to county District Attorney Ismael Ozanne, who referred the matter to special prosecutor Patricia Barrett; Barrett ultimately ruled in late August 2011 that the circumstances and evidence reviewed did not support the filing of criminal charges. On March 16, 2012, the Wisconsin Judicial Commission filed an ethics complaint against Prosser, "recommending that the court discipline him for alleged misconduct", however, three conservative members of the court recused themselves from the matter, with the result that no quorum existed, and no decision could be made. Failure to recuse during "John Doe" probe of Scott Walker Leaked files obtained by the Guardian revealed that a network of dark money groups spent $3.5 million to pay for TV and radio ads backing the judge during his 2011 campaign. According to these leaked emails "The push was seen as vital, the documents disclose, as a means of retaining the rightwing majority of the court and thereby preserving the anti-union measures introduced by Walker. 'If we lose [Justice Prosser], the Walker agenda is toast,' one ally writes in an email sent around to the governor’s chief of staff and several conservative lobbyists." In 2015, a John Doe probe into Scott Walker's funding sources during the 2012 recall campaign against him involved the same set groups that funded Prosser's 2011 campaign. Despite the obvious possible conflicts of interest, Prosser refused to recuse himself, ultimately casting the deciding vote to terminate the probe. Prosser told the Guardian that four years had passed since his re-election before he joined the decision to close the John Doe investigation, over which time any potential conflict of interest had faded. 2011 re-election campaign Prosser faced JoAnne Kloppenburg, a long-time but little-known Wisconsin assistant attorney general, in both the February 5, 2011 spring primary, and the April 5 run-off election. Primary election In December 2010, Prosser's campaign director expressed strong support for governor-elect Walker, saying Prosser's "personal ideology more closely mirrors" Walker's, and that a win by Prosser would result in, "protecting the conservative judicial majority and acting as a common sense complement to both the new administration and Legislature." He later disavowed the statements and claimed he had not seen the release. Prosser's campaign manager also said that, "This election is about a 4-3 commonsense conservative majority vs. a 3-4 liberal majority, and nothing more." In a survey of attorneys conducted by the Milwaukee Bar Association that was published February 2011,