Heritage Foundation
Heritage Foundation is a major conservative policy organization that functions in this investigation primarily as the source institution for election-enforcement and executive-power infrastructure operating inside and adjacent to the second Trump administration. Its relevance spans three areas: (1) Project 2025, coordinated by Heritage, served as the policy and staffing manual that the administration drew on after inauguration, including chapters written by personnel who subsequently entered government; (2) the Election Fraud Database, maintained since 2017, is cited as evidentiary support in NVRA voter-roll litigation filed by PILF, AFL, and Judicial Watch, though the Brennan Center published a counter-analysis concluding that the database's own data shows voter fraud is statistically rare; (3) the December 2025 staff exodus transferred Heritage's operational legal, economic, and data teams to AAF, splitting the conservative policy ecosystem along a Pence/traditional-conservative vs. Roberts/populist-nationalist axis without dissolving the underlying personnel network. Heritage's influence persists through its alumni across multiple organizations even as its own institutional direction remains contested.
The Heritage Foundation is a 501(c)(3) public-policy research organization founded in 1973 (EIN 23-7327730), headquartered at 214 Massachusetts Avenue NE, Washington, D.C. It reports annual revenue consistently in the $100–120 million range, making it one of the largest conservative policy organizations in the United States. Heritage occupies three distinct roles relevant to this investigation: it coordinated the production of Project 2025, the policy and personnel blueprint for the second Trump administration; it maintains the Election Fraud Database, the primary private-sector dataset cited in federal and state voter-roll enforcement actions; and analysis of personnel records indicates it served as the institutional home that trained and credentialed staff who now populate Advancing American Freedom, Public Interest Legal Foundation, and the broader DOJ Voting Section alumni network 1 2.
In October 2025, Heritage President Kevin Roberts refused to retract a statement defending Tucker Carlson's interview with Nick Fuentes. By January 2026, more than 60 staff had departed, including the heads of Heritage's legal center (John Malcolm), economic center (Richard Stern), and data team (Kevin Dayaratna), along with Hans von Spakovsky, who managed the Election Law Reform Initiative and authored the federal election oversight chapter of Project 2025. These personnel migrated to AAF's three newly created institutes, which replicate the Heritage centers they vacated in structure, personnel, and mission 3 4. The Diana Davis Spencer Foundation simultaneously withdrew a multi-million-dollar five-year funding commitment, and its CEO resigned as Heritage trustee 3. The result was a transfer of institutional capability—legal, economic, and data-analytic—from one organization to another, while the Election Fraud Database and Project 2025 infrastructure remained at Heritage.
Project 2025 and the Policy-to-Government Pipeline
Heritage coordinated the production of Project 2025, the 887-page Mandate for Leadership that served as the policy and personnel blueprint for the second Trump administration. Heritage scholars authored or co-authored chapters covering federal election oversight (Hans von Spakovsky), Arctic and Greenland policy (through the Allison Center for Foreign Policy Studies), and multiple domestic policy domains. The Arctic section recommended 'enhanced economic ties' with Greenland and a permanent U.S. consulate there—recommendations Heritage subsequently publicized under the tagline 'Heritage Leads the Way on U.S. Policy With Greenland' 5. Luke Coffey, then director of the Allison Center, published multiple papers arguing for U.S. Arctic defense integration with Greenland before departing for the Hudson Institute.
The Project 2025 pipeline operated through Heritage Action for America, Heritage's 501(c)(4) affiliate, which received $8.8 million from the Only Citizens Vote Coalition's identified donor network (the Issue One figure, covering the 2020–2024 period). That coalition, coordinated by Cleta Mitchell through the Conservative Partnership Institute's Election Integrity Network, co-hosted EIN summits with the RNC and lists Heritage as a sponsor 6. Twenty or more EIN member organizations participated in Project 2025, creating overlap between Heritage's policy output and the litigation and activation network built around Mitchell's EIN 7.
The Greenland policy thread connects Heritage to Rebekah Mercer, who holds a Heritage trustee seat. Mercer co-founded 1789 Capital with Donald Trump Jr. and Omeed Malik; the fund holds positions in Vulcan Elements (which received a $620 million DoD loan under Project Vault), Anduril, and SpaceX—companies whose contract revenues are materially affected by the Greenland mineral and Arctic defense policies Heritage publicly advocated 5 8. Heritage praised Project Vault as 'Trump's Bold Plan To Stop China From Starving Our Military.' The Mercer-Heritage-1789 Capital triangle places a Heritage trustee simultaneously in a private fund that profits from the defense and resource policies Heritage scholars recommended in Project 2025.
The Election Fraud Database and NVRA Enforcement Architecture
Heritage launched the Election Fraud Database at electionfraud.heritage.org in 2017, managed by Hans von Spakovsky through Heritage's Election Law Reform Initiative. It catalogs instances of alleged voter fraud across the United States and is routinely cited by NVRA litigants as evidence that voter-roll maintenance addresses a documented fraud problem. A Brennan Center for Justice counter-analysis concluded that the database's own data demonstrates voter fraud is statistically rare, not a basis for broad voter-roll purge programs. Despite this contested evidentiary status, analysis of litigation filings indicates the database continues to function as a cited authority in cases brought by Public Interest Legal Foundation and America First Legal Foundation 2.
Von Spakovsky also served on Trump's 2017 Presidential Advisory Commission on Election Integrity (PACEI), alongside J. Christian Adams (now PILF president), Ken Blackwell, and Kris Kobach. All four remain active in the election enforcement network as of March 2026, operating through PILF, AAF, FRC/AFPI, and the Kansas Attorney General's office respectively 9. Heritage was a summit sponsor for the Election Integrity Network at the Conservative Partnership Institute. Von Spakovsky sat on the PILF board while running Heritage's election operation, and Mitchell simultaneously chairs PILF while running EIN—positions that create a closed feedback loop between database production (Heritage/AAF), litigation strategy (PILF/AFL/JW), and grassroots activation (EIN) 6 10.
Von Spakovsky's departure to AAF in January 2026 transferred his personal expertise and network relationships to the Pence organization, but the Election Fraud Database's intellectual property remained at Heritage. Heritage stated publicly that election integrity remains a 2026 organizational priority, meaning both institutions now claim the same policy domain with partially overlapping personnel histories 11.
The December 2025 Staff Exodus and Factional Split
On October 30, 2025, Heritage President Kevin Roberts posted a video defending Tucker Carlson's interview with Nick Fuentes, using the phrase 'venomous coalition' to describe critics. Roberts declined to retract the statement over the following seven weeks. On December 22, 2025, thirteen staff members moved simultaneously to Advancing American Freedom, which launched three new institutes that day. The Edwin Meese III Institute for the Rule of Law covers legal work, the Plymouth Rock Institute covers economics, and the Center for Statistical Modeling covers data analysis. These names and functions mirror Heritage's own Meese Center for Legal and Judicial Studies, Roe Institute for Economic Policy Studies, and data analytics group 3 4.
Confirmed departures by name, drawn from AAF press releases, Jewish Insider, Reason.com, and Washington Examiner coverage, include the following. From the legal team: John Malcolm (VP), Hans von Spakovsky (Senior Legal Fellow), Tom Jipping, Paul Larkin, Amy Swearer, Jessica Reinsch, Jenna Hageman, and Meaghen McManus. From the economic team: Richard Stern (VP), Joel Griffith, Rachel Greszler, David Burton, Andrew Hale, Preston Brashers, John Peluso, and Austin Gae. From the data team: Kevin Dayaratna (VP), Philip Eigen, and Gadai Bulgac. Three Heritage trustees resigned as well, including Robby George (Princeton), Shane McCullar, and Abby Spencer Moffat (CEO of the Diana Davis Spencer Foundation). Moffat's resignation came with the withdrawal of a multi-million-dollar five-year funding commitment from the foundation. Eight or more members of Heritage's internal antisemitism task force resigned separately. By January 2026, Think Tank Watch reported total departures exceeding 60 4 3.
Heritage filled key vacancies afterward, promoting Jay Richards to Vice President, hiring Stewart Whitson as Chief of Staff, and bringing back Peter St. Onge as Senior Economist. Heritage maintained that election integrity and its core policy work would continue. Review of the departing Pence faction's public statements indicates they framed the split as a choice between Reagan-era free-market conservatism and Trump-era economic nationalism, including tolerance of far-right figures. This framing reflects one side of the dispute and has not been independently confirmed from primary organizational records. Examination of the primary record documents the scale of the personnel transfer and the structural mirroring of AAF's new institutes to Heritage's vacated centers 12.
Key Organizational Relationships
Advancing American Freedom absorbed Heritage's functional legal, economic, and data infrastructure wholesale during the December 2025 exodus. AAF's three new institutes replicate Heritage's three departing centers in structure, personnel, and stated mission. Marc Short, AAF's board chairman and former Pence Chief of Staff, leads an organization that simultaneously competes with Heritage for conservative donor funding and inherits Heritage's operational capability Connection #3340.
Public Interest Legal Foundation connects to Heritage through two channels. Von Spakovsky served on the PILF board while simultaneously directing Heritage's election law initiative, making him a structural link between Heritage's database production and PILF's litigation deployment of that data Connection #3306. Both von Spakovsky and PILF president J. Christian Adams are DOJ Civil Rights Division and 2017 PACEI alumni, placing them in the same founding cohort of the modern election-enforcement network 10 Connection #3366.
America First Legal Foundation cites Heritage's Election Fraud Database and Project 2025 election chapter as the intellectual framework for its NVRA voter-roll litigation. AFL's September 2024 filings against fifteen Arizona counties and its July 2025 EAC rulemaking petition parallel the policy positions Heritage scholars articulated in Project 2025. This relationship is advisory rather than financial or organizational Connection #3305.
1789 Capital overlaps with Heritage through the Mercer trustee connection, placing a Heritage board member in a private fund whose portfolio companies benefit from policies Heritage scholars recommended. Mercer is a trustee rather than a controlling funder, but the overlap is documented by SEC Form D filings (1789 Capital) and Heritage's own impact page on Greenland policy Connection #3165 5.
Diana Davis Spencer Foundation served as a major multi-year Heritage funder until the foundation withdrew a multi-million-dollar commitment and CEO Abby Spencer Moffat resigned as trustee during the December 2025 crisis. Heritage has not disclosed the precise figure in public filings; multiple outlets report it was a five-year commitment in the several-million-dollar range Connection #3344.
Heritage Foundation
Financial Profile
Heritage's IRS Form 990 (EIN 23-7327730) documents revenue stable in the $100–120 million range from 2013 through 2022, with assets significantly above $100 million as of the most recent available filing year. The organization is classified under NTEE code W050 (public policy research) and has held 501(c)(3) status since 1973. For comparison, AAF reported $10.7 million in 2024 revenue across its two entities, and PILF reported approximately $3.4 million. Even after the December 2025 departures, Heritage retains an order-of-magnitude financial advantage over the organizations that absorbed its former staff 1.
Heritage Action for America, the 501(c)(4) affiliate, received $8.8 million from the Only Citizens Vote Coalition donor network as tracked by Issue One over the 2020–2024 period. Heritage does not publicly disclose individual donors to either the 501(c)(3) or the 501(c)(4), consistent with the donor-advised fund structure that characterizes the broader conservative funding network. The Diana Davis Spencer Foundation's withdrawal of its multi-million-dollar commitment represents the first documented major donor departure tied directly to a Heritage leadership decision 3 13.
All Connections
7 total
All Connections
7 totalMercer is Heritage Foundation trustee; Heritage produced Project 2025 Greenland section. Mercer co-founded 1789 Capital with Greenland-relevant defense portfolio
AAF absorbed Heritage legal, economic, and data teams in Dec 2025-Jan 2026 mass exodus. 20+ staff moved. Three AAF institutes mirror Heritage centers.
Withdrew M 5-year funding commitment from Heritage after antisemitism controversy. CEO Abby Spencer Moffat resigned as Heritage trustee.
Mercer connection creates policy-to-investment pipeline
Heritage election fraud database and Project 2025 election chapter provide intellectual framework for AFL voter roll litigation
Heritage election fraud database provides data cited by PILF in voter roll purge cases; von Spakovsky and Adams share DOJ Voting Section alumni network
All Findings
11 total
All Findings
11 totalfinancial (2)
Heritage Foundation is the largest entity in this scan: Revenue M (2022), M (2021). Assets M (2022). EIN 237327730. 501(c)(3) since 1973. Address: 214 Massachusetts Ave NE, Washington DC. Revenue stable at -120M range since 2013. NTEE code W050 (public policy research).
Combined financial scale of NVRA litigation network (latest 990s): JW ~$82M revenue (2023, EIN 521885088), AFL ~$9.6M (2023, EIN 862190372, but $44.4M in 2022), PILF ~$3.4M (2023, EIN 454355641), TTV ~$1.5M (2022, EIN 272860095), Heritage Foundation ~$100M+ (not broken out for election work). PILF budget tripled from $1.5M (2018) to $3.7M (2023) during period of maximum NVRA litigation. AFL went from zero (founded 2021) to $44M in one year.
relationship (4)
PILF board is a nexus of DOJ Voting Section alumni and election enforcement figures: Chair Cleta Mitchell (Raffensperger call participant, Election Integrity Network founder), Hans von Spakovsky (DOJ Civil Rights 2002-2005, Heritage, now AAF/Pence), John Eastman (disbarred Jan 6 memo author), Ken Blackwell (former OH SOS). All served together on Trump's 2017 Election Integrity Commission.
Full PILF board composition reveals concentrated network of DOJ alumni and election enforcement activists: (1) Cleta Mitchell - Board Chair. Participated in Trump's Jan 2, 2021 Raffensperger call. Founded Conservative Partnership Institute's Election Integrity Network. (2) Hans von Spakovsky - Board member. DOJ Civil Rights Division Counsel 2002-2005, FEC commissioner (recess appointment). Heritage Foundation Election Law Reform Initiative manager until Dec 2025, then left for Advancing American Freedom (Pence org) in Jan 2026 mass exodus. (3) John C. Eastman - Board member since inception. Architect of the Jan 6 coup memo. Disbarred. (4) Ken Blackwell - Treasurer. Former Ohio Secretary of State, Family Research Council. (5) All four served on Trump's 2017 Presidential Advisory Commission on Election Integrity (disbanded). Adams (PILF president) was hired into DOJ in 2005 by Bradley Schlozman, who was found to have violated federal law via politicized hiring.
Heritage mass exodus Dec 2025: 20+ staff departed to AAF after Kevin Roberts defended Tucker Carlson interview with antisemitic Nick Fuentes. 3 trustees also resigned. M funding withdrawn.
Heritage Foundation President Kevin Roberts refused to retract Oct 2025 video defending Tucker Carlson's friendly interview with white nationalist Nick Fuentes. Roberts used phrase 'venomous coalition' to describe critics. This triggered: (1) 13 staff moved to AAF on Dec 22, 2025, including heads of legal (John Malcolm), economic (Richard Stern), and data (Kevin Dayaratna) centers; (2) Hans von Spakovsky and Cully Stimson resigned same day (Stimson later returned); (3) Josh Blackman resigned; (4) 3 trustees resigned: Robby George (Princeton), Shane McCullar, Abby Spencer Moffat (Diana Davis Spencer Foundation); (5) Moffat withdrew M 5-year funding commitment; (6) 5+ members of Heritage antisemitism task force resigned; (7) Total departures exceeded 60 by Jan 2026. Heritage restocked: Jay Richards promoted to VP, Stewart Whitson hired as CoS, Peter St. Onge returned as senior economist.
Von Spakovsky moved Heritage election integrity apparatus to AAF. Election Fraud Database (electionfraud.heritage.org) remains at Heritage but lost its principal architect. Von Spakovsky now at AAF Meese Institute pushing SAVE Act.
Hans von Spakovsky managed Heritage Election Law Reform Initiative and Election Fraud Database (1,412+ proven cases) since 2017. He authored Project 2025 FEC chapter. Resigned from Heritage Dec 22, 2025 (same day Roberts tapped him for interim Meese Center leadership). Joined AAF Meese Institute as Senior Legal Fellow Jan 12, 2026. At AAF, he continues election integrity work: pushing SAVE Act, voter citizenship verification requirements. The Election Fraud Database website (electionfraud.heritage.org) remains live at Heritage but has lost its creator and primary maintainer. Heritage states election integrity remains a 2026 priority but has not named von Spakovsky's replacement for the Election Law Reform Initiative.
Cleta Mitchell (PILF chair) runs the Election Integrity Network (EIN) through Conservative Partnership Institute - the central coordination hub connecting all 5 election enforcement orgs. EIN summits co-hosted with RNC and sponsored by Heritage Foundation. 20+ EIN coalition members involved in Project 2025. EIN central to dismantling ERIC (the interstate voter roll comparison system), creating the data vacuum that PILF then sues to fill. Mitchell simultaneously chairs PILF while running EIN, making her the key nexus between litigation strategy and grassroots activation.
intelligence (3)
Heritage Foundation produced Project 2025 Arctic/Greenland section, Luke Coffey policy papers, and praised Project Vault; Rebekah Mercer (1789 Capital co-founder) is Heritage trustee
Heritage Foundation is the primary think tank making the intellectual case for Greenland engagement. Multiple channels: (1) Project 2025 contained dedicated Arctic section recommending 'enhanced economic ties' with Greenland; (2) Luke Coffey (then Allison Center director, now at Hudson Institute) published multiple Greenland papers arguing for US consulate in Greenland and stronger Arctic defense chain; (3) Heritage praised Project Vault as 'Trump's Bold Plan To Stop China From Starving Our Military'; (4) Heritage impact page boasts 'Heritage Leads the Way on U.S. Policy With Greenland.' Key connection: Rebekah Mercer is both a Heritage Foundation trustee (which produced Project 2025's Greenland recommendations) and co-founder of 1789 Capital (which holds Vulcan Elements, Anduril, SpaceX — companies that benefit from Greenland mineral and defense policies). CSIS also published major Greenland/rare earth/Arctic security report in Jan 2026.
Heritage maintains Election Fraud Database (electionfraud.heritage.org) since 2017, managed by Hans von Spakovsky (Election Law Reform Initiative). Von Spakovsky wrote the Project 2025 chapter on federal election oversight. Brennan Center analysis found the database 'undermines claims of recent voter fraud' - showing voter fraud is vanishingly rare. The database is nonetheless cited as justification for voter roll purge efforts by other groups.
Heritage-AAF split represents Pence (traditional conservative/pro-Israel) vs Roberts (populist/MAGA) factional divide. Not just personnel -- an institutional capability transfer.
The Heritage-AAF exodus is not merely a personnel dispute but a factional split in the conservative movement: (1) IDEOLOGICAL: Pence/AAF represents traditional Reagan conservatism -- free markets, strong defense, pro-Israel. Roberts/Heritage has moved toward populist/MAGA -- tariffs, noninterventionist foreign policy, tolerance of far-right figures. (2) CAPABILITY TRANSFER: AAF absorbed Heritage's entire legal, economic, and data analysis infrastructure -- not just individual scholars but whole teams with institutional knowledge, methodologies, and relationships. (3) FINANCIAL: Diana Davis Spencer Foundation withdrew M commitment from Heritage. AAF raised -13M in weeks for new hires. Heritage had M revenue and M assets (2022) -- still vastly larger. (4) ELECTION ENFORCEMENT: The election integrity apparatus (von Spakovsky, data team, legal scholars) moved to AAF, but the Election Fraud Database IP remains at Heritage. Heritage says election integrity is still a 2026 priority. (5) The Pence faction explicitly frames the split as about antisemitism tolerance, not just policy disagreements.
identity (1)
Eric Neff appointed Acting Chief of DOJ Voting Section — former LA DA who botched Konnech prosecution using True the Vote evidence, placed on admin leave, $5M settlement
Eric V. Neff (CA Bar #289367, admitted 2013) replaced Maureen Riordan as Acting Chief of DOJ Voting Section by Dec 2025. Deputy DA III at LA County DA 2015-2024. Placed on admin leave 2022 after prosecuting Konnech CEO Eugene Yu based on True the Vote/Gregg Phillips tip, withheld TTV involvement from supervisors. Charges dropped in 6 weeks; county paid $5M settlement. Filed tort claim April 2024. Wrote RedState articles on Dominion Sept-Oct 2024. Briefly represented Patrick Byrne alongside Stefanie Lambert; discovered never admitted to Central District of CA bar. RNLA member. Now signs DOJ lawsuits against 30 states seeking unredacted voter rolls.
document (1)
Complete Heritage-to-AAF staff migration: 20+ confirmed by name across legal, economic, data teams. Includes 8 Meese Institute, 8 Plymouth Institute, 3 Center for Statistical Modeling, plus additional hires.
CONFIRMED HERITAGE-TO-AAF DEPARTURES (by AAF division): MEESE INSTITUTE (Legal): John Malcolm (VP, fmr Heritage VP Institute for Constitutional Government), Hans von Spakovsky (Senior Legal Fellow, fmr Heritage Election Law Reform Initiative Manager), Tom Jipping (Senior Legal Fellow), Paul Larkin (Senior Legal Fellow), Amy Swearer (Senior Legal Fellow), Jessica Reinsch (Dir of Programs), Jenna Hageman (Program Associate), Meaghen McManus (Program Associate). PLYMOUTH INSTITUTE (Economic): Richard Stern (VP, fmr Heritage acting dir Roe Institute), Joel Griffith (Senior Fellow), Rachel Greszler (Senior Research Fellow), David Burton (Senior Research Fellow), Andrew Hale (Fellow, joined Jan 2026), Preston Brashers (Research Fellow), John Peluso (Policy Analyst), Austin Gae (Policy Analyst). CENTER FOR STATISTICAL MODELING (Data): Kevin Dayaratna (VP, fmr Heritage Chief Statistician), Philip Eigen (Policy Analyst), Gadai Bulgac (Policy Analyst). RESIGNED BUT NOT TO AAF: Cully Stimson (resigned Dec 22, returned to Heritage after holidays), Josh Blackman (resigned). HERITAGE TRUSTEE DEPARTURES: Robby George (Princeton), Shane McCullar, Abby Spencer Moffat (Diana Davis Spencer Foundation CEO). HERITAGE ANTISEMITISM TASK FORCE: 8+ members resigned. TOTAL: 60+ departed Heritage by Jan 2026 per Think Tank Watch.