Kristi Noem's Complicity in the Assault on American Democracy

                                               

Kristi Noem has repeatedly abused the power of her office. She is also a vocal advocate for an authoritarian political movement that has openly embraced criminal conduct in the highest echelons of our society. She has demonstrated a profound hypocrisy rooted in blind partisanship.

These accusations are not made lightly. They are sound inferences based on thoroughly researched facts. An endnote, citing source material, follows each factual assertion in this informational, and readers are encouraged to evaluate those sources on their own time.  

  •  According to official findings of the South Dakota Government Audit and Operations Committee (GAOC), controlled by Republicans, Kristi Noem abused the power of her office to give her daughter, Kassidy Peters, preferential treatment in a state certified real estate appraiser program.[1] After Kassidy Peter’s failed to obtain her appraiser certification under the normal rules, Kristi Noem had a member of her cabinet change the rules.[2] Kassidy Peters still failed.[3] Noem then ordered the director of the appraiser program, Sherry Bren, to come to the Governor’s Mansion with examples of specific errors found in her daughter’s test results and a plan outlining the next steps so that Kassidy “is able to pass.”[4] At the meeting, Kassidy Peters was present.[5] Bren later testified that she felt “intimidated.”[6] Two weeks later, Kassidy became a certified real estate appraiser.[7] Noem’s actions provided Kassidy three chances to get her certification, whereas everyone else, who is not the Governor’s daughter, gets only one chance and must then wait the required 6-months before reapplying.[8]       
  • Under long established law, members of the House Ways and Means Committee can review a president's tax returns.[9] This allows them to fulfill their constitutional duty to act as a check on executive abuses of power.[10] In 2017, Kristi Noem, who was then in the House of Representatives and on the Committee, voted to not even review Trump’s tax returns.[11] This was especially troubling given Trump’s refusal to divest his businesses or share his returns with the American public.[12] Every day of his presidency, Trump did business with the Federal Government and with foreign allies and foes in direct violation of our nation’s oldest and simplest anti-corruption provisions, the Emoluments Clauses of the U.S. Constitution.[13] It is estimated the Trump Organization made $8 million off the American taxpayer during his administration by using his properties for official government functions.[14] He also took in $10s of millions in gross profits from foreign government backed businesses while simultaneously acting as Commander in Chief.[15] During the Trump presidency, the swamp grew deeper and muddier than ever before. Kristi Noem’s blatant partisanship helped make that possible.
  • South Dakota law stipulates that state owned airplanes can only be used for official state business.[16] Records reveal that Kristi Noem used a state-owned airplane at taxpayer’s expense to attend events for the National Rifle Association, Turning Point USA, and other out of state right-wing political gatherings.[17] Though Noem claims she made the trips as South Dakota’s “ambassador,” her national ambitions beyond the governorship of South Dakota and the fact that these events did not bare directly on South Dakota policy make her excuses highly questionable.[18]
  • Perhaps more so than any politician, Kristi Noem has branded herself a Trump Republican.  On the 4th of July, she gave Trump a model of Mt. Rushmore with his head carved on it.[19] She engaged with, disengaged with, and then reengaged with former Trump campaign manager Corey Lewandowski as her close, trusted political advisor.[20] Even after the January 6th Insurrection at the United States Capitol, even after the shocking revelations from the January 6th Committee, she has committed herself to backing Trump in 2024.[21] She has even been mentioned as Trump’s potential running mate.[22]
  • Immediately after Trump lost the presidential election, Kristi Noem was at the forefront of those Republican Politicians who lied about the election results to the American people.[23] Without providing a shred of evidence, she claimed the 2020 Presidential Election was “rigged.”[24] She even repeated the lie that dead people voted in Pennsylvania on national TV.[25] Never in modern history has a presidential candidate and his political cronies, like Kristi, refused to concede an election they lost in accordance with the laws of our nation.[26]
  • The U.S. has an established system whereby elections are decided based on individual state law.[27] That system clearly determined Joe Biden won the election.[28] Furthermore, almost every election expert across the country – including all of those who officially worked for the Republican White House – said there was no fraud that would change the election outcome.[29] Republican attorneys filed 62 lawsuits across the country designed to overturn the election.[30] They lost these cases resoundingly.[31] Some of the lawyers who filed them have lost their law licenses or were sanctioned by the courts for making frivolous claims.[32] Dominion and Smartmatic, companies that make voting machines, sued Republican lawyers and sycophants who expounded and repeated Trump’s lies for billions in damages.[33] They are also suing Right-Wing Media outlets Fox News, OANN, Newsmax, and many of their on-air personalities for lying to the American public.[34] Judges across the U.S. have refused to dismiss the cases.[35] Kristi Noem simply ignored all of this and continued to spread lies anyway.
  • On January 6th, 2021, a mob of Americans stormed the United States Capitol. The Vice-President and all members of Congress fled for their lives, interrupting the certification of a duly elected president.[36] The only cause of this insurrection was the election lies of Kristi Noem, other Republican Politicians, and the Right-Wing Media. The American public, stunned, watched as the attack on our government unfolded on live TV and rippled across social media. Protestors erected a noose and gallows for hanging the Vice President.[37] There were American’s brandishing the confederate flag and symbols of the American Revolution.[38] Some protestors wore costumes and outfits reminiscent of Hitler’s brown shirts.[39] Rioters utilized chemical irritants.[40] They bludgeoned Capitol Police with flagpoles, baseball bats, and lead pipes.[41] One officer lost a finger, pinched off between a door and the weight of a crowd.[42] Officers suffered rib fractures, concussions, and burns.[43] An enraged, propagandized protestor, Ashli Babbit, was fatally shot while attempting to break into a room filled with members of Congress protected by armed guard.[44] D.C. police officer Michael Fanone was dragged down the Capitol steps, tasered, and beaten while suffering a mild heart attack.[45] 140 Capitol Police were injured.[46] Since the violent insurrection, 4 officers have committed suicide.[47]
  • Despite the senseless, lawless violence at the heart of our nation on January 6th, Kristi Noem continued to create doubt about the 2020 Election outcome.[48] When asked whether she would retract her statement that the election was “rigged,” she refused.[49] Instead, she used the false impression she helped create in voters as a justification for her errors.[50]
  • Upon becoming the Governor of South Dakota, Kristi Noem hired her other daughter, Kennedy Noem, to act as a “policy analyst.”[51] At the time of the announcement, Kennedy was still attending college and did not have a degree.[52] It was Kennedy’s first professional job outside of being hired by the Noem Campaign.[53] While technically legal in South Dakota, the Federal Government and many state governments recognize that nepotism is unethical and illegal.[54] Nepotism has been proven to lead to the misappropriation of public funds, loss of public trust in government, and the hiring of incompetent government employees.[55]  
  • During Trump’s first impeachment, Kristi Noem refused to acknowledge the voluminous evidence against Trump. Instead, she claimed, without providing anything resembling evidence, that Democrats were trying to “destroy our democracy.”[56] On the charge of abuse of power in Trump’s first impeachment trial, the evidence consisted of a reconstructed transcript of a phone conversation in which Trump clearly tried to leverage Ukrainian President Zelensky with taxpayer paid U.S. military aid to investigate the Bidens.[57] There were also videos of both Trump and White House Chief of Staff Mick Mulvaney admitting Trump was attempting to extort Ukraine.[58] The entire diplomatic core to Ukraine – including life-long civil servants, decorated war heroes, and even Trump appointees and campaign donors – unequivocally testified as to Trump’s abuse of power while under oath.[59] Other key points of their testimony were that Trump’s intent was political, not a valid expression of U.S. Foreign Policy; Rudy Giuliani was running shadow diplomacy intended to benefit Trump, not America; and the overall effect of the Republican White House’s illegal foreign policy was to strengthen Russia, undermine democracy internationally, and make a mockery of U.S. foreign policy.[60]
  • On the charge of obstruction of Congress in Trump’s first impeachment, the evidence clearly showed Trump issued a blanket order for White House employees, as well as those in other federal agencies, to completely ignore congressional subpoenas.[61] Subpoenas are legally enforceable under the law and essential to Congress’s function as a check on executive power.[62] Several executive agencies, under White House direction, simply refused to produce a single witness or turn over a single document throughout the investigation, placing a Republican President above the Rule of Law.[63] 
  • In May of 2021, Kristi Noem hitched a ride to the Republican Governor’s Association Conference with My Pillow CEO Mike Lindell.[64] While at the event, Lindell was kicked out after threatening to confront Republican Governors for upholding the 2020 election results in accordance with their respective state laws.[65] Prior to this, in the midst of Trump’s attempts to overturn the 2020 presidential election, Lindell was seen leaving the White House with notes advocating for the imposition of “martial law” in the Untied State of America.[66]
  • In August of 2021, Noem helped Lindell book space for his “Cyber Symposium” in Sioux Falls, South Dakota, which made a mockery of our State.[67] The Symposium purported to prove the 2020 election was stolen.[68] Election experts called the supposed evidence Lindell presented “garbage” and “a big fat nothing.”[69] During the conference, Lindell offered $5 million dollars to anyone who could disprove his claims.[70] When an expert came forward, Lindell refused to pay.[71]
  • Mike Lindell also sued Dominion and Smartmatic, companies which make US voting machines.[72] A judge determined Lindell’s suit was frivolous, and he and his attorneys were sanctioned for asserting “groundless claims.”[73] Meanwhile, Dominion is suing Lindell for $1.3 billion in damages for his lies.[74] Not only has the case against Lindell not been deemed frivolous, but his motion for dismissal has been denied.[75] Noem’s relationship with Lindell demonstrates the depths she will go to promote conspiracies destructive to our nation.     
  • On January 20th, 2021, Kristi Noem, on her Facebook page, publicly stated Trump’s use of the pardon power was “excellent” and balanced “justice with forgiveness.” Trump’s pardons were, in fact, unprecedented in United States history.[76] He pardoned 9 Republican Politicians who were convicted in courts of law for crimes related to violations of the public trust.[77] He pardoned Charles Kushner, his son-in-law Jared Kushner’s father, who was convicted of witness tampering and tax evasion.[78] He pardoned Steve Bannon, his former chief strategist, who was charged with defrauding political donors.[79] And finally, he pardoned Michael Flynn, George Papadopoulos, Paul Manafort, and Roger Stone, all people convicted of serious crimes, including lying about their ties to the Russian government.[80] Even more concerning, they were all suspected of having knowledge of Trump’s criminal conduct.[81] That set a horrendous precedent.[82] From there on out, if someone commits a crime with a president, all they need to do is keep quiet, and they will be free of legal consequences.[83] Trump even toyed with the idea of pardoning the insurrectionists who stormed the Capitol on January 6th.[84] Never in our nation’s history has the pardon power been so flagrantly abused.[85]
  • After Mar-a-Lago was raided pursuant to a court approved warrant in August of 2022, Kristi Noem actively sought to undermine the American public’s trust in the fair administration of justice.[86] The FBI director who oversaw the execution of the warrant was appointed by Trump; an independent federal judge determined that there was probable cause that evidence related to a crime would be found at the scene; and classified documents illegally taken from the White House were in fact found.[87] Regardless, Kristi  took to her Facebook page to convince her followers of widespread governmental corruption based on no evidence.[88] She impugned the integrity of dozens of public servants across two branches of government to protect one man who has routinely lied to the American public.[89] 
  • While acting as Governor of South Dakota, Kristi Noem has been simultaneously setting her sites on either a run for the presidency or a position within the 2024 Trump campaign.[90]  This, of course, divides her attention from the business of South Dakota, but it also enables her donors to skirt campaign finance law.[91] By transferring money from her federal Noem Victory Fund to her three South Dakota PACs, her financial supporters have acceded the $10,000 limit set by campaign finance law.[92] Noem has also pushed a bill to allow for anonymous donations that legal experts say would help enable “dark money” to influence policy and elections.[93]
  • While promoting herself as a national candidate at CPAC in February of 2022, Kristi Noem repeated the Republican Political Establishment’s lie that Trump was spied on.[94] She was referring to filings in the Durham investigation’s case against attorney Michael Sussman.[95] Sussman was accused of lying to the FBI about his contacts with the Clintons, but on May 31st, 2022, after just 6 hours of deliberation, a jury unanimously determined he was not guilty.[96] Though it is true that the Clinton’s did opposition research on Trump, it was not “spying” in any meaningful sense of the term.[97] Opposition research is a given in politics.[98] The opposing party, whether Democrat or Republican, will research their opponents.[99] It has always been that way. This research, if done ethically, can have positive effects.[100] It helps prevent criminals and moral degenerates from being elected to public office.[101] It simply is not, nor has it ever been, spying, and to suggest otherwise is tantamount to lying to the American public.[102]
  • Kristi Noem has vocally blamed the Biden Administration for Putin’s invasion of Ukraine, but she said nothing when Trump extorted the Ukraine with US military aid in order to get a false investigation into the lie that it was Ukraine and not Russia that interfered in the 2016 election.[103] She said nothing when Trump took the side of Putin over the findings of the entire US Intelligence community at the Helsinki summit.[104] She said nothing when Trump called reports of Russian bounties for killing U.S. soldiers in Afghanistan a “Fake News Media Hoax,” even though his own administration admitted their authenticity to Congress.[105] She said nothing when Trump repeatedly attacked NATO, Russia’s nemesis and the force now protecting Europe from Russian aggression.[106] Finally, she said nothing when Trump, after the invasion of Ukraine, called Russian forces a “peace force” and Putin “smart,” “savvy,” and “a genius.”[107] This profound hypocrisy and refusal to critically evaluate her own Party unequivocally demonstrate that Kristi Noem is unfit to be an elected representative in the United States of America, at any level.



[1] Sneve, Joe; Report: Kristi Noem’s daughter got preferential treatment in real estate appraiser program; Argus Leader; May 17th, 2022; available at Panel: Kristi Noem's daughter got preferential treatment in program (argusleader.com).

[2] Ibid.

[3] Ibid.

[4] Ibid.

[5] Mcdade, Aaron; Sherry Bren felt ‘Intimidated’ by Gov. Kristi Noem, Kassidy Peters at Meeting Over LicenseNewsweek; Dec. 14th, 2021; available at Sherry Bren Felt 'Intimidated' by Gov. Kristi Noem, Kassidy Peters at Meeting Over License (newsweek.com)

[6] Ibid.

[7] Sneve, Joe; Report: Kristi Noem’s daughter got preferential treatment in real estate appraiser program; Argus Leader; May 17th, 2022; available at Panel: Kristi Noem's daughter got preferential treatment in program (argusleader.com).

[8] Ibid.

[9] Yates, Janet; Letter: Republican Reps keeping Trump’s tax returns; Argus Leader; March 6th, 2017; available at https://www.argusleader.com/story/opinion/readers/2017/03/06/letter-republican-reps-keeping-trumps-tax-returns/98817146/.

[10] Ibid.

[11] Ibid.

[12] Sullivan, Andy; Stephenson, Emily; Holland, Steve; Trump says’ won’t divest from his business while president; Reuters; January 11th, 2017; available at https://www.reuters.com/article/us-usa-trump-finance/trump-says-wont-divest-from-his-business-while-president-idusKBN14V21I. 

[13] Altman, Alex; Donald Trump’s Suite of Power; Time Magazine; June 8th, 2017, available at The Suite of Power | TIME.

See also Gorod, Brianne J; Frazelle, Brian R.; Houshower, Samuel; The Domestic Emoluments Clause: It’s Text, Meaning, and Application to Donald J. Trump; Constitutional Accountability Center; available at https://www.theusconstitution.org/think_tank/the-domestic-emoluments-clause-its-text-meaning-and-application-to-donald-j-trump/; last visited May 27th, 2020.

See also Hickey, Kevin J; and Foster, Michael A.; The Emoluments Clauses of the U.S. Constitution; Congressional Research Service; available at https://fas.org/sgp/crs/misc/IF11086.pdf.

See also Collins, Sean; Mike Pence stayed at Trump hotel 180 miles away from his Ireland meetings – for ‘safety’; Vox.com; September 3rd, 2019; available at https://www.vox.com/policy-and-politics/2019/9/3/20847247/mike-pence-ireland-doonbeg-trip-180-miles-away-trump-hotel.

See also Dawsey, Josh; Fahrenthold, David A.; Near the airport, ample parking: Why Trump says his Florida golf club should host the next G7; Washington Post; August 26th, 2019; available at https://www.washingtonpost.com/politics/trump-sings-the-praises-of-his-resort-in-florida-as-g-7-host-for-2020/2019/08/26/17409c1e-c7ea-11e9-8067-196d9f17af68_story.html. 

See also Confessore, Nicholas; Haberman, Maggie; and Lipton, Eric; Trump’s ‘Winter White House’: A Peak at the Exclusive Members List at Mar-a-Lago; The New York Times; available at https://www.nytimes.com/2017/02/18/us/mar-a-lago-trump-ethics-winter-white-house.html.

See also Davis, Julie Hirschfield; Trump Won’t Release His Tax Returns, a Top Aide Says; New York Times; Jan. 22nd, 2017; available at Trump Won’t Release His Tax Returns, a Top Aide Says - The New York Times (nytimes.com).

[14] Sheth, Sonam; Trump’s properties have raked in more than $8 million from U.S. taxpayers and the president’s supporters since he took office; Business Insider; Oct. 27th, 2020; available at Trump Properties Got Over $8 Million From Taxpayers, Supporters: WaPo (businessinsider.com)

See also Collins, Sean; Mike Pence stayed at Trump hotel 180 miles away from his Ireland meetings – for ‘safety’; Vox.com; September 3rd, 2019; available at https://www.vox.com/policy-and-politics/2019/9/3/20847247/mike-pence-ireland-doonbeg-trip-180-miles-away-trump-hotel; last visited May 27th, 2020.

[15] Altman, Alex; Donald Trump’s Suite of Power; Time Magazine; June 8th, 2017, available at The Suite of Power | TIME.

See also American Oversight; State Correspondence Regarding Foreign Government Leases at Trump’s New York Properties; August 19th, 2019; available at https://www.americanoversight.org/document/state-correspondence-regarding-foreign-government-leases-at-trumps-new-york-properties. 

See also Kumar, Anita; How Trump fused his business empire to his Presidency; Politico; January 20th, 2020; available at https://www.politico.com/news/2020/01/20/trump-businesses-empire-tied-presidency-100496.

See also McIntire, Mike, and Buettner, Russ, and Craig, Susanne; Trump Records Shed Light on Chinese Business Pursuits; New York Times; Oct. 20th, 2020; available at  Trump Records Shed New Light on Chinese Business Pursuits - The New York Times (nytimes.com)

[16] Groves, Stephen; Democratic lawmaker asks attorney general to investigate Gov. Noem’s plane use; Argus Leader; Feb. 25th 2021; available at Democratic lawmaker asks AG to investigate Gov. Kristi Noem's plane use (argusleader.com)

[17] Newhauser, Daniel; Exclusive: GOP governor Kristi Noem, potential Trump successor, used state aircraft for tens of thousands of dollars in political travel; Raw Story; Feb. 15th, 2021; available at Exclusive: GOP governor Kristi Noem, potential Trump successor, used state aircraft for tens of thousands of dollars in political travel - Raw Story - Celebrating 18 Years of Independent Journalism.

[18] Tsitrian, John; To heck with the law. Noem says she’s an ‘ambassador’ and can use the state plane on our dime while politicizing; The South Dakota Standard; Feb. 18th, 2021; available at  To heck with the law. Noem says she's an ‘ambassador’ and can use the state plane on our dime when politicizing. — The South Dakota Standard (sdstandardnow.com).

[19] Associated Press; South Dakota’s governor gave Trump a miniature Mount Rushmore featuring his face; USA Today; Jan. 22nd, 2021; available at South Dakota Gov. Noem gave Trump mini Mount Rushmore with his face (usatoday.com).

[20] Goss, Austin; Governor Kristi Noem brings Corey Lewandowski back on; Fox: Dakota News Now; May 27th, 2022; available at Governor Kristi Noem brings Corey Lewandowski back on (dakotanewsnow.com).

[21] Ardrey, Taylor; Gov. Kristi Noem says she would be ‘shocked’ if Trump asked her to be his running mate: ‘If he runs, I will support him’; Business Insider; July 3rd, 2022; available at Noem Says She'd Be Shocked If Chosen As Trump VP Pick (insider.com)

[22] Ibid.

[23] Jorgenson, Don; Gov. Noem tweets about “rigged elections”: South Dakota’s congressional delegation weigh in on Presidential election results; Kelo Land News; Nov. 6th, 2020; available at Was the Presidential Election rigged? That's what President Trump is claiming and apparently so is South Dakota governor Kristi Noem. (keloland.com).

[24] Ibid.

[25] Dorman, John L.; South Dakota governor spars with George Stephanopoulus after she insisted on debunked claim that ‘dead people voted in Pennsylvania’; Business Insider; Nov. 8th, 2020; available at S.D. Governor Spars With George Stephanopoulos Over Voter Fraud Claims (businessinsider.com) 

[26] Ibid.

[27] Staff; Election recount laws and procedures in the 50 states, 2020; Ballotpedia; No Date; available at Election recount laws and procedures in the 50 states, 2020 - Ballotpedia.

[28] Staff; 2020 Electoral College Results; National Archive; No Date; available at 2020 Electoral College Results | National Archives.

[29] Staff; It’s Official: The Election Was Secure; Brennan Center for Justice; Dec. 11th, 2020; available at It’s Official: The Election Was Secure | Brennan Center for Justice.

See also You Tube; January 6th Committee Holds Public Hearing On 2021 Capitol Attack; NBC News Broadcast; June 9th, 2022; see 52:56 into video; available at  January 6th Committee Holds Public Hearing On 2021 Capitol Attack | NBC News - YouTube (sworn testimony demonstrating Donald Trump was told he lost the election prior to lying about his victory).

See also Budryk, Zack; Krebs doubles down after threat: ‘2020 election was most secure in U.S. history’; The Hill; Dec. 2, 2020; available at  Krebs doubles down after threat: ‘2020 election was most secure in U.S. history’ | The Hill.

See also Zapotosky, Matt, and Barrett, Devlin, and Dawsey, Josh; Barr says he hasn’t seen fraud that could affect the election outcome; Dec. 1st, 2020; available at Barr: No evidence of election fraud that would swing the race for Trump - The Washington Post.

[30] Rutenberg, Jim, and Corasiniti, Nick, and Feuer, Alan; Trump’s Fraud Claims Died in Court, but the Myth of Stolen Election’s Live on; The New York Times; Dec. 26th, 2020; available at Trump’s Fraud Claims Died in Court, but the Myth of Stolen Elections Lives On - The New York Times (nytimes.com)

See also Wheeler, Russel; Trump’s judicial campaign to upend the 2020 election; a failure, but not a wipe-out; Brookings Institute; Nov. 30th, 2021; available at Trump’s judicial campaign to upend the 2020 election: A failure, but not a wipe-out (brookings.edu).

See also Helderman, Rosalind, and Viebeck, Elise; ‘The last wall’: How dozens of judges across the political spectrum rejected Trump’s efforts to overturn the election; Washington Post; Dec. 12th, 2020; available at Judges across the political spectrum rejected Trump?s efforts to overturn the election - The Washington Post. 

[31] Ibid.

[32] Hong, Nicole, and Rashbaum, William, and Protess, Ben; Court Suspends Giuliani’s Law License, Citing Trump Election Lies; The New York Times; June 24th, 2021; available at Giuliani's Law License Is Suspended Over Trump Election Lies - The New York Times (nytimes.com).

See also Helderman, Rosalind; Sidney Powell, L. Linn Wood among attorneys ordered to pay $175,000 over Michigan’s Kraken suit; Washington Post; Dec. 2nd, 2021; available at Sidney Powell, L. Lin Wood among attorneys ordered to pay $175,000 over Michigan ‘Kraken’ suit - The Washington Post.

[33] Ibid.

[34] Ibid.

[35] Ibid.

[37] Romey, Kristin; Decoding the hate symbols seen at the capitol insurrection; National Geographic; Jan. 12th, 2021; available at Decoding the hate symbols seen at the Capitol insurrection (nationalgeographic.com).

[38] Ibid.

[39] Ibid.

[40] Ibid.

[42] Ibid.

[43] Ibid.

[44] Lonsdorf, Kat, and Dorning, Courtney, and Isackson, Amy, and Kelly, Mary Louise, and Chang, Ailsa; A timeline of how the Jan. 6 attack unfolded – including who said what and when; NPR; Jan. 5th, 2022; available at Timeline: How the Jan. 6 attack on the Capitol unfolded : NPR

[45] Elfrink, Tim; D.C. officer who suffered heart attack on Jan. 6 calls out Trump for downplaying ‘brutal, savage’ riot; Washington Post; Apr. 28th, 2021; available at https://www.washintonpost.com/nation/2021/04/28/michael-fanone-trump-gop-riots/.

[46]  Schmidt, Michael, and Broadwater, Luke; Officer’s Injuries, Including Concussions, Show Scope of Violence at Capitol Riot; The New York Times; Feb. 11th, 2021; available at Officers’ Injuries, Including Concussions, Show Scope of Violence at Capitol Riot - The New York Times (nytimes.com).

[47] Zou, Jie Jenny, and Logan, Erin; Jan. 6: By the numbers; LA Times; Jan. 5th, 2022; available at Jan. 6: By the numbers - Los Angeles Times (latimes.com)

See also Wolfe, Jan; Four officers who responded to U.S. Capitol attack have died by suicide; Reuters; Aug. 2nd, 2021; available at  Four officers who responded to U.S. Capitol attack have died by suicide | Reuters.

[48] Brennan Center for Justice; Voting Laws Roundup: October 2021; Oct. 4th, 2021; available at Voting Laws Roundup: October 2021 | Brennan Center for Justice. 

[49] Staff; Gov. Noem refuses to say whether Biden victory was free and fair; Argus Leader; Jan. 28th, 2021; available at Gov. Kristi Noem refuses to say whether Biden win was free and fair (argusleader.com).

[50] Ibid.

[51] Kennecke, Angela; Governor-Elect Kristi Noem Hires Daughter; Kelo Land; Dec. 7th, 2018; available at Governor-Elect Kristi Noem Hires Daughter (keloland.com).

[52] Tsitrian, John; Gov. Noem touts South Dakota like crazy. So where does her daughter go to get her MBA? Tennessee?; The South Dakota Standard; Aug. 2nd, ?; available at Gov. Noem touts South Dakota like crazy. So where does her daughter go to get her MBA? Tennessee. — The South Dakota Standard (sdstandardnow.com).

[53] Ibid.

[54] Mitchell, Trevor J.; Yes, it’s legal for Kristi Noem to hire her daughter to work in the governor’s office; Argus Leader; Dec. 10th, 2018; available at Is it legal for Noem to hire daughter to work in governor's office? (argusleader.com).

See also Staff; Preventing Nepotism in the Federal Civil Service; U.S. Merit Systems Protection Board; June, 2016; available at Preventing Nepotism in the Federal Civil Service (mspb.gov).

[55] Ibid.

[56] Crowley, James; Republican Governor Says Democrats are Taking ‘Unprecedented Action to Destroy our Democracy’ With Trump’s First Impeachment; Newsweek; Jan. 16th, 2020; available at Republican Governor Says Democrats Are Taking 'Unprecedented Action to Destroy Our Democracy' With Trump's Impeachment (newsweek.com).

[57] See Report of the Permanent Select Committee on Intelligence, Pursuant to H. Res. 660 in Consultation with House Committee on Oversight and Reform and the House Committee on Foreign Affairs; The Trump-Ukraine Impeachment Inquiry Report; December 2019; available at https://intelligence.house.gov/uploadedfiles/the_trump-ukraine_impeachment_inquiry_report.pdf;

[58] Ibid.

[59] See Report of the Permanent Select Committee on Intelligence, Pursuant to H. Res. 660 in Consultation with House Committee on Oversight and Reform and the House Committee on Foreign Affairs; The Trump-Ukraine Impeachment Inquiry Report; December 2019; available at https://intelligence.house.gov/uploadedfiles/the_trump-ukraine_impeachment_inquiry_report.pdf;

See also LaFraniere, Sharon, and Kramer, Andrew E., and Hakim, Danny; Trump, Ukraine and Impeachment: The Inside Story of How We Got Here; New York Times; July 29th, 2021; available at Trump, Ukraine and Impeachment: The Inside Story of How We Got Here - The New York Times (nytimes.com).

[60] Report of the Permanent Select Committee on Intelligence, Pursuant to H. Res. 660 in Consultation with House Committee on Oversight and Reform and the House Committee on Foreign Affairs; The Trump-Ukraine Impeachment Inquiry Report; December 2019; available at https://intelligence.house.gov/uploadedfiles/the_trump-ukraine_impeachment_inquiry_report.pdf.

See also Dreyfuss, Bob; How Rudy Giuliani Became Trump’s Shadow Secretary of State; The Nation; March 6th, 2020; available at How Rudy Giuliani Became Trump’s Shadow Secretary of State | The Nation.

[61] Cippolone, Pat A.; October 8th, 2019, White House Counsel Letter; available at www.whitehouse.gov/wp-content/uploads/2019/10/PAC-Letter-10.08.2019.pdf.

See also Diaz, Alexa; Trump impeachment inquiry: A timeline; Los Angeles Times; October 24, 2012; available at www.latimes.com/politics/story/2019-09-26/ukraine-trump-impeachment-inquiry-timeline. 

See also McPherson, Lindsey; Democrats to punish Trump for obstructing Congress.  What about top employees?; Roll Call; www.rollcall.com/news/congress/democrats-punish-trump-obstructing-congress-top-employees. 

See also Gorod, Brianne; The Need for Congressional Oversight Goes Far Beyond Impeachment; The Atlantic; September 30th, 2019; available at www.theatlantic.com/ideas/archive/2019/09/future-congressional-oversight-risk/598996/.

See also Eastland v. United States Servicemen’s Fund; 421U.S.491 (1975); Pg. 505 (Describing Congressional subpoenas power as an “indispensable ingredient” in lawmaking)

[62] Gorod, Brianne; The Need for Congressional Oversight Goes Far Beyond Impeachment; The Atlantic; September 30th, 2019; available at www.theatlantic.com/ideas/archive/2019/09/future-congressional-oversight-risk/598996/.

See also Eastland v. United States Servicemen’s Fund; 421U.S.491 (1975); Pg. 505 (Describing Congressional subpoenas power as an “indispensable ingredient in lawmaking.

[63] Ibid.

[64] Lippman, Daniel; MyPillow CEO flew Kristi Noem to GOP governors conference on his private jet; May 28th, 2021; available at MyPillow CEO flew Kristi Noem to GOP governors conference on his private jet - POLITICO.

[65] Ibid.

[66] Bump, Phillip; A pillow salesman apparently has some ideas about declaring martial law; Washington Post; Jan. 15th, 2021; available at My Pillow salesman Mike Lindell apparently has some ideas about declaring martial law - The Washington Post.

[67] Staff; Gov. Noem helped Lindell pick venue for cyber symposium; Fox: Dakota News Now; Aug. 14th, 2021; available at Gov. Noem helped Lindell pick venue for cyber symposium (dakotanewsnow.com).

[68] Ibid.

[69] Marks, Joseph; The Cybersecurity 202: My Pillow cyber symposium is yet another font of election fraud lies; Washington Post; Aug. 11th, 2021; available at The Cybersecurity 202: My Pillow cyber symposium is yet another font of election fraud lies - The Washington Post.

[70] Warden, Beth; Cyber Symposium expert delivers papers to Lindell’s attorneys claiming $5 million dollar reward; Fox: Dakota News Now; Aug. 18th, 2021; available at Cyber Symposium expert delivers papers to Lindell’s attorneys claiming $5 million dollar reward (dakotanewsnow.com).

[71] Ibid.

[72] Larson, Erik; MyPillow’s Lindell Sanctioned Over ‘Frivolous’ Election Suit; Bloomberg; May 19th, 2022; available at MyPillow CEO Ordered to Pay Fees in ‘Frivolous’ Election Suit - Bloomberg.

[73] Ibid.

[74] Teh, Cheryl; A judge has rejected My Pillow CEO Mike Lindell’s appeal to dismiss Domion’s 1.3 billion lawsuit against him; Business Insider; March 3rd, 2022; available at Judge Rejects Mike Lindell's Attempt to Get Dominion Lawsuit Dismissed (businessinsider.com).

[75] Ibid.

[76] NPR Interview; Comparing Trump’s Wave of Pardons To Those of Past Administrations; NPR; Dec. 25, 2020; available at  Comparing Trump's Wave Of Pardons To Those Of Past Administrations : NPR

[78] Ibid.

[79] Ibid.

[80] Ibid.

[81]] Ibid.

[82] NPR Interview; Comparing Trump’s Wave of Pardons To Those of Past AdministrationsNPR; Dec. 25, 2020; available at  Comparing Trump's Wave Of Pardons To Those Of Past Administrations : NPR

[83] Ibid.

[84] Pengelly, Martin; Trump pardon promise for Capitol rioters ‘stuff of dictators’ – Nixon aide; The Guardian; Jan. 30th, 2022; available at Trump pardon promise for Capitol rioters ‘stuff of dictators’ – Nixon aide | Donald Trump | The Guardian.

[85] NPR Interview; Comparing Trump’s Wave of Pardons To Those of Past Administrations; NPR; Dec. 25, 2020; available at  Comparing Trump's Wave Of Pardons To Those Of Past Administrations : NPR.

See also Washington Post Staff; All the people President Trump pardoned on his way out of office; Washington Post; Jan. 20th, 2021; available at Trump pardons list: Who was pardoned, granted clemency - The Washington Post.

[86] Breuninger, Kevin; FBI search warrant reveals agents seized top-secret documents in raid of Trump’s home; CNBC; Aug. 12th, 2022; available at FBI search warrant reveals agents seized top-secret documents in raid of Trump's home (cnbc.com)

See also Caputo, Marc, and Shabad, Rebecca, and Gregorian, Dareh; Trump Mar-a-Lago search warrant, property receipt show agents found trove of classified docs; Washington Post; Aug. 12th, 2022; available at Trump Mar-a-Lago search warrant, property receipt show agents found trove of classified docs (nbcnews.com)

[87] Lee, Ella, and Woodall, Candy, and Carless, Will, and Jackson, David, and Johnson, Kevin, and Rouan, Rick, and Mansfield, Erin; Live Updates: DOJ search warrant shows Trump being probed in connection with espionage statutes; USA Today; Aug. 12th, 2022; available at Trump Mar-a-Lago estate warrant unsealed by federal judge (usatoday.com). (provides background on warrants)  

See also Nzanga, Merdie; What you need to know about FBI Director Christopher Wrey; USA Today; Aug. 10th, 2022; available at FBI director: What to know about Christopher Wray (usatoday.com). (provides background on Trump’s appointment of FBI Director Christopher Wrey).

See also Breuninger, Kevin; FBI search warrant reveals agents seized top-secret documents in raid of Trump’s home; CNBC; Aug. 12th, 2022; available at FBI search warrant reveals agents seized top-secret documents in raid of Trump's home (cnbc.com) (on what was seized pursuant to the warrant).

[88] Noem, Kristi; Facebook Page for “Kristi Noem”; Aug. 11th, 2022 post; available at (1) Kristi Noem | Facebook.

[89] Kessler, Glenn, and Rizzo, Salvador; Trump’s false or misleading claims total 30,753 over 4 years; Washington Post; Jan. 24th, 2021; available at Trump’s false or misleading claims total 30,573 over 4 years - The Washington Post.

See also Milligan, Susan; Jan. 6 Committee Dismantles Donald Trump’s Big Lie; US News; June 13th, 2022; available at Jan. 6 Committee Dismantles Donald Trump’s ‘Big Lie’ (usnews.com).

[90] Groves, Stephen; South Dakota’s Noem taking swings at potential 2024 rivals; AP News; July 18th, 2021; available at South Dakota's Noem taking swings at potential 2024 rivals | AP News.

[91] Heidelberger, Cory Allen; Noem Launders Over $1M from Federal PAC into State Committees, Flies Again on Pillow Guy’s Dime; Dakota Free Press; Apr. 4th, 2022; available at Noem Launders Over $1M from Federal PAC into State Committees, Flies Again on Pillow Guy’s Dime – Dakota Free Press.

[92] Ibid.

[93] Groves, Stephen; South Dakota’s Noem taking swings at potential 2024 rivals; AP News; July 18th, 2021; available at South Dakota's Noem taking swings at potential 2024 rivals | AP News.

See also Shaw, Donald; Noem Bill Would Make Dark Money Disclosure Illegal; The American Prospect; Feb. 20th, 2021; available at Noem Bill Would Make Dark Money Disclosure Illegal - The American Prospect.

[94] YouTube; ‘The Clinton’s Spied on Him’: Kristi Noem Defends Trump After Durham Report Filing; Forbes; Feb. 25th, 2022; available at 'The Clintons Spied On Him': Kristi Noem Defends Trump After Durham Report Filing - YouTube.

[95] Kessler, Glenn; How the right embraced the false claim that Hillary Clinton ‘spied’ on President Donald Trump; Washington Post; Feb. 18th, 2022; available at How the right embraced the false claim that Hillary Clinton ‘spied’ on President Donald Trump - The Washington Post.

[97] CBS; How do politicians gather opposition research on other candidates; CBS; July 14th, 2017; available at How do politicians gather opposition research on other candidates? - CBS News. 

See also Savage, Charlie; Court Filings Started a Furor in Right-Wing Outlets, but Their Narrative is Off Track; New York Times; Feb. 14th, 2022; available at Court Filing Started a Furor in Right-Wing Outlets, but Their Narrative Is Off Track - The New York Times (nytimes.com). 

[98] Ibid.

[99] Ibid.

[100] Ibid.

[101] Staff; What is Opposition Research? Understanding the Tactics used by Political Campaigns to Conduct Opposition Research; Master Class Articles; Sept. 29th, 2021; available at What Is Opposition Research? Understanding the Tactics used by Political Campaigns to Conduct and use Opposition Research - 2022 - MasterClass

[102] Ibid.

[103] Feiner, Lauren; Why Trump asked Ukraine’s president to look into Crowdstrike, a U.S. cybersecurity company that recently went public; CNBC; Sept. 25th, 2019; available at Why Trump asked Ukraine's president to look into CrowdStrike (cnbc.com).

See also Vachon, Nick; Noem changes her tune on how US should deal with Russia invading Ukraine; The American Independent; March 11th, 2022; available at Noem changes her tune on how US should deal with Russia invading Ukraine (americanindependent.com).

[104] BBC; Trump sides with Russia against FBI at Helsinki summit; BBC; July 16th, 2018; available at Trump sides with Russia against FBI at Helsinki summit - BBC News

[105] Sprunt, Barbara; Trump Calls Bounty Report a “Hoax” Despite Administration’s Briefing of Congress; NPR; July 1st, 2020; available at Trump Calls Bounty Report A 'Hoax' Despite Briefing Of Congress : NPR

[106] Collinson, Stephen, How Trump’s disdain for NATO could help Putin; CNN; July 12, 2018; available at How Trump's disdain for NATO could help Putin | CNN Politics.

[107] Wise, Alana; Trump praises Putin as ‘savvy’ amid new escalations on Russia-Ukraine border; NPR; Feb. 22, 2022; available at Trump praises Putin as 'savvy' amid new escalations on Russia-Ukraine border : NPR

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