The Florida Supreme Court has declined to suspend the Florida law license of Kenneth Chesebro, convicted in Georgia of filing a false list of electors there to undermine Joe Biden’s victory in the 2020 presidential election.

Instead, the justices issued a reprimand over the objection of Justice Jorge Labarga, the sole member of the court not appointed by Gov. Ron DeSantis. (Former Gov. Charlie Crist placed him on the Supreme Court in January 2009.)

“In my view, the intentional commission of fraud upon the court is one of the most egregious ethical transgressions a lawyer can commit, and such serious misconduct necessitates the imposition of severe professional sanctions,” Labarga wrote.

Labarga said a written reprimand is “disproportionate to the severity of Chesebro’s grave ethical violations” and called Chesebro’s actions “an intolerable breach of professional ethics.” 

Chesebro was a key figure in the plot to submit fraudulent certificates claiming that Trump won the battleground states of Arizona, Georgia, Michigan, New Mexico, Nevada, Pennsylvania, and Wisconsin, instead of Biden.

He was among 77 people pardoned by Trump for any federal crimes shortly after Trump resumed office. The pardon would not preclude any state charges.

Chesebro pleaded guilty in October 2023 in Fulton County, Ga., Superior Court to a felony charge of conspiracy to commit filing false documents for his role in the fake electors plan, Phoenix affiliate Georgia Recorder has reported. He was sentenced to five years’ probation.

“However, because the conviction was entered pursuant to Georgia’s First Offender Act, and Chesebro’s probation was later terminated early, he was ultimately ‘exonerated of guilt’ and now ‘stand[s] discharged as a matter of law.’ Indeed, upon entering a consent order terminating probation, the Georgia trial court declared that Chesebro ‘shall not be considered to have ever had a criminal conviction,’” Florida’s high court noted.

‘Unique’

The unsigned majority opinion said the court was “bound to respect the judgments of sister states under principles of comity.”

However,  “we must fashion a remedy appropriate to the unique facts of this case and, after careful deliberation, find that a reprimand is appropriate,” the opinion says. “Suspension or a more serious sanction would have been fitting had Chesebro not been exonerated under the distinct circumstance presented here; Chesebro’s full discharge under the Georgia First Offender Act, however, is a fact we do not ignore.”

Florida’s attorney ethics standards hold a reprimand appropriate “when a lawyer negligently engages in conduct that is a violation of a duty owed as a professional and causes injury or potential injury to a client, the public, or the legal system,” Labarga wrote.

“Because the discharge of Chesebro’s conviction pursuant to Georgia’s First Offender Act does not undo his admitted act of misconduct, I disagree with the majority’s conclusion that suspension is inappropriate,” he concluded.

This article was originally published by Votebeat, a nonprofit news organization covering local election administration and voting access.

The FBI agents arrived at David Bolter’s Milwaukee home on a cool, cloudy Wednesday morning in late May. They were armed with a list of questions for the 2020 poll worker, who had raised concerns about the way local officials handled the 2020 election, Bolter told Votebeat.

President Donald Trump relied on Bolter’s claims in an unsuccessful 2020 lawsuit that sought to throw out more than 220,000 votes. That would have been more than enough to move Wisconsin’s 10 electoral votes from Democrat Joe Biden, who won the state, to Trump. Though courts, several election reviews, and many audits rejected Trump’s claims, the Republican never stopped believing that he was cheated out of the presidency in 2020.

That appears to be why, last month, the FBI sent agents back to Milwaukee to question Bolter as part of an expanding national effort by the second Trump administration to investigate long-debunked claims of fraud in the 2020 election.

The investigation into the 2020 election appears to be relying on already disproven allegations from people like Bolter. Bolter declined to divulge more about his conversation with the FBI, which has not been previously reported, but allegations from Bolter’s 2020 affidavit were central to some conspiracy theories about the 2020 election. For example, he alleged that somebody in Milwaukee’s absentee ballot counting facility announced around midnight on Election Day that a “huge truckload of ballots” was going to be delivered — an accusation for which there has so far appeared to be no additional evidence.

Around the same time Bolter says he talked to the FBI, two plainclothes agents with FBI badges showed up at the apartment of a former Milwaukee resident and 2020 poll worker about an affidavit she submitted, according to the former poll worker, who asked to be identified only by her first name, Christine, to give her the freedom to discuss an ongoing investigation.

Christine had also submitted an affidavit about the 2020 election, saying election workers had been told that all votes were counted, but she then saw workers continuing to count ballots around midnight. That affidavit was the focus of the agents’ questions, Christine told Votebeat.

“I suspected wrongdoing, but I’m not saying that it actually happened,” she said. “I’m just one lowly person that was working there.”

During the interview, she added, an agent showed her a photograph of Claire Woodall, the former Milwaukee election chief, asking her if she recognized the former election official who has been central to false allegations about the 2020 election. She identified her by name. Woodall didn’t respond to a request for comment.

Caroline Clancy, a spokesperson for the FBI’s Milwaukee office, declined to comment.

While investigators seem mainly focused on the 2020 vote, some elections experts believe the Trump administration’s wide-ranging probe is actually designed to create more doubts among Americans about future elections, as Republicans face strong political headwinds that could cost them control of Congress later this year.

“This isn’t about the 2020 election, this is about the 2026 and 2028 elections,” said David Becker, executive director of the nonpartisan, nonprofit Center for Election Innovation and Research. “This is about intimidating election officials. This is about creating a stream of disinformation designed to delegitimize an election the president may believe he’s going to lose. This is designed by the president’s underlings to satisfy the unrealistic expectations of a president that still cannot comprehend that he lost an election that he definitely lost, and it’s incredibly destabilizing.”

Wisconsin is the latest known target of the Trump administration’s 2020 investigation. The FBI is looking to interview elections officials and Milwaukee police officers in what some worry could be a precursor to an effort to seize ballots from the 2020 presidential race, as it already has in Georgia.

The Trump administration is revisiting allegations of election fraud that have been repeatedly scrutinized

In January, federal investigators seized 600 boxes of ballots from the 2020 election in Fulton County, Georgia. The heavily Democratic county, home to Atlanta, was key to Biden’s narrow 2020 victory in the state.

As in Wisconsin, the FBI in Georgia has built its investigation on allegations that have already been repeatedly scrutinized by audits, investigations, and courts without unearthing any evidence of fraud or tampering that could have overturned the results.

The Georgia search represented an unprecedented intervention by the federal government into local administration. Even more unusually, Tulsi Gabbard, who will step down at end of this month as director of national intelligence, personally oversaw the seizure and arranged for Trump to speak directly to the FBI agents via cell phone after they carried out the operation.

The Trump administration investigations stretch from Arizona, where federal officials subpoenaed computerized records of a partisan review state lawmakers conducted of Maricopa County’s 2020 election, to Puerto Rico, where the Office of the Director of National Intelligence procured voting machines to examine for potential security risks.

The administration’s investigations aren’t entirely limited to 2020. The U.S. Department of Justice sent a letter in April to Wayne County, Michigan — home to Detroit — demanding all ballots cast in the 2024 election, which Trump won. But even in that case, to support the request, the Justice Department cited accusations of fraud made after the 2020 election, including a lawsuit that was quickly dismissed after a judge wrote that “plaintiffs’ interpretation of events is incorrect and not credible.” Wayne County never handed over the ballots, because it doesn’t have possession of them.

What do the 2020 elections mean for 2026?

The FBI faces challenges in pursuing cases tied to the 2020 election since the five-year statute of limitations that applies to most of the likely charges expired last year. Law enforcement veterans said it is possible that the Justice Department could pursue broader conspiracy charges in the case, but the prospect remains unclear.

FBI Director Kash Patel suggested in April that the Justice Department would soon announce arrests related to the 2020 election, but that has not yet occurred. Officials with the FBI and Justice Department did not respond to requests for comment.

John Keller, a former acting head of the Justice Department’s Public Integrity Section who resigned in 2025 after refusing the Trump administration’s demands to drop corruption charges against then-New York City Mayor Eric Adams, said the administration appeared to be trying to normalize federal investigations of state elections to pave the way for future intervention.

“They are using enforcement directed at the 2020 election as a test run for what they can get away with on Election Day this year, or after, to try and delay certification or invalidate an election” if the results don’t go their way, he said.

Injecting federal law enforcement officials into an ongoing election is a more extreme and serious action than investigating a past one, and it could face stiffer opposition. But it’s clear, at least, that the administration is scrutinizing current elections closely.

Trump last week blasted California’s long vote counting process in its primary election and asserted that Democrats were trying to steal the election and federal authorities were investigating. Last month, Trump also said he was ordering the Justice Department to investigate an error that led to some voters in Maryland receiving ballots for the wrong party in the state’s upcoming primary. State officials in both cases have explained the true causes of the issues and that nothing nefarious was behind them.

Any effort to seize ballots in an ongoing election would create unprecedented new issues, such as a breach in the chain of custody over cast ballots, that could prevent election officials from declaring a winner and throw results into uncertainty.

Catherine Engelbrecht, co-founder of the Texas-based conservative group True the Vote, which has promoted debunked theories about the 2020 election, said she understands Trump’s intentions but believes the 2020 election questions should have been resolved “in the immediate aftermath of the 2020 election.”

“This is not necessarily the way I would have recommended that it would be handled,” she said. “The fact that it wasn’t addressed has left this lingering void.”

In most cases, however, Trump’s claims of voter fraud were addressed in the wake of the 2020 election. Time and again, courts, state investigations, and even the Justice Department concluded that there was no evidence of problems or fraud that would have changed the results.

Engelbrecht said she views the Trump administration’s ongoing investigations as an effort to dig into long-standing concerns about the voting process it wants to address for future elections.

“The past is prologue,” she said. “If we don’t understand what happened, we are doomed to repeat it.”

Votebeat is a nonprofit news organization covering local election integrity and voting access. Sign up for their newsletters here.