efforts. Although Claire Woodall-Vogg, the Milwaukee Election
19Commission's leader, recommended Michael Spitzer-Rubenstein to Administrator
20Wolfe without indicating that she had vetted him, Administrator Wolfe promptly
21forwarded this recommendation to the clerks of the Zuckerberg Five Cities,
22suggesting they reach out to him if they were interested in learning more.
AR18,11,423 As a direct result of Administrator Wolfe's recommendation, Michael
24Spitzer-Rubenstein, a designated “partner" of Zuckerberg and CTCL, assumed
25control over various aspects of the Green Bay election, including overriding the

1Clerk's recommendations, signing contracts, controlling access to a key location, and
2determining the acceptance of ballots after the 8 p.m. deadline. Mr.
3Spitzer-Rubenstein lacked the requisite training, certification, and oath of office
4necessary to work in Wisconsin elections.
AR18,11,125 Wisconsin Statute § 5.02 (4e) defines an election official as an individual
6charged with duties related to election conduct. The Wisconsin Election
7Administration Manual emphasizes the importance of qualified and well-trained
8election officials. Michael Spitzer-Rubenstein did not meet these qualifications and
9was disqualified due to his New York residence. After Administrator Wolfe's
10recommendation, any roles assigned to Mr. Spitzer-Rubenstein by the clerks would
11have involved his participation in election activities, constituting a violation of Wis.
12Stat. § 5.02 (4e).
AR18,11,1913 Spitzer-Rubenstein also played a significant role in the Racine 2020 election,
14setting up systems, collecting ballots, and creating absentee ballot logs. He authored
15the Election Day Manual in Milwaukee, had exclusive access to critical information,
16and recruited out-of-state personnel. This scheme included “ballot navigators" who
17could visit citizens' homes, represent themselves as being “from the City" (although
18funded by Zuckerberg/CTCL), offer assistance in completing absentee ballots, and
19potentially illegally return the ballots to the clerk's office.
AR18,11,2320 Administrator Wolfe's cooperation in this scheme was vital for covering the
21Zuckerberg Five Cities clerks. By participating in and facilitating this scheme,
22Administrator Wolfe betrayed the trust of Wisconsin citizens who had entrusted her
23with the position of Administrator of WEC.
AR18,11,25 24Article 8. Administrator Wolfe's Maladministration of Third-Party
25Submission of Absentee Ballot Applications
1Administrator Wolfe's actions regarding submitting absentee ballot
2applications by individuals other than the voter, contravening Wisconsin election
3laws, were unlawful. Administrator Wolfe is responsible for the guidance provided
4in the Election Administration Manual for Wisconsin Municipal Clerks.
AR18,12,85 According to the manual, “If an absentee ballot request is delivered by someone
6other than the registered elector (spouse, campaign volunteer, etc.), it is treated as
7a by-mail request." This directive lacked a legal basis, and Administrator Wolfe's
8actions in this regard were unlawful, as outlined in the Teigen case.
AR18,12,149 Wisconsin Statute § 6.86 describes six distinct “methods for obtaining an
10absentee ballot," and § 6.86 (1) (a) 2. specifies the law for submitting an absentee
11ballot application directly to the municipal clerk, stating, “In person at the office of
12the municipal clerk or at an alternate site under s. 6.855, if applicable." Notably, Wis.
13Stat. § 6.86 (1) (a) 2. allows the elector to personally submit their absentee ballot
14application at the clerk's office.
AR18,12,1915 Administrator Wolfe's directive to clerks, permitting a “spouse," “ campaign
16volunteer," or other agents to submit absentee ballot applications on behalf of
17electors, contradicted the plain language of Wis. Stat. § 6.86 (1) (a) 2. Furthermore,
18her treatment of absentee ballot applications submitted by agents as “by-mail"
19requests also conflicted with the statute's language.
AR18,13,220 How Wolfe mishandled the return of absentee ballot applications paralleled her
21maladministration of absentee ballot returns. In the Teigen case, the Wisconsin
22Supreme Court addressed the delivery of absentee ballots and emphasized that
23Wisconsin law did not allow agents or anyone other than the elector to submit an
24elector's absentee ballot directly to a clerk's office. Similarly, Wisconsin law did not

1permit a family member or agent to submit an elector's absentee ballot application
2directly to a clerk's office, as Administrator Wolfe allowed.
AR18,13,113 The court noted that the guidance provided by Administrator Wolfe in the
4March 2020 memo was contrary to Wis. Stat. § 6.87 (4) (b) 1., similar to the situation
5with absentee ballot applications. Wis. Stat. § 6.86 (1) (a) 2. required a
6person-to-person exchange between the elector submitting an absentee ballot
7application and the clerk or the clerk's authorized representative. The court
8reaffirmed that absentee ballots could only be returned through two authorized
9methods: mailing by the voter to the municipal clerk or personal delivery by the voter
10to the municipal clerk. Therefore, Administrator Wolfe's memos advising otherwise
11conflicted with the law and were rightly void.
AR18,13,13 12Article 9. Administrator Wolfe's Inadequate Absentee Ballot Request
13Web Page and Violation of Wisconsin Election Law
AR18,13,1514 Administrator Wolfe's absentee ballot request web page potentially facilitated
15ballot maladministration and contradicts Wisconsin election law requirements.