U.S. GOVERNMENT PRINTING OFFICE

WASHINGTON : 

1 

49–006 

" ! HOUSE OF REPRESENTATIVES 113TH CONGRESS

2d Session 

REPORT

2014

113–665 

House Calendar No. 153 

IN THE MATTER OF ALLEGATIONS 

RELATING TO REPRESENTATIVE JUDY CHU 

R E P O R T 

OF THE

COMMITTEE ON ETHICS 

DECEMBER 11, 2014.—Referred to the House Calendar and ordered to be 

printed 


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(II) 

COMMITTEE ON ETHICS 

K. MICHAEL CONAWAY, Texas 

Chairman 

CHARLES W. DENT, Pennsylvania 

PATRICK MEEHAN, Pennsylvania 

TREY GOWDY, South Carolina 

SUSAN W. BROOKS, Indiana 

LINDA T. SA ́ NCHEZ, California 

Ranking Member 

PEDRO R. PIERLUISI, Puerto Rico 

MICHAEL E. CAPUANO, Massachusetts 

YVETTE D. CLARKE, New York 

TED DEUTCH, Florida 

REPORT STAFF 

THOMAS A. RUST, Chief Counsel/Staff Director 

DEBORAH SUE MAYER, Director of Investigations 

JACKIE M. BARBER, Counsel to the Chairman 

DANIEL J. TAYLOR, Counsel to the Ranking Member 

PATRICK MCMULLEN, Senior Counsel 

BRITTANY M. BOHREN, Investigator 

C. TUCKER CARR, Investigative Clerk 


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LETTER OF TRANSMITTAL 

HOUSE OF REPRESENTATIVES, 

COMMITTEE ON ETHICS, 

Washington, DC, December 11, 2014. 

Hon. KAREN L. HAAS, 

Clerk, House of Representatives, 

Washington, DC. 

DEAR MS. HAAS: Pursuant to clauses 3(a)(2) and 3(b) of rule XI 

of the Rules of the House of Representatives, we herewith transmit 

the attached Report, ‘‘In the Matter of Allegations Relating to Representative Judy Chu.’’ 

Sincerely, 

K. MICHAEL CONAWAY, 

Chairman. 

LINDA T. SA ́ NCHEZ, 

Ranking Member. 


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CONTENTS 

Page 

I. INTRODUCTION .......................................................................................... 1 

II. HOUSE RULES, LAWS, REGULATIONS, AND OTHER STANDARDS 

OF CONDUCT ............................................................................................ 2 

III. BACKGROUND ............................................................................................. 2 

IV. FINDINGS ...................................................................................................... 3 

A. USE OF HOUSE RESOURCES FOR CAMPAIGN PURPOSES . 3 

1. PREPARATION OF CAMPAIGN-RELATED MEMORANDA .. 3 

2. REVIEW OF CAMPAIGN-RELATED COMMUNICATIONS ... 5 

3. PREPARATION FOR AND DOCUMENTATION OF CAMPAIGN EVENTS ......................................................................... 5 

4. VIOLATIONS OF LAW AND HOUSE REGULATIONS ........... 5 

B. INTERFERENCE WITH THE COMMITTEE’S INVESTIGATION ................................................................................................ 7 

V. CONCLUSION ............................................................................................... 11 

VI. STATEMENT UNDER HOUSE RULE XIII, CLAUSE 3(C) ...................... 11 

APPENDIX A: LETTER OF REPROVAL .................................................... 13 


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House Calendar No. 153 

113TH CONGRESS REPORT " ! HOUSE OF REPRESENTATIVES 2d Session 113–665 

IN THE MATTER OF ALLEGATIONS RELATING TO 

REPRESENTATIVE JUDY CHU 

DECEMBER 11, 2014.—Referred to the House Calendar and ordered to be printed 

Mr. CONAWAY, from the Committee on Ethics, 

submitted the following 

R E P O R T 

In accordance with House rule XI, clauses 3(a)(2) and 3(b), the 

Committee on Ethics (Committee) hereby submits the following Report to the House of Representatives: 

I. INTRODUCTION 

In June 2011, the Committee received information that Representative Chu’s Chief of Staff and Legislative Director had required other staff to perform campaign-related work in the House 

office, during regular working hours. Pursuant to Committee Rule 

18(a), the Committee investigated these allegations. This investigation uncovered evidence that Representative Chu’s Chief of Staff 

and Legislative Director directed members of Representative Chu’s 

staff to perform campaign-related work using official resources on 

a sporadic and limited basis, but did not reveal any evidence that 

Representative Chu was aware of any improper use of official resources for campaign purposes. However, the Committee did find 

that Representative Chu took actions that interfered with the Committee’s investigation of this matter. 

Representative Chu has expressed regret for her inappropriate 

communications with two of her staff members, during the Committee’s investigation, regarding matters the Committee was investigating. The Committee finds, however, that Representative Chu’s 

expression of regret, while commendable, does not overcome the 

need for a letter of reproval regarding her interference with the 

Committee’s investigation. For her violations of House Rules, the 

Committee has issued a public letter of reproval to Representative 

Chu. 


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1Letter from former Chairman Bonner and Ranking Member Sa ́nchez to Representative Chu, 

Aug. 23, 2012, at 1. 

II. HOUSE RULES, LAWS, REGULATIONS, AND OTHER 

STANDARDS OF CONDUCT 

The following House Rules, laws, regulations, and other standards of conduct are implicated in this matter. 

First, 31 U.S.C. § 1301(a) and implementing regulations of the 

Committee on House Administration prohibit the use of appropriated funds for purposes other than for which the appropriations 

were made. 

Second, House rule XXIII, clause 1 provides that ‘‘[a] Member 

. . . of the House shall behave at all times in a manner that shall 

reflect creditably on the House.’’ 

III. BACKGROUND 

Based on information the Committee obtained regarding the improper use of official resources in Representative Chu’s office, the 

Chairman and Ranking Member of the Committee in the 112th 

Congress issued a Request for Information (RFI) to Representative 

Chu on March 6, 2012 (March 6, 2012 RFI). The March 6, 2012, 

RFI included several requests related to the use of official resources, including staff time, for campaign purposes. On April 3, 

2012, Representative Chu provided information and documents in 

response to this RFI. Following the receipt of that response, Committee staff interviewed a member of Representative Chu’s staff 

(Staffer A). In August 2011, Staffer A drafted a memo at the direction of Representative Chu’s Legislative Director for a fundraising 

lunch that Representative Chu attended with owners of grocery 

stores that participated in the Women, Infants, and Children (WIC) 

program (WIC Event). Staffer A felt required to draft the ‘‘WIC 

Memo,’’ and did so during regular working hours, using a House 

computer and other official resources. During its investigation, the 

Committee obtained emails, from the August 2011 period, between 

Staffer A and Representative Chu’s Chief of Staff and Legislative 

Director related to the WIC Memo. Although these documents appeared to be responsive to the Committee’s March 6, 2012 RFI, 

Representative Chu did not provide them to the Committee in her 

April 3, 2012 response. 

The Chairman and Ranking Member issued a second RFI to Representative Chu on August 23, 2012 (August 23, 2012 RFI). This 

RFI requested all documents related to the WIC Event, including 

emails from ‘‘personal, campaign, and official email accounts.’’ 1 In 

response, Representative Chu produced emails from and between 

her official and campaign staff related to the WIC Event, but did 

not produce any emails from her own personal email account. 

On September 19, 2012, the Committee obtained an email, dated 

March 20, 2012, from Representative Chu to her Chief of Staff, discussing concerns Staffer A had expressed that the work on the WIC 

Memo was improper. In that email, Representative Chu directed 

the Chief of Staff to explain Representative Chu’s view of the work 

to Staffer A. Representative Chu did not produce this email exchange in response to either the March 6, 2012, or the August 23, 

2012, RFI. 


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2Letter from Chairman Conaway and Ranking Member Sa ́nchez to Representative Chu, Feb. 

6, 2013, at 1 (‘‘Please provide any previously unproduced emails, with attachments, from any 

of your personal or campaign-related email accounts, that are (1) responsive to any of the Committee’s requests of March 6, 2012, or August 23, 2012; (2) related to any event concerning the 

Women, Infant, and Children (WIC) program which you attended on or around August 25, 2011 

(the WIC event); or (3) related to [Staffer A]’’). 3The Chairman and Ranking Member participated in the interview of Representative Chu. 

4 Representative Chu provided the Committee with talking points and background memos for 

multiple campaign events, which her staff emailed to her from personal email accounts, during 

regular working hours. The Committee had substantial questions about these documents, but 

could not determine whether they were drafted in House offices, during official time. 

On February 6, 2013, the Chairman and Ranking Member of the 

Committee for the 113th Congress issued a third RFI (February 6, 

2013 RFI) to Representative Chu, which included a number of requests specifically intended to capture Representative Chu’s March 

20, 2012, email to her Chief of Staff.2 Representative Chu finally 

produced that document to the Committee on March 6, 2013. 

In addition, pursuant to Committee rule 18(a), Committee staff 

conducted interviews of 13 persons, including Representative Chu, 

her Chief of Staff, and her Legislative Director.3

Before the Committee decided how to resolve this matter, Representative Chu was invited to address the full Committee, and did 

so. The Committee carefully considered all of Representative Chu’s 

written submissions and oral remarks in resolving the matter. 

IV. FINDINGS 

Following the Committee’s investigation, the Committee reached 

the following findings and conclusions. 

A. USE OF HOUSE RESOURCES FOR CAMPAIGN PURPOSES

The Committee determined that Representative Chu’s Chief of 

Staff and Legislative Director directed several other members of 

Representative Chu’s official staff to engage in campaign-related 

activities, while on official time, including (1) preparing background 

memoranda for a campaign fundraising event; (2) reviewing campaign-related communications; and (3) preparing for and documenting campaign events. This work, while sporadic and limited, 

involved improper uses of official resources, including staff time. 

However, as discussed below, the Committee obtained no evidence 

that Representative Chu was aware that her staff was engaged in 

this improper campaign work. 

1. Preparation of campaign-related memoranda 

The Committee obtained evidence that established at least one 

instance of use of House staff and other official resources to research and draft background materials for Representative Chu’s 

use at a campaign fundraising event.4 Through interviews and review of email documents, the Committee determined that on Monday, August 22, 2011, Representative Chu’s campaign consultant 

sent an email to her Legislative Director stating: ‘‘Did you get the 

info from [Representative Chu’s Scheduler] for Judy’s fundraising 

lunch with the WIC people on Thursday? If not, Judy is supposed 

to talk about WIC issues. It will be an informal lunch.’’ The next 

morning, Tuesday, August 23 at 9:11 AM, the Legislative Director 

forwarded this email to the Chief of Staff and Staffer A, and added: 

‘‘This is an ‘informal’ talk on the calendar. I am assuming that she 

would just need background, since she has expressed to me that at 


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5 18(a) Interview of Representative Chu. 

6 Id. 

these types of things she can’t really work off a written speech. But 

what do you think?’’ The Committee is not aware of any response 

by the Chief of Staff. 

Staffer A stated that on the morning of the Legislative Director’s 

email, the Legislative Director came to Staffer A’s desk and told 

Staffer A to prepare background materials for a fundraising lunch 

for Representative Chu, where the other attendees would be owners of grocery stores that participated in the WIC program. Staffer 

A had never done any campaign-related work for Representative 

Chu previously, and had never attended any of her campaign 

events. Staffer A was asked to work on the WIC Memo because 

Staffer A’s legislative portfolio included the WIC program. Staffer 

A did not feel free to decline the request, as the Legislative Director was Staffer A’s supervisor. 

Staffer A began working on the WIC Memo shortly after discussing it with the Legislative Director, and created an initial draft 

from Representative Chu’s House office, during regular working 

hours. The work was interrupted by an earthquake, which struck 

Washington, DC, just before 2 PM. The House office buildings were 

then closed, and Staffer A went home, logged into an official computer remotely, and finished the WIC Memo. At 6:14 PM, Staffer 

A emailed the Legislative Director: ‘‘Sorry, I had trouble logging 

into my work computer from home (maybe because everyone is trying to do that right now). I think this is the kind of thing you needed—let me know what you think.’’ Staffer A attached two documents to this email—a memorandum with background information 

on the WIC program, and a copy of Representative Chu’s remarks 

on the House floor regarding the program. The Legislative Director 

replied ‘‘this looks great! I will make some small changes tomorrow 

and send to J.C.’’ The Legislative Director forwarded Staffer A’s 

email and documents to the Chief of Staff that night, then sent the 

materials to Representative Chu on Wednesday, August 24, at 1:24 

PM. The Legislative Director wrote, in relevant part: ‘‘Judy—In 

preparation for the Thursday luncheon with WIC store owners 

[Staffer A] and I have prepared a background memo, with overall 

talking points, on cuts to WIC and your record on WIC.’’ The Committee is not aware of any email response from Representative 

Chu. 

Representative Chu confirmed for the Committee that the WIC 

Event was a fundraising event, and that she always knew that was 

the case. She also confirmed that the event had no official component or purpose. However, Representative Chu stated that she 

‘‘never asked for a memo’’ from her staff, and explained that she 

did not expect any background materials from staff because ‘‘I 

thought this would be more casual, and also I know the subject 

pretty well.’’ 5 She stated that she read the WIC Memo when the 

Legislative Director sent it to her, and though she was ‘‘puzzled at 

the time,’’ she did not tell the Legislative Director that she did not 

need the memo.6 Representative Chu stated that she had no idea, 

at the time she received the WIC Memo, how, where, or when it 

was created. 


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7The Chief of Staff stated that she assumed the staff member would transmit the photographs 

from home. 

2. Review of campaign-related communications 

The Committee determined that a member of Representative 

Chu’s staff (Staffer B) was told by both the Chief of Staff and Legislative Director to access Representative Chu’s campaign email account, chuforcongress@gmail.com, in order to review, sort, and 

‘‘tag’’ responses to an email sent from that account regarding Representative Chu’s efforts to reduce hazing in the U.S. military. 

Staffer B did this work in Representative Chu’s House office, using 

a House computer, during regular working hours. The work was 

done on three or four occasions, and totaled several hours. 

Representative Chu has asserted that the initial ‘‘military hazing’’ email was not a campaign communication because it did not 

advocate for Representative Chu’s reelection or solicit campaign 

contributions, and the email was not sent exclusively to campaign 

donors. However, the initial email was drafted by a campaign consultant, and sent from Representative Chu’s campaign email account. Thus, Representative Chu’s Chief of Staff and Legislative 

Director should not have directed other staff to do work related to 

the email in the House office during regular working hours. There 

is no evidence, however, that Representative Chu directed any of 

her staff to do anything with the campaign email account, or was 

aware that staff members were accessing or working with the account improperly. 

3. Preparation for and documentation of campaign events 

The Committee obtained information that several members of 

Representative Chu’s staff prepared for and participated in campaign events while on official House time and/or directed other 

staff to do so. Some of this conduct involved or was observed by 

multiple members of Representative Chu’s staff. Specifically, it appears that Representative Chu’s Chief of Staff asked staff to place 

candy in envelopes to be given to attendees at a Chinese New Year 

fundraising event, and that staff did so on House grounds (either 

in the House office or in the House parking garage). The evidence 

also showed that the Chief of Staff asked a staff member to photograph a campaign event, and the staff member used a camera purchased with funds from the MRA. The Chief of Staff also asked the 

staff member to transmit the campaign event photos to one of Representative Chu’s campaign consultants—who was not a House employee—and the staff member did so during regular House working 

hours, using a House email address and computer.7 However, it 

does not appear that the staff member was required to attend the 

campaign event or take or transmit photos; the staff member was 

asked to volunteer their time, and willingly agreed to do so. Further, to the extent any staff were required to assist in preparations 

for campaign events, or to attend such events, the Committee 

found no evidence that Representative Chu directed, or was aware 

of, such conduct. 

4. Violations of law and House regulations 

As discussed in Section II, the use of official resources for nonofficial purposes, including campaign-related purposes, can be a 


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8See 18 U.S.C. § 641; 2 U.S.C. § 1301(a). 9See Ethics Manual at 125 (‘‘The Members’ Handbook provides that ‘[o]nly expenses the primary purpose of which [is] official and representational’ are reimbursable from the MRA, and 

that the MRA may not pay for campaign expenses or political expenses.’’) (emphasis in original). 10 Id. at 124. 11 Id. at 126 (while ‘‘the Members’ Handbook permits the incidental personal use of House 

equipment and supplies ‘when such use is negligible in nature, frequency, time consumed, and 

expense,’ . . . this policy applies only to incidental personal use of those resources, and not 

to their use for campaign or political purposes.’’) (emphasis in original). 12The Ethics Manual states that staff may engage in only limited and expressly defined campaign-related tasks while in House offices, during regular working hours. Staff may (1) ‘‘coordinate with those in the campaign office who schedule the Member’s campaign appearances;’’ (2) 

‘‘refer to the campaign office letters and other communications and inquiries that it receives concerning the campaign;’’ and (3) ‘‘provide a campaign office with a copy of any materials that the 

congressional office has issued publicly, such as press releases, speeches, and newsletters.’’ Id. 

at 132–33. The Ethics Manual also states that ‘‘[t]he press secretary in the congressional office 

may answer occasional questions on political matters, and may also respond to such questions 

that are merely incidental to an interview focused on the Member’s official activities. However, 

while in the congressional office, the press secretary should not give an interview that is substantially devoted to the campaign, or initiate any call that is campaign-related.’’ Id. at 133. 

None of the campaign-related work at issue here falls into these categories. 13 Id. 14See Comm. on Standards of Official Conduct, In the Matter of Rep. E.G. ‘‘Bud’’ Shuster, H. 

Rpt. 106–979, 106th Cong. 2d Sess. 64 (2000) (holding Member accountable for improper use 

of official resources even though the Committee found ‘‘no direct evidence that [the Member] 

was aware that this activity was taking place.’’); see also Comm. on Standards of Official Conduct, Investigation Into Officially Connected Travel of House Members to Attend the Carib News 

Foundation Multi-National Business Conferences in 2007 and 2008, H. Rpt. 111–422, 111th 

Cong. 2d Sess. 192–93 (2010) (‘‘[B]ased upon the Standards Committee’s longstanding precedent 

. . . the Subcommittee finds that it would not well serve the House as an institution to allow 

its Members to escape responsibility by delegating authority to their staff to take actions and 

hide behind their lack of knowledge of the facts surrounding those actions. . . . In this case, 

Representative Rangel acted . . . through [his Chief of Staff’s] actions of completing and signing 

the forms necessary for the approval to attend the conference. Representative Rangel authorized 

his Chief of Staff . . . to complete and sign the traveler forms on his behalf. Representative 

Rangel, therefore, can and should be held responsible for the knowledge [his staff] had regarding 

the corporate sponsors.’’) 

violation of federal law.8 Regulations of the Committee on House 

Administration also provide that House funds and resources may 

not be used for any campaign or political purposes.9 Regarding 

these laws and regulations, the Ethics Manual states: 

The misuse of the funds and other resources that the 

House of Representatives entrusts to Members for the conduct of official House business is a very serious matter. 

Depending on the circumstances, such conduct may result 

in not only disciplinary action by the House, but also 

criminal prosecution.10

Thus, it is clear that to the extent Representative Chu’s Chief of 

Staff or Legislative Director directed other staff to do campaign-related work during regular office hours, in the House office and 

using House email accounts and equipment,11 those directions were 

improper.12

It bears emphasis that the Committee found no evidence that 

Representative Chu was aware that members of her staff were 

using official resources for campaign-related purposes, or were directing other staff to do so. Instead, it appears that the Chief of 

Staff and Legislative Director, who acted as supervisors of other 

staff, directed the improper use of official resources. However, as 

the Ethics Manual explains, ‘‘each Member should be aware that 

he or she may be held responsible for any improper use of House 

resources that occurs in the Member’s office.’’ 13 Consistent with 

this caution, in some instances the Committee has held Members 

responsible for their staff’s improper use of official resources, even 

when the Members were not aware of their staff’s actions.14 In 


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15See Comm. on Ethics, In the Matter of Allegations Relating to Representative Laura Richardson, H. Rpt. 112–642, 112th Cong. 2d Sess. 97 (hereinafter Richardson) (‘‘The ISC recognizes 

that misconduct in a Member office can range on a spectrum between subordinates following 

orders despite their wrongfulness, and ‘rogue’ agents acting outside the authority granted to 

them by a Member.’’) 16 After the Committee commenced its investigation, Representative Chu revised her office 

policies to ensure that campaign-related events are clearly indicated on official schedules and 

make certain that any staff members who participate in campaign-related work or events do 

so voluntarily and on personal time. 17Mar. 6, 2012, RFI at 1. 18 Id. at 3. 

doing so, the Committee has distinguished between cases where a 

Member knew, or had reason to know, of improper conduct and instances where a Member reasonably believed that staff was acting 

properly.15

In this case, Representative Chu has stated that she did not 

know of any misuse of official resources for campaign-related purposes, and there is no evidence to the contrary. Further, Representative Chu has said that she took steps to ensure that staff understood the prohibition on using official resources for campaign-related purposes, including requiring staff to certify that they had 

read the office manual, which explained the relevant rules, and 

having her Chief of Staff reiterate the rules in conversations with 

other staff.16 In light of the evidence, the Committee did not find 

that Representative Chu failed to properly supervise her staff, or 

that she is otherwise responsible for any of her staff’s violations of 

laws, rules, or other standards of conduct. However, the Committee 

emphasizes the responsibility of staff in supervisory positions to 

both ensure that other staff members are using official resources 

appropriately and to inform their employing Members of any improper or questionable uses of such resources. 

B. INTERFERENCE WITH THE COMMITTEE’S INVESTIGATION

As previously discussed, the Chairman and Ranking Member 

issued a total of three RFIs to Representative Chu. The first RFI, 

sent on March 6, 2012, stated that ‘‘the Committee has authorized 

investigation into allegations that members of your staff have performed campaign work while on official House time and/or used official House resources for campaign-related purposes.’’ 17 The RFI 

further stated that the ‘‘Committee also requests that you inform 

your congressional staff that they are to fully and honestly cooperate with the Committee’s requests for information,’’ and explained 

that ‘‘[o]ther than [this] notification . . . we request that you not 

discuss this matter with anyone other than your own legal counsel.’’ 18

Shortly after Representative Chu received this RFI, her Chief of 

Staff held a meeting to inform other staff of the Committee’s investigation and its focus. Following this meeting, Staffer A approached 

the Chief of Staff and expressed concern that the work Staffer A 

had done to prepare the WIC Memo involved an improper use of 

official resources. The Chief of Staff stated that she relayed this 

concern to Representative Chu, and described Representative Chu’s 

response: 

A. I actually did talk to the Congresswoman a little bit 

about [Staffer A’s concern], too. 

Q. And what was that discussion? 


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19 18(a) Interview of Chief of Staff (emphasis added). 20The Chief of Staff stated: ‘‘Well, yeah, I did talk to [Staffer A, after discussing Staffer A’s 

concerns with Representative Chu] and just [said] that there was this two-part that we hadn’t 

realized that there was just to clarify for [Staffer A]. But that was pretty much that. You know. 

Just [so] that [Staffer A] wasn’t so stressed out about it.’’ 18(a) Interview of Chief of Staff. 21 In fact, the Committee had not contacted Staffer A regarding an interview at this time. But 

Staffer A was interviewed in June 2012. 

A. It was just that, you know, this was [Staffer A’s] concern. [Staffer A] was really worried and, you know, and 

just letting her know and giving her an update. Pretty 

much it. 

Q. What did she say? 

A. She just said, you know, well that’s unfortunate and 

you know, nothing’s happened, nothing wrong has 

gone on so you know, to the extent that you can make 

[Staffer A] feel better about the situation, you know, that 

was kind of it, yeah.19

It appears that, following this exchange, Representative Chu re-reviewed Staffer A’s memo for the WIC Event and emailed additional 

comments to the Chief of Staff. In a March 20, 2012, email to her 

Chief of Staff, Representative Chu wrote: 

Here is [Staffer A’s] background memo for the event of 

August 25, 2011. 

In the schedule, the event is referred to as a luncheon 

of WIC owners, and is not referred to as a fundraiser. 

I wish [Staffer A] hadn’t referred to the event [in the 

background memo]. [Staffer A] didn’t need to in order to 

produce the memo, which was on what I’ve done on WIC 

since I’ve been in Congress. 

You might point that out to [Staffer A]. No where 

[sic] in the memo nor in the calendar does it refer 

to a fundraiser. 

The Chief of Staff responded by email: ‘‘Okay, good to know. I will 

let [Staffer A] know tomorrow.’’ The Chief of Staff stated that after 

receiving this email, she spoke to Staffer A again, and explained 

that the WIC Memo was for an event with both official and fundraising components, and that the memo related to the official component.20

This sequence of events is troubling in several respects. First, 

Representative Chu’s oral and written comments to the Chief of 

Staff could be viewed as an attempt to shape Staffer A’s testimony 

to the Committee. Representative Chu stated that she believed 

Staffer A went to the Chief of Staff because the Committee had requested an interview, and Staffer A was anxious about potential 

questions regarding the work on the WIC Memo.21 In these circumstances, Representative Chu should have recognized that it 

was inappropriate to communicate with a potential material witness in a manner suggestive of an interpretation of events that the 

Committee was investigating. 

Second, to the extent Representative Chu communicated to Staffer A, through the Chief of Staff, that the WIC Event had any official component or purpose, that suggestion was incorrect. In her 

interview with the Chairman and Ranking Member, Representative 

Chu stated unequivocally that ‘‘from the time that the [WIC] event 

was planned,’’ she understood ‘‘that this was to be a fundraising 


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22 18(a) Interview of Representative Chu. 23 Id. 24 Id. 25 Id. To the extent Representative Chu believed, when she spoke to and emailed her Chief 

of Staff about the WIC Memo, that Staffer A drafted the memo on Staffer A’s ‘‘own volunteer 

time,’’ without using any official resources, that belief is incorrect. Staffer A stated, and contemporaneous emails indicate, that Staffer A started working on the WIC Memo in Representative 

Chu’s House office, during regular working hours, then went home after the House office buildings were closed due to earthquake, logged onto an office computer remotely, again during regular working hours, and completed the memo. 

26See Comm. on Standards of Official Conduct, Korean Influence Investigation, H. Rpt. 95– 

1817, 95th Cong. 2d Sess. 122 (1978). 

event, with no official component to it.’’ 22 Further, on the day of 

the WIC Event, Representative Chu received several thousands of 

dollars in campaign contributions from individuals who attended 

the event. Thus, it is clear that Representative Chu knew that the 

WIC event was a campaign fundraiser—with no separate official 

component—when she wrote her March 20, 2012, email, even if her 

official calendar did not describe it as such. 

In an interview with the Chairman and Ranking Member, Representative Chu was asked about her actions in response to Staffer 

A’s initial meeting with the Chief of Staff. Representative Chu first 

explained that her intention was to ‘‘relieve [Staffer A’s] anxiety,’’ 

because Staffer A ‘‘was very, very concerned about the whole interview, about being interviewed at all.’’ 23 Representative Chu was 

asked whether, in directing her Chief of Staff to speak with Staffer 

A again, she had ‘‘any intention to influence what Staffer A would 

tell the Committee on Ethics about the memo?’’ She explained: ‘‘I 

thought this [March 20, 2012, email to the Chief of Staff] might 

clarify things, but, of course, it—it didn’t. And it was based on a 

mistaken assumption. And I shouldn’t have had any communication with [Staffer A] at all.’’ 24 Representative Chu continued: 

Well, I shouldn’t have written the [email] at all. I truly regret it. I shouldn’t have had any communication at all with 

[Staffer A]. And it would have been better if I knew exactly how this [WIC] memo was produced. But I wrote this 

[email] impulsively, and so I didn’t know at the time what 

the true circumstances were, that [Staffer A had] actually 

done [the WIC memo] on [Staffer A’s] own volunteer 

time.25

The Committee has noted in the past that the support of the 

Members, officers and employees of the House for its work is crucial to its continuing effectiveness.26 In the Matter of Allegations 

Relating to Representative Laura Richardson, the Committee stated: 

Representative Richardson also violated clauses 1 and 2 

of House Rule XXIII by engaging in a pattern of behavior 

intended to obstruct this investigation. This is among the 

most troubling aspects of the case, and the easiest to see 

the manner in which it would bring discredit to the House: 

if a Member has such little respect for the internal discipline of the House that she would attempt to evade its 

questioning, rather than submitting to the fact gathering 

process in good faith, it raises the question of why the 

American people should believe that the House does a sufficient job policing itself. For the House to have the trust 


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27 Richardson at 95. 28 Id. at 14 (discussing a staff meeting where Representative Richardson ‘‘began a mock dialogue with herself, stating some of the questions she expected the Committee to ask, such as 

‘did you feel that your campaign work was mandatory or you were compelled in some way?’ and 

then an answer—‘no.’ ’’) 29This matter is also distinguishable in that, in Richardson, the Committee found that Representative Richardson herself was both aware of and personally directed the compelled use of 

official resources for campaign purposes. Id. at 5–14. That is not the case here. 30 Aug. 23, 2012, RFI at 1. 31 18(a) Interview of Representative Chu. 

of the people, it must vigorously protect its ability to investigate wrongdoing.27

One part of the ‘‘pattern’’ of obstructive behavior Representative 

Richardson engaged in involved discussing with her staff questions 

the Committee might ask them about campaign-related work, and 

providing self-serving answers that would vindicate Representative 

Richardson.28 Representative Richardson was reprimanded by the 

House for her repeated improper use of official resources and obstruction of the Committee’s investigation of her. 

The underlying conduct at issue in Richardson—compelled use of 

House staff for campaign work—was much more egregious than the 

limited, though still impermissible, use of official resources for campaign purposes here.29 The Committee determined that Representative Richardson herself regularly compelled her official staff to 

perform campaign work, obstructed the Committee’s investigation 

by altering or destroying evidence, failed to produce documents responsive to requests for information and a subpoena, and repeatedly attempted to influence the testimony of witnesses. However, 

with respect to the charge of interference with the Committee’s investigation, Representative Chu’s actions here were nonetheless 

improper, and the Committee was troubled by them. Representative Chu interfered with the Committee’s investigation by incorrectly advising two material witnesses, Staffer A and the Chief of 

Staff, that the production of the WIC Memo did not involve improper use of official resources for campaign-related purposes—the 

very conduct the Committee was investigating. The fact that Representative Chu’s advice was incorrect—even if Representative Chu 

believed it to be true—only amplifies the concerns regarding it. 

It is also concerning that Representative Chu failed to produce 

her March 20, 2012, email exchange with the Chief of Staff to the 

Committee, in response to the Committee’s August 23, 2012, RFI. 

That RFI specifically asked for documents related to the WIC 

Event, including emails from ‘‘personal, campaign, and official 

email accounts.’’ 30 Representative Chu stated that she read this request as referring to staff email accounts, not her own, but admitted that, in preparing a response to the August 23, 2012, RFI, she 

‘‘searched for ‘WIC’ ’’ and ‘‘inputted the words ‘WIC’ ’’ in her personal email account.31 She did not explain how that search would 

not have produced her March 20, 2012, email to the Chief of Staff, 

which includes the word ‘‘WIC.’’ Indeed, Representative Chu told 

the Committee that in searching her personal email account in response to the August 23, 2012, RFI, she found the email from her 

Legislative Director transmitting the WIC Memo to her on August 

24, 2011, but not the email Representative Chu sent to her Chief 

of Staff on March 20, 2012, regarding Staffer A’s concerns about 

the WIC Memo. However, it appears that any search which produced the August 24, 2011, email would have also produced the 


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32 Id. 

March 20, 2012, email. Representative Chu only produced the 

March 20, 2012, email in response to the Committee’s third RFI, 

dated February 6, 2013, which specifically asked for previously 

unproduced documents concerning the WIC Memo and all documents, including all emails, concerning Representative Chu’s responses to the Committee’s investigation. 

Representative Chu has stated that she responded to Staffer A’s 

communication of concerns ‘‘impulsively,’’ and explained that she 

intended only to ease Staffer A’s anxiety regarding the Committee’s 

investigation.32 She has further stated that she regrets her actions, 

and understands that she should not have communicated with 

Staffer A at all during the Committee’s investigation. Regardless of 

Representative Chu’s intentions, interference with a Committee investigation is a very serious matter, and Representative Chu’s actions here were clearly improper and reflected very poor judgment 

on her part. Thus, the Committee found that Representative Chu 

violated clause 1 of House rule XXIII, by not acting in a manner 

that ‘‘reflect[ed] creditably on the House.’’ 

V. CONCLUSION 

For Representative Chu’s violations of House Rules, the Committee has determined to publicly reprove her. The Committee recognizes and appreciates that Representative Chu has expressed regret for her inappropriate communications with two of her staff 

members, during the Committee’s investigation, regarding matters 

the Committee was investigating. The Committee finds, however, 

that Representative Chu’s expression of regret, while commendable, does not overcome the need for a letter of reproval regarding 

her interference with the Committee’s investigation. Therefore, the 

Committee has issued a letter of reproval to Representative Chu 

for her conduct in this matter. Following the publication of this Report, the Committee will consider this matter closed. 

VI. STATEMENT UNDER HOUSE RULE XIII, CLAUSE 3(C) 

The Committee made no special oversight findings in this Report. 

No budget statement is submitted. No funding is authorized by any 

measure in this Report. 


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