This project, In the Sheriff We Trust, was produced by the Howard Center for Investigative Journalism, in collaboration with the Arizona Center for Investigative Reporting. The Howard Center is based at Arizona State University’s Walter Cronkite School of Journalism and Mass Communication and is an initiative of the Scripps Howard Fund in honor of the late news industry executive and pioneer Roy W. Howard. AZCIR is an independent, nonpartisan, nonprofit newsroom dedicated to statewide, data-driven investigative reporting.
It’s about finding fun and easy ways for the public to be civically engaged, Sue Frost says in the video describing her nonprofit, the Gorilla Learning Institute. It’s about strength through knowledge so that busy families can “advocate lawfully and professionally and peacefully.”
Standing in a navy blue blazer and red top against a light backdrop, the Sacramento politician stars in her own YouTube video about the group. Its name, she explains, is a reference to both the gorilla as a peaceful, powerful and highly intelligent animal ready to fight if threatened and “guerrilla” fighters who “use creative tactics” to get the job done.
The Gorilla Learning Institute uses its tax-exempt status to help fund other groups’ activities, including the Friends of CSPOA, a California chapter of the Constitutional Sheriffs and Peace Officers Association. That national organization trains law enforcement officers on the idea that sheriffs’ constitutional authority supersedes that of the federal government.
The Southern Poverty Law Center, a national civil rights nonprofit that monitors extremist movements in the U.S., has identified both the sheriffs group and the Gorilla Learning Institute as being “part of the antidemocratic hard-right movement.”
The relationship between the Gorilla Learning Institute – which operates out of the home Frost shares with her husband Jack – and “Friends of CSPOA” was spelled out on the group’s website as of late May, according to an investigation by the Howard Center for Investigative Journalism and the Arizona Center for Investigative Reporting.
“‘Friends of CSPOA’ was recently approved to operate their educational program under Gorilla Learning Institute’s Re-Grant Program allowing fundraising and even registrations to be tax deductible under Gorilla Learning Institute’s 501(c) 3 non profit,” the institute’s website said. It directed all inquiries on “how you can JOIN OUR EFFORTS” to Jack Frost. He is identified as both the secretary of the institute and the co-founder of the Friends of CSPOA.
Sue Frost, a member of the Sacramento County Board of Supervisors and the institute’s chief executive officer, said CSPOA supporters approached the Gorilla Learning Institute about creating the “Friends of CSPOA” as the educational arm of the national sheriffs group.
“They brought their educational arm under the Friends of CSPOA application, and our board approved it,” Frost said. “And so they began, we began that effort to spread the word and get people in every single county to study the Constitution.”
While the sheriffs group’s efforts to educate law enforcement officers about the alleged supremacy of sheriffs’ power have spread nationally, the public would have little way of knowing about its ties to the Gorilla Learning Institute without combing through past financial documents, submitting public records requests to government agencies and scouring internet archives.
The Gorilla Learning Institute received its federal and state nonprofit status in 2021. As a 501(c)(3) nonprofit, it is required to submit documents to the IRS about its financial earnings, donations and other activities. The IRS allows nonprofits to file a simplified return, called a 990-EZ, if the organization has gross income under $200,000 and assets below $500,000.
The Gorilla Learning Institute’s 990-EZ for 2021 – the only year available – shows income of about $112,000, which appears to have come from a 2021 event it hosted, and roughly $99,000 in expenses, reported as being related to conferences and meeting expenses.
The 990-EZ form also lists the Gorilla Institute as operating out of a home on Taurus Court in Citrus Heights, California, which belonged to Frost’s parents and was handed down to her through a trust in 2015, according to the Sacramento County Recorder’s office.
Frost, who was elected to the county’s Board of Supervisors in 2016 after serving as Citrus Heights’ mayor in 2015, must file statements of economic interest with the Fair Political Practice Commission, an independent, nonpartisan body that regulates campaign finances, conflicts of interest, lobbying and governmental ethics.
The statements, commonly referred to as Form 700, are supposed to reveal a candidate’s business entities, trusts, donations, assets and property or anything that could pose a potential conflict of interest.
In her 2021 disclosure, filed in March 2022, Frost listed a consulting firm called Frost Enterprises at the Taurus Court address. From 2017, when Frost assumed office, to 2021, she listed Frost Enterprises at that address and said it was valued between $100,000 and $1 million.
Records show that Frost did not disclose in her most recent filings any ownership in businesses or trusts for 2021 that were filed in 2022, a year after the Gorilla Institute received its state nonprofit status.
Frost has never listed the Gorilla Learning Institute on any of her financial disclosures, a review of her forms showed.
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“We’re not required to list our personal business on our Form 700,” Frost said in an interview. “I guess my understanding is you wouldn’t have to report a nonprofit; I don’t really own the nonprofit.”
Jay Wierenga, communication director for the Fair Political Practices Commission, declined to comment on any specific individual or group. He said politicians typically weren’t required to list their personal home on disclosure forms, though there could be instances when they should do so, such as if they were earning income on the property.
There is also no mention on Frost’s Form 700 of a fundraiser that the Gorilla Institute hosted in 2021, featuring former Sacramento County Sheriff Scott Jones and California Congressman Kevin Kiley, a gubernatorial candidate at the time. According to a flyer for the off-site event, proceeds were meant for citizens coalitions.
After Howard Center reporters began asking questions, the Gorilla Learning Institute website was scrubbed of most references to the national sheriffs group and its California-based Friends of CSPOA.
Previously, the website listed the state chapter as a participant of the re-grant program and included a section of events hosted in partnership with the Freedom Coalition, a far-right group that has paired with Friends of CSPOA to offer citizen training.
It also included a page where members of the public could sign up to become “FOCSPOA county leaders.”
Jack Frost said in a late July interview that because of poor health he was no longer affiliated with the sheriffs group. In early August, Sue Frost announced unexpectedly that she would not seek re-election to the Board of Supervisors.
Friends of CSPOA
In 2021, Jack Frost emailed the California Commission on Peace Officers Standards and Training about getting the founder of the national constitutional sheriffs group, Richard Mack, the required certification needed to teach a class for state law enforcement officers.
A public records request to the California commission yielded more than 140 pages of emails showing how Frost corresponded with the state agency after the sheriffs group initially tried and failed to get Mack approved.
The emails show that Frost was also unsuccessful. However, he was told by one state official that the best way to reach his goal would be to partner with any law enforcement agency. Only then, the emails read, could Mack be a speaker for the training. It is not clear from the records whether Mack later participated in a law enforcement training.
During a November 2022 meeting of board members and state leaders, including Frost, the sheriffs’ group discussed the possibility of establishing private grant-funded training in other states.
This sponsorship of the “Friends of CSPOA” training would seem to conflict with Gorilla Learning Institute’s state nonprofit status.
According to the organization’s articles of incorporation filed with the California Secretary of State, “no substantial part of the activities” of the Gorilla Learning Institute “shall be the carrying on of propaganda or otherwise attempting to influence legislation.”
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Sue Frost said the constitutional sheriffs’ political agenda was not part of the Gorilla Institute’s re-grant educational program. But she acknowledged that the institute had hosted “a couple of educational events” taught by Mack.
“Those were educational events where people could come and learn the history of the sheriff and the Constitution, and so we rationalized in our mind that those were, fell under our mission of education,” she said.
“Gorilla wasn’t involved or really part of the political side of it, or the activism side of it,” Frost said. “I guess it’s activism to try and get someone to learn the Constitution, but that’s our mission.”
According to the website of the California Attorney General, the Gorilla Learning Institute is delinquent on the necessary paperwork to legally operate in the state.
Kelly Lawler, the Gorilla Institute’s treasurer, said the group had not filed the required forms because the person contracted to handle those filings died suddenly.
“I had to contract with someone new to help us with those forms,” Lawler said. “It’s not like we’re hiding anything. It’s just more procedural,” said Lawler, who has been cited several times by the California Fair Political Practices Commission for failing to report campaign donations and expenditures for other groups that she independently serves.
The Gorilla Learning Institute is not the only third-party entity in California that has helped the constitutional sheriffs group. Its members and supporters have also benefited from the Claremont Institute, a well-known conservative think tank headquartered in Southern California.
This decades-old, IRS-designated nonprofit is known in part for being the intellectual home of John C. Eastman, the attorney who advised former President Donald Trump on his election challenges. Eastman has been identified as one of the unnamed co-conspirators in the special prosecutor’s federal indictment of the former president and was named in Georgia’s state racketeering indictment against Trump filed in mid-August.
The institute hosts a sheriff fellowship that provides a $1,500 honorarium, up to $700 in travel costs and lodging.
Notable participants in the program have included Michigan Sheriff Dar Leaf, a board member of the national sheriffs group who received a fellowship in 2022; and self-proclaimed constitutional sheriffs Scott Jenkins of Culpeper County, Virginia, and Chad Bianco of Riverside County, California, who were fellows in 2021.
It was unclear whether the sheriffs used personal vacation or taxpayer-funded work hours to attend the weeklong fellowships. Neither Leaf, Bianco nor Jenkins responded to the requests for comment about their fellowships. A message left with the Claremont Institute was not returned.
Howard Center reporter Jimmy Cloutier in Virginia and AZCIR reporter Isaac Stone Simonelli contributed to this story.
This project was produced by the Howard Center for Investigative Journalism, in collaboration with the Arizona Center for Investigative Reporting. The Howard Center is based at Arizona State University’s Walter Cronkite School of Journalism and Mass Communication and is an initiative of the Scripps Howard Fund in honor of the late news industry executive and pioneer Roy W. Howard. AAZCIR is a nonpartisan, nonprofit newsroom that focuses on data-driven investigative journalism.