Did the DNC essentially plead "no contest" to FEC charges in the Steele Dossier?

Question

I'm trying to understand the exact legal implications of this "conciliation agreement" in other potential legal cases (e.g. if the DNC or Clinton were charged in some US state that has lower thresholds for some kinds prosecutions).

After conducting an investigation in this matter, the Commission found probable cause to believe that the DNC violated 52 U.S.C. § 30104(b)(5)(A) and (b)(6)(B)(v) and 11 C.F.R. § 104.3(b)(3)(i). The Commission further found probable cause to believe that HFA violated 52 U.S.C. § 30104(b)(5)(A) and 11 C.F.R. § 104.3(b)(4)(i). On February 17, 2022, signed conciliation agreements with the DNC and HFA were accepted by the Commission. Accordingly, the Commission closed the file in this matter on March 25, 2022. Documents related to the case will be placed on the public record within 30 days.

According to CNN's way of relating that:

The Clinton campaign and the DNC never conceded that they violated campaign finance laws, but they agreed to drop their pushback and accept the civil fines, according to the FEC letter.

Did the DNC essentially plead "no contest" there? Does it imply it can't be used as an admission in potentially any other cases?

unlike a guilty plea, a defendant in a nolo contendere plea may not be required to allocute the charges. This means that a nolo contendere conviction typically may not be used to establish either negligence per se, malice, or whether the acts were committed at all in later civil proceedings related to the same set of facts as the criminal prosecution.

Does that implication hold for such agreements [to pay a fine] with FEC in general, and in this case in particular?

Or as a more direct question (as suggested in a comment, since "no contest" might not technically apply to civil fines): can paying that fine be used as evidence of anything in some other putative trial?

Answer 1

In US civil law, the mere fact that someone settled a claim that they were liable for some conduct X, is not admissible as evidence that they actually did X.

See Federal Rule of Evidence 408, "Compromise Offers and Negotiations":

(a) Prohibited Uses. Evidence of the following is not admissible — on behalf of any party — either to prove or disprove the validity or amount of a disputed claim or to impeach by a prior inconsistent statement or a contradiction:

(1) furnishing, promising, or offering — or accepting, promising to accept, or offering to accept — a valuable consideration in compromising or attempting to compromise the claim; and

(2) conduct or a statement made during compromise negotiations about the claim — except when offered in a criminal case and when the negotiations related to a claim by a public office in the exercise of its regulatory, investigative, or enforcement authority.

(b) Exceptions. The court may admit this evidence for another purpose, such as proving a witness’s bias or prejudice, negating a contention of undue delay, or proving an effort to obstruct a criminal investigation or prosecution.

If part of the settlement is to actually admit that they did do X, then I assume that statement would be admissible. But in this case, the conciliation agreements (which you linked at the beginning of your question) very explicitly say that the DNC does not admit having done anything wrong. See paragraph VI of each one: "Solely for the purpose of settling this matter expeditiously and to avoid further legal costs, Respondent does not concede, but will not further contest the Commission's finding of probable cause to believe."

So I don't see any way that these agreements could be used as evidence that they did anything illegal.