Minnesota Report
STATE OF MINNESOTA
COURT OF ADMINISTRATIVE HEARINGS
PO Box 64620
St. Paul, MN 55164-0620
COMPLAINT FORM
FAIR CAMPAIGN PRACTICES ACT or
CAMPAIGN FINANCIAL REPORTS ACT
Instructions
This form may be used when any person believes a violation of Minnesota election law has occurred or is occurring under the Minnesota Fair Campaign Practices Act and/or the Minnesota Campaign Financial Reports Act (Minnesota Statutes Chapters 211A and 211B). These statutes are available online:
https://www.revisor.leg.state.mn.us/statutes/?id=211A
https://www.revisor.leg.state.mn.us/statutes/?id=211B
The Court of Administrative Hearings does not investigate campaign complaints.
The burden of proving the allegations in this Complaint is on the Complainant. Minn. Stat. § 211B.32, subd. 4.
1. Complainant Information
Name: Shawn Towle
Pronouns (e.g., he/him; she/her; they/them): he/him
Title (e.g., Mr.; Mrs.; Ms.; Mx.): Mr
Address: Redacted
City, State, Zip: Redacted
Phone: Redacted
Email Address: s.towle@checksandBalances.com
2. Information on person(s) or organization(s) against whom the Complaint is brought. Attach additional pages, if needed.
Name: Mike Lindell-Governor Candidate-Mike Lindell for Governor
City, State, Zip: Lindell-(Faribault, MN 55021
Telephone Number: (651) 900-4343
Email Address: lorileebp@gmail.com
Name: Phillip C Parrish-Lt Governor Candidate- Mike Lindell for Governor
City, State, Zip: Parrish-PO Box 132 Faribault, MN 55021
Telephone Number(s): Parrish-(612) 460-1717 & (507) 838-6514
Email Address: phillip@parrish4mn.com
Name: Lorilee Peterson, Treasurer- Mike Lindell for Governor
City, State, Zip: Peterson-Ham Lake, MN 55304
Telephone Number: Peterson-(651) 900-4343
Email Address: lorileebp@gmail.com
3. Violation
Provide the specific statute(s) under Chapter 211A or Chapter 211B you believe were violated.
Statute(s): 211B.13 BRIBERY, TREATING, AND SOLICITATION.
Date(s) of violation(s): June 17, 2026, July 4, 2026 and potentially other dates
Elected office or ballot question: Governor & Lt Governor
Date of election or ballot question: Statewide Primary August 11,2026 & General Election November 3, 2026
If allowed by law, are you requesting an expedited probable cause hearing? Yes
4. Statement of Facts
The Judge must dismiss this Complaint if the Complaint does not show a prima facie violation of the identified statutes occurred. Minn. Stat. § 211B.33, subd. 2. “Prima facie” means that the facts you present, if true, are sufficient to show a violation of law. Minn. Stat. § 211B.32, subd. 3.
State in your own words the detailed facts that support your Complaint. Identify any relevant person(s), include any relevant dates and times, and include the names of other persons who have knowledge of the facts. Attach additional pages and supporting documentation, if any. Do not include original documents.
On July 4, 2026, I personally witnessed the preparation to distribute items of value (pillows) to voters in Delano, Minnesota, and subsequently distribute them by pitching them out from the back of a pick-up truck, led by a Recreational Vehicle (RV) with many pillows stuffed into the back of the RV, in the bed of the pick-up and in a trailer towed by said pick-up.
During the set-up I approached Mr Lindell, because I am the publisher of Minnesota’s first digital political publication Checks & Balances http://checksandbalances.com and engaged him directly. I said, “Do you know you are in violation of the “Twinkie Law?” To which he replied, “I have spoken to the Campaign Finance Board, and my lawyers have dotted all the i’s and crossed all the t’s.” I in turn, jokingly said, I hope it’s not the same lawyers as you used in the Dominion case because, if so, you need to get another team.”
I asked him where he got the pillows from, he explained, “The campaign bought them from my company,” hence he established value.
Then I proceeded to record video of the candidate in action, along with others commence “pitching pillows” to the assembled throng. There was a robust effort to do so, and people gathered to get their own opportunity to catch a pillow. I noticed the plastic bag did contain a piece of paper or flyer, which was campaign related and many people around the pick-up truck were carrying Mike Lindell for Governor signs. Here is the video: Mike Lindell Pitching Pillows. Here are photographs of corroborating information: Lindell Pitching Pillows 1, Lindell Pitching Pillows 2, and Here is the RV.
Because I have been involved in Minnesota politics for over 40-years, have been publishing for more than 30 years during this time, and have written other stories about the “Twinkie Law” being violated, I knew I was standing on comfortable ground.
As I tried to access the situation, I know there were a lot of pillows pitched and having personally watched a similar event on KSTP Channel 5, after the event, and during previous testimony in a Probable Cause hearing, where I was called as the witness, I understood from the testimonies of Mr Lindell, and Mr Phillip C Parrish, there was at least one other occasion.
Additionally, I reviewed the Pre-Primary Campaign Finance Report 2026 Pre-Primary Report, Amendment #1 & Amendment #2 and saw no reflection of any purchases of this type of “Promotional Material”, reflected in the reports. Because of what I do for a profession this struck me as odd, and begs further questions.
- When were the pillows purchased and what is the actual price they were purchased for?
- Because if the pillows were purchased at a high dollar amount like a special-order price, then the candidate could have pocketed the money himself, which may not be ethical, but legality is a question mark.
- If the pillows purchased at a discount, that would be another issue, which is a corporate contribution, which is a separate violation.
- The amount of the purchase price also is a matter of serious concern, because the total value of anything found to be illegal, and the if the amount in question passes a specific threshold and enters into felony consideration.
- The other side produced a receipt, which was dated July 11, 2026, but again it establishes value, but how is it that a purchase after the fact is justified as not being favorable treatment by a corporation and not another benefit to the Mike Lindell Campaign for Governor, which is an additional violation of law?
I have named all three parties, of whom I understand have potential legal liabilities, the named candidates and the campaign treasurer. Again, during the Probable Cause hearing, Mr Parrish, said, a committee had authorized the purchase and others might be implicated as well.
Additionally, the opposing side has repeatedly tried to conflate this issue with another provision in Statute, which has no semblance of relevance and that is the $5,00 provision for “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.”
If the pillows, were even found to be edible, which I believe they are not, this does not even apply. The question is strictly is there a value, and I believe this to be clear and declarative.
Now, in spite of the Mike Lindell Campaign for Governor, having lost the Primary on August 11, 2026, I believe the violation of law is still relevant and hence the reason for this complaint.
Based on my discussions with Mr Lindell, he knowingly and willing committed this violation of Statute(s): 211B.13 BRIBERY, TREATING, AND SOLICITATION. In my opinion, Mr Mike Lindell knew what he was doing and when informed of the illegality of his actions, showed no form of remorse.
I declare under penalty of perjury that everything I have stated in this document is true and correct. Minn. Stat. § 358.116.
Date: 08/17/2026 Complainant Signature: Shawn Towle
County and state where Print Name: Shawn Towle
signed:
Ramsey
Filing Instructions
Send the completed form with a check for $50 made payable to: Court of Administrative Hearings. If you believe you are financially unable to pay the filing fee, you may seek a waiver of the fee by submitting an affidavit for waiver of filing fee (available at https://mn.gov/oah/forms-and-filing/forms/index.jsp) with your completed form instead of a check. The court will consider your request for a fee waiver and issue an order granting or denying your request.
Send your complaint to the Court of Administrative Hearings by personal delivery to 600 North Robert Street, St. Paul, MN 55101, or by U.S. mail to the Court of Administrative Hearings, PO Box 64620, St. Paul, MN 55164-0620.
Complaints are not deemed filed until both the Complaint form and filing fee are received at the Court of Administrative Hearings.
Any person with a disability who needs an accommodation or modification to participate in this hearing process may request one in writing. To request an accommodation pursuant to Title II of the Americans with Disabilities Act, please submit an accommodation request at: https://mn.gov/oah/lawyers-and-litigants/title-ii.jsp. If you cannot complete the electronic form, please call 651-361-7900 and ask to speak with the ADA Coordinator or email accommodations.oah@state.mn.us.
Statement Concerning Data Collection and Usage
The Court of Administrative Hearings will use the data requested in this form to carry out its responsibilities in the Complaint process established under the Minnesota Fair Campaign Practices Act and/or the Minnesota Campaign Finance Act. The court will use this information to initiate proceedings, provide required notice to other parties, and conduct any review and hearing according to statute. If you do not provide the requested information, the court might take additional time to process the Complaint, reject the Complaint as incomplete, or dismiss the Complaint for lack of probable cause.
All records relating to the hearing, including this Complaint, are presumed to be public. If you believe that any data you are submitting is not public under law, please identify which data is protected and why it is not public data under the Minnesota Government Data Practices Act.