Jail time given in first super-PAC conviction
© Greg Nash

A former congressional campaign manager received a two-year prison sentence on Friday for illegally coordinating spending with a super-PAC, the first prosecution since the Citizen United Supreme Court case spurred the creation of the outside groups.

Tyler Harber, 34, had previously pleaded guilty to charges surrounding the 2012 election. That year, he worked for Chris Perkins, a former Army colonel who lost a challenge to Rep. Gerry ConnollyGerald (Gerry) Edward ConnollyOvernight Defense: Senate confirms Haspel as CIA chief | Trump offers Kim 'protections' if he gives up nukes | Dem amendments target Trump military parade Dem plans amendment to block Trump from using military bases to house undocumented minors separated from parents Politicians, media explode over White House aide's comments MORE (D-Va.).

Court documents do not name the candidate he worked for, but Perkins told news outlets that Harber had worked for him.

Federal prosecutors previously recommended almost four years in prison for Harber, a sentence that they said in a brief would hopefully make it clear that violations would not be tolerated “given the substantial opportunity for coordination crimes that is presented by the vast amounts of political spending.”

“The significant prison sentence imposed on Tyler Harber should cause other political operatives to think twice about circumventing laws that promote transparency in federal elections,” Assistant Attorney General Leslie Caldwell said in a statement.

“As the first conviction for illegal campaign coordination, this case stands as an important step forward in the criminal enforcement of federal campaign finance laws. Illegal campaign coordination can be difficult to detect, which is why we strongly encourage party or campaign insiders to come forward and blow the whistle.”

Harber pleaded guilty in February to a campaign finance charge and to lying to the FBI about his arrangement with Perkins and with a super-PAC that he helped create to support the candidate. In his plea agreement, he admitted to directing that super-PAC to spend $325,000 on attack ads against Connolly despite serving as Perkins’s campaign manager.

The controversial Citizens United decision found that the government can’t place restrictions on the political spending of independent, nonprofit groups, because it is free speech. As long as those groups don’t coordinate with candidates about expenditures, they are free to spend unlimited sums.

A later Supreme Court ruling allowed the outside groups to accept unlimited donations.