Georgia Non-Profit’s President, General Counsel Oppose LGBTQ+ Rights at Legislature, Raise Ethics Questions

Non-profit policy groups Frontline Policy Council (FPC) and Frontline Policy Action (FPA) often publicize their contacts with policymakers, but the activities of the groups’ president and Frontline's new general counsel raise questions about compliance with state ethics rules for lobbyists. “Conducting lobbyist activities without registering as a lobbyist would be considered a violation of the Campaign Finance Act,” Joseph Cusack, deputy director and general counsel for the State Ethics Commission, told Hatewatch in an emailed statement, provided the activity does not fall into several exemptions in the statute.

Cole Muzio co-founded and leads both organizations. Their missions largely involve changing public policy in Georgia to align with far-right anti-abortion and anti-LGBTQ ideologies.

Lobbying successes

Since 2023, more than one dozen anti-LGBTQ+ bills have moved through the Georgia legislature. According to LGBTQ+ advocates in the state, two groups have led the charge: FPC and its affiliate FPA. Prior to 2021, the groups were affiliates of the national Family Policy Alliance, which often partners with anti-LGBTQ+ hate groups like Family Research Council (FRC). In 2021, the groups split from Family Policy Alliance to form independent organizations, and representatives of the groups have been fixtures at the state Capitol since then.

The groups have direct impact with their advocacy of bills to restrict abortion, ban gender-affirming care and limit inclusive educational practices in Georgia. The successes appear to be a function of their contact with state lawmakers and their endorsements of state legislative candidates. “I can tell you there’s no organization that made a bigger difference in putting that [Georgia’s 6-week abortion ban] into law than Frontline did,” state Sen. Ed Setzler, R-Acworth, said in an FPA promotional video in October 2023. Setzler won his seat in 2022 and was FPA’s first endorsement during that election season.

When asked about Frontline's lobbying activity, Cindy Battles, policy and engagement director for the Georgia Coalition for the People’s Agenda, said: “There are multiple instances including the defunding of public education in SB 233, the push for RFRA [Religious Freedom Restoration Act], the inclusion of puberty blockers in bills meant to save lives at schools. ... It feels hopeless to win against this. It’s trying to put out a forest fire with a bucket.”

FCP/A’s direct advocacy work is undertaken, in part, by two registered lobbyists and two people not registered as lobbyists with the state Government Transparency and Campaign Finance Commission (GTCFC) in either 2023 or 2024: Muzio and Frontline general counsel Chelsea Thompson.

Frontline did not respond to an emailed request for comment.

Lobbying code

In 2021, leaders of the Georgia affiliate of Family Policy Alliance – first founded as a “ministry” of long-time far-right personality James Dobson’s Focus on the Family – broke away from the national organization and formed two independent tax-exempt groups: FPC, a tax-exempt “charitable” group organized under section 501(c)(3) of the Internal Revenue Code, and FPA, a tax-exempt “social welfare” group organized under section 501(c)(4) of the Internal Revenue Code. Both types can engage in forms of lobbying, but regulations for 501(c)(3)s are far stricter.

According to the National Council of State Legislatures, lobbying in Georgia is largely defined by an exchange in funds – how much money the person spends or is compensated to influence how a policymaker votes.

The statute considers a lobbyist as any person who receives more than $250 in compensation for efforts to promote legislation. Similarly, a person who spends more than $1,000 in a calendar year to promote or oppose legislation is also considered a lobbyist.

Georgia code also lists other particulars, including compensation “specifically for undertaking to promote or oppose the passage of any ordinance or resolution by a public officer,” and employment to influence vendor selection in state contracts or influence state agencies.

People who meet the criteria in Georgia are required to register with the state GTCFC, which involves verifying whom the lobbyist is hired to represent and that group’s purpose. It also requires lobbyists to submit reports of their activity, including a semimonthly report, when the legislature is in session, on how much money they spend on things like meals, entertainment tickets or travel for policymakers. The reports are required to be filed monthly when the legislature is not in session.

“Most nonprofit organizations using paid staff to do any type of direct or grassroots lobbying activities at the state or local level” trigger a lobbying registration, according to guidance from Alliance for Justice, a judicial advocacy group. The group also warns non-profit lobbyists that missing a reporting deadline can result in financial penalties: “Late filing fees in Georgia can cumulatively amount to $11,275 per person per report!”

Even though the threshold is low, neither Muzio nor Thompson registered or filed lobbying disclosure reports for the 2023 legislative session or beyond. But both engaged in what appears to be lobbying under Georgia code, according to FPC/A’s websites and social media.

‘Never stopped working the phones’

Muzio maintained “active” lobbyist status for FPA until April 16, 2022, according to filings with the GTCFC. Since that time, Muzio has not registered as a lobbyist for either FPC or FPA and filed no lobbying expense reports (of the 15 required from registered lobbyists in 2023), according to public records. To date in 2024, five filing deadlines have passed with no report from Muzio or Thompson.

Still, Muzio was a fixture at the state Capitol during the 2023 and 2024 legislative sessions, according to social media and FPC blog posts reviewed by Hatewatch. In 2023, Muzio began the legislative session with a January visit to Georgia Commissioner of Labor Bruce Thompson’s office. FPC lobbyist Scott McInnis (who registered with the GTCFC in January 2023), and members of Frontline’s Church Ambassador Network – an FPC program designed to “connect pastors with elected leaders” and “represent God’s Church to those He has put in positions of government authority” – joined Muzio. They discussed how church leaders can “bless the Labor Department and the State of Georgia,” according to pictures and a description of the meeting shared by FPC.

By the third week of the 2023 legislative session in late January, FPA’s Taylor Hawkins shared in a blog post that “Muzio met with Representative John Carson” about a bill to increase spending on a voucher school program in the state. “We have assured Rep. Carson that he has our complete support in this effort,” Hawkins added.

During the 2023 session, Muzio also met with Georgia Gov. Brian Kemp, where he and Hawkins “heard his thoughts [and] shared our agenda” and joined Georgia physician Quentin Van Meter, former president of the anti-LGBTQ+ hate group American College of Pediatricians, at the Capitol after Van Meter’s testimony on a gender-affirming care ban.

Later in the 2023 session, Hawkins wrote about a long day he and Muzio had at the Capitol: “Cole and I arrived at the Capitol before 8am, stayed until roughly 10pm, and then did a wrap-up dinner where we were still communicating with our legislative allies.”

FPC/A highlighted the lobbying efforts of their president outside Georgia. In an April blog post just prior to the end of the legislative session, Hawkins said Muzio’s efforts continued despite being out of state at Family Policy Alliance’s “SoConCon” conference in Charleston, South Carolina – an event held March 20-23, 2023, and co-sponsored by the anti-LGBTQ hate groups FRC and Alliance Defending Freedom. Muzio “never stopped working the phones with legislators and allies here as we ramp up toward the conclusion of a topsy turvy session,” Hawkins wrote.

At the end of the 2023 session in May, Muzio again joined Kemp and members of the legislature for a bill-signing ceremony for a measure that would prevent the state from issuing so-called COVID “vaccine passports.”

‘Legal and public policy insights’

In late 2023, Frontline hired a new general counsel, Chelsea Thompson, whom the group said in a press release would “not just provide legal counsel, but also actively participate in drafting legislation that shapes the future of pro-family policies in our state.”

According to a job description of the general counsel position posted to the FPC website in about October 2023, the key responsibilities of the position include: “create and advance Frontline Policy Agenda [sic]” in “partnership with [Muzio] and the Policy Team … cultivate relationships with key lawmakers, political appointees, and other stakeholders” and “prepare and give legislative testimony in support of bills of Frontline’s legislative agenda or in opposition to bills that undermine our mission.”

In addition, the general counsel was hired to “[provide] the Body of Christ with legal ... insights” and create a litigation arm, called the Frontline Law Center, that plans to file legal challenges and “build a Christian Lawyer Coalition within the state of Georgia.” The position reports directly to the FPC president, Muzio.

One of the group’s claimed lobbying successes in 2024 involves a ban on puberty blockers – a component of gender-affirming care often falsely panned as experimental. In March 2023, Muzio indicated a desire to ban puberty blockers for minors in Georgia and FPA social media suggested a ban would be a key policy goal for the 2024 legislative session.

The AP reported that on March 11, state Sen. Ben Watson, R-Savannah, chairman of the Senate Health and Human Services Committee, “inserted the proposed [puberty blocker] ban into an unrelated bill about providing opioid antidotes in public buildings, catching opponents off guard.”

Prior to the committee hearing, FPA’s Facebook page posted an update “encourag[ing]” their followers to “watch the Senate Health Committee Hearing today at 3pm for a potential special appearance and possible legislative win.”

Later that afternoon, FPA thanked Watson on Twitter/X for his help passing the ban out of committee. The post included a photo of Watson flanked by Hawkins and Thompson in the state Capitol.

In a Facebook post after the hearing, FPA called the development a “victory,” referred to puberty blockers as “barbarism” and said, “we are immensely grateful to Chairman Ben Watson for dialoguing with us throughout the year, working with us on the language."

“Going up against groups like Frontline and groups with deep pockets is exhausting,” Lena Kotler, a Georgia parent and advocate for her trans daughter, told Hatewatch. “So much of activism falls on the shoulders of people who are already marginalized,” and most of those people do not engage in lobbying as a full-time job, Kotler said.

Citing a fast-paced legislative calendar and a last-minute bill substitute that brought a ban on puberty blockers quickly before the Senate Health and Human Services Committee, Kotler said procedural “tricks” seem designed to exclude unpaid advocates from being able to provide input on bills that deeply affect their families.

Despite this, Kotler shared her belief that advocating for her family at the Capitol will help make it “easier for other [LGBTQ+ kids]” and that living life “truthfully and openly makes it easier to combat misinformation.” She also told Hatewatch that trans people and their families are “putting their lives on the line” in Georgia by being advocates and that they need allies to “do that work alongside us.”

Federal filings

Despite Muzio leading both FPC and FPA from July 1, 2021, through June 30, 2022, FPC reported to the IRS that it did not engage in lobbying activities and reported zero expenditures on lobbying that year.

As a 501(c)(4), FPA faces fewer restrictions on political activity than its counterpart. According to the group’s most recent publicly available federal tax return, for the tax year ending midway through 2022, the group reported almost $140,000 in program expenses.

The return confirms that programmatic expenses included "lobbying the State Legislature.” According to the documents, however, the group reported zero lobbying expenses; and recorded no response when prompted by the tax form with the question “Did the organization engage in lobbying activities...?”

In the portion of the form dedicated to reporting campaign and lobbying expenses, called Schedule C, the group reported over $17,000 in “political campaign activity expenditures” including a $250 payment to the Georgia Republican Party. The group recorded no responses in the remainder of Schedule C, reserved for detailing lobbying expenditures.

According to other tax filings, almost $30,000 of FPA’s $262,000 revenue that tax year came directly from Family Policy Alliance when the groups parted ways.

Photo illustration by SPLC