National & Minnesota
August 26, 2026
VIA EMAIL ONLY
Shawn Towle
Address Redacted
s.towle@checksandbalances.com
VIA EMAIL ONLY
Mike Lindell
lorileebp@gmail.com
VIA US MAIL & EMAIL
Phillip C Parrish
PO Box 132
Faribault, MN 55021
phillip@parrish4mn.com
VIA EMAIL ONLY
Lorilee Peterson
lorileebp@gmail.com
Re: In the Matter of Shawn Towle (Mike Lindell, Phillip C. Parrish, Lorilee
Peterson)
CAH 28-0320-42006
Dear Parties:
Enclosed and served upon you please find the NOTICE OF DETERMINATION
OF PRIMA FACIE VIOLATION AND ORDER FOR PREHEARING CONFERENCE in
the above-entitled matter.
If you have any questions, please contact me at (651) 361-7857,
nichole.sletten@state.mn.us, or via facsimile at (651) 539-0310.
Sincerely,
NICHOLE SLETTEN
Legal Assistant
Enclosure
cc: Docket Coordinator
CAH 28-0320-42006
STATE OF MINNESOTA
COURT OF ADMINISTRATIVE HEARINGS
Shawn Towle,
Complainant,
v.
Mike Lindell, Phillip C. Parrish, and
Lorilee Peterson,
Respondents.
NOTICE OF DETERMINATION OF
PRIMA FACIE VIOLATION AND
ORDER FOR PREHEARING
CONFERENCE
On August 21, 2026, Shawn Towle (Complainant) filed a Fair Campaign Practices
Complaint (Complaint) with the Court of Administrative Hearings.1 The Complaint alleges
that Mike Lindell, Phillip C. Parrish, and Lorilee Peterson (collectively, Respondents)
violated Minn. Stat. § 211B.13 (2026) of the Fair Campaign Practices Act2 by distributing
pillows during an event that contained campaign-related flyers in the packaging. The
Chief Administrative Law Judge assigned the matter to Administrative Law Judge
Joseph C. Meyer on August 21, 2026.
After reviewing the Complaint, the Complaint sets forth a prima facie violation of
Minn. Stat. § 211B.13 as to Respondent Lindell. For the reasons detailed in the
Memorandum below, this matter will proceed to a telephone prehearing conference and,
if necessary, an evidentiary hearing before a panel of three administrative law judges.3
The Administrative Law Judge will hold the prehearing conference to discuss procedures
and set a date for further proceedings.
Based upon the Complaint and the supporting filings, and for the reasons set out
in the accompanying Memorandum, the Administrative Law Judge now hereby issues the
following:
1 Complainant filed the Complaint, along with an Affidavit for Waiver of Filing Fee for Campaign Complaint,
on August 18, 2026. Complainant filed an amendment to the Complaint on August 20, 2026. The filing of
the Complaint was deemed complete upon issuance of the Order Waiving Filing Fee on August 21, 2026.
2 Minn. Stat. §§ 211A.01-.14, 211B.01-.37 (2026).
3 Chapter 211B provides two possible timelines for resolution of a fair Campaign Practices Act complaint.
If the election “to which the complaint relates” is withing 60 days for a primary or 90 days for a general
election, the judge must conduct an expedited probable cause hearing. Minn. Stat. § 211B.33, subd. 2(b).
If the election “to which the complaint relates” is not within 60 or 90 days, then the matter proceeds directly
to an evidentiary hearing. Minn. Stat. § 211B.33, subd. 2(c). Here, the conduct alleged proceeded the
August 11 primary, the campaign at the time concerned the primary election, and the Complaint itself notes
that the alleged violation concerned the primary election. Complaint at 5. Accordingly, the election to which
the complaint relates is the August 11 primary. As that election has passed, the matter will proceed directly
to evidentiary hearing under Minn. Stat. § 211B.35.
[243536/1] 2
ORDER
1. Respondents Parrish and Peterson are DISMISSED as parties from this
proceeding.
2. The remaining parties shall attend a prehearing conference before Judge
Meyer at 10:00 a.m. on September 4, 2026. The prehearing conference will be held by
telephone, and the parties must call in for the conference. At the appointed time, the
parties are directed to do the following:
(a) Dial telephone number 1 651-395-7448, and, when prompted,
(b) Enter the Conference Code 826 031 471#.
3. At the prehearing conference, preliminary matters will be addressed such
as identifying the issues to be resolved, the number of potential witnesses and exhibits,
a date for the hearing, and determining whether the matter may be disposed of without
an evidentiary hearing.
4. Accommodations Under the Americans with Disabilities Act. The
parties shall notify the Court of Administrative Hearings in writing as soon as possible if
any additional accommodation is needed. To request an accommodation, the requesting
party shall complete and submit this form: https://mn.gov/oah/lawyers-and-litigants/titleii.jsp. To request the form in paper format, please call 651-361-7900.
5. Interpreters. The parties have not requested the appointment of an
interpreter. To request an interpreter, please email oah.courtpersonnel@state.mn.us or
call 651-361-7900.
Dated: August 26, 2026
JOSEPH C. MEYER
Administrative Law Judge
[243536/1] 3
MEMORANDUM
Mike Lindell (Respondent Lindell) was a candidate for Governor of Minnesota in
the primary election held on August 11, 2026.4 Phillip C. Parrish (Respondent Parrish)
was Lindell’s running mate and candidate for lieutenant governor.5 Lorilee Peterson
(Respondent Peterson) served as the campaign treasurer for the Lindell for Governor
committee.
6 The Complaint alleges that on July 4, 2026, Complainant observed Respondent
Lindell and other unidentified individuals throw pillows to an “assembled throng” in
Delano, Minnesota.
7 The Complaint alleges the packaging of the pillows contained
campaign materials for Respondents, and many individuals gathered around Respondent
Lindell were carrying campaign signs.
8 The Complaint alleges that the pillows were items
of monetary value purchased by Respondent Lindell’s campaign.
9 The Complaint also
alleges that “a committee had authorized the purchases.”
10 Complainant asserts the
distribution of pillows at the parade constitutes a violation of Minn. Stat. § 211B.13.11
Complainant filed the Complaint with the Court of Administrative Hearings effective
August 21, 2026.12
I. Standard for Prima Facie Determinations
To establish a prima facie violation of the Fair Campaign Practices Act, a
complainant must allege sufficient facts to support a claim that a violation of law has
occurred.13 The complaining party must submit evidence or allege facts that, if accepted
as true, would be sufficient to prove a violation of Minn. Stat. §§ 211A.01-.14, 211B.01-.37
(2026).14
For purposes of a prima facie determination, the Court must accept the facts that
are alleged in the Complaint as true, without independent substantiation.
15 In determining
4 Campaign Complaint (Complaint) at 2.
5 Complaint at 2.
6 Complaint at 2.
7 Complaint at 4.
8 Complaint at 4.
9 Complaint at 5.
10 Complaint at 5.
11 Complaint at 5.
12 The Complaint contains what appear to be links to additional material that Complainant intended to have
incorporated into their factual allegations. The Complaint was hand-delivered, so the links cannot be
accessed directly by the Court. Further, the links mostly do not include URLs. Accordingly, the Court cannot
access the linked material and, without opining on whether it would have been procedurally proper to do
so, was unable to consider the linked material in making its prima facie determination. However, in a posture
where all factual allegations in the Complaint are presumed true, the Court does accept as true any
assertions as to what the linked material shows to the extent it can be discerned from the text of the
Complaint.
13 Minn. Stat. § 211B.32, subd. 3.
14 Barry v. St. Anthony-New Brighton Indep. Sch. Dist. 282, 781 N.W.2d 898, 902 (Minn. Ct. App. 2010).
15 Id.[243536/1] 4
whether a complaint alleges sufficient facts to state a prima facie case, reasonable
inferences must be drawn in the light most favorable to the Complainant.16
A complaint must be dismissed if it does not include evidence or allege facts that,
if accepted as true, would be sufficient to prove a violation of Minn. Stat. §§ 211A.01-.14,
211B.01-.37.
17 II. Analysis
Minn. Stat. § 211B.13, subd. 1 reads as follows:
A person who willfully, directly or indirectly, advances, pays, gives,
promises, or lends any money, food, liquor, clothing, entertainment, or other
thing of monetary value, or who offers, promises, or endeavors to obtain
any money, position, appointment, employment, or other valuable
consideration, to or for a person, in order to induce a voter to refrain from
voting, or to vote in a particular way, at an election, is guilty of a felony. This
section does not prevent a candidate from stating publicly preference for or
support of another candidate to be voted for at the same primary or election.
Refreshments of food or nonalcoholic beverages having a value up to $5
consumed on the premises at a private gathering or public meeting are not
prohibited under this section.
This provision prohibits giving, or promising, anything of monetary value, except
refreshments having a value up to $5, to a person to induce or deter voting in a particular
way in an election.
The Complaint alleges that Respondent Lindell intentionally distributed pillows
containing campaign flyers at a campaign event.
18 The Complaint alleges the purpose of
this event, and the pillows, was to promote Respondents’ campaign for Governor by
inducing voters to vote for Respondents Lindell and Parrish.
19 The Complaint further alleges that the pillows are items of monetary value.
20Taking the allegations in the Complaint as true, as required at this stage of review,
the Complaint sets forth a prima facie violation of Minn. Stat. § 211B.13, subd. 1 with
respect to Respondent Lindell, who is alleged to have distributed the pillows personally.
16 Abrahamson v. St. Louis Cty. Sch. Dist., 819 N.W.2d 129, 136 (Minn. 2012).
17 Barry, 781 N.W.2d at 902.
18 Complaint at 4–5.
19 Complaint at 4.
20 Complaint at 5. The Complaint does allege Respondent Lindell asserted that “a committee had authorized
the purchase.” Complaint at 5. Even charitably reading this allegation as implying that Respondent Lindell’s
campaign committee authorized the purchases, the Complaint lacks specific allegations as to actions by
Respondents Parrish and Peterson as individuals. This determination should not be read as implying that
authorizing the purchase of material to be given away in violation of Minn. Stat. § 211B.13, subd. 1 would
not amount to a violation of the statute.
[243536/1]
5 The Complaint does not, however, allege sufficient facts to establish a prima facie
violation against Respondents Parrish or Peterson. The Complaint alleges that “a
committee” authorized the purchase of the pillows,21 but does not allege any members of
that committee. The Complaint refers to Respondent Parrish having given testimony in a
previous proceeding,22 but does not allege Respondent Parrish distributed, authorized,
or in any way was directly or indirectly responsible for the alleged violation.
The Complaint’s recitation of factual allegations contains no mention whatsoever
of Respondent Peterson by name, and refers to her title only in a conclusory assertion
that Complainant “named all three parties, of whom I understand have potential legal
liabilities, the named candidates and the campaign treasurer.”23 Unlike factual allegations,
which are presumed true for the purposes of a prima facie review, legal assertions as to
who has responsibility for an alleged violation are entitled to no deference in this analysis.
Absent specific facts which, if true, would establish a violation by either Respondents
Parrish or Peterson, the Complaint does not establish a prima facie violation as to those
two individuals.
III. Conclusion
Because the Complaint alleges no specific wrongdoing by Respondents Parrish
and Peterson, those individuals are DISMISSED as parties from this proceeding.
Accepting the facts alleged in the Complaint as true, Complainant has set forth a prima
facie violation of Minn. Stat. § 211B.13 with respect to Respondent Lindell. Accordingly,
this matter will proceed to a prehearing telephone conference to schedule an evidentiary
hearing and discuss(sp) related procedural matters.
J. C. M.
21 Complaint at 5.
22 Complaint at 4–5.
23 Complaint at 5.