1 

" ! HOUSE OF REPRESENTATIVES 115TH CONGRESS

2d Session 

REPORT

115–617 

House Calendar No. 135 

IN THE MATTER OF ALLEGATIONS 

RELATING TO REPRESENTATIVE 

LUIS V. GUTIE ́ RREZ 

R E P O R T 

OF THE

COMMITTEE ON ETHICS 

MARCH 22, 2018.—Referred to the House Calendar and ordered to be 

printed 


E:\Seals\Congress.#13
IN THE MATTER OF ALLEGATIONS RELATING TO 

REPRESENTATIVE LUIS V. GUTIE ́ RREZ 

U.S. GOVERNMENT PUBLISHING OFFICE

WASHINGTON : 

1 

29–435 

" ! HOUSE OF REPRESENTATIVES 115TH CONGRESS

2d Session 

REPORT

2018

115–617 

House Calendar No. 135 

IN THE MATTER OF ALLEGATIONS 

RELATING TO REPRESENTATIVE 

LUIS V. GUTIE ́ RREZ 

R E P O R T 

OF THE

COMMITTEE ON ETHICS 

MARCH 22, 2018.—Referred to the House Calendar and ordered to be 

printed 


E:\Seals\Congress.#13
(II) 

COMMITTEE ON ETHICS 

SUSAN W. BROOKS, Indiana 

Chairwoman 

KENNY MARCHANT, Texas 

LEONARD LANCE, New Jersey 

MIMI WALTERS, California 

JOHN RATCLIFFE, Texas 

THEODORE E. DEUTCH, Florida 

Ranking Member 

YVETTE D. CLARKE, New York 

JARED POLIS, Colorado 

ANTHONY BROWN, Maryland 

STEVE COHEN, Tennessee 

REPORT STAFF

THOMAS A. RUST, Chief Counsel/Staff Director 

BRITTNEY L. PESCATORE, Director of Investigations 

MEGAN H. SAVAGE, Counsel to the Chairwoman 

DANIEL J. TAYLOR, Counsel to the Ranking Member 

DAVID W. ARROJO, Counsel 

KATHRYN LEFEBER DONAHUE, Senior Counsel 

MOLLY N. MCCARTY, Investigator 

ANDREW KLEIMAN, Investigative Clerk 

(III)

LETTER OF TRANSMITTAL 

HOUSE OF REPRESENTATIVES, 

COMMITTEE ON ETHICS, 

Washington, DC, March 22, 2018. 

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 Luis V. Gutie ́rrez.’’ 

Sincerely, 

SUSAN W. BROOKS, 

Chairwoman. 

THEODORE E. DEUTCH, 

Ranking Member. 

(V) 

C O N T E N T S 

Page 

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

II. PROCEDURAL BACKGROUND .................................................................. 2 

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

OF CONDUCT ............................................................................................ 3 

IV. BACKGROUND ............................................................................................. 4 

A. REPRESENTATIVE GUTIE ́ RREZ’S CONTRACT WITH SCOFIELD COMMUNICATIONS .................................................... 5 

B. REQUEST FOR CHA REVIEW OF THE CONTRACT ............. 6 

C. PAYMENTS TO SCOFIELD COMMUNICATIONS .................. 7 

D. SERVICES PERFORMED UNDER THE SCOFIELD CONTRACT ......................................................................................... 9 

E. TERMINATION OF THE CONTRACT ....................................... 13 

F. POTENTIAL LOBBYING ACTIVITIES BY SCOFIELD COMMUNICATIONS .......................................................................... 16 

1. Greater Chicago Food Depository ...................................... 16 

2. Chicago Botanical Gardens ................................................ 17 

3. National Museum of Puerto Rican Arts and Culture ...... 17 

V. FINDINGS ...................................................................................................... 19 

A. UNAUTHORIZED USE OF THE MEMBERS’ REPRESENTATIONAL ALLOWANCE .............................................................. 19 

B. HOUSE RULE XXIII, CLAUSES 1 AND 2 ................................ 29 

C. CODE OF ETHICS, SECTION 5 ................................................. 31 

VI. CONCLUSION ............................................................................................... 32 

VII. STATEMENT UNDER HOUSE RULE XIII, CLAUSE 3(C) ...................... 32 

APPENDIX 1: REPORT AND FINDINGS OF THE OFFICE OF CONGRESSIONAL ETHICS (REVIEW NO. 13–7135) ....................................................... 33 

APPENDIX 2: REPRESENTATIVE GUTIE ́ RREZ’S SUBMISSIONS ................. 211 

APPENDIX 3: EXHIBITS TO COMMITTEE REPORT ....................................... 218 

House Calendar No. 135 

115TH CONGRESS REPORT " ! HOUSE OF REPRESENTATIVES 2d Session 115–617 

IN THE MATTER OF ALLEGATIONS RELATING TO 

REPRESENTATIVE LUIS V. GUTIE ́ RREZ 

MARCH 22, 2018.—Referred to the House Calendar and ordered to be printed 

Mrs. BROOKS of Indiana, 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 

On December 4, 2013, the Office of Congressional Ethics (OCE) 

transmitted to the Committee a Report and Findings (OCE’s Referral) regarding Representative Luis Gutie ́rrez. OCE reviewed allegations that Representative Gutie ́rrez used his Members’ Representational Allowance (MRA) to pay his former Chief of Staff, Doug Scofield, through his firm Scofield Communications, for services that 

may not be paid for using MRA funds. OCE found that there was 

substantial reason to believe Representative Gutie ́rrez used funds 

from his MRA for an impermissible purpose—to retain Mr. Scofield 

to provide services to his congressional office that more closely resembled those provided by an employee or consultant, rather than 

a contractor—in violation of federal law and House rules. OCE’s 

Referral also discussed a separate allegation: that Representative 

Gutie ́rrez may have impermissibly granted special favors or benefits to entities that retained Scofield Communications as a lobbyist 

while the firm contracted with the Member’s office. However, 

OCE’s Referral did not assert that OCE found substantial reason 

to believe there was merit to this allegation. Thus, OCE recommended that the Committee further review only the allegation 

related to misuse of the MRA. 

2 

1 In the interest of completeness, the Committee also reviewed the allegation—which OCE did 

not recommend for further review—that Representative Gutie ́rrez violated the Code of Ethics 

for Government Service, Section 5, by dispensing special favors or privileges to non-profit entities that retained Scofield Communications for lobbying or fundraising services. As discussed 

further in Section V.C., the Committee found no evidence that this allegation was true. 

The Committee did further review this allegation.1 After an extensive investigation, the Committee found that although an overwhelming majority of the work Mr. Scofield performed from 2003 

to 2013 clearly accorded with the contract’s terms, Mr. Scofield occasionally performed work for Representative Gutie ́rrez’s office that 

was either ‘‘legislative’’ in nature or otherwise exceeded the scope 

of work outlined in the contract. Representative Gutie ́rrez thus 

impermissibly used MRA funds to pay Mr. Scofield for some work 

that exceeded the scope of the Scofield Communications contract, 

and the limits of what a contractor retained to provide services to 

a Member’s congressional office may do, as defined by the Committee on House Administration (CHA). The Committee also concluded that the resulting violations, though unintentional, were 

significant enough to warrant a reproval by the Committee. While 

the Committee could not quantify the degree of the impermissible 

work or the associated MRA payments with exact precision, the 

Committee concluded, based on conservative estimation, as discussed further in this Report, that Representative Gutie ́rrez must 

reimburse his MRA in the amount of $9,700, or approximately 

three percent of the total amounts paid from Representative 

Gutie ́rrez’s MRA to Scofield Communications from September 2007 

until the contract’s termination in June 2013. 

Accordingly, the Committee unanimously voted to issue this Report, which will serve as a reproval of Representative Gutie ́rrez’s 

conduct, and concluded that he must reimburse the U.S. Treasury 

for those MRA funds used impermissibly. Upon issuance of this Report and Representative Gutie ́rrez’s reimbursement of the amount 

described above, the Committee will consider this matter closed. 

II. PROCEDURAL BACKGROUND 

OCE undertook a preliminary review of this matter on July 26, 

2013. On August 25, 2013, OCE initiated a second-phase review. 

On November 22, 2013, the OCE Board unanimously voted to 

adopt the Findings and refer the matter to the Committee with a 

recommendation for further review. The Committee received OCE’s 

referral on December 4, 2013. 

The Committee reviewed material provided by OCE, including its 

Report and Findings, along with other documentary and testimonial evidence obtained by OCE. In addition, the Committee’s 

then-Chairman and Ranking Member sent Representative 

Gutie ́rrez a Request for Information (RFI), and Representative 

Gutie ́rrez voluntarily provided a brief narrative submission and 

relevant documents. In the course of the Committee’s investigation, 

the then-Chairman and Ranking Member sent additional RFIs to 

Representative Gutie ́rrez and five of his former staff members, 

seeking personal or non-official email communications related to 

any work Scofield Communications performed for Representative 

Gutie ́rrez’s office or campaign. Committee staff received and reviewed additional documents responsive to those requests. 

3 

2 Representative Gutie ́rrez paid Mr. Scofield with MRA funds for his services under the contract from March 2003 to June 2013. Thus, any alleged MRA payments to Mr. Scofield for services performed from January 5, 2011, to June 2013 occurred after the 112th Congress began 

on January 5, 2011. Any payments for services rendered by Mr. Scofield from March 2003 to 

January 4, 2011, occurred prior to the start of the 112th Congress, and thus would be outside 

of the Committee’s usual jurisdiction. 3 House Rule XI, cl. 3(a)(2). 

4 31 U.S.C. § 1301(a). 

5 Exhibit 1 (Members’ Handbook (2001)) at 8. 

Some of the allegations reviewed by the Committee occurred before the 112th Congress, prior to the Committee’s general investigative jurisdiction, which includes the current and three previous 

Congresses. However, pursuant to House Rule XI, clause 3(b)(3) 

and Committee Rule 18(d), the Committee voted to determine that 

these allegations were directly related to alleged violations that occurred within the Committee’s general jurisdiction and did investigate those allegations.2

In total, Committee staff reviewed over 10,000 pages of documents, including Representative Gutie ́rrez’s submissions and the 

other documents described above. The Committee also interviewed 

sixteen individuals, including current and former members of Representative Gutie ́rrez’s staff, current and former CHA staff who 

consulted Representative Gutie ́rrez’s staff on the Scofield contract, 

Mr. Scofield, and Representative Gutie ́rrez, who fully cooperated 

with the Committee’s investigation. 

In December 2017, the Committee notified Representative 

Gutie ́rrez that it was considering the adoption of a public report 

that would serve as a reproval of him regarding this matter. Before 

the Committee decided how to resolve this matter, in accordance 

with House Rules, Representative Gutie ́rrez was invited to be 

heard by the Committee in writing and/or in person.3 Representative Gutie ́rrez opted to both provide a written submission, via counsel, and to appear in person before the Committee. The Committee 

carefully considered Representative Gutie ́rrez’s written submission 

and his appearance before the Committee while deliberating how 

to resolve the matter. Ultimately, the Committee determined that 

the appropriate resolution of this matter was to issue this Report, 

which will serve as a reproval of Representative Gutie ́rrez’s conduct. 

III. HOUSE RULES, LAWS, REGULATIONS, AND OTHER 

STANDARDS OF CONDUCT 

Representative Gutie ́rrez’s contract with Scofield Communications to provide services to his congressional office may have implicated the following laws, House Rules, regulations, or other standards of conduct. 

Federal appropriations law states that ‘‘[a]ppropriations shall be 

applied only to the objects for which the appropriations were 

made . . . .’’ 4 MRA expenditures are reimbursable according to 

regulations contained in the Members’ Congressional Handbook 

(Members’ Handbook), which provides examples of items for which 

reimbursement may be permitted, as well as a list of prohibited expenditures.5 Generally, the MRA ‘‘may only be used for official and 

representational expenses,’’ and ‘‘may not be used to pay for any 

expenses related to activities or events that are primarily social in 

4 

6 House Ethics Manual (2008) at 323 (hereinafter Ethics Manual). 7 Exhibit 1 at 9; see also Member’s Handbook (2017) at 2. 8 Ethics Manual at 323. 9 Exhibit 1 at 13 (citing 2 U.S.C. § 72a (recodified at 2 U.S.C. § 4301)). 

10 Id. The current version of the Members’ Handbook, last updated on February 27, 2018, includes a revised contractor rule stating that general office services should be ‘‘outside core office 

functions.’’ See https://cha.house.gov/sites/republicans.cha.house.gov/files/documents/member_services_docs/Members%20Handbook%20115th.pdf, at 6 (last accessed Mar. 6, 2018). It also 

includes a revised consultant rule, which explicitly prohibits hiring speech writers and communications advisers. See id. 11 Id. 12 Code of Ethics for Government Service ¶ 5. 13 Ethics Manual at 27. 

nature, personal expenses, campaign or political expenses, or 

House committee expenses.’’ 6 The Members’ Handbook states: 

Each Member is personally responsible for the payments 

of any official and representational expenses incurred that 

exceed the provided MRA or that are incurred but are not 

reimbursable under these regulations.7

The House Ethics Manual also states that ‘‘Members may be personally liable for misspent funds or expenditures exceeding the 

MRA.’’ 8

Regarding the retention of outside contractors or consultants, the 

Members’ Handbook explains that ‘‘only committees are authorized 

. . . to procure the temporary services of consultants. Consultants 

are not authorized for Member Offices.’’ 9 Rather, Member offices 

may only retain ‘‘contractors.’’ The Member’s Handbook in existence 

at the time that Representative Gutie ́rrez signed the initial contract with Scofield Communications stated that a Member office: 

may contract with firms or individuals only for general, 

non-legislative, office services (e.g., equipment maintenance, systems integration, data entry, staff training, photography, custodial services) for a specific, limited time period not to exceed the Member’s term. Such contracts are 

reimbursable. Such contractors are not employees of the 

House and are ineligible for government-provided benefits.10

The Members’ Handbook also states that ‘‘Members are advised to 

consult the Committee on House Administration when entering 

into such contracts.’’ 11

The Code of Ethics for Government Service (Code of Ethics), section 5, provides that any person in government service should 

‘‘never discriminate unfairly by the dispensing of special favors or 

privileges to anyone, whether for remuneration or not. . . .’’ 12 The 

Ethics Manual notes the Committee ‘‘has cautioned all Members ‘to 

avoid situations in which even an inference might be drawn suggesting improper action.’ ’’ 13

Finally, House Rule XXIII, clause 1, states that ‘‘[a] Member . . 

. shall behave at all times in a manner that shall reflect creditably 

on the House,’’ and clause 2 states that ‘‘[a] Member . . . shall adhere to the spirit and the letter of the Rules of the House. . . .’’ 

(Emphasis added). 

IV. BACKGROUND 

Representative Luis Gutie ́rrez is the Representative for the 

Fourth District of Illinois. He has held that position since 1993. 

5 

14 18(a) Interview of Doug Scofield. 15 Id. 16 Exhibit 2 at 3. 17 18(a) Interview of Representative Gutie ́rrez. 18 Id. 19 Id. (‘‘[M]y Chief of Staff and Doug Scofield had a very intimate working relationship for 

many years, and . . . I delegated to them this responsibility.’’). 20 Id. 21 Exhibit 1 at 7. 

Douglas Scofield served as Representative Gutie ́rrez’s chief of staff 

from 1993 until 2002, when he resigned his position in order to 

serve as deputy campaign manager for then-Representative Rod 

Blagojevich’s successful Illinois gubernatorial campaign.14 After 

working for a few months as then-Governor Blagojevich’s deputy 

governor, Mr. Scofield resigned from that position to form his own 

consulting firm, Scofield Communications, in early 2003. 

A. Representative Gutie ́rrez’s Contract with Scofield Communications 

Shortly after founding Scofield Communications, Mr. Scofield, 

through his consulting firm, negotiated a contract with Representative Gutie ́rrez’s congressional office. Mr. Scofield told Committee 

staff he remained in touch with Representative Gutie ́rrez during 

his time on the Governor’s staff; when Representative Gutie ́rrez 

learned that Mr. Scofield resigned from his new position, he ‘‘wanted to know if [Mr. Scofield] wanted to come back on [official] 

staff.’’ 15 When Mr. Scofield declined this offer, Representative 

Gutie ́rrez decided to retain him as a contractor instead. At the time 

he made this decision, Representative Gutie ́rrez told his then-Chief 

of Staff ‘‘we’d have Doug back on staff.’’ 16 When Committee staff 

asked Representative Gutie ́rrez what he meant by this statement, 

he said he had wanted to ‘‘see if [Mr. Scofield] could continue to 

help with our staff and to work in our office,’’ though not as an official employee.17

Representative Gutie ́rrez told Committee staff he had no role in 

drafting his office’s initial contract with Scofield Communications.18

Rather, Representative Gutie ́rrez delegated the task of preparing 

the contract to his then-Chief of Staff and Mr. Scofield.19 Representative Gutie ́rrez did not remember giving either his thenChief of Staff or Mr. Scofield any parameters for preparing the contract.20

The initial contract between Representative Gutie ́rrez and Scofield Communications stated: 

Neither the contract, nor the Members’ Handbook, define ‘‘nonlegislative’’ office services. However, the version of the Members’ 

Handbook then in existence listed examples of the types of ‘‘nonlegislative’’ work a contractor may perform for a personal office 

within the category of ‘‘general office services.’’ Though not intended to be exhaustive, the list included services such as ‘‘equipment maintenance, systems integration, data entry, staff training, 

photography, custodial services, [and] web services.’’ 21 RepresentaVerDate Sep 11 2014 05:45 Mar 29, 2018 Jkt 029435 PO 00000 Frm 00013 Fmt 6659 Sfmt 6602 E:\HR\OC\HR617.XXX HR617

Insert folio 9 HR617.001
6 

22 18(a) Interview of Representative Gutie ́rrez. 23 Id. 24 Exhibit 3. 25 Id. 26 18(a) Interview of Representative Gutie ́rrez. 27 Exhibit 2 at 3. 

tive Gutie ́rrez told Committee staff he never had discussions with 

either his then-Chief of Staff or Mr. Scofield about their understanding of the relevant CHA rules on hiring contractors.22 Nor did 

Representative Gutie ́rrez recall having any conversation with Mr. 

Scofield as to whether or not Mr. Scofield would or would not be 

allowed to perform specific functions for his congressional office.23

The contract also included a Scope of Work section, which listed 

tasks Scofield Communications ‘‘may’’ perform under the contract: 

While some of these areas of potential work are described broadly, the entire ‘‘Scope of Work’’ was subject to the contract’s first 

clause, which stated that Scofield Communications was retained for 

the purpose of providing Representative Gutie ́rrez’s office with 

‘‘non-legislative, general office services.’’ 24

Representative Gutie ́rrez personally signed the original contract 

between his congressional office and Scofield Communications on 

April 1, 2003.25 Though Representative Gutie ́rrez told Committee 

staff he read the contract before signing it,26 he told OCE he had 

not read the agreement ‘‘with any attention to detail’’ until June 

2013, when his office first received press inquiries about the office’s 

relationship with Mr. Scofield.27

B. Request for CHA Review of the Contract 

On April 1, 2003, Representative Gutie ́rrez’s then-Chief of Staff 

faxed a copy of a proposed contract with Scofield Communications—signed only by Mr. Scofield—to a professional staff member 

in CHA’s Department of Member Services for the (Republican) majority (hereinafter ‘‘Former Member Services Employee’’). The thenChief of Staff testified that, before sending the fax, she called CHA 

‘‘on behalf of the Congressman because we want[ed] to hire a 

former Chief of Staff,’’ and asked the Former Member Services EmVerDate Sep 11 2014 05:45 Mar 29, 2018 Jkt 029435 PO 00000 Frm 00014 Fmt 6659 Sfmt 6602 E:\HR\OC\HR617.XXX HR617

Insert graphic folio 10 HR617.002
7 

28 18(a) Interview of Former Staffer A. 29 Exhibit 4. 30 18(a) Interview of Former Staffer A. 31 18(a) Interview of Former Member Services Employee. 32See 18(a) Interview of Former Staffer A (‘‘My understanding of the process is that the contractor doesn’t get paid unless House Administration approves a contract that is approvable . . . 

So I assume the evidence that it got approved is that they made it possible for [Mr. Scofield] 

to get paid.’’). 33 18(a) Interview of Representative Gutie ́rrez. 34 Id.; see also Exhibit 2 at 3 (Representative Gutie ́rrez told OCE he believed the Scofield contract had been ‘‘renewed five times under identical conditions.’’). 35 18(a) Interview of Representative Gutie ́rrez. 

ployee whether that arrangement would be allowed.28 The fax included a cover page stating: ‘‘As per conversation, please let me 

know [] if this contract falls within what is acceptable under the 

current regulations.’’ 29 The then-Chief of Staff testified that it was 

‘‘impossible for [her] to remember what happened after this fax,’’ or 

whether the Former Member Services Employee called or emailed 

her back.30

The Former Member Services Employee did not remember a 

phone call with Representative Gutie ́rrez’s then-Chief of Staff, nor 

did he recall an April 1, 2003, fax transmission, and current CHA 

staff did not locate any record of such a call or fax, or of any approval of the Scofield contract.31 However, CHA staff indicated that 

such records may not have been archived or otherwise preserved, 

given their age. Representative Gutie ́rrez also did not produce any 

record of his former Chief of Staff’s call with the Former Member 

Services Employee, or any evidence that CHA received the faxed 

contract, reviewed it, or approved it. 

The absence of written records notwithstanding, both Representative Gutie ́rrez’s office and Mr. Scofield apparently operated under 

the belief that CHA had reviewed and approved the contract.32

Representative Gutie ́rrez told Committee staff: ‘‘I know we had the 

approval of House Administration for Doug to do many of the 

things that are included in this contract.’’ 33 Representative 

Gutie ́rrez said he knew this because his then-Chief of Staff ‘‘told 

[him] that it was approved not only one time, but in subsequent 

years.’’ 34 Representative Gutie ́rrez also believed his then-Chief of 

Staff showed him documents or an email from CHA stating the 

contract had been approved,35 though the Committee found no such 

document. 

Regardless of whether CHA ever formally approved the contract, 

as discussed below, there is evidence the contract was submitted 

for CHA’s review, and it is clear the House Finance Office received 

multiple versions of the contract from 2003–2013 and authorized 

payments under the contract from its inception until its termination in 2013. The Committee saw no indication that CHA or 

House Finance ever raised questions or concerns with Representative Gutie ́rrez or his staff about the terms of the Scofield contract, 

or declined to authorize any MRA payments to Scofield Communications, until a USA Today June 2013 newspaper story asserted 

that the payments may have been improper, at which point Representative Gutie ́rrez consulted with CHA and terminated the contract. 

C. Payments to Scofield Communications 

Beginning in March 2003, Scofield Communications issued nonitemized monthly invoices to Representative Gutie ́rrez’s office, 

8 

36See, e.g., Exhibit 5. 37 18(a) Interview of Doug Scofield. 38 Id. 39 18(a) Interview of Representative Gutie ́rrez. 40 Exhibit 6 at 2–3. 41 Exhibit 7. 42 By comparison, Representative Gutie ́rrez’s Communications Director was paid an average of $4,631.94 per month in 2004; in 2008, his Press Secretary was paid an average of $4,408.65 

per month. 43 18(a) Interview of Representative Gutie ́rrez. 44See, e.g., 18(a) Interview of Former Staffer A (‘‘[M]essage is key. And Doug, for better or 

for worse, mastered that so brilliantly, that he was worth it.’’). 45 18(a) Interview of Representative Gutie ́rrez. 46 18(a) Interview of Staffer B. 

charging a ‘‘fee for services: as described per contract, including 

staff training [and] assistance with non-legislative message development.’’ 36 Mr. Scofield told Committee staff that he personally 

performed nearly all of the work billed under the contract.37 He 

also stated that the workload varied significantly by week: though 

he never tracked any of the hours he worked for Representative 

Gutie ́rrez, Mr. Scofield estimated he may have done as little as two 

hours of work during slower weeks, and as much as thirty hours 

during busy weeks.38 Representative Gutie ́rrez told Committee 

staff he expected Mr. Scofield to do ‘‘a lot of work’’ under the contract, and to be available ‘‘whenever he was needed.’’ 39

For such work, Representative Gutie ́rrez’s office paid Scofield Communications a flat monthly retainer of $5,500 from March to 

June 2003, which was reduced to $4,500 month beginning in July 

1, 2003.40 The firm was paid $4,500 per month until January 2013, 

when its monthly fee rose to $6,000.41 Though Mr. Scofield’s firm 

was retained to provide services on a part-time basis, its monthly 

fee was at times equal to, if not greater than, what some of Representative Gutie ́rrez’s full-time communications staffers were paid 

each month.42 Representative Gutie ́rrez told Committee staff he 

‘‘never really gave it much thought’’ that Mr. Scofield was compensated similarly to a full-time communications director on his 

staff.43 When Committee staff asked members of Representative 

Gutie ́rrez’s official staff to explain the parity in pay, they explained 

that Mr. Scofield was highly trained and valued within the office 

for his knowledge of Representative Gutie ́rrez and his communications style.44 Representative Gutie ́rrez provided a similar explanation: ‘‘Doug really understands me, how I communicate . . . and 

it gave me such [] confidence that I would be communicating what 

I really felt and what my intentions were.’’ 45

From March 2003 until the contract’s termination in June 2013, 

Scofield Communications received over $590,000 in total MRA payments for services provided under the contract. Payments to Scofield Communications were processed by a financial administrator, 

who submitted any invoices, along with vouchers that accompanied 

each payment request, to House Finance for reimbursement from 

Representative Gutie ́rrez’s MRA. Representative Gutie ́rrez’s financial administrator since 2008 described her general practice for 

processing MRA reimbursement requests: where it is unclear if a 

specific expense may be paid using MRA funds, she escalates the 

matter to House Finance and—if it remains unclear—to CHA for 

guidance before processing.46 The Committee found no evidence 

that any individual Scofield Communications invoices were sent to 

House Finance or CHA for review prior to payment. The financial 

9 

47See id. 48 18(a) Interview of Former Staffer A. 49 Even so, Mr. Scofield’s speech-related work was sometimes intertwined with the legislative 

process, such as when he drafted, edited and commented on remarks that were intended as potential House floor speeches for Representative Gutie ́rrez. See, e.g., Exhibit 8 (Scofield: ‘‘Thinking about the five minute . . . I will get something to you today. . .’’) and Exhibit 9 (Communications Director states that ‘‘LVG wants a 5 minute on Wednesday on the PR police DOJ report’’ and would ‘‘like Scofield (by phone) . . . to work on it with him’’). 50 18(a) Interview of Former Staffer A. 51 18(a) Interview of Doug Scofield. 52 Id. 53 Id. 

administrator also told Committee staff she never referred back to 

CHA guidelines on retaining contractors when processing Scofield 

Communications invoices because the Scofield contract was ‘‘already in place when [she] came to work in the office [in 2008]. And 

it was approved by [House] Finance.’’ 47

D. Services Performed Under the Scofield Contract 

The record shows Mr. Scofield performed a range of tasks consistent with the terms of the contract between Scofield Communications and Representative Gutie ́rrez’s congressional office. Representative Gutie ́rrez appears to have retained Scofield Communications in large part to obtain Mr. Scofield’s expertise in public 

communications. Accordingly, the Scofield contract anticipated that 

Mr. Scofield would be ‘‘[a]ssisting staff or training staff in the areas 

of preparing remarks or press events,’’ and ‘‘assisting or training 

the staff to publicize programs and activities of Congressman 

Gutie ́rrez.’’ 

With respect to his charge to ‘‘assist’’ with official communications, Mr. Scofield primarily worked with Representative 

Gutie ́rrez’s communications director. Mr. Scofield focused on ‘‘helping the communications team run smoothly and ensuring consistency or strength of message,’’ namely by assisting on messaging 

and speech writing.48 Mr. Scofield did so by regularly editing remarks prepared by official staff, assisting in responding to press inquiries, and drafting press statements and speeches for Representative Gutie ́rrez.49 On various occasions, Mr. Scofield also assisted 

with communications tasks related to immigration casework, including working with local reporters to publicize Representative 

Gutie ́rrez’s work on such matters. In all of these circumstances, 

Mr. Scofield coordinated with official staff to make sure the language of any public statements reflected Representative Gutie ́rrez’s 

unique communications style.50

Mr. Scofield also engaged in ‘‘training’’ Representative 

Gutie ́rrez’s communications staff. Following considerable staff turnover in 2003 (including Mr. Scofield’s own departure as Chief of 

Staff), there was a ‘‘hole in the office,’’ particularly on the messaging and communications teams.51 Leveraging his decade-long 

experience in messaging for Representative Gutie ́rrez, Mr. Scofield 

worked closely with the new press secretary to ensure that ‘‘the 

messaging moved forward,’’ in many cases providing initial drafts 

of press statements and speeches to serve as templates or guideposts.52 Mr. Scofield noted that this role also included a ‘‘mentoring 

component.’’ 53

In addition to the core communications functions, the Scofield 

contract anticipated that Mr. Scofield would assist or train staff 

with a number of other tasks, including dealing with ‘‘casework’’ 

10 

54 18(a) Interview of Doug Scofield; 18(a) Interview of Former Staffer A. 55 18(a) Interview of Former Staffer A. 56 18(a) Interview of Representative Gutie ́rrez. 57 Id. 

and ‘‘community outreach efforts,’’ attending ‘‘non-legislative meetings,’’ and ‘‘[p]roviding staff with guidance and training as determined necessary by the [M]ember of Congress or Chief-of-staff.’’ 

Consistent with these terms, Mr. Scofield helped official staff to 

plan citizenship workshops in the district office, and spent considerable time training new official staff in a variety of areas. For example, Mr. Scofield organized, and made presentations at, staff retreats in 2003 and 2004, where DC and district staff met to improve office morale, strategize on dealing with the caseload of immigration-related constituent work, and in some cases discuss legislative efforts.54 Representative Gutie ́rrez’s former Chief of Staff 

told Committee staff Mr. Scofield ‘‘ran’’ these retreats approximately once per Congress.55

Representative Gutie ́rrez described Mr. Scofield’s training role to 

be one of ‘‘staff development’’ and ‘‘enhancement of skills,’’ and said 

he never saw an endpoint to Mr. Scofield’s role as a trainer under 

the contract.56 Representative Gutie ́rrez also told Committee staff 

he never instructed Mr. Scofield how to train his staff, because Mr. 

Scofield had been training the staff when he served as Chief of 

Staff, and ‘‘[m]ost of the people that Doug hired were still there 

when he took on these new responsibilities.’’ 57

Finally, in addition to ‘‘assisting’’ and ‘‘training’’ official staff in 

a variety of specific areas, the contract included a broad catch-all 

authorization for Mr. Scofield to work in ‘‘[o]ther relevant and appropriate areas as determined by the Member of Congress and 

Chief of Staff.’’ Read without context, this term of the contract 

would seem to allow Representative Gutie ́rrez to pay Mr. Scofield, 

using MRA funds, to do virtually anything the Congressman or his 

Chief of Staff wanted done. However, it bears emphasis that, under 

the contract’s express terms, all of the work Mr. Scofield was expected to do would be in the category of ‘‘non-legislative, general 

office services.’’ That limitation matched the language of the section 

on retaining contractors found in the Member’s Handbook in effect 

at the time the Scofield contract was first executed. Thus, under 

both the terms of the contract and CHA’s guidance on hiring contractors, Mr. Scofield could only be reimbursed for performing work 

for the official office that was ‘‘non-legislative’’ in nature, and that 

could be characterized as ‘‘general office services.’’ 

Despite these limitations, some of the work Mr. Scofield performed for Representative Gutie ́rrez’s congressional office appeared 

to have a legislative component. Most notably, Mr. Scofield repeatedly advised Representative Gutie ́rrez on legislative strategy surrounding immigration legislation. For example: 

• In September 2007, the House Judiciary Subcommittee on Immigration and Border Security scheduled a hearing on the STRIVE 

Act, Representative Gutie ́rrez’s comprehensive immigration reform 

bill. Prior to the hearing, Representative Gutie ́rrez’s then-Legislative Director told Mr. Scofield ‘‘we have to start inviting witnesses 

this week,’’ and that Representative Gutie ́rrez asked her to ‘‘conVerDate Sep 11 2014 05:45 Mar 29, 2018 Jkt 029435 PO 00000 Frm 00018 Fmt 6659 Sfmt 6602 E:\HR\OC\HR617.XXX HR617
11 

58 Exhibit 10. 59 Exhibit 11. 60 Exhibit 12. 61 Exhibit 13. 62 Exhibit 14. 63 Exhibit 15. 64 Exhibit 16. 65 Exhibit 17. 

sult with [Mr. Scofield] on moving forward with planning for the 

hearing.’’ 58

• In September 2009, Representative Gutie ́rrez’s staff discussed 

a number of strategic considerations for ‘‘how to keep the pressure 

on the immigration debate’’, including ‘‘what kind of a bill, how to 

roll it out and with whom.’’ Representative Gutie ́rrez’s then-Legislative Director contacted Mr. Scofield after Representative 

Gutie ́rrez asked her to write a memo laying out those considerations and get Mr. Scofield’s ‘‘opinion on them.’’ 59

• In a series of emails in November 2012, Mr. Scofield advised 

Representative Gutie ́rrez’s staff on ‘‘next steps’’ for Representative 

Gutie ́rrez’s legislative strategy on immigration reform. To ‘‘stay in 

the middle of the new immigration frenzy,’’ Mr. Scofield suggested 

Representative Gutie ́rrez meet with several Senators.60 Mr. Scofield also suggested Representative Gutie ́rrez introduce his own immigration bill, because ‘‘it seems like a natural reaction from the 

Congressman,’’ and concluded it was ‘‘probably worth making everyone react to his bill.’’ 61 After continued discussion on the subject, Mr. Scofield emailed the Communications Director, copying 

the then-Legislative Director: ‘‘Are we doing a bill? I think we need 

to lay down a marker quickly.’’ 62

• In January 2013, the then-Legislative Director sent Mr. Scofield a memorandum that Representative Gutie ́rrez ‘‘asked [] to put 

together for Scofield in particular,’’ outlining the ‘‘state of play with 

regard to legislative developments’’ on immigration reform and 

‘‘seeking guidance [] on some key decisions.’’ One of the decisions 

facing Representative Gutie ́rrez, as detailed in the memo, was 

whether to ‘‘put his name on the bill’’ put forth by a bipartisan 

group.63 Mr. Scofield replied with his thoughts on which measure 

or legislative coalition Representative Gutie ́rrez should support.64

While there is no indication Mr. Scofield was asked to draft any 

part of an immigration bill, a member of Representative Gutie ́rrez’s 

staff did consult with Mr. Scofield on language for a separate bill 

in September 2009. On that occasion, a staff member asked for Mr. 

Scofield’s input on the wording of a criminal penalties provision for 

legislation Representative Gutie ́rrez planned to introduce regarding 

employer-owned life insurance.65 The staffer had drafted the penalty provision of the bill and asked Mr. Scofield: ‘‘Do you think this 

is what the Congressman was talking about in terms of criminal 

penalties?’’ The Committee has no record that Mr. Scofield replied 

to this question, or that Representative Gutie ́rrez was aware his 

staff asked it. 

Mr. Scofield was also apparently involved in drafting or editing 

legislative testimony: in April 2012, the then-Legislative Director 

asked Mr. Scofield to advise on changes to a draft oral statement 

on the subject of racial profiling to be delivered by Representative 

12 

66 Exhibit 18. 67 18(a) Interview of Doug Scofield. 68 Id. 69 Id. 70 Exhibit 19. 71 Exhibit 20. 72 18(a) Interview of Representative Gutie ́rrez. 73 18(a) Interview of Doug Scofield. 74 Exhibit 21. 

Gutie ́rrez at a hearing of the Senate Judiciary Subcommittee on 

the Constitution, Human Rights, and Civil Rights.66

Mr. Scofield told Committee staff that any work he may have 

performed relating to legislation was ‘‘strategic messaging’’ of Representative Gutie ́rrez’s positions, and thus a communications function permitted under the contract.67 When questioned about examples of his potential involvement in the legislative process, Mr. Scofield stated that ‘‘virtually everything that comes through a congressional office has a legislative component,’’ and he only considered those things a ‘‘legislative assistant does day-to-day, attending 

committee hearings, tracking legislation, writing an analysis of a 

bill’’ as the kind of ‘‘legislative’’ tasks he could not perform.68 However, Mr. Scofield acknowledged he may have performed ‘‘legislative’’ tasks he was not authorized to perform under the contract, 

stating: ‘‘Did they ask me to do some things on the continuum that 

are more legislative than others? I suppose they did.’’ 69

In addition to performing work for Representative Gutie ́rrez’s office that appeared to include a legislative component, Mr. Scofield 

also performed a number of office management and administrative 

functions that closely approximated the duties of senior members 

of Representative Gutie ́rrez’s official staff. These functions were not 

clearly detailed in the ‘‘Scope of Work’’ section of the Scofield contract, and do not resemble the types of ‘‘general office services’’ the 

Member’s Handbook permits contractors to perform. For example: • In February 2010, the then-Chief of Staff asked Mr. Scofield to 

talk with an applicant for a ‘‘press’’ position with Representative 

Gutie ́rrez’s office, both to inform him of the demands of the job and 

to answer his questions about the position.70

• In a memorandum addressed from Representative Gutie ́rrez 

and written by his Chief of Staff, Mr. Scofield and Representative 

Gutie ́rrez’s Communications Director were asked to coordinate 

whenever they took vacation time ‘‘to ensure that [the] office always has press and communications coverage.’’ 71 When asked 

about the memorandum, Representative Gutie ́rrez told Committee 

staff he expected Mr. Scofield ‘‘would be there’’ whenever the Communications Director was out of the office, so ‘‘someone of his stature and someone of his competence [would] be in a position to answer questions to the media and the press and to help [Representative Gutie ́rrez].’’ 72

• Mr. Scofield told Committee staff Representative Gutie ́rrez 

asked him to get ‘‘a little more involved in the district office,’’ to 

provide ‘‘leadership’’ in the office and fill a ‘‘vacuum in leadership’’ 

following the District Director’s demotion in 2012.73

• In a September 2012 email to Mr. Scofield and the then-Chief 

of Staff, Representative Gutie ́rrez instructed Mr. Scofield to ‘‘evaluate district operations and report changes and improvements,’’ prepare staff evaluations and ‘‘make recommendations as to [staff] 

conditioned employment.’’ 74 While the Committee’s investigation 

13 

75 18(a) Interview of Representative Gutie ́rrez. 76 18(a) Interview of Doug Scofield. 77 Id. 78 Exhibits 22 and 23; 18(a) Interview of Doug Scofield (‘‘I don’t remember being paid for it.’’). 

Committee staff also found no FEC records reflecting payments from Representative Gutie ́rrez’s 

campaign committee to Mr. Scofield or Scofield Communications for work done in 2010 on the 

‘‘Joint Black Latino Luncheons.’’ However, FEC records show that Representative Gutie ́rrez used campaign funds to pay for meals for at least one of those meetings. 79 18(a) Interview of Staffer C. 80 Id. 81 18(a) Interview of Doug Scofield. 82 18(a) Interview of Staffer C; 18(a) Interview of Doug Scofield. 

could not confirm whether Mr. Scofield actually performed staff 

evaluations or made related recommendations, Representative 

Gutie ́rrez said he was ‘‘sure’’ that Mr. Scofield evaluated district 

operations and reported on changes or improvements to him.75

Finally, along with his substantial work for Representative 

Gutie ́rrez’s official office, Mr. Scofield also worked on a variety of 

campaign-related tasks for Representative Gutie ́rrez, including, but 

not limited to: planning and staffing district campaign events; preparing scripts for ‘‘robo calls’’; and assisting with fundraisers.76 On 

at least one occasion, in January 2008, Mr. Scofield also reviewed 

Representative Gutie ́rrez’s responses to a local news outlet’s ‘‘meet 

the candidates’’ questionnaire. Though Mr. Scofield told Committee 

staff he billed Representative Gutie ́rrez’s campaign committee separately for some campaign work, he also explained there were a 

handful of ‘‘incidental’’ campaign tasks ‘‘that required little time or 

effort’’ for which he volunteered his time.77 Among such unpaid 

tasks, Mr. Scofield and Scofield Communications staff issued meeting invitations and placed follow-up calls to Black and Latino elected officials from Chicago, who convened on at least two occasions 

to discuss ‘‘common priorities and concerns’’ in anticipation of the 

2010 general election.78

E. Termination of the Contract 

In May 2013, Paul Singer, a reporter with USA Today, contacted 

Representative Gutie ́rrez’s staff with questions about the Scofield 

contract. This was not the first time questions about the contract 

were raised. Representative Gutie ́rrez’s Communications Director 

testified that ‘‘a year earlier [in 2012], a reporter got in touch with 

us about Scofield and whether he was under contract with our office.’’ 79 The Communications Director recalled a separate press inquiry about the contract in 2010,80 and Mr. Scofield recalled previous press calls about the contract, likely in 2007 or 2008.81

Representative Gutie ́rrez, for his part, told the Committee he 

was unaware of these prior press inquiries, and that he first 

learned that there were questions about the Scofield contract in 

May 2013. Neither the Communications Director nor Mr. Scofield 

appear to have discussed the earlier press questions with Representative Gutie ́rrez at the time they were raised, and Representative Gutie ́rrez noted that no press stories resulted from the earlier 

press inquiries.82

On May 30, 2013, Representative Gutie ́rrez’s Communications 

Director sent the following response to Mr. Singer: 

Doug Scofield, the Congressman’s former Chief of Staff, 

through the Scofield Company, works with District staff on 

a wide range of concerns, training them to run the office 

14 

83 Exhibit 24. 84 18(a) Interview of Staffer A. 85 18(a) Interview of Doug Scofield. 86 Id. 87 Exhibit 25; 18(a) Interview of Staffer A (‘‘[T]he exercise of having to regenerate a contract 

and get it signed to submit to Finance, because they needed a copy of it, was . . . what communicated to me that Finance reviews it [every Congress].’’). 88 Exhibit 26. 89Paul Singer, ‘‘Rep. Gutie ́rrez pays Chicago lobbyist with tax dollars,’’ USA Today, June 6, 

2013, available at https://www.usatoday.com/story/news/politics/2013/06/05/gutierrez-chicagolobbyist-scofield-staff-congress-democrat/2391499/ (last accessed Mar. 6, 2018). 90 Id. 91 Id. 92 Id. 

and handle constituent services, management and everything else they do. He trained me and still works with me 

on some press issues, especially Chicago-related press and 

who is who, and helps draft or edit some statements and 

speeches.83

Representative Gutie ́rrez’s Chief of Staff helped respond to Mr. 

Singer’s questions by reviewing the office’s records on the Scofield 

contract. She found the office’s files ‘‘didn’t have much more’’ than 

the then-Chief of Staff’s 2003 fax transmission to CHA.84 Due to 

the lack of records, Representative Gutie ́rrez’s staff sought Mr. Scofield’s assistance in responding to Mr. Singer’s inquiry. Mr. Scofield 

testified the Chief of Staff told him Representative Gutie ́rrez’s 

records did not necessarily indicate that the contract had been approved repeatedly,85 and they were not sure ‘‘that all of the appropriate procedures had been followed for approval.’’ 86

In response to Mr. Singer’s questions, Representative Gutie ́rrez’s 

Chief of Staff also consulted with CHA. The Chief of Staff provided 

CHA with several iterations of the Scofield contract, and told CHA 

staff the contract had been approved by House Finance every Congress.87

On June 4, 2013, Mr. Scofield wrote Representative Gutie ́rrez’s 

Chief of Staff and Communications Director with his views on some 

of the reporter’s allegations, stating: 

The case they can make is that I do government work 

outside the scope of the contact, though if you read the 

contract it really is quite broad. We are following the language of a repeatedly approved House contract, and the 

worst that can be said is that I might occasionally do more 

government, official work than is specifically authorized.88

On June 5, 2013, USA Today published a report by Mr. Singer 

on Mr. Scofield’s contract with Representative Gutie ́rrez, which 

noted Mr. Scofield had been retained since March 2003 to assist 

with training and ‘‘non-legislative message development.’’ 89 Mr. 

Singer’s article also alleged that ‘‘Scofield has represented clients 

in his communication and lobbying practice, including some for 

whom Gutie ́rrez has sought federal aid.’’ 90 The article quoted a 

spokesperson from CHA’s minority staff who ‘‘confirmed the contract was approved.’’ 91 Mr. Singer’s article also stated: ‘‘[I]n light 

of questions raised by USA Today, [Representative] Gutie ́rrez has 

asked the House Administration Committee to review the contract.’’ 92

15 

93 18(a) Interview of Staffer A. 94 18(a) Interview of Staffer A. 95 18(a) Interview of Representative Gutie ́rrez. 96 Id. 97 Exhibit 2 at 8. 98 18(a) Interview of Representative Gutie ́rrez. 99 Exhibit 27. 

On June 12, 2013, Representative Gutie ́rrez’s Chief of Staff and 

several CHA staff members met to discuss the contract.93 CHA 

staff told Committee staff that, at that meeting, they raised various 

concerns with the contract. For example: 

• Based on the Chief of Staff’s description of Mr. Scofield’s duties, CHA staff was concerned Mr. Scofield had performed in a 

manner equivalent to official staff in some circumstances. For example, CHA staff observed that preparing remarks and press 

events are core duties of regular staff. Moreover, the type of ‘‘training’’ Mr. Scofield provided might also be typically provided by a 

Chief of Staff, Communications Director, or District Director. 

• CHA staff was also concerned that the term ‘‘non-legislative 

message development,’’ which was used in invoices to describe the 

firm’s monthly work, was undefined by the contract, particularly in 

light of the potential difficulty in separating matters relating to a 

Member’s voting decisions (i.e., ‘‘legislative’’ activity) from his or 

her message generally. 

• The absence of any written documentation relating to CHA’s 

review or approval of the contract was also a significant issue. 

According to the Chief of Staff, based on these concerns, CHA 

staff told her they did not recommend the contract continue ‘‘as is,’’ 

and it should be either revised or cancelled.94 Representative 

Gutie ́rrez told Committee staff that, until this point, he was unaware of CHA or House Finance having or raising any concerns 

with him or his staff about the contract.95

It is also worth noting that many of the concerns CHA staff expressed in 2013 related to the explicit terms of the Scofield contract—which CHA itself may have reviewed in 2003, and which 

House Finance received and did not object to over several subsequent congresses. 

Following the Chief of Staff’s meeting with CHA staff, she relayed the concerns CHA staff had expressed to Representative 

Gutie ́rrez, who decided to promptly terminate the Scofield contract. 

When Committee staff asked Representative Gutie ́rrez what he 

then understood to be the problem with the contract, he said ‘‘there 

could have been instances in which Doug Scofield acted as a consultant and/or an employee outside of the parameters of the contract.’’ 96 Representative Gutie ́rrez told OCE that, at that time, he 

‘‘saw that there were only two options: Mr. Scofield would have to 

become a full-time employee of the congressional office or he would 

have to resign.’’ 97 However, Mr. Scofield did not wish to return as 

a congressional employee. As Representative Gutie ́rrez explained to 

Committee staff: ‘‘I looked at [Mr. Scofield’s] contract, and as you 

can see his contract is very broad . . . it was pretty clear that you 

could blur the lines and if there is a blurring of the lines, you 

should let somebody go.’’ 98 On June 13, 2013, Representative 

Gutie ́rrez informed Mr. Scofield that he was cancelling the contract.99 Scofield Communications was paid for services rendered 

16 

100See Statement of Disbursements of the House, July 1, 2013 through September 30, 2013, 

at 903, available at https://www.house.gov/sites/default/files/uploads/documents/ 

2013q3llsinglevolume.pdf (last accessed Mar. 6, 2018); 18(a) Interview of Doug Scofield. 101See supra Section IV.E. 102 Exhibit 28; see also 18(a) Interview of Doug Scofield. 103 18(a) Interview of Doug Scofield; 18(a) Interview of Representative Gutie ́rrez. 104 18(a) Interview of Representative Gutie ́rrez. 105 Exhibit 2 at 7. 106 Id. 107 18(a) Interview of Doug Scofield. 108 Id. 109 Id. 110 Exhibit 29 at 1. 

through June 13, 2013, at which point Mr. Scofield and his firm did 

no more work for Representative Gutie ́rrez.100

F. Potential Lobbying Activities by Scofield Communications 

As previously noted, the June 2013 USA Today article included 

allegations that two Scofield Communications clients—the Greater 

Chicago Food Depository and the Chicago Botanical Garden— 

sought federal earmarks from Representative Gutie ́rrez while Mr. 

Scofield was under contract with his congressional office.101

Though Mr. Scofield registered as a lobbyist with the State of Illinois soon after forming Scofield Communications in 2003, he has 

never been registered as a federal lobbyist for any entity.102 Both 

Mr. Scofield and Representative Gutie ́rrez testified that no one 

from Scofield Communications ever lobbied Representative 

Gutie ́rrez or his congressional office.103 Representative Gutie ́rrez 

also testified that he might have spoken with Mr. Scofield about 

his work at the Illinois state government level, but he never had 

a conversation with Mr. Scofield about being a registered lobbyist 

in Illinois.104 However, Representative Gutie ́rrez told OCE that, 

after the press inquiries regarding Mr. Scofield’s status as a registered state lobbyist, he determined it would be difficult to continue his contract with Mr. Scofield.105 Representative Gutie ́rrez 

also stated it would have been difficult to identify and avoid potential conflicts of interests in the future, even if positions he were to 

take were wholly independent of Mr. Scofield’s lobbying work.106

1. Greater Chicago Food Depository 

Scofield Communications engaged in state-level lobbying on behalf of the Greater Chicago Food Depository (Food Depository), 

though Mr. Scofield testified that his firm never did any federal 

lobbying for the organization.107 While Mr. Scofield was retained 

under contract, the Food Depository did have a ‘‘big federal project 

. . . building a large building in [Representative Gutie ́rrez’s] district.’’ 108 However, Mr. Scofield stated the Food Depository never 

spoke to him about the project, nor did he discuss the project with 

Representative Gutie ́rrez. Mr. Scofield told Committee staff: ‘‘I had 

no role in it.’’ 109

In March 2004, Representative Gutie ́rrez co-signed a letter drafted by Representative William Lipinski to Representative James 

Walsh, Chairman of the Appropriations Subcommittee on VA, HUD 

and Independent Agencies, in support of a $2 million earmark for 

the Food Depository.110 On July 20, 2004, Mr. Scofield emailed 

Representative Gutie ́rrez’s then-Chief of Staff and asked: ‘‘What do 

you think is the timing for any decision regarding the appropriation? Thanks, as always. Also, Food Depository success will help 

17 

111 Exhibit 30. 112 18(a) Interview of Doug Scofield. 113 18(a) Interview of Former Staffer A. 114 Id. 115 Id. 116 Exhibit 31; see also Exhibit 32. 117 Exhibit 26. 118 Exhibit 32. 

me to clear my mind and find a wealthy and handsome husband 

for you.’’ 111 Neither Mr. Scofield’s nor Representative Gutie ́rrez’s 

productions to the Committee included any replies to this communication. 

When Committee staff asked Mr. Scofield about this email, he 

said a representative from the Food Depository had called him, because she knew he worked for Representative Gutie ́rrez, to ask 

whether he could find out about the status of the appropriation request.112 Representative Gutie ́rrez’s then-Chief of Staff told Committee staff she did not recall having any discussions with Mr. Scofield about the timing of any appropriation to the Food Depository.113 The then-Chief of Staff said she did not handle appropriations as part of her duties, but ‘‘if [Mr. Scofield] had made a call 

to the staff about this . . . [she] probably would have been alerted 

by the staff.’’ 114 She said she ‘‘must have had’’ other communications with Mr. Scofield about the Food Depository, though she did 

not recall specific conversations on the subject. Nor did she recall 

anyone else in Representative Gutie ́rrez’s office having communications with Mr. Scofield about the Food Depository.115

The Food Depository received federal funding as part of a 2005 

omnibus appropriations bill. An undated internal memorandum 

prepared by Representative Gutie ́rrez’s staff labeled ‘‘2005 Appropriations: Member Project Requests’’ listed appropriations requests 

made by Representative Gutie ́rrez that made it into the final bill. 

The memo included an entry for ‘‘VA–HUD Greater Chicago Food 

Depository,’’ in the amount of $539,500, which was listed under the 

heading ‘‘Projects We Supported, But Did Not Take the Lead 

On.’’ 116

Around the time of the USA Today story in June 2013, Mr. Scofield discussed his work for the Food Depository by email with Representative Gutie ́rrez’s Chief of Staff and Communications Director, when he provided his views on some of the reporter’s allegations. Mr. Scofield wrote: 

On the food depository, I would re-emphasize that I simply did not talk to Luis about money. A member of Congress supporting an appropriation for a food bank that 

feeds hungry people in his district is both routine and admirable, and in this case not caused or initiated by me— 

it was led by [Representative] Lipinski and [Senator] Durbin.117

In a separate email, Mr. Scofield stated: ‘‘I think we can be more 

emphatic—[Representative Gutie ́rrez] and Doug Scofield did not 

have any discussions about funding for the food depository. I 

strongly believe that is accurate.’’ 118

All of the current and former members of Representative 

Gutie ́rrez’s staff who were interviewed by Committee staff said neiVerDate Sep 11 2014 05:45 Mar 29, 2018 Jkt 029435 PO 00000 Frm 00025 Fmt 6659 Sfmt 6602 E:\HR\OC\HR617.XXX HR617
18 

119See, e.g., 18(a) Interview of Staffer A; 18(a) Interview of Staffer C; 18(a) Interview of 

Former Staffer A; 18(a) Interview of Former Staffer B. 120 18(a) Interview of Doug Scofield. 121 Exhibit 33. 122 Exhibit 26. 123See, e.g., 18(a) Interview of Staffer A; 18(a) Interview of Staffer C; 18(a) Interview of 

Former Staffer A; 18(a) Interview of Former Staffer B. 124 18(a) Interview of Doug Scofield. 125 Exhibit 34. 126 Id. 

ther Mr. Scofield nor anyone associated with Scofield Communications ever lobbied them on behalf of the Food Depository.119

2. Chicago Botanical Gardens 

Mr. Scofield told Committee staff the Chicago Botanical Gardens 

might have been registered as a lobbying client of Scofield Communications, though he did not advocate for the organization at the 

federal level.120 In March 2010, Representative Gutie ́rrez sent a 

letter of support to the Chair and Ranking Member of the House 

Appropriations Subcommittee on Agriculture, Rural Development, 

Food and Drug Administration, and Related Agencies for a 

$620,000 earmark for the Chicago Botanical Gardens.121 The Committee’s investigation revealed no evidence that Mr. Scofield or 

anyone from Scofield Communications was involved in requesting 

or otherwise preparing this letter. 

By email to Representative Gutie ́rrez’s Chief of Staff and Communications Director, Mr. Scofield commented on the allegations 

from the USA Today story: 

I never lobbied for the Chicago Botanic Garden and I 

don’t know anything about an earmark for them and had 

nothing to do with it. They were briefly a [public relations] 

client. I never personally did any work for them at all— 

it would have been other staff members of the company, 

and it wouldn’t have had anything to do with Luis. I had 

no contact, ever, with anyone on the Congressional staff, 

or Luis, about the Botanical Garden.122

All the current and former members of Representative 

Gutie ́rrez’s staff who were interviewed by Committee staff stated 

that neither Mr. Scofield nor anyone associated with Scofield Communications ever lobbied them on behalf of the Chicago Botanical 

Gardens.123

3. National Museum of Puerto Rican Arts and Culture 

Mr. Scofield told Committee staff the National Museum of Puerto 

Rican Arts and Culture (IPRAC) was a fundraising client, not a 

lobbying client, of Scofield Communications.124 Thus, Scofield Communications helped IPRAC raise money, but did not lobby for state 

or federal appropriations on the organization’s behalf. However, in 

March 2007, a Scofield Communications employee sent Representative Gutie ́rrez’s then-Chief of Staff a completed federal funding request form for IPRAC, for the Subcommittee on Transportation, 

Housing and Urban Development, and Related Agencies for FY 

2008.125 Mr. Scofield’s wife, who was then employed by Scofield 

Communications, later communicated with the then-Chief of Staff 

on the funding request, in July 2007.126 Mr. Scofield’s wife told the 

then-Chief of Staff that she would send her a copy of their previous 

19 

127 Id. 128 18(a) Interview of Doug Scofield (‘‘Q: Were you involved in any work done by Representative Gutie ́rrez on behalf of IPRAC in that VA–HUD Appropriations bill? A: No.’’). 129 18(a) Interview of Representative Gutie ́rrez. 130 Exhibit 35; see also 18(a) Interview of Former Staffer B (‘‘The only name that is referenced 

here is Natalie Angelo, who I think handled appropriations back then.’’). 131 Exhibit 35. 132 18(a) Interview of Former Staffer B. 133 18(a) Interview of Doug Scofield; 18(a) Interview of Former Scofield Communications Employee. 134See, e.g., 18(a) Interview of Staffer A; 18(a) Interview of Staffer C; 18(a) Interview of 

Former Staffer A; 18(a) Interview of Former Staffer B. 135 31 U.S.C. § 1301(a). 

correspondence on the subject, and noted: ‘‘That was the last correspondence there was on this except conversations that took place 

between Doug and Luis.’’ 127 Mr. Scofield told Committee staff he 

was not involved in any work done by Representative Gutie ́rrez on 

behalf of IPRAC in the fiscal year 2008 appropriations bill passed 

by the House.128 Representative Gutie ́rrez also told Committee 

staff he could not recall having any conversations with Mr. Scofield 

about IPRAC’s funding request.129

In July 2007, a Scofield Communications employee emailed Representative Gutie ́rrez’s then-Deputy Chief of Staff and another staff 

member who handled appropriations matters, attaching a template 

of a letter of support for Senator Durbin to ‘‘help secure the funds 

for IPRAC.’’ 130 The email noted Mr. Scofield had been ‘‘giving his 

input’’ on the letter. The Deputy Chief of Staff asked: ‘‘Is the objective to ask the Senator to support the House position in the 

Approps Conference?’’ The Scofield Communications employee responded: ‘‘we [want] him to protect and support the $150,000 Congressman Gutie ́rrez has secured in the [H]ouse.’’ Representative 

Gutie ́rrez’s Deputy Chief of Staff then provided the Scofield Communications employee with some suggestions on the letter.131

When asked about this email, the then-Deputy Chief of Staff said 

that he did not recall why an employee of Scofield Communications 

would have written him about IPRAC.132 In their testimony to 

Committee staff, neither Mr. Scofield nor the former Scofield Communications employee could recall IPRAC requesting federal funding.133

Each of the current and former members of Representative 

Gutie ́rrez’s staff who were interviewed by Committee staff stated 

that neither Mr. Scofield nor anyone associated with Scofield Communications ever lobbied them on IPRAC’s behalf.134

V. FINDINGS 

A. Unauthorized Use of the Members’ Representational Allowance 

Federal appropriations law, which states ‘‘[a]ppropriations shall 

be applied only to the objects for which the appropriations were 

made,’’ restricts use of the MRA to only those purposes and reimbursements authorized by federal law or CHA regulations governing the reimbursement of expenses from a Member’s MRA.135

The Members’ Handbook, which details those regulations, says 

Member offices are authorized to retain contractors, not consultants. The Member’s Handbook in effect at the time the Scofield 

Communications contract was in place also states Members, using 

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136 Exhibit 1 at 13. 137 In 2015, CHA publicly announced the creation of a working group ‘‘to review current House 

regulations and explore ways to strengthen the regulations governing official expenses, as well 

as ways to enhance the training and educational opportunities available to assist each office 

with compliance.’’ Comm. on House Admin., ‘‘Committee Members to Review House Regulations 

Governing Official Expenses,’’ Mar. 27, 2015, available at https://cha.house.gov/press-release/ 

committee-members-review-house-regulations-governing-official-expenses (last accessed Mar. 6, 

2018). 138 Neither Representative Gutie ́rrez nor Mr. Scofield has asserted that, while Scofield Communications was a contractor for Representative Gutie ́rrez’s office, Mr. Scofield performed any 

official work for the office in an unpaid, volunteer capacity. Thus, the Committee assumed Scofield Communications was paid, using MRA funds, for all of the official work it performed for 

Representative Gutie ́rrez’s office. If Mr. Scofield or Scofield Communications had performed 

work for the official office in a volunteer capacity, that would likely violate House Rule, XXIV, 

clause 1(a), which prohibits the maintenance of an ‘‘unofficial office account.’’ See Ethics Manual 

at 284 (‘‘[I]n addition to money, the prohibition on unofficial office accounts proscribes the private, in-kind contribution of goods or services for official purposes.’’); see also id. at 288 (‘‘A 

Member or House office may accept the temporary services of a volunteer, provided the Member 

or office has a clearly defined program to assure that: (1) The voluntary service is of significant 

educational benefit to the participant; and (2) such voluntary assistance does not supplant the 

normal and regular duties of paid employees. In this regard, limitations should be imposed on 

. . . the duration of services any one volunteer may provide.’’). Indeed, the Committee has previously found that permitting a former Chief of Staff to volunteer with an office, in a capacity 

that included routine political advice to the Member, violated the prohibition on unofficial aceral, non-legislative, office services . . . for a specific, limited period not to exceed the Member’s term.’’ 136

The Members’ Handbook advises Members to consult the CHA 

when entering into agreements with contractors. The Committee 

found Representative Gutie ́rrez took appropriate steps to get approval for the initial contract with Scofield Communications. While 

the Committee’s investigation did not reveal conclusive evidence regarding CHA approval of the Scofield Communications contract, 

there is substantial evidence that CHA and the House Finance office either expressly approved Representative Gutie ́rrez’s contract 

with Scofield Communications, or at a minimum raised no objection 

to that contract from 2003 to 2013, until the press inquiries that 

eventually prompted Representative Gutie ́rrez to terminate the 

contract. Once Representative Gutie ́rrez became aware of CHA’s 

concerns over the contract in 2013, he also took appropriate steps 

to address those concerns. 

It could be argued that some of the work the contract expressly 

authorized Mr. Scofield to do was beyond the scope of what CHA’s 

Members’ Handbook anticipated for contractors. However, the Committee did not find Representative Gutie ́rrez at fault for permitting 

a contractor to perform work consistent with a contract that CHA— 

the entity that authors the Members’ Handbook—appears to have 

reviewed and not objected to. Moreover, CHA has subsequently 

taken steps to review its regulations governing use of the MRA and 

related oversight processes.137

A significant portion of Mr. Scofield’s work from 2003 to 2013 

also accorded with the contract’s terms and with the guidance in 

the Members’ Handbook. Mr. Scofield regularly edited remarks prepared by official staff, assisted in responding to press inquiries, 

drafted press statements and speeches, organized staff retreats, 

and conducted training—all activities specified in the contract’s 

scope of work. 

On the other hand, to the extent Representative Gutie ́rrez used 

MRA funds to compensate Mr. Scofield for performing services that 

were both outside the scope of the contract that CHA reviewed and 

not authorized by the regulations detailed in the Members’ Handbook, such disbursements were not permissible.138 And while a sigVerDate Sep 11 2014 05:45 Mar 29, 2018 Jkt 029435 PO 00000 Frm 00028 Fmt 6659 Sfmt 6602 E:\HR\OC\HR617.XXX HR617
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counts. See House Comm. on Standards of Official Conduct, In the Matter of Rep. E.G. ‘‘Bud’’ 

Shuster, H. Rep. 106–979, 106th Cong., 2d Sess. at 44–51 (2000). 139 Exhibit 1 at 13. The Members’ Handbook, which was last updated on February 27, 2018, 

currently includes a revised contractor rule stating that general office services should be ‘‘outside core office functions.’’ 140 18(a) Interview of Doug Scofield. 141 Exhibit 11 at 2. 142 Id. 143 Id. 144 Exhibit 15. 

nificant portion of the work Mr. Scofield and his firm performed for 

Representative Gutie ́rrez’s office was within the contract’s broad 

terms—and fit the contract’s description of ‘‘non-legislative, general 

office services’’—some of the services provided appeared to be ‘‘legislative’’ in nature, or otherwise exceeded both the contract’s scope 

and Members’ Handbook guidelines governing the work contractors 

may perform for a congressional office. The phrases ‘‘non-legislative’’ and ‘‘general office services’’ are both important to this determination. 

The Committee is unaware of a specific definition for a ‘‘legislative’’ task in this context, either in the CHA regulations or in the 

Committee’s guidance. Nor does the contract between Representative Gutie ́rrez and Scofield Communications supply a definition. 

However, it is reasonable to conclude that a contractor who is retained to perform ‘‘non-legislative’’ work should not be actively involved in a Member’s decisions regarding whether, when, or how 

to introduce legislation. The phrase ‘‘general office services’’ is also 

important, as it modifies ‘‘non-legislative’’ in both the Scofield contract and the CHA guidelines regarding retention of contractors by 

personal offices. The Members’ Handbook does not define ‘‘general 

office services,’’ but it does provide some representative examples: 

‘‘equipment maintenance, systems integration, data entry, staff 

training, photography, custodial services.’’ 139 Notably, none of 

these tasks are even remotely related to the process of crafting and 

passing legislation. 

Generally speaking, both Representative Gutie ́rrez and Mr. Scofield acknowledged that some of Mr. Scofield’s work had at least 

some ‘‘legislative component.’’ When discussing his work generally, 

Mr. Scofield told Committee staff: ‘‘Did they ask me to do some 

things on the continuum that are more legislative than others? I 

suppose they did.’’ 140 Two incidents in particular illustrate the accuracy of this statement. 

First, in September 2009, Representative Gutie ́rrez’s then-Legislative Director emailed Mr. Scofield to tell him she ‘‘just sat down 

with the Congressman to discuss how to keep the pressure on the 

immigration debate, to keep things moving forward.’’ 141 The thenLegislative Director clarified this ‘‘was not a conversation about bill 

content (although I am readying a bill), but about strategy: what 

kind of bill, how to roll it out and with whom.’’ 142 The then-Legislative Director explained they ‘‘talked about a number of considerations with regard to strategy,’’ and said ‘‘the boss asked me to . . . 

get your opinion on them.’’ 143 This request was repeated in January 2013, when Representative Gutie ́rrez sought Mr. Scofield’s 

‘‘guidance on some key decisions’’ with respect to various immigration bills being developed in the House.144 At Representative 

Gutie ́rrez’s request, the then-Legislative Director prepared a 

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145 Id. 146See supra Section IV.D (discussing Exhibit 17). 147 18(a) Interview of Doug Scofield. 148See Exhibit 1 at 5. 149Supra note 49. 150 18(a) Interview of Representative Gutie ́rrez. 

opments and strategic considerations, in preparation for a discussion as to what particular bill(s) Representative Gutie ́rrez should 

sponsor or otherwise support.145

Moreover, as previously discussed, on at least one occasion, Representative Gutie ́rrez’s staff directly consulted Mr. Scofield for his 

input on a bill’s substantive language.146 While it is unclear whether or how Mr. Scofield responded, there is no evidence in the record 

that Mr. Scofield ever declined to answer any question the official 

staff directed to him, or refused any request to do any particular 

task. Nor is there any evidence Mr. Scofield ever raised concerns 

that anything he was asked to do was beyond the scope of Scofield 

Communications’ contract with Representative Gutie ́rrez. Moreover, the mere fact that a member of Representative Gutie ́rrez’s 

staff would ask Mr. Scofield to weigh in on the language of a bill 

she was drafting for the Congressman suggests Representative 

Gutie ́rrez did not set, or communicate to staff, clear limits on Mr. 

Scofield’s services to the office. 

Mr. Scofield told Committee staff he understood the contract to 

broadly permit his work on communications-related tasks for Representative Gutie ́rrez, and that any work he may have performed 

relating to legislation was ‘‘strategic messaging’’ of Representative 

Gutie ́rrez’s positions, and thus a communications function. When 

questioned about documents that appeared to show his involvement advising Representative Gutie ́rrez on strategic decisions regarding whether, when, and how to introduce legislation, Mr. Scofield stated ‘‘virtually everything that comes through a congressional office has a legislative component,’’ and that he only considered those things a ‘‘legislative assistant does day-to-day, attending 

committee hearings, tracking legislation, writing an analysis of a 

bill’’ as the kind of ‘‘legislative’’ tasks he could not perform.147 Yet 

there is no basis for concluding that ‘‘legislative’’ work is limited to 

those tasks typically done by a legislative assistant. To start, the 

examples of permissible contractor services in the Member’s Handbook involve no ‘‘legislative component’’ whatsoever,148 which suggests Mr. Scofield’s interpretation of where the line falls is overly 

restrictive. Further, while it is true that Mr. Scofield’s input on decisions about whether, when, and how to introduce legislation may 

have had a messaging-related component, they were also integral 

to the legislative process. Indeed, even some of Mr. Scofield’s communications work was deeply intertwined in the legislative process, 

such as when he drafted, edited and commented on speeches Representative Gutie ́rrez gave on the House Floor, some of which related to legislation.149

Notwithstanding any ambiguities over whether some of the services Mr. Scofield provided under the contract were more ‘‘legislative’’ in nature, Congressman Gutie ́rrez has argued that the contract was broad and, more importantly, repeatedly ‘‘approved’’ by 

CHA.150 Representative Gutie ́rrez has also asserted that neither 

CHA nor the House Finance Office, when it received new copies of 

the Scofield contract at the beginning of each Congress, objected to 

23 

151 Id. 152 Exhibit 26. 153 Under the contract, Scofield Communications was paid a monthly fee of $5,500 from March to June 2003, which was reduced to $4,500 month beginning in July 1, 2003. See Exhibit 6. The 

firm was apparently paid at that same rate through 2008 and 2009. See Exhibit 36. By comparison, Representative Gutie ́rrez’s Communications Director was paid an average of $4,631.94 per month in 2004; in 2008, his Press Secretary was paid an average of $4,408.65 per month. Meanwhile, the firm’s monthly fee rose to $6,000 per month in January 2013. See Exhibit 7. Current 

and former members of the official staff explained this parity in pay—despite Mr. Scofield’s parttime, contractor status—by saying that Mr. Scofield was highly trained and valued within the 

office for his knowledge of Representative Gutie ́rrez and his communications style. See, e.g., 18(a) Interview of Former Staffer A (‘‘[M]essage is key. And Doug, for better or for worse, mastered that so brilliantly, that he was worth it.’’). 154 Representative Gutie ́rrez Submission (July 18, 2014) at 2. 

the descriptions in the scope of work Mr. Scofield would perform.151

Thus, Representative Gutie ́rrez asserts he reasonably relied on 

such ‘‘approval’’ to conclude that the Scofield contract, as well its 

descriptions of the tasks Mr. Scofield would perform, were permissible and compliant with relevant rules and regulations. To be 

clear, the Committee did not fault Representative Gutie ́rrez for allowing Mr. Scofield and his firm to do the work specified in the 

contract, even if the Committee itself would have raised questions 

about the breadth of the contract in the first instance. 

However, even if CHA approved the Scofield contract, there is no 

indication CHA monitored or was informed of the work Mr. Scofield 

was actually doing for Representative Gutie ́rrez’s office. To the extent Mr. Scofield did work that exceeded the scope of the contract— 

however broad it may have been—CHA’s approval of the contract’s 

terms is no defense. Further, Mr. Scofield acknowledged the possibility that he did more official work for Representative Gutie ́rrez 

than he was authorized to perform under the contract, noting in response to the inquiries from USA Today that ‘‘the worst that can 

be said is that I might occasionally do more government, official 

work than is specifically authorized.’’ 152

There is also substantial evidence that, while the contract described Scofield Communications as an ‘‘independent contractor,’’ 

Representative Gutie ́rrez and his office treated Mr. Scofield as 

equivalent to official staff. As a part-time contractor, Mr. Scofield’s 

annual compensation was at times equal to, if not greater than, the 

salary of a full-time communications staffer in the congressional office.153 In his submissions to the Committee, Representative 

Gutie ́rrez asserted Mr. Scofield’s role in his office was distinct from 

that of official staff because: 

Mr. Scofield had no office space or office hours in either 

the Washington, D.C., or district offices; he did not use 

House equipment or resources to complete tasks associated 

with his contract; he did not utilize a House email address; 

he had no specific job responsibilities, nor did he hire, fire, 

direct or supervise any member of the official staff. Mr. 

Scofield generally received assignments for specific tasks, 

as provided by the contract, primarily from Representative 

Gutie ́rrez, his chief of staff or his communications director.154

While Mr. Scofield may not have had a desk in Representative 

Gutie ́rrez’s congressional offices, he appears to have spent considerable time in a district office in 2012, in order to fill a ‘‘vacuum in 

24 

155 18(a) Interview of Doug Scofield. 156 Exhibit 21. 157 18(a) Interview of Representative Gutie ́rrez. 158 Id. 159Supra Section IV.E. 

leadership’’ following a staff demotion.155 And while Mr. Scofield 

may not have hired or fired any congressional employees, he was 

asked by Representative Gutie ́rrez on one occasion to ‘‘evaluate district operations and report changes and improvements,’’ prepare 

staff evaluations, and ‘‘make recommendations as to [staff] conditioned employment.’’ 156

Further, Representative Gutie ́rrez described Mr. Scofield as ‘‘so 

tightly knit to our staff,’’ that he was consulted ‘‘[w]henever he was 

needed’’ and was expected to ‘‘be there’’ whenever the Communications Director was out of the office, so ‘‘someone of his stature and 

someone of his competence [would] be in a position to answer questions to the media and the press . . .’’ 157 Representative Gutie ́rrez 

told OCE that, given the breadth of the ‘‘Scope of Work’’ in the Scofield contract, ‘‘it was pretty clear that you could blur the lines’’ between what Mr. Scofield could and could not do. Yet Representative 

Gutie ́rrez’s own statements, actions, and failure to supervise both 

his contractor and his official staff contributed to this blurring. The 

difficulty began with Representative Gutie ́rrez’s 2003 statement to 

his then-Chief of Staff that by retaining Scofield Communications, 

the office would have Mr. Scofield ‘‘back on staff.’’ Given this statement and belief, it is not surprising Representative Gutie ́rrez’s official staff would not easily distinguish between Mr. Scofield’s role 

as a contractor and his former role as Chief of Staff. Representative 

Gutie ́rrez also failed to clearly define, and communicate to his 

staff, the boundaries of Mr. Scofield’s role, which likely contributed 

to his performance of work that exceeded the scope of his contract, 

and the staff’s practice of consulting Mr. Scofield on matters outside the contract’s scope. 

Ultimately, the Committee found clear evidence that Representative Gutie ́rrez directly asked Mr. Scofield on various occasions to 

perform work that was ‘‘legislative’’ in nature, beyond the scope of 

the contract Representative Gutie ́rrez personally signed with Scofield Communications, or otherwise impermissible for contractors to 

provide to a congressional office. In addition, it appeared Representative Gutie ́rrez made no effort to communicate to his staff 

any limits on the scope of work which staff could ask Mr. Scofield 

to do. The incident where a legislative assistant asked Mr. Scofield 

for guidance on specific language to insert into a bill illustrated the 

danger of such a ‘‘hands-off’’ approach to retaining a contractor, especially one who had previously served as the office’s Chief of Staff. 

The Committee accepted Representative Gutie ́rrez’s assertion 

that he did not, until allegations surfaced in the press in 2013, ‘‘understand the extraordinary nature’’ of the services Mr. Scofield was 

asked to perform as a contractor, or the House rules and CHA regulations governing such services.158 However, as previously discussed, it appears the press raised questions about Mr. Scofield’s 

work with Representative Gutie ́rrez’s office on several occasions 

prior to the USA Today report in 2013, going back as early as 

2007.159 The precise nature of these inquiries is not clear, and it 

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160See House Comm. on Ethics, In the Matter of Allegations Relating to Representative Ed 

Whitfield, H. Rept. 114–387, 104th Cong. 2nd Sess. 44 (2016) (hereinafter Whitfield) (citing 

House Comm. on Standards of Official Conduct, In the Matter of Representative Richard Stallings, H. Rept. 100–382, 100th Cong. 1st Sess. 5 (1987) (hereinafter Stallings) (noting that the 

Committee has historically ‘‘refused to accept claims of mitigation that ‘would effectively result 

in the condonation of improper action based upon a defense of ignorance of House Rules, stating 

that ‘[s]uch an approach is clearly untenable on its face.’ ’’)). 161 18(a) Interview of Representative Gutie ́rrez. 162 Id. see also id. (describing his decision in 2013 to terminate Mr. Scofield’s contract, Representative Gutie ́rrez stated: ‘‘[A]s I looked at his contract . . . it was pretty clear that you could 

blur the lines.’’). 

field’s role until 2013. However, at a minimum, these inquiries 

could have prompted Representative Gutie ́rrez’s office to re-examine the Scofield contract and consider whether all of Mr. Scofield’s 

work was consistent with the contract’s terms and CHA’s guidance. 

Even before and aside from any press inquiries about Mr. Scofield’s 

role, Representative Gutie ́rrez should have known the rules and 

regulations governing his use of the MRA,160 and should have better supervised Mr. Scofield’s work performance to make sure it accorded with both those rules and the contract’s terms. 

To his credit, when USA Today published its report in 2013, Representative Gutie ́rrez promptly directed his Chief of Staff to consult 

with CHA staff. When CHA staff informed him the contract would 

have to be revised or canceled, Representative Gutie ́rrez immediately terminated the contract. Further, Representative Gutie ́rrez 

told the Committee he has gained a greater understanding of how 

and why Mr. Scofield’s role with his office was in some ways problematic. As Representative Gutie ́rrez explained: 

I have come to the understanding [of] what is a contractor . . . House Administration isn’t going to come to 

my office every 6 months and say, hey, by the way [Mr. 

Scofield] didn’t do this, right? We have to do that internally . . . And so—would I have done it differently? Yeah, 

I would have done it really, really differently . . . [and] I 

know ignorance is not an excuse . . ..161

Likewise, when Committee staff asked Representative Gutie ́rrez 

about instances where he directed staff to consult with Mr. Scofield 

about the kind of immigration bills he should introduce, how he 

should position the bills to achieve passage, and who he should 

work with on the bills, he said: ‘‘I get the legislative stuff, and I 

get where the questions are coming from, that is why [Mr. Scofield] 

was let go.’’ 162

The Committee found no reason to believe that Representative 

Gutie ́rrez or his office intentionally misused the MRA in this case. 

Nor did Representative Gutie ́rrez personally benefit from any misuse of MRA funds. The Committee also accepted Representative 

Gutie ́rrez’s subjective belief that the terms of the contract with Scofield Communications—however broad—were permissible, given his 

understanding that the contract was submitted for CHA’s review, 

and that the House Finance Office continually authorized payments of Scofield Communications invoices from the contract’s inception until its termination in 2013. Yet the evidence is clear that 

some portion of the work for which Representative Gutie ́rrez used 

MRA funds to pay Scofield Communications exceeded the scope of 

the contract, as well as CHA rules defining those tasks that contractors retained by congressional offices may perform. Any use of 

26 

163 Regarding Mr. Scofield’s assistance on ‘‘incidental’’ campaign-related matters, the lack of 

detailed invoices or sufficient division between the performance of official work and campaign 

work could present a problem of appearances: members of the public or individuals unfamiliar 

with Mr. Scofield’s practices might speculate whether Mr. Scofield was paid to do campaign 

work under the general retainer agreement. However, the Committee found no evidence that 

Mr. Scofield or anyone at Scofield Communications was paid for campaign work with MRA 

funds. 164Members’ Handbook at 2; see also Ethics Manual at 323 (‘‘Members may be personally liable for misspent funds or expenditures exceeding the MRA.’’). 165See, e.g., Comm. on Standards of Official Conduct, In the Matter of Representative Charles 

C. Diggs, H. Rept. 96–351, 96th Cong. 1st Sess. (1979) (Member was required to repay House $40,031.66 for the ‘‘personal benefit he received from his misconduct’’ in giving his office staff 

raises and requiring them to pay certain of his personal expenses out of those raises); Comm. 

on Standards of Official Conduct, In the Matter of Adam Clayton Powell, H. Rept. 90–27, 90th Cong. 1st Sess. (1967) (Member was censured and fined $40,000 for various acts, including misappropriating public funds for personal travel, and for paying his wife a salary though she performed no official duties; the Committee noted that the fine would ‘‘offset any civil liability of 

Mr. Powell to the United States of America with respect to’’ the allegations.). 166The Clerk Hire Allowance has since been merged into the MRA. See Legislative Branch 

Appropriations Act, Pub. L. 110–161, Division H, Title I—House of Representatives—Members’ 

Representational Allowances Including Clerk Hire, Official Expenses of Members, and Official 

Mail (2008). 167 In so concluding, the Committee noted ‘‘the individual who authorized the disbursements 

should be held responsible for such actions since the recipient is not in a position to set into 

motion the administrative process resulting in payment.’’ Comm. on Standards of Official Conduct, Summary of Activities, One Hundredth Congress, H. Rept. 100–1125, 100th Cong. 2nd 

Sess. 7 (1989). 

official funds to pay Scofield Communications for such work violated House rules and CHA regulations restricting the MRA to approved uses.163

As the Members’ Handbook states, ‘‘[e]ach Member is personally 

responsible for the payments of any official and representational 

expenses incurred that exceed the provided MRA or that are incurred but are not reimbursable under these regulations.’’ 164 Consistent with this guidance, where Members have used official funds 

for impermissible purposes, the Committee has regularly directed 

them to repay any misspent funds.165 This requirement has most 

frequently arisen in circumstances where official funds were used 

for a Member’s personal benefit or to benefit their campaign, which 

is not the case here. However, the Committee has also made clear 

that a Member is responsible to repay MRA funds used for impermissible purposes, even where neither the Member nor the Member’s campaign benefitted from the use of official funds. Thus, in 

The Matter of Representative Mary Rose Oakar, the Committee concluded that Representative Oakar’s payment of salary to an individual residing and working in New York directly violated House 

and statutory requirements that all individuals paid from the Clerk 

Hire Allowance were required to perform their official duties either 

in Washington, D.C., or in the state or the district represented by 

the Member.166 Though the Committee took no further action in 

the matter—in part because Representative Oakar admitted fault 

and had already reimbursed the U.S. Treasury for any impermissible disbursements—it stated that the Member, ‘‘as the individual 

who authorized the erroneous salary disbursements, bore financial 

responsibility for all payments improperly made.’’ 167

In some cases, however, the Committee has sanctioned Members 

for unauthorized uses of official funds, but has not required them 

to repay such funds. In The Matter of Representative Austin J. 

Murphy, the Committee recommended, and the House voted to 

issue, a reprimand to Representative Murphy for various violations 

of law and House rules, including permitting a private law firm, 

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168 Comm. on Standards of Official Conduct, In the Matter of Representative Austin J. Murphy, H. Rept. 100–485, 100th Cong., 1st Sess. 5 (1987) (hereinafter Murphy). 169 Id. at 4. 170 As the Committee has long made clear, ignorance of the law, rules, and other standards 

of conduct is not a defense or excuse. See supra n.160. 171 Representative Gutie ́rrez also knew, or should have known, there was some limit on Mr. 

Scofield’s relationship with the official office. When Representative Gutie ́rrez signed the contract 

with Scofield Communications, he told his then-Chief of Staff something to the effect of ‘‘we’d 

have Doug back on staff.’’ See Exhibit 2 at 3. But there is no plausible reading of CHA’s guidance on hiring contractors that would allow a Member to hire a contractor to do everything an 

official staffer would do. The Committee does not credit readings of the rules that have no reasonable basis. See, e.g., Comm. on Ethics, In the Matter of Allegations Relating to Representative 

Don Young, H. Rept. 113–487, 113th Cong. 2d Sess. 69 (2014) (hereinafter Young) (Member’s 

receipt of travel ‘‘based on an exception to the gift rule that does not exist’’ was ‘‘not a reasonable difference of opinion on the nature of the rules,’’ but rather ‘‘at best, a grievous error in 

interpretation.’’). To the extent Representative Gutie ́rrez knew or should have known that any 

reasonable reading of the rules required him to limit Mr. Scofield’s work for the office in some 

way, he should have been more mindful of, and attentive to, what those limits were and how 

he could avoid exceeding them. 172See, e.g., Black’s Law Dict. (10th Ed.) (defining de minimis as ‘‘trifling; negligible’’); see also 

Ethics Manual at 96 (lobbyist’s involvement in planning, organizing, requesting, or arranging 

a one-day event trip is permissible under House Rule 25, clause 5(c)(2) only if it is de minimis, meaning ‘‘the involvement of a lobbyist . . . in connection with the trip must be ‘only negligible 

or otherwise inconsequential in terms of time and expense to the overall planning purpose of 

the trip.’ ’’). 173See Murphy at 4. 

plies, and a telephone account paid for with official funds.168 In resolving the matter, it appears the Committee did not discuss the 

possibility of requiring Representative Murphy to reimburse the 

U.S. Treasury for any impermissible disbursements from the MRA, 

nor did it cite the CHA regulation providing that a Member is personally responsible for such disbursements. Rather, the Committee 

noted Representative Murphy ‘‘either disclaimed his knowledge or 

approval of [the improper use of official resources], or asserted that 

such instances were de minimis,’’ and stated ‘‘precise quantification 

of the value of diverted resources is not possible.’’ 169

In this case, Representative Gutie ́rrez cannot claim he was unaware Mr. Scofield was asked to do work that exceeded the scope 

of his contract because, in several instances, it was Representative 

Gutie ́rrez who asked that the work be done. Thus, while Representative Gutie ́rrez may not have been aware of CHA’s guidance on the 

work a contractor may do,170 and may have forgotten how the contracts he repeatedly signed defined those limits, he certainly knew 

Mr. Scofield was told to do ‘‘legislative’’ work, and that Mr. Scofield 

did such work.171 Also unlike the Murphy matter, even though 

Representative Gutie ́rrez asserts he did not learn of press inquiries 

about Mr. Scofield’s contract until May 2013, his office had fielded 

questions about the contract several times, starting years before 

the USA Today article that ultimately caused him to cancel the 

contract. Finally, although the amount of impermissible work may 

have been minimal, relative to the vast majority of the work Mr. 

Scofield appropriately performed, it was not ‘‘de minimis,’’ because 

it was not negligible or inconsequential, given Mr. Scofield’s billing 

rate and the significance of some of the impermissible requests to 

Representative Gutie ́rrez’s legislative goals and official work.172

As in the matter of Representative Murphy, in this case ‘‘precise 

quantification of the value of diverted resources is not possible.’’ 173

Scofield Communications charged Representative Gutie ́rrez’s office 

a flat monthly fee for its services, over a span of over ten years, 

and did not track or itemize the value of its work on discrete tasks 

for the office. As a result, it is difficult to attribute individualized 

sums or hours worked by Mr. Scofield to specific tasks. Nor has 

28 

174 In this case, the formula for determining the monetary value of any impermissible work 

is relatively straightforward: the Committee calculates the proportion of any month’s billable 

work that consisted of impermissible tasks and applies that same proportion to the MRA funds 

disbursed to Scofield Communications. It is the key input to this formula—the amount of time 

that Mr. Scofield dedicated to impermissible work—that the Committee cannot precisely determine. 175 Comm. on Standards of Official Conduct, In the Matter of the Investigation into Officially 

Connected Travel of House Members to Attend the Carib News Foundation Multi-National Business Conferences in 2007 and 2008, H. Rept. 111–422, 111th Cong., 2d. Sess. 2–3 (2010). 176 Id. at n.387. 177 Id. 178 Id. at 75. 179See Young at 62 (ISC could not determine the precise value of lodging and hunting services 

given to a Member because the host ‘‘did not prepare an invoice for the trip’’ and it was unclear 

what hunting services the Member took advantage of. Accordingly, the ISC valued the hunting 

services based on the least expensive option available). 180 Id. at 63 (ISC could not determine the actual value of food eaten by the Member, so it 

valued meals based on the maximum per diem rate for travel in the geographic area where the 

meals were taken). 

Representative Gutie ́rrez proposed any method for calculating the 

value of any MRA funds that may have been improperly spent to 

compensate Scofield Communications for services provided under 

the contract. 

However, the Committee believes Members should be required to 

reimburse the U.S. Treasury for impermissible disbursements from 

the MRA even where the exact amount of such disbursements cannot be determined.174 This is particularly true where the Member 

was aware of, and in fact directed, the impermissible conduct. As 

previously discussed, the Murphy matter, which dealt with circumstances where the misspent funds were arguably de minimis, is distinguishable. In any case, a requirement of ‘‘precise quantification’’ of amounts a Member must repay is not consistent with 

the Committee’s more recent practice and precedent. For example, 

in The Matter of the Investigation into Officially Connected Travel 

of House Members to Attend the Carib News Foundation Multi-National Business Conferences in 2007 and 2008, the Committee required Members to repay the value of travel they received from a 

private sponsor because the sponsor misled the Members and the 

Committee about the sources of funds for the travel.175 In calculating the amounts Members were required to repay, the Investigative Subcommittee (ISC) was unable to determine the precise value 

of the plane tickets Members received, because they were provided 

to the trip sponsor, and then to the Members, at a ‘‘promotional’’ 

rate, but the airline could not determine what ‘‘non-promotional’’ 

tickets, purchased at the same time, would have cost.176 Instead, 

the airline proffered the cost of a ticket purchased on the days the 

travel occurred.177 Faced with an inability to calculate the precise 

value of the tickets, the Committee required Members to repay the 

cost of a same-day ticket,178 even though that price likely exceeded 

the actual cost of the Members’ tickets. In this and other recent 

matters, the Committee has directed Members to make repayments 

even where ‘‘estimating [a] value is imprecise,’’ 179 or determining 

a valuation ‘‘is relatively complicated.’’ 180

Although the Committee could not determine the exact proportion of the payments to Scofield Communication attributable to impermissible work, the Committee has attempted to calculate a reasonable reimbursement amount. In so doing, the Committee placed 

considerable weight on the fact that, while Mr. Scofield occasionally 

performed work for Representative Gutie ́rrez’s office that was either ‘‘legislative’’ in nature or otherwise exceeded the Scope of 

29 

181The Committee’s calculation required some estimation, given the lack of detailed evidence 

as to the work Mr. Scofield performed over the contract’s duration. The Scofield Company never 

provided Representative Gutie ́rrez with invoices itemizing work on specific tasks or subjects; nor 

did Mr. Scofield or Representative Gutie ́rrez’s office maintain any time-keeping records for work 

performed or services billed. However, documents and emails produced to the Committee illustrate Mr. Scofield’s involvement in specific tasks that were clearly legislative in nature or related to core office functions such as office management, as early as fall of 2007. Roughly three 

percent of the documents in the Committee’s possession were identified as pertaining to either 

impermissible legislative or office management work by Mr. Scofield from 2007 until the contract’s termination. Thus, the Committee determined that three percent of the fees charged by 

Mr. Scofield from September 2007 through June 2013, or $9,700, represented a conservative yet 

reasonable estimate of the share of his billings that should not have been paid using MRA 

funds. This estimated repayment amount compares to a total of $590,000 that Representative 

Gutie ́rrez paid to Mr. Scofield using MRA funds across the contract’s ten-year span. The Committee notes that this methodology likely omits some instances of impermissible legislative work 

performed by Mr. Scofield: witnesses testified that Mr. Scofield had regular calls and meetings 

with Representative Gutie ́rrez and staff, the content of which would not necessarily be captured 

in the available documents. 182See Whitfield at 44 (citing In the Matter of Allegations Relating to Representative Phil 

Gingrey, H. Rept. 113–664, 113th Cong. 2d Sess. 25 (2014) (hereinafter Gingrey) (finding violations of House Rules, and issuing a reproval, even though ‘‘the Committee credited Representative Gingrey’s assertion that he believed his actions were consistent with House Rules’’)); see also In the Matter of Allegations Relating to Representative Shelley Berkley, H. Rept. 112–716, 

112th Cong. 2d Sess. 10 (2012) (hereinafter Berkley) (reproval was appropriate even though 

‘‘[t]he ISC found that Representative Berkley mistakenly believed the rules governing what assistance her office could provide to her husband’s practice required only that they treat him in 

the same manner by which they treated any other constituent’’); Stallings at 5 (Committee 

issued a public reproval where the Member was unaware of the applicable House Rule and did 

not intend to violate it). 

Work outlined in the contract, the overwhelming majority of the 

work Mr. Scofield performed from 2003 to 2013 clearly accorded 

with the contract’s terms. Further, it appears the bulk of Mr. Scofield’s ‘‘legislative’’ work for Representative Gutie ́rrez began in the 

fall of 2007 and continued to the contract’s termination in June 

2013, a period when Representative Gutie ́rrez was heavily involved 

in leading the effort for legislative fixes to the immigration system. 

Thus, having reviewed this evidence in light of the totality of the 

circumstances, the Committee believes a reimbursement of $9,700, 

or approximately three percent of the total amounts paid from Representative Gutie ́rrez’s MRA to Scofield Communications from September 2007 until the contract’s termination in June 2013, would 

be appropriate to compensate the U.S. Treasury for any impermissible disbursements of MRA funds to Scofield Communications.181

Having considered the foregoing record and applied the relevant 

standards of conduct and related precedent, the Committee also 

concluded Representative Gutie ́rrez’s conduct in this matter warrants a public reproval. Although the Committee accepts Representative Gutie ́rrez’s assertion that he did not intend to 

misspend his MRA, he did directly ask Mr. Scofield, on several occasions to perform work that was ‘‘legislative’’ in nature, or otherwise exceeded the scope of the Scofield contract and CHA regulations. At a minimum, Representative Gutie ́rrez inadequately supervised his staff’s interactions with Mr. Scofield, and the work Mr. 

Scofield was asked to do, to ensure it accorded with both the contract’s terms and CHA’s regulations. These oversights resulted in 

an improper use of MRA funds to compensate Mr. Scofield for work 

he could not perform as a contractor, but which was nonetheless 

provided to Representative Gutie ́rrez’s congressional office over a 

ten-year period. Where oversights like these result in such repeated, substantial, non-technical violations of House rules, Committee precedent holds that a reproval is appropriate.182

30 

183 House Comm. on Standards of Official Conduct, Report Under the Authority of H. Res 418, H. Rept. 90–1176, 90th Cong. 2d Sess. 17 (1968). 184 114 Cong. Rec. 8778 (Apr. 3, 1968) (Statement of Representative Price). 185 Ethics Manual at 17 (citing House Select Comm. On Ethics, Advisory Opinion No. 4, H. 

Rept. 95–1837, 95th Cong. 2d Sess. App. 61 (1979)). 186 Representative Gutie ́rrez’s inattention to the applicable rules and his contractor’s relation 

to them bears some resemblance to the matter of Representative Young, whom the Committee 

reproved in part due to the ISC’s finding ‘‘that he was, at best, blithe with respect to the question of gift rule compliance,’’ and exhibited a ‘‘casual attitude’’ regarding the relevant rules. See 

Young at 69. 

B. House Rule XXIII, clauses 1 and 2 

As stated in previous reports, the Committee observes two basic 

principles when applying the first two clauses of the Code of Conduct. First, Members must at all times act in a manner that reflects creditably upon the House. Second, the Committee has noted 

that the Code of Conduct and other standards of conduct governing 

the ethical behavior of the House community are not criminal statutes to be construed strictly, but rather—under clause 2 of House 

Rule XXIII—must be read to prohibit violations not only of the letter of the rules, but of the spirit of the rules. Ethical rules governing the conduct of Members were created to assure the public 

of ‘‘the importance of the precedents of decorum and consideration 

that have evolved in the House over the years.’’ 183 The standard 

‘‘provide[s] the House with the means to deal with infractions that 

rise to trouble it without burdening it with defining specific 

charges that would be difficult to state with precision.’’ 184 The 

practical effect of Clause 2 is to allow the committee to construe 

the ethical rules broadly, and prohibit Members from doing indirectly what they would be barred from doing directly. The Ethics 

Manual states that ‘‘a narrow technical reading of a House Rule 

should not overcome its ‘spirit’ and the intent of the House in 

adopting that and other rules of conduct.’’ 185

The Committee, after analyzing the conduct at issue in this matter under these standards, found Representative Gutie ́rrez violated 

House Rule XXIII clauses 1 and 2, by paying Mr. Scofield as a contractor when he occasionally functioned as an official employee, 

and using MRA funds to pay Scofield Communications for some 

work that exceeded the scope of the contract. As noted previously, 

the Committee credits Representative Gutie ́rrez’s assertion that 

any impermissible disbursements from his MRA to Mr. Scofield 

were not the result of a deliberate intent to violate House Rules. 

Yet Representative Gutie ́rrez’s inattention to the rules and regulations governing the retention of contractors, and inadequate supervision of both his own staff and Mr. Scofield’s work, resulted in the 

use of MRA funds to compensate Mr. Scofield for an array of tasks 

that he could not permissibly perform as a contractor.186

The Committee explained its approach to matters such as this 

one in a recent case, and it has followed this approach in many 

matters, over many years: 

[T]here is no evidence that [the Member] actually intended to receive inappropriate gifts, or purposefully violated the rules . . . But there are a range of mindsets between completely innocent and unforgivably corrupt. 

Somewhere along that span sit Members who fail to exercise care that a reasonable Member would exercise in similar circumstances to ensure compliance with the Code of 

31 

187Young at 70. 188See Gingrey at 25; Berkley at 10; Stallings at 5. 189 Comm. on Post Office and Civil Service, Code of Ethics for Government Service, H. Rept. 

1208, 85th Cong. 1st Sess. 1 (1957). 190 Id. at 2. 191See, e.g., Whitfield at 42 (citing House Comm. on Standards of Official Conduct, Investigation of Financial Transactions Participated In and Gifts of Transportation Accepted by Representative Fernand J. St Germain, H. Report 100–46, 100th Cong. 1st Sess. 3, 9, 43 (1987)). 192See Whitfield at 42; Gingrey at 25 (noting that the Member ‘‘took some care to limit the 

scope of his official actions’’); Berkley at 55–56 (noting that ‘‘reasonable people would construe 

the benefit [the Member] received as her motivation, whether it was or not.’’). 193 Exhibit 2. 194Supra Section IV.F.3. 

Conduct. And in cases where a Member fails to exercise 

that care—where they ‘should have known’ . . . or they 

‘lack[ed] . . . discernible policies’ for compliance . . . the 

Committee has consistently reproved the offending Members.188

Thus, consistent with its precedent, the Committee has decided 

to publicly reprove Representative Gutie ́rrez.188

C. Code of Ethics, Section 5 

The Code of Ethics was adopted by the House to assist federal 

employees, including officeholders, ‘‘in guiding and correcting any 

tendency toward cynicism of the high trust associated with public 

service.’’ 189 It thus reaffirmed standards of conduct ‘‘to which all 

federal employees unquestionably should adhere.’’ 190 In this spirit, 

Section 5 includes two prohibitions applicable to House Members: 

(1) ‘‘never discriminate unfairly by the dispensing of special favors 

or privileges to anyone, whether for remuneration or not;’’ and (2) 

‘‘never accept for himself or his family, favors or benefits under circumstances which might be construed by reasonable persons as influencing the performance of his governmental duties.’’ Finding a 

violation of Section 5 requires no proof of a connection between an 

official action and compensation to the acting Member. 

The Committee has also long cautioned Members that when taking official actions, they must ‘‘avoid situations in which even an 

inference might be drawn suggesting improper action.’’ 191 Indeed, 

the Committee has found violations of Section 5 where an individual or entity is singled out for special treatment, and such special treatment creates an appearance of favoritism.’’ 192 Representative Gutie ́rrez seems to have recognized the appearances problem 

when he decided in 2013 to terminate the contract with Mr. Scofield. That decision, Representative Gutie ́rrez told Committee staff, 

was partly based on his belief that it would have been difficult to 

identify and avoid potential, prospective conflicts of interest with 

Scofield Communications clients, even if his policy positions were 

formulated and taken wholly independently of any lobbying work 

by Mr. Scofield.193

In this case, the Committee did find some evidence that Mr. Scofield and/or employees of Scofield Communications discussed federal appropriations requests relating to Scofield Communications 

clients with Representative Gutie ́rrez and/or his congressional 

staff.194 At least one email communication between Mr. Scofield’s 

wife (an employee of Scofield Communications) and Representative 

Gutie ́rrez’s Chief of Staff also referred to a conversation between 

Mr. Scofield and Representative Gutie ́rrez in the context of a federal funding request for IPRAC—an organization located in RepVerDate Sep 11 2014 05:45 Mar 29, 2018 Jkt 029435 PO 00000 Frm 00039 Fmt 6659 Sfmt 6602 E:\HR\OC\HR617.XXX HR617
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195See Exhibit 34; 18(a) Interview of Representative Gutie ́rrez; 18(a) Interview of Doug Scofield. 196 18(a) Interview of Doug Scofield. 

resentative Gutie ́rrez’s congressional district—though neither Mr. 

Scofield nor Representative Gutie ́rrez recalled having such conversation.195 And at least one of Mr. Scofield’s clients, recognizing 

Mr. Scofield’s working relationship with Representative Gutie ́rrez 

to their advantage, asked him to inquire about the status of an appropriation request.196

However, while the Committee’s guidance on this subject is intended to guard against even an inference of improper action, the 

Committee did not find any evidence that Mr. Scofield received special privileges on behalf of his firm’s fundraising or state-level lobbying clients with respect to federal funding requests for their organizations. Nor did the Committee uncover any evidence that Scofield Communications employees or Mr. Scofield, who was not registered as a federal lobbyist at any time while retained under contract by Representative Gutie ́rrez’s congressional office, ever lobbied Representative Gutie ́rrez or his staff on behalf of any Scofield 

Communications client. Thus, the Committee found no violation of 

Section 5 of the Code of the Ethics in this matter. 

VI. CONCLUSION 

The Committee reiterates that none of its findings in this case 

should be read to indicate any knowing or willful intent by Representative Gutie ́rrez or his staff to misuse the MRA or otherwise 

violate House Rules or CHA regulations governing the work contractors may perform for a congressional office. Although an overwhelming majority of work Mr. Scofield performed from 2003 to 

2013 clearly accorded with the contract’s terms, Mr. Scofield occasionally performed work for Representative Gutie ́rrez’s office that 

was either ‘‘legislative’’ in nature or otherwise exceeded the scope 

of work outlined in the contract. Representative Gutie ́rrez’s payment to Scofield Communications for services that appeared to be 

‘‘legislative’’ in nature, or clearly exceeded both the contract’s scope 

and Members’ Handbook guidelines, resulted in an impermissible 

use of MRA funds. Based on the totality of the circumstances, and 

consistent with prior precedent, the Committee decided to reprove 

Representative Gutie ́rrez for his conduct in this matter. Moreover, 

the Committee concluded that Representative Gutie ́rrez must reimburse the U.S. Treasury in the amount of $9,700 for those inadvertent misuses of MRA funds arising out of his congressional office’s retention of Scofield Communications under contract from 

2003 to 2013, or approximately three percent of the total amounts 

paid from Representative Gutie ́rrez’s MRA under the contract during that period. 

Upon publication of this Report and Representative Gutie ́rrez’s 

reimbursement of funds to the U.S. Treasury, the Committee considers this matter closed. 

VII. 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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