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The OCE previously found, as noted in the report findings, in 2021 that Jackson’s committee was paying the Amarillo Club monthly dues for membership, which the OCE said counted as costs toward personal use instead of “bona fide campaign or political purposes.” However, after the OCE’s findings on the 2021 investigation were released in May 2022, the OCE report said that Jackson’s committee “continued to make consistent payments to the Amarillo Club.”

Instead of halting the payments, according to the OCE report, Jackson’s committee shifted from describing the Amarillo Club payments in its Federal Election Commission reports as “registration fees” in its reports to other descriptors including “membership fees,” “food/beverage,” “membership dues,” and “membership for exclusive campaign purposes.”

The OCE report noted that Jackson “referred to the not-yet-resolved [previous 2021 review] as a reason not to cooperate with the OCE.” Further, the OCE said that Jackson’s counsel “communicated to the OCE that a response would not be provided because – in their view – the present inquiry was merely an extension of the previous investigation and that Rep. Jackson intended to reassert all of the arguments made in his official response to the prior OCE matter.”

“In summary, between October 2020 and January 2024, Rep. Jackson’s campaign committee spent $11,928.27 at the Amarillo Club for dues, fees, meals, and other services,” said the OCE findings, “Since Rep. Jackson and employees of the Amarillo Club refused to cooperate with this review, the OCE could not determine to what extent his use of the club and the campaign committee’s food and beverage spending at the club was campaign related. Regardless, the campaign committee’s payment of monthly dues implicates the prohibition against personal use of campaign funds.”