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PeerBasis
Compensation Comparability Determination

Annapolis Immigration Justice Network Inc

Executive Director / CEO

EIN 832499061
MD · NTEE I80
FY ending 2023-12-31
June 9, 2026

This analysis benchmarks the total compensation of Jessa Coulter, Executive Director / CEO ($52,613) against every comparable organization that fit the selection criteria — 102 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 13th percentile of comparable organizationsbelow the typical range for comparable organizations

Benchmarked executive: Jessa Coulter — reported title “Executive Director from June 2023”, a direct title match to the Executive Director / CEO role.

How comparable organizations were selected

102 organizations qualified on sector, size, and geography 102 within the band form the benchmarked peer set.

Distribution of comparable compensation

$1,270 total compensation of comparable organizations → $348,384 $52,613
$47,24710th
$69,42025th
$87,859Median
$107,50975th
$135,00590th
$52,613This org · 13th
p10$47,247
p25$69,420
p50$87,859
p75$107,509
p90$135,005
$52,613

Comparable organizations

Each figure is Form 990 Part VII columns D + F (reportable pay plus other compensation and benefits; column F may include amounts from related organizations), normalized to MD cost of living (BEA RPP, 2023) and to its filing year (CPI-U); the reported amount is on each linked 990.

OrganizationStateRevenueMatched titleComp
(reported)
Comp
(adjusted)
FY
Choosing Justice Initiative TN$436,697 President $101,093 $110,401 2024
Voices For Children Inc MD$438,297 Executive Director $84,342 $79,811 2025
Open Hands Legal Services Inc NY$443,206 Executive Director $107,981 $104,368 2023
Casa Of Grant County Inc IN$448,126 Executive Director $67,097 $75,684 2023
Arizona Senior Citizens AZ$424,724 Interim Dire $103,514 $103,428 2024
The Liberty Initiative Inc AR$424,640 Executive Di $47,800 $55,822 2024
Innocent MI$452,829 President $88,000 $94,367 2024
Gallia County Defense Attorney Corp OH$420,000 President $122,959 $135,303 2024
Christian Legal Clinics Of Philadelphia PA$455,121 Executive Director $92,475 $95,810 2024
South Alabama Volunteer Lawyers Program AL$455,874 Executive Director $70,449 $81,408 2023
Inner Banks Legal Services NC$417,113 Excutive Dir $61,439 $65,954 2024
Energy & Mineral Law Foundation KY$458,300 Executive Director $143,586 $160,271 2024
A Legacy Of Equality Leadership And Organizing WA$415,878 Executive Director $84,075 $78,204 2024
University Student Legal Services NC$459,750 Attorney $128,596 $142,125 2023
Miracle Of Innocence Inc KS$413,890 President $45,000 $50,508 2024
Triple Twelve Ministries Inc KY$461,984 Executive Director $85,231 $92,683 2025
Restoring Justice TX$464,811 Ceo $122,405 $127,211 2024
Volunteer Lawyer Program Of Northeast IN$409,557 Executive Dir. $84,500 $92,580 2024
People With Disabilities Foundation CA$409,253 President & $91,826 $84,813 2023
All For The Family Legal Clinic Inc CA$466,149 Managing Attorney Ceo $94,246 $84,550 2024
Legal Assistance Center MI$406,111 Executive Di $100,570 $107,848 2024
Steen Mountain Defenders OR$471,908 Ex Director $95,046 $91,702 2024
Access The Law OR$472,403 Excutive Director $113,377 $112,619 2023
Ventura County Legal Aid Inc CA$400,550 Director $70,050 $62,843 2024
Software Freedom Law Center Inc NY$478,107 Pres, Exec Dir, & Chairman $61,584 $56,325 2025

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to MD cost of living and 2023 dollars. Click any organization to verify the figure on ProPublica.

Methodology

Comparable organizations were drawn from electronically filed IRS Form 990 returns and matched on sector (NTEE code), budget (a size-adaptive revenue band that tightens as the organization grows), and geography (same-state first, broadening only when too few peers qualify); every organization within the band forms the peer set. To compare fairly across regions and years, peer compensation is normalized to MD cost of living (BEA Regional Price Parities, 2023) and to the subject's filing year (CPI-U). The figure benchmarked is Form 990 Part VII, Section A, columns D + F — reportable pay plus other compensation, benefits, and deferred amounts (column F may include amounts from related organizations) — with the chief executive matched by role. Related-organization amounts (column E) and institutional trustees are excluded. Full methodology: peerbasis.org/methodology.

Sample, role match & sensitivity

Sensitivity — the subject's percentile under alternative compensation definitions:

BasisSubject percentile
Total compensation (D + F), cost-of-living + inflation adjusted — the PeerBasis default13th
Total compensation (D + F), as reported (no adjustments)14th
Reportable pay only (column D), adjusted11th
All sources (D + E + F), adjusted9th

If the percentile moves materially across these definitions, the result is sensitive to methodology choices, and the board should weigh which basis best fits its facts.

Rebuttable presumption of reasonableness · 26 CFR 53.4958-6

Compensation paid by a tax-exempt organization is presumed reasonable — shifting the burden to the IRS — when three requirements are met. This report supplies the comparability data for the second. The board should record the following in its minutes concurrently with its decision:

Draft board minutes — executive compensation

  1. The compensation of the Executive Director / CEO (Jessa Coulter) was approved in advance by [the Board / Compensation Committee], composed of members with no conflict of interest with respect to the arrangement.
  2. Prior to its determination, the authorized body obtained and relied upon appropriate comparability data, namely the PeerBasis Compensation Comparability Determination dated June 9, 2026, comparing compensation against 102 similarly situated organizations (Same NTEE sector (I80), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $52,613 is reasonable (approximately the 13th percentile of comparable organizations) and documented the basis for this determination concurrently, on [date], by a vote of [__ for / __ against].

Sources: IRS Form 990 e-file data (apps.irs.gov); IRS Business Master File (NTEE classification). Every figure traces to an original public filing — click any organization above to verify it on ProPublica. PeerBasis is a service of Prismind Analytics; its methodology is published, was commissioned for independent adversarial review, and discloses its own limitations. This report is comparability data to support a board's good-faith determination under IRC 4958; it is not legal or tax advice. Generated by PeerBasis on June 9, 2026.