Tennessee has a rule about this, and the rule is not complicated: money Marsha Blackburn raised for her U.S. Senate seat cannot be spent on her campaign for governor. Different race, different rules, different pot of money.
New campaign finance filings, reported by Adam Friedman at the Tennessee Lookout, show what happened to that money instead.
On May 8, 2026, Blackburn's Senate campaign donated $4.8 million to the Club for Growth Action PAC. That nearly emptied the account.
Between June and July, a Club for Growth affiliate called the School Freedom Fund transferred $4.81 million to a Tennessee state PAC called the Tennessee Freedom Fund. The Tennessee Freedom Fund has been buying TV ads praising Blackburn and attacking her Republican opponent, U.S. Rep. John Rose.
Out: $4.8 million. Back in: $4.81 million.
"Hard to ignore the obvious connection"
That's Brendan Glavin, director of insights at OpenSecrets, the nonpartisan group that tracks political money. He told the Lookout the layering makes the cash supporting Blackburn look like it's "technically coming from another source."
"It clearly reads as a workaround to get her remaining federal campaign war funds into the state race."
Here's the part that makes the connection hard to dismiss. Three of the PACs in this chain — Club for Growth Action, the School Freedom Fund, and the Tennessee Freedom Fund — all list the same treasurer and are registered to the same Washington, D.C., address. That address is Club for Growth's office. The Tennessee Freedom Fund and Club for Growth Action list the same two officers: Club for Growth CEO David McIntosh and CFO Adam Rozansky.
The Tennessee Freedom Fund didn't exist a year ago. It was formed on February 10, 2026 — six months before the primary.
The Lookout sent Blackburn's campaign manager, Abigail Sigler, specific questions about the transactions. She didn't answer any of them. Club for Growth said someone would get back to the paper. Nobody did.
The billionaire at the end of the chain
The money didn't originate with Club for Growth either. Its primary funder — and the primary funder of the School Freedom Fund — is billionaire Jeff Yass, a Wall Street investor who has been writing Blackburn checks since her very first congressional campaign in 2002.
We've written before about what Yass and Club for Growth want for their money: expanding Tennessee's private-school voucher program, which pulls public dollars out of the schools that serve almost every child in this state and hands them to private schools that get to pick who they admit. Among the top Republicans running for governor, Blackburn is the only one fully behind that expansion.
So the $4.8 million round trip isn't an accounting curiosity. It's the mechanism by which a voucher billionaire's money — parked in a federal Senate account Tennessee law says can't touch this race — arrives in this race anyway.
Nothing here is technically illegal. That's the point.
Federal law doesn't prohibit a Senate campaign from donating to a super PAC. Super PACs can raise and spend unlimited money as long as they don't coordinate with the campaign they're helping. Each individual step in this chain is legal on its own.
What Tennessee law prohibits is Blackburn spending her Senate money on the governor's race directly. She didn't do that. She did something that produced the same result.
And this isn't the first time she's been accused of blurring the line between the two campaigns.
Blackburn began telling people she planned to run for governor in December 2024. She didn't announce until August 2025. In between, FEC records show she kept fundraising and spent $3.2 million out of her Senate account during 2025 — roughly the same pace as during an actual election year, even though her next Senate race wouldn't come until 2030.
Gary Loe, a longtime Knoxville Republican activist, filed a complaint with Tennessee's campaign finance regulator arguing that Senate money paid for ads, staff and travel that helped her run for governor before she was officially a candidate. The state board dismissed it — not because the spending was fine, but because it decided it had no authority: she's allowed to run both accounts, she wasn't officially a gubernatorial candidate yet, and any complaint about federal spending belongs at the FEC.
No FEC complaint has been filed. So nobody has actually looked at it.
Tennessee has prosecuted people for moving money between accounts
This part deserves attention, because Tennessee politicians have gone to prison over the general idea.
Brian Kelsey, a former state senator, moved about $106,000 from his state campaign account through several PACs during his failed 2016 congressional bid. The money ended up at the American Conservative Union, which bought radio ads boosting him. Prosecutors cited the lengths Kelsey went to in order to conceal the money's path as a reason for charging him. He pleaded guilty to two counts of campaign finance violations and served two weeks in prison before Donald Trump pardoned him.
Beth Harwell, a former state House speaker, paid a $16,000 fine after moving $47,000 from two state PACs to a federal super PAC that attacked a primary opponent in her failed 2022 congressional run.
There's a real legal distinction: Kelsey and Harwell moved state money into federal races, which the FEC explicitly bans. Blackburn moved federal money in the direction of a state race, which federal law doesn't ban. She is not accused of a crime, and no regulator has found she broke any rule.
But the shape of the transaction — money leaving one account, passing through affiliated PACs run by the same people at the same address, and landing as ads in the race the law said it couldn't fund — is the same shape prosecutors described in the Kelsey case. The difference is which direction it flowed.
What this says about who she works for
Blackburn wants to be governor of Tennessee. Her campaign for that job is being paid for, in substantial part, by money that Tennessee voters gave her for a completely different job — routed through a Washington, D.C., office that answers to a Pennsylvania billionaire with an agenda for Tennessee's public schools.
She has spent more than two decades in Washington. Her donor list runs through payday lenders, a private prison company, and out-of-state billionaires. Her campaign manager wouldn't answer a single question about where $4.8 million went.
Tennesseans are entitled to a straight answer about who is buying this race. We deserve better.
Source
Adam Friedman, "Blackburn moves $4.8M from US Senate campaign account in apparent legal 'workaround,'" Tennessee Lookout, August 3, 2026, with contributions from Sam Stockard. Photo: John Partipilo / Tennessee Lookout.
