Elections

Mr. Wood said he would appear before the special grand jury in Atlanta.ATLANTA — L. Lin Wood, a trial lawyer and an ardent supporter of Donald J. Trump who pushed a number of falsehoods about election fraud after the 2020 presidential contest, has been asked to give testimony in the criminal investigation into efforts to overturn the Georgia election, he confirmed on Tuesday.In a phone call, Mr. Wood said that his lawyer had been informed that Mr. Wood’s testimony was being sought by the Fulton County District Attorney’s Office. Mr. Wood said he would comply and go before the special grand jury that has been looking into efforts by Mr. Trump and his allies to reverse Mr. Trump’s election loss.“I didn’t do anything wrong,” Mr. Wood said. “I’ve got nothing to hide, so I’ll go down and talk to them.”Prosecutors’ efforts to secure Mr. Wood’s testimony in the closed-door grand jury sessions were first reported by The Atlanta Journal-Constitution.Mr. Wood, a trial lawyer, earned national fame for taking on high-profile clients, most notably Richard A. Jewell, who was wrongly suspected of setting off a bomb at the Atlanta Olympics in 1996.Last week, prosecutors in the election-meddling case noted — in court documents seeking the testimony of another pro-Trump lawyer, Sidney Powell — that Mr. Wood had given a December 2021 interview to CNBC in which he spoke of hosting meetings “at a plantation in South Carolina for the purpose of exploring options to influence the results of the November 2020 elections in Georgia and elsewhere.”The court filing noted that the meetings had been attended by Ms. Powell; Michael Flynn, a former national security adviser to Mr. Trump; “and other individuals known to be associated with the Trump campaign.”Mr. Wood said that he had been informed that he was a material witness but that he had not been informed that he was a target of the investigation.Prosecutors in Fulton County, which includes much of Atlanta, have brought more than 30 witnesses before the special grand jury, which was impaneled with the sole purpose of looking into election interference. Once it has completed the work of hearing from witnesses and considering evidence, it will issue an advisory report that could be taken to a regular grand jury with the power to issue indictments.Prosecutors have already brought Rudolph W. Giuliani, a former lawyer for Mr. Trump, before the special grand jury and have told him he is a target, meaning he could eventually face an indictment. In recent days they have also signaled that they hope to compel the testimony of other well-known Trump associates, including Ms. Powell and Mark Meadows, the former White House chief of staff. More

AMERICAN

BRIDGE

21ST CENTURY

Once he made the private decision to become a candidate, Mr. Trump was obligated to file a Statement of Candidacy with the Commission within 15 days of receiving contributions or making expenditures of more than $5,000 to influence his election, either directly or through third parties. 26 This Statement of Candidacy has not yet been filed. Yet, subsequent to several of his public remarks about a 2024 candidacy, Mr. Trump’s leadership committee, Save America, has spent more than $100,000 per week on Facebook ads and has consistently raised more than $1 million per week.27 Save America’s ads are clearly an attempt to influence Mr. Trump’s election to federal office in 2024.28 Commission regulations specify that an individual becomes a federal candidate when he has 1) consented to expenditures beyond $5,000 on his behalf, and 2) those expenditures have been made.29 Because he sponsors Save America, Donald Trump has consented to Save America’s expenditures on his behalf, which greatly exceed $5,000, and thus he has become a federal candidate. ³

30

Google Transparency Report, Save America Joint Fundraising Committee (Feb. 9, 2022, 3:30 P.M.), https://transparencyreport.google.com/political

ads/advertiser/AR386358112438714368/creative/CR536153033986277376 (“Biden has turned his back on America, and completely failed the American people. Biden is Weak. We all know it.”). 26 52 U.S.C. § 30101(2)(B); 11 C.F.R. § 100.3(a).

27 Michael Scherer & Josh Dawsey, Trump Looks To 2024, Commanding a Fundraising Juggernaut, as He Skirts Social Media Bans, WASH. POST (Oct. 30, 2021, 6:00 AM),

07223c50280a_story.html.

28 Kayla Gogarty, Facebook Is Letting Trump’s PAC Run Ads Implying He Is The “True President”, MEDIA MATTERS (Oct. 4, 2021, 3:10 PM), https://www.mediamatters.org/facebook/facebook-letting-trumps-pac-runads-implying-he-true-president (“Our latest study has found that Trump’s PAC has created over 1,600 ads since we last reported in August. Among these new ads, 186 pushed election misinformation, 322 were about Trump’s September rally in Georgia, and 139 were about Trump’s October rally in Iowa.”).

11 C.F.R. § 100.3(a)(2).

30 See, e.g., Jason Lange & Alexandra Ulmer, Trump Fundraising Slows but Still Yields Over $100 Million in Cash, REUTERS (Feb. 1, 2022, 1:55 AM), https://www.reuters.com/world/us/trumps-fundraising-groups-haveover-122-mln-cash-2022-01-31/ (“Trump is spending large sums to hold political rallies that ostensibly support Republican candidates but which feature his own speeches as the main event.”).

800 Maine Ave SW, suite 400 Washington DC 20024 | 202.747.2060

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A conservative group has filed a complaint against President Biden accusing him of violating federal election law by not officially informing the Federal Election Commission that he plans to run again in 2024.The complaint is unlikely to succeed or be resolved quickly — not only because the commission has been hobbled for years by partisan infighting, but also because of the high burden of proof required to show that Mr. Biden has in fact decided to pursue re-election.It nonetheless highlights the political bind the White House has found itself in while facing grumbling about the president from his fellow Democrats, as well as the gridlock that has crippled the nation’s top election agency and has led it to be mocked on late-night talk shows.The complaint was filed more than five months after a Democratic super PAC filed a similar complaint against former President Donald J. Trump, who has openly flirted with another White House bid.Complaint About Biden From Americans for Public Trust to the Federal Election CommissionA conservative group filed a complaint against President Biden that accuses him of violating federal election law by not officially informing the F.E.C. that he plans to run again in 2024.Read Document 6 pagesAmericans for Public Trust filed the complaint against Mr. Biden on Tuesday. The group is led by Caitlin Sutherland, a former research director for the National Republican Congressional Committee, the campaign arm of House Republicans.“It is very clear that President Biden meets the requirements of a candidate who needs to file with the F.E.C.,” Ms. Sutherland said in an interview.Her group is asking the commission to investigate whether Mr. Biden is running what she described as a “shadow campaign,” using taxpayer money to conduct what in essence are political activities under the guise of official travel to swing states like Pennsylvania and Wisconsin. A potential punishment could include a hefty fine, as the F.E.C. has levied in the past.The complaint claims that Mr. Biden’s official campaign committee, Biden for President, has spent more than $5 million since Jan. 20, 2021. Most of that money has gone toward expenses related to the 2020 presidential election, but the complaint notes that Biden for President has reported spending $1 million on outreach to voters over email and text messages.Those messages, which are reviewed by Mr. Biden’s campaign lawyers for compliance with the law, promote his policy accomplishments, such as the signing of the Inflation Reduction Act, and direct recipients to donate money to the Democratic National Committee.The Biden PresidencyWith midterm elections looming, here’s where President Biden stands.On the Campaign Trail: Fresh off a series of legislative victories, President Biden is back campaigning. But his low approval ratings could complicate his efforts to help Democrats in the midterm elections.‘Dark Brandon’ Rises: White House officials recently began to embrace this repackaged internet meme. Here is the story behind it and what it tells us about the administration.Questions About 2024: Mr. Biden has said he plans to run for a second term, but at 79, his age has become an uncomfortable issue.A Familiar Foreign Policy: So far, Mr. Biden’s approach to foreign policy is surprisingly consistent with the Trump administration, analysts say.But they also serve a tried-and-true function in political campaigns: keeping a valuable contact list warm in case Mr. Biden needs it for a future run.The complaint also details a litany of public statements made by White House officials, including Vice President Kamala Harris, indicating that Mr. Biden plans to seek re-election.In late June, for instance, Ms. Harris told Dana Bash of CNN, “Joe Biden is running for re-election and I will be his ticketmate. Full stop.”She quickly walked back those comments, however, as aides apparently realized the legal implications of prematurely declaring Mr. Biden’s candidacy before he has officially decided to run again.Similarly, Karine Jean-Pierre, the White House press secretary, said on June 13 that Mr. Biden was “running for re-election.” She later tweeted that the president “intends to run in 2024,” only to clarify later that Mr. Biden had not yet decided.Those comments came in response to public reports, including in The New York Times, suggesting that many Democrats were not eager to see Mr. Biden become their party’s nominee again in 2024 given his advanced age and his relative unpopularity.White House officials and other surrogates for Mr. Biden leaned in hard against the emerging narrative, and, according to some accounts noted in the complaint, told reporters anonymously that they recognized that those comments had risked running afoul of legal restrictions on fund-raising.“Biden cannot hide behind the word ‘intend’, and it’s not the shield he thinks it is,” Ms. Sutherland said.The White House declined to comment, as did the Democratic National Committee. Mr. Biden himself has been coy about whether he has indeed decided to seek the Oval Office again, often couching his answers with a caveat: that he intends to do so if he remains in good health, but will not make that determination until sometime after the November midterms.In February, when a reporter asked if he was satisfied with Ms. Harris’s working on voting rights and whether she would be his running mate in 2024 “provided that you run again,” Mr. Biden replied, “yes and yes.”The complaint omits the reporter’s conditional phrase.Some campaign lawyers affiliated with the Democratic Party, who asked for anonymity to speak candidly, argued that the White House press secretary and even the vice president could not speak for Biden for President, the campaign committee — and therefore the commission was likely to dismiss the complaint quickly.That would be unusual: The F.E.C. is notoriously lax about meeting its own statutory deadline of 120 days. A different election-law-related complaint filed by the same group, Americans for Public Trust, about the pre-candidacy activities of Jeb Bush, who ran for the Republican presidential nomination in 2016, has been languishing for years.Complaint About Trump From American Bridge to the Federal Election CommissionA Democratic super PAC filed a complaint in March against former President Donald J. Trump that accused him of violating federal election law by not officially informing the F.E.C. that he planned to run again in 2024.Read Document 10 pagesAnn Ravel, a Democratic former commissioner at the F.E.C., said she found the complaint about Mr. Biden’s putative candidacy “persuasive.”Ms. Ravel, who has long been an outspoken critic of the commission, which consists of three members appointed by each of the two major political parties, added that “of all the government agencies, the F.E.C. is probably the most dysfunctional of all.”By law, a candidate is required to notify the commission within 15 days of deciding to run for federal office.Despite the F.E.C.’s dysfunction, the convention among presidents has been to obey the letter of the law while countermanding its spirit.Mr. Trump, Mr. Biden’s predecessor, exploded that convention through moves like holding his nominating convention on the White House grounds and failing to police violations of the Hatch Act, a law that governs political activities by presidential aides.In March, American Bridge, a group aligned with Democrats, lodged an F.E.C. complaint against Mr. Trump, accusing him of violating campaign finance law by spending political funds on a 2024 presidential bid without formally declaring himself a candidate. The group later sued the F.E.C. over the matter, claiming that the agency’s inaction gave Mr. Trump a competitive advantage.In a July interview with New York magazine, Mr. Trump said that “in my own mind, I’ve already made that decision, so nothing factors in anymore.” More

STATEMENT OF FACTS

9. President Joseph R. Biden, Jr. was elected as President of the United States in 2020 and was sworn in on January 20, 2021.²

10. Since January 20, 2021, President Biden’s principal campaign committee, Biden for President, has spent more than $5 million dollars, including $1 million on “text message/email

outreach” and almost $250,000 on a “database subscription” – thereby exceeding the $5,000 threshold to be declared a candidate.³

11. In addition to significant campaign expenditures, President Biden’s White House staff, spokespersons, Vice President, and surrogates have made numerous on-the-record statements indicating that he has commenced his candidacy for the 2024 presidential election.

12. Beginning in November of 2021, in response to a reporter’s question, “[t]here were reports that President Biden was telling allies that he is going to run for re-election in 2024. Can you confirm, is he going to run in 2024? Is he telling staff that?,” then-White House Press Secretary Jen Psaki stated, “[h]e is, that’s his intention.”4

13. President Biden’s current Press Secretary – Karine Jean-Pierre – conclusively stated on June 13, 2022, “[y]es, he’s running for reelection. I’m I can’t say more than that.” Later that day, she doubled down and tweeted that, “[t]o be clear, as the President has said repeatedly, he plans to run in 2024,” and a month later again tweeted that, “[t]he president has been very clear about this. He intends to run in 2024.”5

–

14. U.S. Transportation Secretary Pete Buttigieg has also gone on-the-record to discuss President Biden’s campaign for reelection, stating, “I’m looking forward to supporting the president’s reelection. Ah, that is as much as I can say about these things while I’m here on an official…capacity”

15. President Biden himself has gone so far as to confirm that Vice President Kamala Harris will be his running mate in 2024: “Yes’ and ‘yes,’ Biden responded during his first news conference of the year [2022] when a reporter asked whether Harris would be on his ticket and whether he thought she was doing a good job on voting rights policies.”

16. Vice President Kamala Harris emphatically told CNN’s Dana Bash – when asked about the president’s campaign for reelection in 2024 – that, “Joe Biden is running for reelection and I will be his ticket mate…Full stop. That’s it.”

998

17. Public reporting has stated that, “[i]n public and private, Biden himself has emphasized that he is running, effectively shutting down any discussion of the topic between the president and

2 Toluse Olorunnipa and Annie Linskey, Joe Biden is Sworn In as the 46th President, Pleads for Unity in Inaugural Address to a Divided Nation, The Washington Post (Jan. 20, 2021).

3 Federal Election Commission, Statement of Organization, Biden for President (Apr. 25, 2019). Federal Election Commission, Disbursements (search for spender “Biden for President” and Disbursement Type “Made By Presidential Committees: Operating Expenditures,” time period “1/20/21 to date”); Federal Election Commission, Disbursements (search for spender “Biden for President” and Disbursement Detail “text message/email outreach,” reporting time period “2021-2022”); Federal Election Commission, Disbursements (search for spender “Biden for President” and Disbursement Detail “database subscription,” reporting time period “2021-2022”); 11 C.F.R. § 100.3.

4 Steve Nelson, Psaki Says Biden Still Intends to Run in 2024 Despite Poor Polls, Old Age, New York Post (Nov. 22, 2021).

5 The White House, Press Briefing by Press Secretary Karine Jean-Pierre (June 13, 2022); Karine Jean-Pierre (@PressSec), Twitter (June 13, 2022); CBS News (@CBSNews), Twitter (July 28, 2022).

6 CNBC, Squawk Box, Squawk Newsmaker: Prices at the Pump: Transportation Secretary Weighs In, Clip begins at 0:54 (Aug. 4, 2022).

7 Claire Rafford, Biden Commits to Harris as His Running Mate for 2024, Politico (Jan. 19, 2022).

8 Dana Bash (@DanaBashCNN), Twitter (June 27, 2022).

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Attorney General Merrick B. Garland on Tuesday imposed new restrictions on partisan activity by political appointees at the Justice Department, a policy change that comes ahead of the midterm elections.The new rules prohibit employees who are appointed to serve for the duration of a presidential administration from attending rallies for candidates or fund-raising events, even as passive observers.Under the Hatch Act, which bars federal employees from engaging in political activities while on the job, the department had previously allowed appointees to attend such events as passive participants provided they had permission from a supervisor.That is now banned. Under the new policy, the department also prohibits appointees from appearing at events on election night or to support relatives who are running for office. Both had been allowed in the past with prior approval.“We have been entrusted with the authority and responsibility to enforce the laws of the United States in a neutral and impartial manner,” Mr. Garland wrote in a memo sent to department employees.“In fulfilling this responsibility, we must do all we can to maintain public trust and ensure that politics — both in fact and appearance — does not compromise or affect the integrity of our work,” he added.Mr. Garland’s memo was accompanied by a pair of notices from Jolene Ann Lauria, acting assistant attorney general for administration, reminding employees of the department’s existing regulations under the Hatch Act.All department employees are prohibited from engaging in political activity at work, and when using a government-issued phone, email account or vehicle. They are not allowed to seek partisan elective office, enlist subordinates in campaigns or ask co-workers for political donations.Other career employees, including F.B.I. employees and administrative law judges, are banned from a much broader array of partisan activity; they are prohibited, for example, from addressing a political rally or helping a political group with driving voters to the polls on Election Day.The policy change coincides with intensifying government investigations into former President Donald J. Trump.Mr. Trump has lashed out at the attorney general and President Biden, baselessly claiming that they conducted a partisan witch hunt in the search of his Mar-a-Lago residence in Florida on Aug. 8.After the search, the F.B.I. reported a surge in threats against its agents; an armed man tried to breach the bureau’s Cincinnati field office, before being killed in a shootout with the local police.Mr. Garland is also overseeing the sprawling investigation into the attack on the Capitol on Jan. 6, 2021, which has increasingly focused on the actions of Mr. Trump and his supporters.The attorney general has repeatedly said he will go where the evidence leads him, unmoved by political considerations or concerns about a backlash, without “fear or favor.” More

Listen and follow ‘The Run-Up’Apple Podcasts | Spotify | Stitcher | Amazon MusicStarting Sept. 6, 2022First launched in August 2016, three months before the election of Donald Trump, “The Run-Up” is back.Through conversations with colleagues, newsmakers and voters across the country, Astead Herndon will grapple with the big ideas animating the 2022 midterm election cycle — and explore how we got to this fraught moment in American politics.Elections are about more than who wins and who loses. “The Run-Up” starts Sept. 6. See you there.Meet Your HostASTEAD HERNDON is a national politics reporter for The New York Times. Previously, Astead was an integral part of The Times’s reporting on the 2018 midterm elections and the 2020 presidential elections, anchoring the coverage on Senators Elizabeth Warren and Kamala Harris. Before joining The Times, Astead held several positions as a reporter at The Boston Globe, including one as a national politics reporter in the Washington office, where he covered the Trump White House.In 2020, Astead was included on Forbes magazine’s 30 Under 30 media list. His reporting on grass-roots voters and the politics of white grievance was included in a New York Times submission that was named a finalist for a 2021 Pulitzer Prize. Astead is also a political analyst for CNN. More

GRANBY, Colo. — It was a bit tense for a groundbreaking ceremony.Against the striking backdrop of the enveloping Rocky Mountains, Senator Michael Bennet, a Colorado Democrat seeking a third full term, symbolically shoveled dirt to start a $30 million Colorado River restoration project for which he had helped secure nearly half the funding.Watching from a respectable distance was Joe O’Dea, a Republican political novice who is trying to come out of nowhere to upset Mr. Bennet — and whose Denver construction company is coincidentally the lead contractor on the job. Their confluence on a recent Tuesday at the Windy Gap Reservoir in the heart of rugged Grand County had the crowd of environmentalists, government officials, ranchers and outdoor enthusiasts buzzing.Mr. Bennet eschewed a hard hat, aware of the risk of being photographed in ill-fitting headwear during a political campaign, à la Michael Dukakis. Mr. O’Dea donned a well-worn round-brimmed version and an orange construction vest. The two did not interact, but each had something to say about the other.Mr. Bennet noted his rival’s usual distaste for government spending, which the Republican has blamed for inflation.“I hear he hates federal spending, except for the $14 million that built this thing,” said the incumbent, who was a surprise appointee to a Senate vacancy in 2009 before winning election for the first time in a difficult environment the next year.Mr. O’Dea, standing near the heavy equipment his workers will employ to return a stretch of the imperiled river to its natural flow, was not impressed by the praise heaped upon Mr. Bennet by the assembled backers of the project.“That’s what politicians do,” Mr. O’Dea said, making clear that he did not consider himself part of that cohort. “I’m into building things, and we will do our job here.”Joe O’Dea, the Republican candidate, owns a construction company and is running as a political outsider.Rachel Woolf for The New York TimesColorado was not expected to be part of the Senate battleground landscape this year. While not yet in the solid blue column, the state has been trending Democratic, and Mr. Bennet seemed a good bet for another term as Republicans invested their resources in what they saw as riper opportunities elsewhere.Democrats sought to bolster Mr. Bennet’s chances through backdoor advertising on behalf of hard-right, MAGA-embracing candidates in the Republican primary who would most likely have been weaker adversaries with little chance of being embraced by the state’s unaffiliated voters, now the largest voting bloc in Colorado.More Coverage of the 2022 Midterm ElectionsEvidence Against a Red Wave: Since the fall of Roe v. Wade, it’s hard to see the once-clear signs of a Republican advantage. A strong Democratic showing in a New York special election is the latest example.Sensing a Shift: Democrats, once beaten down by the prospect of a brutal midterm election, are daring to dream that they can maintain control of Congress, but a daunting map may still cost them the House.G.O.P.’s Dimming Hopes: Republicans are signaling concern that the midterm sweep they anticipated is complicated by attention on former President Donald J. Trump’s legal exposure.Campaign Ads: In what critics say is a dangerous gamble, Democrats are elevating far-right candidates in G.O.P. primaries, believing they’ll be easier to defeat in November. We analyzed the ads they’re using to do it.But Mr. O’Dea won the primary anyway, and while Mr. Bennet remains the favorite, the Cook Political Report recently shifted the contest from “Likely Democrat” to “Lean Democrat.” The Republican is threatening to make a race of it if he can increase his fund-raising and land his message that he is not a typical partisan politician.“As far as I’m concerned, any politician who votes for the party line is part of the problem, not part of the solution,” Mr. O’Dea said after exchanging the orange vest for a sport coat for a speech before the Colorado Water Congress in Steamboat Springs. “The national parties have become vehicles to perpetuate power and promote discord. And I’m tired of it.”Mr. O’Dea has been a welcome relief for Senate Republicans who have seen their once-strong chances of retaking the Senate shrink with a field of problematic arch-conservatives struggling in what should a favorable midterm year. Mr. O’Dea has been willing to say that Joseph R. Biden Jr. won the 2020 election and that President Donald J. Trump did not and should not run again. In this cycle, that is enough to qualify a Republican as moderate.Senator Mitch McConnell, the Kentucky Republican who hopes to become the majority leader next year, has said he is “all in” on Mr. O’Dea. To Democrats, that is a big liability. They frame Mr. O’Dea as another potential foot soldier for Mr. McConnell and a conservative agenda, particularly on abortion rights, which have become a major issue in this race as well as other Senate contests across the country after the Supreme Court overturned Roe v. Wade in June. More

Gov. Kathy Hochul’s campaign says contributions from board and commission members and their families are fair game because she did not appoint them.ALBANY, N.Y. — On the road to building one of the largest campaign war chests the state of New York has ever seen, Gov. Kathy Hochul has been taking money from appointees of the governor — despite an executive order designed to prevent it.In her first year in office, Ms. Hochul has accepted more than $400,000 from appointees on boards from Buffalo to Battery Park City as well as the appointees’ spouses, a New York Times analysis of campaign finance data has found.The fund-raising has occurred despite the longstanding executive order — reissued by Ms. Hochul on her first day in office — that prohibits such transactions in order to avoid even the appearance of rewarding donors with jobs in exchange for contributions.Ms. Hochul’s campaign said it was appropriate to accept the contributions because they came from people appointed by her predecessor, Andrew M. Cuomo. The argument underscored a loophole in the ethics order that would seem to allow one governor to accept money from another governor’s board and commission appointees. In some cases, Ms. Hochul received donations from people Mr. Cuomo had appointed and then gave them new appointments.A spokesman for Ms. Hochul’s campaign, Jerrel Harvey, said that Ms. Hochul had not accepted money from people she appointed and emphasized that all of her fund-raising had been aboveboard.“We’ve been clear from the beginning of Governor Hochul’s term that people who are appointed by her are prevented from donating once they are appointed,” Mr. Harvey said. “We have followed that straightforward standard consistently and strictly.”But legal experts and good government advocates have called Ms. Hochul’s reasoning into question.“It’s a silly argument to say if I appointed you then you can’t contribute to me, but if my predecessor appointed you, then I can hit you up for donations,” said Bruce Green, a professor at Fordham University Law School and a former member of the New York City Conflicts of Interest Board. “Going forward, presumably, they’re both going to want to be reappointed.”Ms. Hochul has already raised some $35 million and set a goal of raising as much as twice that amount ahead of the general election in November. Cindy Schultz for The New York TimesThe donations that Ms. Hochul accepted from appointees represent just a small portion of her campaign’s huge haul ahead of the election in November. She has already raised some $35 million and set a goal of raising as much as twice that amount, people familiar with her plans said. Doing so would put the 2022 governor’s race at or near the most expensive in state history.Ms. Hochul, a Democrat who was sworn in as governor after Mr. Cuomo resigned amid a scandal last year, easily defeated two primary rivals this summer and is heavily favored to win against Representative Lee Zeldin, a Republican, in the fall.Although she has promised a clean break from the ways of her predecessor, Ms. Hochul’s willingness to raise money from appointees runs counter to that pledge. Mr. Cuomo was known for taking a hawkish approach to soliciting donations from the people he appointed, raising ethics concerns.Ms. Hochul’s campaign has not shrunk from accepting donations from Mr. Cuomo’s appointees, receiving more than $250,000 from them, records show.She got more than $56,000 from the real estate developer Don Capoccia, whom Mr. Cuomo appointed to the Battery Park City Authority in 2011 and who did not respond to requests for comment.She accepted more than $90,000 between October and May from a trial lawyer, Joe Belluck, who was chosen by Mr. Cuomo for two statewide panels, and his wife. Ms. Hochul appointed Mr. Belluck to the state’s new Cannabis Advisory Board in June.Mr. Belluck scoffed at the notion of any impropriety in his donation.“I receive no remuneration and do no business with the state, period,” he said. “I have no private interests related to these positions. I donate to Governor Hochul because I support her policies and admire her leadership, and I am honored to serve.”Ms. Hochul also received $45,200 from John Ernst, an heir to the Bloomingdale’s fortune, whom Mr. Cuomo appointed to the Adirondack Park Agency board in 2016, and Mr. Ernst’s wife. Less than three weeks after receiving those donations, she reappointed Mr. Ernst to the park agency’s board and made him chairman.Mr. Ernst said he initially turned down Ms. Hochul’s offer of the chairmanship, which comes with a $30,000 annual salary, and emphatically denied any connection between his donating and being appointed to the position.“If I had thought it was a conflict, I wouldn’t have done it — wouldn’t have made a contribution,” he said. “I did it independently as a citizen because I believed in Kathy Hochul.”A spokeswoman for the governor’s office, Julie Wood, said Ms. Hochul has applied the ethics order far more “broadly and strictly” than Mr. Cuomo did, saying his administration “violated their own rules.”“Governor Hochul holds herself to a higher ethical standard,” Ms. Wood said.Ms. Hochul has also accepted contributions and then appointed the donors to state boards and commissions. She received $3,000 from Robert Simpson, the chief executive of a Syracuse nonprofit that promotes economic development, in two donations and named him to the board of Empire State Development, New York’s economic development agency, less than a month after the second one.A spokeswoman for Mr. Simpson said that after he assumed the post he adopted policies to limit conflicts of interest and pledged to no longer contribute to or raise money for Ms. Hochul.Ms. Hochul accepted more than $7,800 from Janice Shorenstein, the mother of Ms. Hochul’s former transition director, Marissa Shorenstein, and Janice Shorenstein threw a fund-raiser for the governor in May. Marissa Shorenstein, who attended the event, was confirmed to the New York State Gaming Commission about two weeks later. Ms. Shorenstein and her mother did not respond to requests for comment left at their offices.And Ms. Hochul accepted another $5,000 in April from Sammy Chu, a Long Island businessman whose company also paid more than $2,100 for a Hochul fund-raiser in Plainview two days later. In late May, she tapped him for a spot on the Metropolitan Transportation Authority.Mr. Chu said he learned of the rules against governors’ accepting money from appointees only when The Times informed him of them in August.“There was certainly no quid pro quo,” Mr. Chu said. “Now that I’m appointed to the board, you know, I’ll be hypervigilant about it. But at that time, I was not a nominee or a board member.”Taken together, records show, Ms. Hochul accepted at least 40 donations totaling more than $475,000 from her nominees or Mr. Cuomo’s appointees and their family members. Those appointees are sitting on more than 20 boards, commissions and public authorities across New York, including the State University of New York board, the Port Authority of New York and New Jersey, the New York Power Authority and the United Nations Development Corporation.Ms. Hochul’s campaign stressed that she had been careful not to take contributions from any person she appointed to a state position. In at least one case, The Times found, Ms. Hochul accepted contributions from a person appointed by Mr. Cuomo, appointed that person to a different commission and then declined to accept further contributions from him.While none of the donations accepted by Ms. Hochul’s campaign from her own appointees appeared to violate any rules, they nevertheless might create the appearance of impropriety, legal experts said.Some might feel pressure to give to an elected official with power over their appointed positions. Others who wish to be appointed might donate in hopes of getting the job, said Kathleen Clark, a Washington University law professor.“It may appear that the way to get appointed is to give money or to hold fund-raisers,” Professor Clark said, adding: “The scandal is what we allow rather than what we prohibit.”For her part, Ms. Hochul has dismissed any suggestion that her fund-raising practices might raise ethical concerns. When a reporter asked at a recent news conference if she worried about the optics of taking campaign money from people who are doing business with the state, she bristled.“I will say one sentence on this,” she said. “I follow all the rules, always have, always will.”Nicholas Fandos More