U.S. GOVERNMENT PUBLISHING OFFICE

WASHINGTON : 

1 

89–006 

" ! HOUSE OF REPRESENTATIVES 115TH CONGRESS

2d Session 

REPORT

2018

115–1042 

House Calendar No. 194 

IN THE MATTER OF ALLEGATIONS 

RELATING TO REPRESENTATIVE 

MARK MEADOWS 

R E P O R T 

OF THE

COMMITTEE ON ETHICS 

NOVEMBER 20, 2018.—Referred to the House Calendar and ordered 

to be printed 


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(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 PESCATORE, Director of Investigations 

MEGAN H. SAVAGE, Counsel to the Chairwoman 

DANIEL J. TAYLOR, Counsel to the Ranking Member 

KATHRYN LEFEBER DONAHUE, Senior Counsel 

C. EZEKIEL ROSS, Counsel 

MOLLY N. MCCARTY, Investigator 

MARK HAMILTON, Investigative Clerk 


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(III)

LETTER OF TRANSMITTAL 

HOUSE OF REPRESENTATIVES, 

COMMITTEE ON ETHICS, 

Washington, DC, November 16, 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 Mark Meadows.’’ 

Sincerely, 

SUSAN W. BROOKS, 

Chairwoman. 

THEODORE E. DEUTCH, 

Ranking Member. 


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C O N T E N T S 

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

II. PROCEDURAL HISTORY ............................................................................ 4 

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

OF CONDUCT ............................................................................................ 5 

A. Sex Discrimination and Sexual Harassment .............................. 5 

B. Payment of Compensation and Severance to House Employees ................................................................................................ 6 

IV. BACKGROUND ............................................................................................. 7 

A. Representative Meadows’ Relationship with Mr. West .............. 7 

B. Allegations that Mr. West Acted Inappropriately toward Female Employees in Representative Meadows’ Offices .............. 8 

1. Unwanted touching ................................................................. 8 

2. Inappropriate staring ............................................................. 9 

3. Unprofessional comments about female employees’ appearances ..................................................................................... 9 

C. Representative Meadows becomes Aware of the Alleged Inappropriate Behavior ...................................................................... 10 

1. Representative Meadows’ awareness before October 2014 . 10 

2. October 2014 allegations of inappropriate behavior ............ 11 

D. Reactions to Allegations of Inappropriate Behavior ................... 13 

E. Corrective Measures Representative Meadows Took regarding 

the Allegations of Inappropriate Behavior ................................ 14 

F. Representative Meadows Requests an Independent Investigation ............................................................................................... 15 

G. Mr. West’s Work and Responsibilities Following the Independent Investigation and Recommendation to Terminate 

Him .............................................................................................. 17 

H. Staff’s Understanding of Mr. West’s Work and Responsibilities 

Following the Independent Investigation ................................. 17 

I. Mr. West’s Failure to Comply with Restrictions to Protect 

Female Staff ................................................................................ 18 

J. Representative Gowdy and the Speaker’s Office Advise Representative Meadows to Terminate Mr. West .......................... 19 

K. Mr. West becomes Senior Advisor ............................................... 20 

L. Mr. West Resigns and is Paid Severance .................................... 21 

M. Speculation About the Hiring and Delayed Termination of 

Mr. West ...................................................................................... 22 

V. FINDINGS ...................................................................................................... 22 

A. Mr. West’s Behavior ...................................................................... 23 

B. Representative Meadows’ Response to Mr. West’s Behavior ..... 24 

C. Mr. West’s Revised Duties, Compensation, and Severance ....... 30 

1. House Rule XXIII, clause 8, and the Committee’s guidance 

and precedent ....................................................................... 30 

2. Representative Meadows’ compensation of Mr. West .......... 33 

D. Repayment of Funds to the U.S. Treasury ................................. 36 

E. Representative Meadows’ Conduct Merits Reproval by the 

Committee ................................................................................... 37 

VI. CONCLUSION ............................................................................................... 38 

VII. STATEMENT UNDER HOUSE RULE XIII, CLAUSE 3(c) ....................... 39 

APPENDIX A: REPORT AND FINDINGS OF THE OFFICE OF CONGRESSIONAL ETHICS (REVIEW NO. 15–1671) ....................................................... 40 

APPENDIX B: REPRESENTATIVE MEADOWS’ SUBMISSIONS TO THE 

COMMITTEE AND OFFICE OF CONGRESSIONAL ETHICS ...................... 156 

APPENDIX C: EXHIBITS TO THE COMMITTEE REPORT .............................. 184 

APPENDIX D: TIMELINE OF EVENTS .............................................................. 272 


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House Calendar No. 194 

115TH CONGRESS REPORT " ! HOUSE OF REPRESENTATIVES 2d Session 115–1042 

IN THE MATTER OF ALLEGATIONS RELATING TO 

REPRESENTATIVE MARK MEADOWS 

NOVEMBER 20, 2018.—Referred to the House Calendar and ordered to be printed 

Ms. BROOKS, from the Committee on Ethics, 

submitted the following 

R E P O R T 

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

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

I. INTRODUCTION 

In the 114th Congress, the Committee began an investigation of 

allegations regarding Representative Mark Meadows. The Committee conducted a thorough review of these allegations. This Report explains the Committee’s investigation and its conclusions. 

News reports in the fall of 2015 alleged that multiple female 

staffers in Representative Meadows’ office had complained to him 

that they were sexually harassed by his then-Chief of Staff, Kenny 

West. It was alleged that in response Representative Meadows 

changed Mr. West’s title to Senior Advisor, but kept him on his official staff for months after learning of the allegations, when he 

may not have performed work commensurate with his rate of pay. 

Mr. West then resigned, but Representative Meadows continued to 

pay him at his full salary for another two months, and Mr. West 

also received official mileage reimbursement during that time period. 

On October 23, 2015, the Office of Congressional Ethics (OCE) 

began a preliminary review of allegations that Representative 

Meadows paid Mr. West when he did not perform duties commensurate with his official duties. On November 17, 2015, Representative Meadows wrote to OCE and stated he intended to report the 

allegation to the Committee, and would decline to cooperate with 

OCE’s review. The next day, Representative Meadows sent a letter 

to the then-Chairman and Ranking Member of the Committee reVerDate Sep 11 2014 04:29 Nov 27, 2018 Jkt 089006 PO 00000 Frm 00007 Fmt 6659 Sfmt 6602 E:\HR\OC\HR1042.XXX HR1042

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1See Report and Findings of the Office of Congressional Ethics (Review No. 15–1671) (Appendix A) (hereinafter OCE’s Referral). 2 Id. at 6, OCE Interview of Witness B (OCE’s Referral, Exhibit 3) at 9, OCE Interview of 

Witness C (OCE’s Referral, Exhibit 4) at 5–6. 3OCE’s Referral at 6. 

questing the Committee review his decision to continue paying his 

former Chief of Staff, Kenny West, from May 21, 2015, when Mr. 

West resigned from Representative Meadows’ office, through August 15, 2015. Representative Meadows explained that he continued paying Mr. West for purposes of a smooth transition and as 

‘‘severance.’’ He also stated that Mr. West engaged in ‘‘legitimate 

official activity’’ during that time period, including traveling to 

‘‘constituent meetings on my behalf.’’ Representative Meadows also 

said he declined to cooperate with a concurrent review of the severance payments by OCE, but would fully cooperate with the requested Committee review. 

On March 18, 2016, OCE transmitted a Report and Findings 

(OCE’s Referral) regarding Representative Meadows to the Committee.1 OCE’s Referral stated that, in October 2014, several female employees in Representative Meadows’ congressional office 

made complaints to him of inappropriate behavior by Mr. West, including unwanted touching, inappropriate staring and unprofessional comments.2 Following those reports, Representative 

Meadows restricted Mr. West from his congressional offices and 

from contacting female employees. However, Mr. West remained in 

his position until April 2015 when his title was changed to Senior 

Advisor. Despite the change in his title and loss of responsibilities 

to supervise Representative Meadows’ congressional staff, the thenSenior Advisor continued to receive the same salary from the 

House of Representatives until August 15, 2015. 

OCE examined what official congressional work Mr. West performed after his title changed to Senior Advisor and, based on that 

review, found substantial reason to believe Representative Meadows retained an employee who did not perform duties commensurate with the compensation the employee received, and certified the 

compensation met applicable House standards, in violation of 

House rules and standards of conduct.3 OCE recommended the 

Committee conduct a further review of the allegations. 

The Committee did conduct a further review of the allegations in 

OCE’s Referral. On August 17, 2016, the Committee published 

OCE’s Referral and a response from Representative Meadows, and 

publicly announced the Committee would investigate the matter 

under Committee Rule 18(a). The Committee considered whether 

Representative Meadows violated any House rule or other standard 

of conduct when he paid Mr. West his full salary when Mr. West 

(1) was restricted from the congressional offices and from contacting female employees; (2) lost his supervisory responsibilities 

and became Senior Advisor; and (3) was paid his full salary for two 

months as ‘‘severance.’’ The Committee also considered whether 

Representative Meadows violated any House rule or other standard 

of conduct in connection with the allegations that Mr. West engaged in inappropriate behavior and/or sexual harassment in his 

office. 

As discussed more fully below, it was generally within Representative Meadows’ discretion as the employing Member to change the 


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terms and conditions of Mr. West’s employment. However, clause 

8 of the Code of Official Conduct provides that Members may not 

retain an employee who does not perform duties for the employing 

office commensurate with the compensation the employee receives. 

When Mr. West was demoted to Senior Advisor, his pay remained 

the same but the Committee found little evidence of official work 

that he completed during that time. Thus, the Committee found 

that his duties as Senior Advisor were not commensurate with his 

pay. 

With respect to the payment of severance, the Committee acknowledges that there was little and inconsistent guidance on severance payments available to the House community at the time 

Representative Meadows paid severance to Mr. West. That said, 

after Mr. West ended his duties for the congressional office, Representative Meadows continued to pay his salary for two months. 

Representative Meadows sought no guidance on whether such payments were permissible and did not obtain anything of discernible 

value in exchange for those official funds, such as a release of legal 

claims. Accordingly, the Committee found that Representative 

Meadows’ payment of severance to Mr. West ran afoul of clause 8. 

In addition to further reviewing the compensation-related issues 

in OCE’s Referral, the Committee considered (1) when Representative Meadows learned about Mr. West’s inappropriate behavior; 

and (2) whether Representative Meadows exercised reasonable care 

to prevent and promptly correct Mr. West’s inappropriate behavior 

after he learned about it. Based on the evidentiary record, the 

Committee found that Representative Meadows did not know about 

Mr. West’s inappropriate conduct until October 2014, when several 

of his female staff made complaints about Mr. West’s behavior to 

him. The Committee also found that, once Representative Meadows 

became aware of Mr. West’s behavior, he should have done more 

to address that behavior and prevent it from occurring again in the 

future. While Representative Meadows took some important immediate steps—restricting Mr. West from the congressional offices and 

prohibiting him from contacting most of the female employees— 

those steps were essentially all he did to prevent and correct the 

alleged sexual harassment for nearly six months. 

Soon after he received the complaints, Representative Meadows 

arranged for an independent investigation into the allegations instead of contacting the Committee, the Office of House Employment Counsel (OHEC), or the Office of Compliance (OOC). After 

that independent review was complete, he ignored its findings and 

the recommendation by the independent investigator to terminate 

Mr. West’s employment. In the months that followed, Mr. West retained his title, full salary and supervisory responsibilities over all 

of the congressional staff. Representative Meadows kept Mr. West 

in his position even after Mr. West failed to abide by the restrictions Representative Meadows put in place to separate him from 

the female staff. In fact, another Member approached Representative Meadows on the House Floor to inform him that his remedial 

measures had not worked, and yet, Representative Meadows kept 

Mr. West as Chief of Staff. It was not until the Speaker’s office became involved that Representative Meadows removed Mr. West 

from his supervisory role in April 2015. Mr. West, however, was 


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merely demoted to Senior Advisor, and continued to draw the same 

salary until August 15, 2015. 

As discussed further in this Report, the Committee’s review 

found that Mr. West’s behavior toward the female staff was inappropriate in every sense of the word. The Committee found the witnesses who described Mr. West’s conduct to be credible and their 

testimony was consistent. There is no place in any congressional office for looking up skirts, or down shirts; staring at a woman’s 

chest; unwanted touching; or making sexual comments, even if subtle or in jest. The fact that Mr. West supervised the women he did 

these things to makes his behavior even more unacceptable. Just 

as between Members and their staff, a power imbalance exists between senior staff and junior staff in congressional offices. Those 

entrusted with supervisory responsibilities in the workplace must 

be sensitive to the potential for discrimination and for creating uncomfortable working conditions for staff. 

Mr. West is no longer a House employee and thus, is no longer 

subject to the House Rules that prohibit sexual harassment, nor to 

this Committee’s jurisdiction. However, the Committee does not 

want to leave the impression that his behavior was appropriate in 

any way. 

The Committee found that at a minimum, Mr. West’s actions violated the spirit of clause 9, because his actions were inappropriate 

and discriminatory, and would thus violate clause 2 of the Code. 

The Committee also found that Mr. West’s actions while employed 

by the House did not reflect creditably on Representative Meadows’ 

office or the House as a whole, in violation of clause 1 of the Code. 

Such behavior has no place in the House of Representatives. The 

women that worked in Representative Meadows’ office deserved 

much better. However, because Mr. West is no longer a House employee, the Committee does not have jurisdiction over him. 

Representative Meadows’ failure to take prompt and decisive action to deal with the alleged sexual harassment in his congressional office was troubling to the Committee. The Committee found 

Representative Meadows violated House rules by failing to take appropriate steps to ensure that his House office was free from discrimination and any perception of discrimination. 

In addition, the Committee is concerned that Representative 

Meadows’ ‘‘solution’’ to the sexual harassment allegations, to cut off 

all contact between Mr. West and most of his female employees, 

caused another potential problem. An environment where only 

male staff have access to the Chief of Staff risks unequal treatment 

of employees based solely on sex. 

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

conduct, and to require Representative Meadows to reimburse the 

U.S. Treasury for the overpayment of Mr. West, in the amount of 

$40,625.02. Upon issuance of this Report and Representative Meadows’ reimbursement to the Treasury, the Committee will consider 

this matter closed. 

II. PROCEDURAL HISTORY 

OCE began a preliminary review on October 24, 2015. On November 17, 2015, Representative Meadows wrote to OCE and stated, ‘‘I am choosing to forego the costly and burdensome process of 


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4Letter from Representative Meadows to Omar Ashmawy, Staff Director & Chief Counsel, 

OCE (Nov. 17, 2015) (Appendix B). 5Letter from Representative Meadows to Chairman Charles W. Dent and Ranking Member 

Linda T. Sa ́nchez, Committee on Ethics (Nov. 18, 2015) (Appendix B). 6 Id. 

7 2 U.S.C. §§ 1311 et seq. 

participating in duplicate investigations, and instead will self-report to the Committee on Ethics and follow their instructions to resolve this matter.’’ 4 On November 18, 2015, Representative Meadows wrote to the Committee regarding ‘‘an allegation made against 

me for the manner in which I paid a member of my staff upon his 

termination.’’ 5 Representative Meadows stated that the matter was 

currently the subject of a preliminary review by OCE, but that ‘‘because I would like to save the cost and burden of duplicate inquiries, I have informed the OCE that I will not participate in their review, but will cooperate fully with your Committee in order to 

reach a resolution of these allegations.’’ 6

On November 23, 2015, OCE began a second phase review. OCE 

extended its review an additional 14 days, until January 20, 2016. 

OCE’s Board voted to adopt findings in the matter on February 26, 

2016. OCE transmitted its Referral in this matter to the Committee on March 18, 2016. 

Committee staff reviewed OCE’s Referral, along with other documentary and testimonial evidence obtained by OCE. In addition, 

the Committee issued voluntary requests for information to Representative Meadows and 21 other individuals, including current 

and former members of Representative Meadows’ official and campaign staff and others familiar with the allegations. The Committee 

also issued a subpoena for documents to a former member of Representative Meadows’ campaign staff, and received and reviewed 

additional documents from that individual. In total, the Committee 

reviewed over 3,700 pages of materials. The Committee also interviewed 22 witnesses, including current and former members of 

Representative Meadows’ official and campaign staff, others familiar with the allegations, another Member who was familiar with 

the allegations, and Representative Meadows. Representative 

Meadows fully cooperated with the Committee’s investigation. 

Before its final vote on this matter, the Committee provided Representative Meadows with a copy of this Report on October 26, 

2018, and an opportunity to address the full Committee in person 

or in writing. Representative Meadows declined the Committee’s 

invitation to do so. 

III. HOUSE RULES, LAWS, REGULATIONS, AND OTHER 

STANDARDS OF CONDUCT 

A. SEX DISCRIMINATION AND SEXUAL HARASSMENT

Sexual harassment and other forms of employment discrimination are prohibited in the House by both federal statute and House 

Rule. The Congressional Accountability Act (CAA),7 prohibits discrimination based on sex, including sexual harassment, and also 

prohibits intimidation, reprisal or other discrimination against a 

person for opposing sex discrimination. During the period under review, House Rule XXIII, clause 9, stated that ‘‘[a] Member . . . 

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8 House Ethics Manual (2008) at 268–69 (hereinafter Ethics Manual) (citing House Comm. on 

Standards of Official Conduct, In the Matter of Representative Jim Bates, H. Rep. 101–293, 101st 

Cong., 1st Sess. 8–10 (1989) (hereinafter Bates)). 9 H.R. Res. 724, 115th Cong. (2018). On February 6, 2018, the House passed H.R. 4924, the 

Congressional Accountability Act of 1994 Reform Act. That legislation would make certain 

changes to the CAA. See, e.g., Statement of the Chairwoman and Ranking Member of the Committee on Ethics, (Feb. 6, 2018), https://ethics.house.gov/press-release/statement-chairwomanand-ranking-member-committee-ethics-0. On May 24, 2018, the Senate passed S. 2952, its 

version of legislation to reform the Congressional Accountability Act of 1994 Reform Act. The 

Senate’s version was transmitted to the House on May 29, 2018. As of this time, no further action has been taken on either version of the Congressional Accountability Act of 1994 Reform 

Act. 10Office of Compliance, CAA Handbook (2010) at 44, available at https://compliance.gov/sites/ 

default/files/wp-content/uploads/2010/01/CAA-Handbook.pdf. 11 42 U.S.C. § 2000e et seq. 12Office of Compliance, Compliance@Work at 2 (2012), https://www.compliance.gov/sites/default/files/wp-content/uploads/2012/09/Newsletter-for-Staff.pdf. 

pensation, terms, conditions, or privileges of employment, because 

of the race, color, religion, sex (including marital or parental status), disability, age, or national origin of such individual.’’ The 

Committee has long held that a Member who violates applicable 

sex discrimination and sexual harassment laws also violates House 

Rule XXIII, clause 9.8 On February 6, 2018, the House formally 

amended clause 9 to confirm that the prohibition includes ‘‘committing an act of sexual harassment against such an individual.’’ 9

The CAA created the OOC as a forum to administer disputes 

that arise under the CAA, including claims of gender discrimination and sexual harassment. The OOC’s guidance defines sexual 

harassment as ‘‘[u]nwelcome sexual advances, requests for sexual 

favors, or other verbal or physical conduct of a sexual nature if the 

implication is that submission to such conduct is expected as part 

of the job.’’ 10 Consistent with judicial interpretations of Title VII 

of the Civil Rights Act of 1964,11 the OOC has also recognized that 

harassment, including sexual harassment, can occur ‘‘when there is 

unwelcome conduct, such as insults, slurs, or other verbal or physical conduct or activity regarding a protected trait,’’ which ‘‘creates 

an intimidating, hostile, or offensive work environment, that unreasonably interferes with an individual’s work performance.’’ 12

Sexual harassment and other forms of sex discrimination also 

implicate House Rule XXIII, clauses 1 and 2, which state that ‘‘[a] 

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

that shall reflect creditably on the House,’’ and ‘‘shall adhere to the 

spirit and the letter of the Rules of the House.’’ 

B. PAYMENT OF COMPENSATION AND SEVERANCE TO HOUSE

EMPLOYEES

House Rule XXIII, clause 8, states that ‘‘[a] Member . . . of the 

House may not retain an employee who does not perform duties for 

the offices of the employing authority commensurate with the compensation such employee receives.’’ Thus, a Member is responsible 

for ensuring that each employee the Member retains performs official work commensurate with that employee’s pay. As the Ethics 

Manual states: 

The underlying standard for the receipt of compensation 

by an employee of the House is that the employee has regularly performed official duties commensurate with the 

compensation received. The Code of Ethics for Government 

Service instructs every employee to ‘[g]ive a full day’s labor 


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13 Ethics Manual at 279. 14 Id. at 267; see also Members’ Congressional Handbook, July 25, 2018 at 4 (hereinafter Members’ Handbook (2018)) (‘‘the Member determines the terms and conditions of employment and 

service for their staff’’); Exhibit 1 (Members’ Handbook (2011)) at 3 (the Members’ Handbook in 

effect at the time Mr. West was employed in Representative Meadows’ office). 15 18(a) Interview of Representative Meadows. 16 Id. 17 18(a) Interview of Kenny West. 18 18(a) Interview of Representative Meadows. 19 18(a) Interview of Witness P; 18(a) Interview of Representative Meadows. See also infra 

Section V.B. 20 18(a) Interview of Representative Meadows. 21 Id. 22 Id. 

for a full day’s pay; giving to the performance of his duties 

his best effort and best thought.’ Employees are paid 

United States Treasury funds to perform public duties. Appropriated funds are to be used solely for purposes for 

which appropriated. Funds appropriated for congressional 

staff to perform official duties should be used only for assisting a Member in his or her legislative and congressional functions.13

Notwithstanding these restrictions, the ‘‘general terms, conditions, and specific duties of House employees traditionally have 

been within the discretion of the employing Member.’’ 14

IV. BACKGROUND 

A. REPRESENTATIVE MEADOWS’ RELATIONSHIP WITH MR. WEST

Representative Mark Meadows represents the Eleventh District 

of North Carolina. He has been a Member of the House of Representatives since 2013. Representative Meadows first became acquainted with Mr. West before he was elected to Congress, when 

Mr. West was one of his opponents in the 2012 Republican primary 

election.15 Representative Meadows hired Mr. West after he was 

elected to the House, and Mr. West became Chief of Staff when 

Representative Meadows was sworn into office on January 3, 

2013.16 Before he joined Representative Meadows’ congressional office, Mr. West sold insurance in North Carolina.17

Representative Meadows told the Committee he hired Mr. West 

because he had good connections in rural areas of the District 

where Representative Meadows was less well known, and also because he wanted, ‘‘someone who could do outreach in the district 

as a chief of staff.’’ 18 After Representative Meadows hired Mr. 

West but before he was sworn into office, a campaign supporter 

and local business owner (hereinafter Campaign Supporter) told 

Representative Meadows that Mr. West had previously exhibited 

behavior in a professional setting that made females uncomfortable.19 That information was conveyed as a part of a larger conversation about the Campaign Supporter’s displeasure with Representative Meadows’ decision to hire Mr. West.20

After Representative Meadows was sworn in, Mr. West began 

managing the congressional office from the district, but spent some 

of his time in Representative Meadows’ Washington, D.C., office.21

He was responsible for supervising all of Representative Meadows’ 

congressional employees and evaluating their performance.22 He 

also made recommendations to Representative Meadows related to 


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23 Id. 24See, e.g., 18(a) Interview of Employee A; 18(a) Interview of Employee G; 18(a) Interview of 

Employee B; 18(a) Interview of Employee D. 25 18(a) Interview of Employee J. 26 18(a) Interview of Employee A; 18(a) Interview of Employee B; 18(a) Interview of Employee 

C; 18(a) Interview of Employee E; 18(a) Interview of Employee F; 18(a) Interview of Employee 

G; see also 18(a) Interview of Employee J; 18(a) Interview of Employee K. 27 18(a) Interview of Employee E. 28 18(a) Interview of Employee C; 18(a) Interview of Employee B; 18(a) Interview of Employee 

K. 29 18(a) Interview of Employee B. 30 Exhibit 2. 31 18(a) Interview of Employee F; 18(a) Interview of Employee G. In an email produced to the 

Committee, dated November 12, 2013, two female employees who worked in the Washington, 

D.C. office discussed Mr. West touching their hair. One said Mr. West had an ‘‘affinity for touching [her] hair.’’ Exhibit 3. 32 18(a) Interview of Employee G. 33OCE Interview of Witness B (OCE’s Referral, Exhibit 3) at 6. 

hiring, firing, salaries and bonuses for all of the congressional employees.23

B. ALLEGATIONS THAT MR. WEST ACTED INAPPROPRIATELY TOWARD

FEMALE EMPLOYEES IN REPRESENTATIVE MEADOWS’ OFFICES

According to multiple witnesses, female employees in the Washington, D.C. and district offices began to feel uncomfortable with 

Mr. West’s behavior toward them shortly after he became Chief of 

Staff in January 2013, and this discomfort persisted through October 2014.24 The individual who served as the Legislative Director 

and Deputy Chief of Staff (hereinafter D.C. Deputy Chief), a male 

employee who started in Representative Meadows’ Washington, 

D.C., office in January 2013, said he heard as early as January or 

February 2013 that Mr. West made female employees feel uncomfortable.25

Mr. West’s alleged inappropriate behavior fell into three main 

categories: (1) unwanted touching, (2) inappropriate staring, and 

(3) unprofessional comments related to female employees’ appearances. 

1. Unwanted touching 

Six female employees told the Committee that they experienced 

unwanted touching by Mr. West on multiple occasions in the congressional office, and other employees, male and female alike, observed this behavior.26 One female employee described Mr. West as 

being very ‘‘handsy.’’ 27 Indeed, testimony shows Mr. West touched 

multiple female staff in ways that were not overtly sexual, but 

were nonetheless inappropriate. Mr. West placed his hands on the 

backs or shoulders of multiple female staff dozens of times,28 poked 

a female employee in the side at least a dozen times,29 grabbed a 

female employee’s hand to look at her nail polish,30 and repeatedly 

touched the heads or hair of female staff, including scratching their 

heads and pulling on ponytails.31 One female employee said that 

Mr. West pulled her ponytail when he would walk by her desk, estimating that it occurred less than a dozen times, beginning in October 2013 shortly after she started in the congressional office.32

Another female staffer told OCE that she was warned when she 

started in the congressional office not to wear her hair in a ponytail because Mr. West liked to play with it.33 Mr. West’s unwanted 

touching was also directed towards interns in the office. One female employee recounted a conversation that a female intern had 


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34 18(a) Interview of Employee D. 35See e.g., 18(a) Interview of Employee J (describing instances of hovering closely to two 

former female employees); 18(a) Interview of Employee K (describing instances of looking down 

a female’s shirt); 18(a) Interview of Employee B (describing a female ‘‘contort[ing] into weird 

positions’’ to avoid Mr. West staring at her); 18(a) Interview of Employee F (describing instances 

of Mr. West ‘‘creepily watching’’ females during meetings). 36 18(a) Interview of Employee E. 37 18(a) Interview of Employee D; 18(a) Interview of Employee A; 18(a) Interview of Employee 

F; see also 18(a) Interview of Employee J. 38 18(a) Interview of Employee B. 39 18(a) Interview of Employee D; see also 18(a) Interview of Employee K (observed Mr. West 

standing shoulder to shoulder with a female employee and looking down her shirt); 18(a) Interview of Employee B (‘‘I kind of recall him [standing shoulder to shoulder] with all the girls in 

the office.’’). 40 18(a) Interview of Employee D; 18(a) Interview of Employee B; see also 18(a) Interview of 

Employee J. 41 18(a) Interview of Employee D; 18(a) Interview of Employee B; 18(a) Interview of Employee 

K. 42 18(a) Interview of Employee F; 18(a) Interview of Employee B. 43 18(a) Interview of Employee J. 44 18(a) Interview of Employee B. 45 Id.; 18(a) Interview of Employee J. 46 18(a) Interview of Employee G; 18(a) Interview of Employee B. 47 18(a) Interview of Employee B. 

with the entire Washington, D.C., staff at the end of her internship. She said, ‘‘the typical question we would ask our interns is, 

what [were] your highs and lows? Her low was how uncomfortable 

Kenny made her feel and how he would always touch her hair.’’ 34

2. Inappropriate staring 

Many of Representative Meadows’ congressional staff told the 

Committee that Mr. West stared at female employees inappropriately on a regular basis.35 Several female employees reported that 

Mr. West looked at their chests, down their blouses, or up their 

skirts. One female employee told the Committee, ‘‘[m]ost people you 

talk to have eye contact. Kenny’s eyes, if you’re a woman, they’re 

on your breast.’’ 36 Multiple female employees expressed discomfort 

with Mr. West ‘‘hovering’’ closely to them, invading their personal 

space.37 One female employee told the Committee that she moved 

to a standing desk to avoid Mr. West’s ‘‘hovering.’’ 38 Another, who 

also worked at a standing desk, said Mr. West would stand next 

to her while she worked, ‘‘shoulder to shoulder’’ so he could look 

down her shirt.39 Two female employees described sitting in awkward positions in staff meetings or at their desks to prevent Mr. 

West from looking up their skirts.40

3. Unprofessional comments about female employees’ appearances 

Numerous witnesses testified that Mr. West commented frequently about female employees’ appearances, including their looks 

and clothing. Mr. West would often describe female staff as attractive or beautiful,41 and would make comments to female staff like, 

‘‘you should wear heels more often,’’ 42 ‘‘[w]ow, I can’t believe your 

husband lets you out that way,’’ 43 and ‘‘ooh, that red dress.’’ 44 Mr. 

West also commented on female employees’ weight, including asking one how much she weighed.45 Two female employees recounted 

a story to the Committee that was relayed to them by Mr. West’s 

wife: in New York City, Mr. West encountered a topless performer 

in Central Park and told his wife the performer looked like Employee B.46 Employee B, who heard Mr. West’s wife tell the story, 

said she felt ‘‘really uncomfortable.’’ 47


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48OCE Interview of Witness B (OCE’s Referral, Exhibit 3) at 24; 18(a) Interview of Employee 

D. 49OCE Interview of Witness B (OCE’s Referral, Exhibit 3) at 24. 50 18(a) Interview of Employee D. 51 18(a) Interview of Employee J. The Committee did learn about one instance where Representative Meadows received a written complaint about Mr. West from a female district staff 

employee in 2013, but that complaint discussed only Mr. West’s alleged dishonesty in salary negotiations, and did not mention any inappropriate behavior towards women. 18(a) Interview of 

Employee E. 52 18(a) Interview of Witness Q. 53 Id. 54 18(a) Interview of Employee R. 

C. REPRESENTATIVE MEADOWS BECOMES AWARE OF THE ALLEGED

INAPPROPRIATE BEHAVIOR

1. Representative Meadows’ awareness before October 2014 

Although it was widely known among Representative Meadows’ 

staff that Mr. West made female employees uncomfortable, there is 

some question about when Representative Meadows first learned of 

the problem. During the course of the Committee’s investigation, 

the Committee reviewed allegations that Representative Meadows 

may have known, prior to October 2014, that Mr. West made his 

female employees feel uncomfortable. The investigation did not, 

however, substantiate any of those allegations. 

Employee D told both OCE and the Committee she heard from 

the D.C. Deputy Chief that a district office staffer sent an email 

to Representative Meadows, prior to February 2014, complaining 

that Mr. West ‘‘would always try to hug her too closely. She felt 

like it was always him trying to feel her chest, and look down her 

shirt, and she didn’t like that.’’ 48 Employee D stated that she had 

learned Representative Meadows ‘‘just forwarded [the district staffer’s email] to Kenny.’’ 49 However, Employee D never saw the 

email, and the events she described took place before she joined 

Representative Meadows’ office.50 Further, neither Representative 

Meadows nor any other member of his staff corroborated this account.51

Second, a former campaign staffer, Witness Q, independently 

contacted the Committee after learning about the Committee’s investigation and alleged that Representative Meadows and his senior staff knew as early as April 2014 that Mr. West acted inappropriately toward female staff. More specifically, Witness Q alleged 

that complaints about Mr. West’s behavior toward women were 

lodged in April 2014 and that Mr. West was prohibited from entering the congressional offices at that time, rather than in October 

2014 as the OCE Referral stated.52 Witness Q had no firsthand 

knowledge of his allegations, but based them on conversations he 

had with two of Representative Meadows’ congressional staff in 

April 2014.53 The Committee, however, was unable to confirm that 

the alleged conversations with the two staffers occurred. One of the 

staffers that was supposedly a part of those conversations told the 

Committee that he had no recollection of them, and the other staffer could not be reached by the Committee.54

Thus, the Committee was unable to substantiate allegations that 

Representative Meadows knew prior to October 2014 that Mr. West 

acted inappropriately toward female staff. 


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55 18(a) Interview of Employee B. 56 Id. 57 18(a) Interview of Employee J. 58 Id. ; see also, e.g., 18(a) Interview of Employee D; 18(a) Interview of Employee A. Mr. West 

suggested to the Committee that the D.C. Deputy Chief shared the complaints he had compiled 

with all of the female employees, causing them to unfairly ‘‘pile on’’ additional complaints. 18(a) 

Interview of Kenny West. However, the D.C. Deputy Chief explained he was aware that other 

female employees had expressed concerns and wanted to give them the opportunity, if they 

chose, to raise any issues with Representative Meadows. 18(a) Interview of Employee J; see also 

18(a) Interview of Employee A. He further explained he did not want it to be a ‘‘she said/he 

said’’ situation, and thought Representative Meadows should hear from more than one female 

employee. 18(a) Interview of Employee J. 59 18(a) Interview of Employee J. 60 Id.; Exhibit 4. 61 Exhibit 4; see also 18(a) Interview of Employee J. 62 18(a) Interview of Employee J; 18(a) Interview of Representative Meadows. 63 Id.; see also Exhibit 4. 64 18(a) Interview of Representative Meadows. 

2. October 2014 allegations of inappropriate behavior 

Within the span of a few days in October 2014, employees in 

Representative Meadows’ Washington, D.C. and Hendersonville, 

North Carolina, offices complained to Representative Meadows 

about Mr. West’s inappropriate behavior toward female employees. 

The first complaints were made by the five female staff in the 

Washington, D.C., office and relayed to Representative Meadows by 

the D.C. Deputy Chief. The complaints were prompted by Mr. 

West’s insistence in August and September 2014 that one of the females in that office, Employee B, make a trip to the district that 

would have required her to spend substantial time alone with Mr. 

West.55 Employee B initially avoided the trip but eventually felt 

her job was at risk if she continued to do so.56 She discussed her 

concerns with the D.C. Deputy Chief, who told the Committee 

‘‘[t]he only recourse that [he] saw as deputy chief at this time was 

to go talk to Congressman Meadows.’’ 57

In early October 2014, before he talked to Representative Meadows, the D.C. Deputy Chief told all female employees in the Washington, D.C., office that he would be speaking to the Congressman 

regarding Mr. West’s inappropriate behavior toward women.58 All 

five female employees in the Washington, D.C., office emailed instances of inappropriate behavior they had experienced with Mr. 

West to the D.C. Deputy Chief.59 He created a document that listed 

the complaints from each female employee, without identifying 

them by name, for his discussion with Representative Meadows.60

The list described instances of unwanted touching, inappropriate 

staring, and comments by Mr. West, of the kind described previously.61

On or around Friday, October 17, 2014, the D.C. Deputy Chief 

told Representative Meadows that female employees in the Washington, D.C., office were uncomfortable around Mr. West.62 He also 

gave Representative Meadows the list of complaints he had compiled.63 The D.C. Deputy Chief also relayed to Representative 

Meadows that Employee B did not feel comfortable traveling to the 

district due to Mr. West’s behavior toward her.64 Representative 

Meadows immediately met with his Washington, D.C., congressional staff and told them he had zero tolerance for the inapproVerDate Sep 11 2014 04:29 Nov 27, 2018 Jkt 089006 PO 00000 Frm 00017 Fmt 6659 Sfmt 6602 E:\HR\OC\HR1042.XXX HR1042

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65 Id.; see also 18(a) Interview of Employee J. Mr. West was not in Washington, D.C. at the 

time and was not in this meeting. 66 18(a) Interview of Representative Meadows; see also 18(a) Interview of Employee J. 67 18(a) Interview of Representative Meadows; see also 18(a) Interview of Kenny West. 68 Id. 69 Id. 70 Exhibit 5. 71 Id. 72 Id. 73 Id. 74 18(a) Interview of Employee C. 75 18(a) Interview of Employee M. 76 Id. 77 18(a) Interview of Employee C; 18(a) Interview of Employee E; see also 18(a) Interview of 

Kenny West. Mr. West said Employee E told him he could not enter the district office because 

he ‘‘looked at [her] boobs.’’ 78 18(a) Interview of Employee E. 79 18(a) Interview of Representative Meadows; see also 18(a) Interview of Kenny West. 

priate behavior and would address it.65 He did not, however, tell 

them how he would address it.66

After learning about the allegations, Representative Meadows 

called Mr. West, who was in the district at the time, to inform him 

of the claims against him.67 After the call, he provided Mr. West 

the document that listed the allegations.68 At that time, Representative Meadows also instructed Mr. West not to have contact with 

any female employees in the Washington, D.C. office, other than 

the scheduler, and told Mr. West that there would be an investigation.69

On the evening of Tuesday, October 21, 2014, just four days after 

learning about the allegations from the Washington, D.C., office, 

Representative Meadows received another complaint, this time 

from a female employee in his Hendersonville district office. The 

individual serving as District Director and Deputy Chief of Staff 

(hereinafter District Deputy Chief) forwarded to Representative 

Meadows an email from Employee C.70 In her email, Employee C 

said that Mr. West made her feel uncomfortable in a meeting that 

day.71 She wrote that Mr. West made her feel ‘‘extremely ill at 

ease,’’ that he ‘‘stare[d] inappropriately,’’ and was ‘‘overly 

touchy.’’ 72 She also requested in the email that Mr. West ‘‘maintain his distance’’ from her.73 Employee C told the Committee that 

she complained after Mr. West stared at her ‘‘like he was trying to 

look down my shirt’’ during her performance evaluation that day.74

The District Deputy Chief also attended the performance evaluation meeting. When asked by the Committee what he observed, he 

said, ‘‘I was in there the entire time during this discussion, and I 

never saw anything inappropriate.’’ 75 However, he also said that 

Mr. West had a tendency to be long-winded and he did not remember whether he was paying attention during the entire meeting.76

The following morning, on Wednesday, October 22, 2014, Mr. 

West attempted to return to the Hendersonville district office but 

another district office employee, Employee E, barred him from entering. She told Mr. West he made both she and Employee C feel 

uncomfortable and therefore he could not come into the office.77

After arguing with Employee E, Mr. West eventually left.78 Mr. 

West immediately called Representative Meadows and reported 

that he was blocked from entering the Hendersonville office.79


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80 18(a) Interview of Representative Meadows; see also 18(a) Interview of Employee J. 81 18(a) Interview of Representative Meadows. 82 Id. 83 Id. 84 Id. 85 Id. 86 Id. 87 18(a) Interview of Kenny West. 88 Id. Employee A recalled one instance in which she said something to Mr. West about his 

behavior, but believed it related to him hovering close to her. 18(a) Interview of Employee A. 

She also told the Committee that she observed Mr. West engaging in the behavior alleged, such 

as standing close and touching hair, with other women in the office. Id. 89 18(a) Interview of Kenny West (‘‘Q. Did you ever look down a female staffer’s blouse? . . . 

A. [T]he answer to that is no, but I will tell you some of our female staff . . . they dressed inappropriately. . . . I said: You cannot dress like that and be meeting with the Ambassador of 

[]Israel. You can’t do that. And some of them took offense I imagine. Okay? But the answer 

to that is no.’’). 90 Id. 91 Id. Mr. West also said that one female employee, who he declined to identify, straightened 

his tie and rubbed his head when he had a headache. 92 Id. 

D. REACTIONS TO ALLEGATIONS OF INAPPROPRIATE BEHAVIOR

Representative Meadows told the Committee he was ‘‘shocked, 

upset [and] surprised’’ when he received the allegations from his 

Washington, D.C. staff in mid-October 2014.80 When he learned 

about Employee C’s allegations and the subsequent confrontation 

at the Hendersonville office, he said he knew he had ‘‘a pervasive 

problem.’’ 81 He explained, ‘‘probably the biggest thing that was difficult for me is that some of these things, one, I missed, but the 

other was . . . why didn’t I hear about them?’’ 82 Representative 

Meadows said he did not recall ever being told or hearing that Mr. 

West acted inappropriately toward his female staff before they 

brought complaints to him in October 2014.83

According to Representative Meadows, Mr. West ‘‘vigorously’’ denied the allegations against him.84 Representative Meadows told 

the Committee that Mr. West thought the congressional staff, particularly the D.C. Deputy Chief and the District Deputy Chief were 

just trying to get Mr. West fired.85 Mr. West also told Representative Meadows that the staff did not like having an ‘‘older guy’’ 

around.86

In his testimony to the Committee, Mr. West denied all but one 

of the allegations about his behavior: he admitted that he touched 

Employee A’s hair when she wore it in a bun.87 Mr. West explained 

that Employee A told him she did not like to be touched, and so 

he never touched her again.88

Mr. West suggested alternative explanations for the allegations. 

To illustrate, he suggested that the allegations related to his comments about female employee’s clothing may have been a response 

to him telling female employees that they dressed inappropriately.89 He also said that he told female and male employees alike 

that they ‘‘[l]ooked nice today.’’ 90 Further, Mr. West said that while 

he never touched a female employee’s back or shoulders, he may 

have ‘‘brushed against them in the office trying to get by.’’ 91

Mr. West also claimed the allegations were ‘‘coordinated,’’ speculating, ‘‘I think some of them wanted me out of the way so somebody else could be the chief.’’ 92 He thought that Representative 

Meadows’ staff were unhappy that he supported Representative 

Meadows’ decision not to vote with House leadership in a few inVerDate Sep 11 2014 04:29 Nov 27, 2018 Jkt 089006 PO 00000 Frm 00019 Fmt 6659 Sfmt 6602 E:\HR\OC\HR1042.XXX HR1042

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93 Id. 94 Id. (‘‘Q. Did you ever tell Representative Meadows that you thought that staff were discriminating against you in some way? A. Never discriminating.’’) 95 18(a) Interview of Representative Meadows. Representative Meadows told Mr. West that the 

only female employee he could have direct contact with was his scheduler because it was necessary for scheduling purposes. 96 Id. 97 Id. 98 Id. As discussed more fully in section V.C.2., infra, Mr. West actually received an increase 

in compensation around the same time, apparently as part of a year-end bonus. 99 18(a) Interview of Representative Meadows. 100See Exhibit 6. 101 18(a) Interview of Representative Meadows. 102 Id. 103 Id. 104 Id. 105 Id. 

stances.93 Although Representative Meadows told the Committee 

that Mr. West, who was fifty-six years old at the time, alluded to 

age discrimination when Representative Meadows confronted him 

about the allegations, Mr. West denied doing so to the Committee.94

E. CORRECTIVE MEASURES REPRESENTATIVE MEADOWS TOOK

REGARDING THE ALLEGATIONS OF INAPPROPRIATE BEHAVIOR

Almost immediately after learning about the allegations, Representative Meadows made two changes. First, he attempted to 

separate Mr. West from the female employees in his offices. He directed Mr. West to (1) have no contact with female employees other 

than the scheduler; 95 (2) not return to the Washington, D.C., or 

district congressional offices when female employees were present; 

and (3) use the D.C. Deputy Chief and District Deputy Chief, both 

male employees, as a conduit for any supervisory interactions with 

female employees.96 Representative Meadows told the Committee 

Mr. West was upset about the restrictions and told him, ‘‘I can’t 

even do my job.’’ 97 Despite the restrictions that even Mr. West 

identified as an impediment to doing his job, Mr. West’s title did 

not change and his compensation was not reduced.98

Second, Representative Meadows gave Mr. West access to the 

email accounts of the D.C. and District Deputy Chiefs.99 Mr. West 

received access on October 22, 2014, five days after Representative 

Meadows learned about the Washington, D.C., allegations and the 

same day that Employee E barred Mr. West from entering the 

Hendersonville office.100 This access allowed Mr. West to see all of 

the emails the Deputies sent and received on their official congressional email accounts, without them knowing.101 On the same day, 

Representative Meadows received access to every member of his 

staff’s emails.102 However, Representative Meadows never utilized 

that access himself.103

Representative Meadows told the Committee he gave Mr. West 

access to the Deputies’ emails so Mr. West could ‘‘properly monitor 

things’’ because ‘‘he’s not going to have as much direct contact with 

the office.’’ 104 Representative Meadows said he did not instruct Mr. 

West to look for anything in particular in the emails, nor did he 

provide Mr. West with the email access in response to, or connection with, the allegations against Mr. West.105 Mr. West gave the 

Committee a very different explanation: he said Representative 

Meadows ‘‘wanted me to see what was transpiring between [the 

Deputies],’’ because ‘‘[i]t’s my opinion that them [sic] two were a 


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106 18(a) Interview of Kenny West. 107 Id. 108 18(a) Interview of Representative Meadows. 109 Id. 110 Id.; 18(a) Interview of Representative Gowdy. 111 18 (a) Interview of Representative Meadows; see also 18(a) Interview of Gowdy Staffer. 112 18(a) Interview of Representative Meadows; 18(a) Interview of Gowdy Staffer. Gowdy Staffer was not asked to meet with the female employees in the district offices. 

main cause of what happened.’’ 106 Mr. West told the Committee 

that when he accessed the Deputies’ emails, he was looking for information about the allegations because he believed the allegations 

were a result of the Deputies’ scheme to get him fired.107

The investigative record shows that on at least five occasions, 

Mr. West shared information he found in either or both the D.C. 

and District Deputy Chief’s emails with Representative Meadows. 

Only one of the five emails appears to be related to Mr. West or 

the allegations: a March 2015 email exchange between the D.C. 

Deputy Chief and a staffer that worked for a Member in House 

leadership. In that email, the leadership staffer asked the D.C. 

Deputy Chief whether a rumor that Mr. West was leaving was 

true, and the D.C. Deputy Chief responded that he could not confirm the rumor. The other emails Mr. West shared with Representative Meadows generally concerned conversations between the Deputies and other Member offices, or speculation about personnel 

moves not involving Mr. West. 

F. REPRESENTATIVE MEADOWS REQUESTS AN INDEPENDENT

INVESTIGATION

In addition to the steps he took within his congressional office, 

Representative Meadows sought Representative Trey Gowdy’s advice in early November 2014.108 Representative Meadows said he 

consulted Representative Gowdy because he wanted a prosecutor’s 

advice on the best way to investigate the allegations.109 As a result 

of this conversation, Representative Gowdy recommended his senior female staffer (hereinafter Gowdy Staffer), a former Violence 

Against Women prosecutor who could talk to Representative Meadows’ female employees in a comfortable, non-threatening way, assess the situation in Representative Meadows’ Washington, D.C., 

office.110 Representative Meadows told the Committee he wanted 

‘‘[a]n independent third-party evaluator who could evaluate the 

merits of [the allegations] without being obligatory to [him] or anybody else . . . and make a recommendation.’’ 111 Gowdy Staffer was 

trained and had extensive experience in conducting independent investigations and interviewing sensitive witnesses. 

On November 18, 2014, Gowdy Staffer met with the female employees that worked in Representative Meadows’ Washington, D.C., 

congressional office.112 Representative Gowdy was not involved in 

the investigation. Shortly after the meetings, Gowdy Staffer talked 

to Representative Meadows about what she learned in those meetings, and made a recommendation to terminate Mr. West. She described her conversation with Representative Meadows to the Committee: 

We met and I relayed to him my honest opinion and 

feeling, I guess recommendation. The question was: What 

would you do if you were the chief of staff? That was the 

question to me. I said: I would let him go, for a couple of 


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113 18(a) Interview of Gowdy Staffer. 114 18(a) Interview of Representative Meadows. 115 18(a) Interview of Representative Gowdy. 116 18(a) Interview of Representative Meadows. 117 Id. 118 Id. 119 Id. At the time, Representative Gowdy served on the Committee. However, in his interview 

with the Committee, Representative Gowdy said that he viewed the issues with Mr. West as 

an employment matter, which he assumed was resolved because he believed Mr. West had been 

reasons. One is, you know, he—Mr. Meadows relayed to 

me that he had a great staff, that they all had done a fantastic job, and there was a mutual respect there. And if he 

truly valued the staff, my feeling was, if it didn’t get resolved, they were going to eventually move on. I mean, 

they were—they did not feel like they could stay in that 

office and work in that office with Kenny West. But the 

first and foremost is if you value your staff, you—and this 

continues, you may not keep your staff. So that was number one. 

Number two was they had some serious claims. And 

from my perspective and sort of from having my legal perspective, that this could be a real problem for Mr. Meadows. Because you have someone working in your office, 

and these claims are very much, for me, sexual harassment potentially. Hostility in the workplace potentially. 

And that’s not something I as a chief of staff would even 

entertain, tolerate, even if there was a suggestion. So that 

was my personal feeling based on what they had all said 

to me. That the stories were consistent, that there didn’t 

seem, to me, to be some sort of ulterior motive or just animosity where they were just trying to get rid of Kenny. It 

was truly a sense of: We’re not comfortable. We don’t feel 

comfortable working here. I don’t want to leave, but here 

we are. So that’s what I relayed to him.113

Representative Meadows told the Committee he did not recall 

Gowdy Staffer telling him anything about sexual harassment or a 

hostile work environment, but he did remember she told him the 

allegations against Mr. West were serious and he ‘‘needed to take 

action to terminate the employment.’’ 114 After Gowdy Staffer made 

her recommendation, both Representative Gowdy and Gowdy Staffer believed Mr. West was terminated.115

Representative Meadows did not, however, fire Mr. West. He told 

the Committee he thought the allegations were credible but he still 

had reservations.116 In particular, he said he was debating whether 

to give Mr. West the opportunity to tell his side of the story.117 He 

explained to the Committee, that from mid-November 2014 when 

Gowdy Staffer completed her investigation until April 1, 2015, 

when he demoted Mr. West, he went ‘‘back and forth, maybe longer 

than I should have, wrestling with what was fair and what was 

not.’’ 118

Representative Meadows did not do anything further to address 

his reservations about whether it would be ‘‘fair’’ to terminate Mr. 

West. The Committee notes that Representative Meadows did not 

seek assistance from any of the resources available to the House 

community, such as the Committee, OOC, or OHEC.119 RepresentVerDate Sep 11 2014 04:29 Nov 27, 2018 Jkt 089006 PO 00000 Frm 00022 Fmt 6659 Sfmt 6602 E:\HR\OC\HR1042.XXX HR1042

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fired after Gowdy Staffer’s investigation. Representative Gowdy did not engage in Committee 

decisions or discussions regarding this matter. 18(a) Interview of Representative Gowdy. 120 18(a) Interview of Representative Meadows. 121 Id. 122 Id. 123 Id. Representative Meadows told the Committee he did not hire any employees nor were 

there any formal performance evaluations from October 17, 2014, when he became aware of the 

allegations against Mr. West, through April 1, 2015, when he changed Mr. West’s title to Senior 

Advisor. 124 Exhibits 7 and 8. 125 18(a) Interview of Kenny West. 126See Exhibits 7 and 8. 127 18(a) Interview of Representative Meadows. 128 Id. 129 Id. Representative Meadows told the Committee that at the time he received positive responses about Mr. West’s work in the district, but he said that since then, he learned that Mr. 

West had not been doing the additional outreach in the district as he had asked. He said that 

other employees have told him that Mr. West could have done things better. 130 Id. 

ative Meadows told the Committee that, at the time, he did not 

know what congressional resources were available.120 However, 

there is no indication he made any effort to find that out. Representative Meadows also did not consult any private legal counsel.121

G. MR. WEST’S WORK AND RESPONSIBILITIES FOLLOWING THE INDEPENDENT INVESTIGATION AND RECOMMENDATION TO TERMINATE

HIM

After the independent investigation, Representative Meadows did 

not make any immediate changes to Mr. West’s responsibilities.122

Mr. West continued to make recommendations to Representative 

Meadows regarding employees’ salaries and positions and the office 

budget.123 In fact, the investigative record shows that Mr. West 

provided Representative Meadows with written evaluations of all 

congressional staff on two occasions: in November 2014 and February 2015.124 In those evaluations, Mr. West was critical of the 

D.C. and District Deputy Chiefs—who he believed had devised the 

allegations as a way to get him fired 125—and several of the female 

employees that made allegations against him.126

Because Mr. West continued to be barred from entering the congressional offices and from contacting most of the female employees, Mr. West worked from his home in the district. 127 Representative Meadows told the Committee he asked Mr. West to perform 

additional outreach throughout the district because he would not 

be coming back to Washington, D.C.128 This included attending 

events with Representative Meadows, outreach to county managers 

and more casework related to governmental officials.129 Representative Meadows testified that he did not view the restrictions on Mr. 

West as a change or reduction in his responsibilities.130

H. STAFF’S UNDERSTANDING OF MR. WEST’S WORK AND

RESPONSIBILITIES FOLLOWING THE INDEPENDENT INVESTIGATION

In late November 2014, after the independent investigation was 

complete, Representative Meadows asked his D.C. Deputy Chief to 

announce to the female employees in the Washington, D.C. office 

that: (1) Mr. West would no longer have a role in the Washington, 

D.C. office; (2) he would have limited contact with the female employees; and (3) he would no longer have office space in Washington, D.C., after Representative Meadows moved to a new office 


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131 Exhibit 9; 18(a) Interview of Employee J; see also 18(a) Interview of Employee B. 132 18(a) Interview of Employee J; 18(a) Interview of Employee B; 18(a) Interview of Employee 

A; 18(a) Interview of Employee G. 133 18(a) Interview of Employee M. 134 18(a) Interview of Employee E; 18(a) Interview of Employee C. 135 18(a) Interview of Employee E. 136 18(a) Interview of Employee R. 137 18(a) Interview of Employee F; 18(a) Interview of Employee D; 18(a) Interview of Employee 

A; 18(a) Interview of Employee G. 138 18(a) Interview of Employee B. 139 18(a) Interview of Employee D. 140 Id. 141 18(a) Interview of Employee C; 18(a) Interview of Employee E. Employee E told the Committee Mr. West never appeared to be doing any work before the allegations were raised to Representative Meadows, so she did not see a change after. 142 18(a) Interview of Employee R. 143 18(a) Interview of Employee E. 

in the Longworth House Office Building in January 2015.131 The 

D.C. Deputy Chief made the announcement at a staff meeting with 

the female employees.132

It is unclear whether a similar announcement was made to Representative Meadows’ district staff. The District Deputy Chief testified he was not aware Representative Meadows had restricted Mr. 

West from the district offices or directly communicating with female employees, and thus, did not make any announcements.133

Likewise, female staff in the Hendersonville office told the Committee they were never told Mr. West was not allowed in the office, 

or was not allowed to contact them.134 Employee E, a district office 

staffer, said, ‘‘I didn’t know if Kenny would be in the office the next 

day . . . it was just not discussed.’’ 135 However, one male employee 

that worked in the Lenoir district office testified that the District 

Deputy Chief told him that Mr. West would no longer be coming 

to the Hendersonville congressional office because a complaint had 

been filed about Mr. West’s behavior.136

Regardless of what they were told about Mr. West, the record 

shows that the congressional staff were confused about Mr. West’s 

role in the fall of 2014. Several D.C.-based staff said they did not 

know what Mr. West was doing after he was no longer coming to 

the office.137 Employee B told the Committee, ‘‘I don’t think we 

were sure if he was working for [Representative Meadows] or 

not.’’ 138 Employee D told the Committee the only indication Mr. 

West was still working for Representative Meadows were a few 

emails that he sent.139 Employee D also told the Committee that 

she knew that Mr. West remained involved in staff salary decisions 

because Representative Meadows had mentioned to her in an email 

on March 11, 2015, that he talked to Mr. West about her salary.140

Similarly, district office employees were uncertain about what Mr. 

West was doing.141 One told the Committee that he thought Mr. 

West was still Chief of Staff, but said, ‘‘his status in the office at 

that time, I wasn’t really sure about.’’ 142 Another said, ‘‘Kenny was 

not discussed, didn’t know where he was working, what he was 

doing. He just wasn’t discussed.’’ 143

I. MR. WEST’S FAILURE TO COMPLY WITH RESTRICTIONS TO PROTECT

FEMALE STAFF

Despite the assurances Representative Meadows had given to female staff in the Washington, D.C., office, Mr. West did contact 

some of them in early January 2015, and even suggested that he 


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144 18(a) Interview of Employee J; 18(a) Interview of Employee B; 18(a) Interview of Employee 

D. 145 18(a) Interview of Representative Meadows. 146 Id. 147 Id. 148 Id. 149 Exhibit 10. 150 Id. 151 18(a) Interview of Representative Gowdy; 18(a) Interview of Gowdy Staffer. 152 18(a) Interview of Representative Meadows; 18(a) Interview of Representative Gowdy. 153 18(a) Interview of Representative Gowdy. 154 Id. 155 Id. 

would return to the Washington, D.C., office.144 In March 2015, 

Mr. West again contacted two female congressional employees, one 

multiple times over the weekend and one at the office.145 Representative Meadows learned of these contacts soon after they occurred.146 Despite Mr. West’s failure to follow his instructions, Representative Meadows did not terminate his employment. When 

asked why he did not fire Mr. West on either of these occasions, 

Representative Meadows explained: ‘‘The justification that he gave, 

I mean, was that he was contacting the particular individual based 

on a case that he was working. I mean, he gave a business reason 

for the contact.’’ 147 Representative Meadows merely told Mr. West 

again not to contact the female employees and to work through the 

Deputies.148

J. REPRESENTATIVE GOWDY AND THE SPEAKER’S OFFICE ADVISE

REPRESENTATIVE MEADOWS TO TERMINATE MR. WEST

On January 7, 2015, nearly two months after Gowdy Staffer completed her investigation and recommended Representative Meadows terminate Mr. West, a female employee in Representative 

Meadows’ Washington, D.C., office emailed Gowdy Staffer saying 

that Mr. West ‘‘is still on staff,’’ was ‘‘temporarily out of the picture’’ but he ‘‘will be back up in DC, despite previous assurances 

to the contrary.’’ 149 She also said that the women in the office were 

not comfortable with Mr. West returning and they did not know 

how to properly address it.150

Gowdy Staffer told Representative Gowdy this information. Representative Gowdy and Gowdy Staffer both told the Committee 

they were surprised to learn Representative Meadows had not yet 

fired Mr. West.151 As a result, Representative Gowdy approached 

Representative Meadows on the House Floor. 152 Representative 

Gowdy told him the steps he had taken to resolve the allegations 

about Mr. West had not worked.153 Representative Gowdy advised 

Representative Meadows against keeping Mr. West on staff.154

Representative Gowdy explained that he gave Representative 

Meadows ‘‘some pretty firm impolite counsel, which would have 

been along the lines of: He has already hurt you, and it is going 

to continue.’’ Representative Gowdy explained to the Committee he 

knew Representative Meadows was concerned for and valued his 

female staff and wanted the environment in his office to change.155

Despite this counsel from Representative Gowdy, Representative 

Meadows continued to retain Mr. West without making any 

changes to his role. In late March 2015, the Speaker’s office became 

involved. Representative Meadows told the Committee that rumors 

were circulating about Mr. West’s behavior toward female staff, 


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156 18(a) Interview of Representative Meadows. 157 Id. 158 Id. 159 Exhibit 11. 160 Exhibit 12. 161 18(a) Interview of Representative Meadows. 162See e.g., 18(a) Interview of Employee C; 18(a) Interview of Employee D; 18(a) Interview 

of Employee G. 163 18(a) Interview of Representative Meadows. 164 18(a) Interview of Kenny West. 165 Id. 166 18(a) Interview of Representative Meadows. 167 18(a) Interview of Kenny West. 

which prompted the Speaker’s office to contact him.156 According to 

Representative Meadows, the General Counsel for the Speaker told 

Representative Meadows that even though Mr. West was physically 

separated from the female employees, because he had hiring, firing, 

and financial responsibilities, the female employees could make 

claims that they were not properly compensated or that there was 

a hostile work environment.157 Representative Meadows told the 

Committee this was when he finally realized Mr. West could no 

longer serve as Chief of Staff.158

K. MR. WEST BECOMES SENIOR ADVISOR

On March 25, 2015, Representative Meadows sent an email to 

his D.C. Deputy Chief and District Deputy Chief instructing them 

that, effective immediately, they would report directly to him and 

would be responsible for supervising their respective employees in 

Washington, D.C., and the district.159 A week later, on April 1, 

2015, Representative Meadows announced to his entire congressional staff that he had decided to have a full time chief of staff 

in Washington, D.C., and he would be replacing Mr. West.160 The 

same day, Representative Meadows officially changed Mr. West’s 

title to Senior Advisor but kept his salary the same.161 Representative Meadows did not inform his staff that Mr. West would be Senior Advisor. As a result, most of Representative Meadows’ staff did 

not know Mr. West was still on staff; they thought he had left the 

congressional office.162

According to Representative Meadows, as Senior Advisor, Mr. 

West had the same responsibilities that he previously had, including working on the budget and outreach in the district, except that 

he no longer supervised any employees.163 Mr. West, however, told 

the Committee that as Senior Advisor, he provided Representative 

Meadows with advice on legislation and continued to meet with 

constituents.164 He said he did not work on the office budget, but 

instead had turned those responsibilities over to Representative 

Meadows.165

Representative Meadows said he tried to encourage Mr. West to 

do work in the district during this time period, but admitted he did 

not do much follow up with Mr. West to ensure he was working.166

Mr. West, however, told the Committee that he called Representative Meadows every day and that Representative Meadows was 

aware of Mr. West’s meetings with constituents because his travel 

for those meetings was recorded on his mileage expense reports.167

The Committee reviewed the mileage reimbursements that Mr. 

West received for travel in his privately owned vehicle during the 


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168 Exhibit 13. Documents reviewed by the Committee show that Mr. West was on leave for 

five days in April 2015. Mr. West did not receive reimbursements for travel on those days and 

they are not included in the 48 total working days as Senior Advisor. 169 18(a) Interview of Representative Meadows. 170 Id. 171 Id. 172 Exhibit 14. 173 18(a) Interview of Representative Meadows. 174 Exhibit 14. 175 18(a) Interview of Representative Meadows; 18(a) Interview of Kenny West. 176 Representative Meadows later reimbursed the U.S. Treasury $400.96 for the three mileage 

reimbursements that Mr. West received from Representative Meadows’ Members Representation 

Allowance (MRA). The reimbursements were for travel on May 27, 2015, June 2, 2015 and June 

9, 2015. When asked about these trips, Mr. West claimed they were for official purposes. He 

also said Representative Meadows was aware of the trips, ‘‘because I told him I had other 

events.’’ 18(a) Interview of Kenny West. Representative Meadows told the Committee in a November 18, 2015, letter that the reimbursements were for legitimate official activity, but that 

he reimbursed the U.S. Treasury to address any concerns his constituents may have had. Letter 

from Representative Meadows to Chairman Charles W. Dent and Ranking Member Linda T. 

Sa ́nchez, Committee on Ethics (Nov. 18, 2015) (Appendix B). 

177 18(a) Interview of Representative Meadows. 178 Id. 179 Id. 180 Id. 

time he was Senior Advisor. Those reimbursements show that Mr. 

West traveled on 14 days out of a total of 48 working days.168

Representative Meadows said he did not change Mr. West’s pay, 

despite his decreased responsibilities, because he viewed this as a 

‘‘transition period.’’ 169 Representative Meadows explained, ‘‘[I]f I 

was in the private sector, I would have left his pay the same and 

figured out a way to get him gone.’’ 170 Representative Meadows 

also said he hoped that changing Mr. West’s title would encourage 

him to quit.171

L. MR. WEST RESIGNS AND IS PAID SEVERANCE

On May 21, 2015, Mr. West resigned.172 While Representative 

Meadows did not ask for his resignation that day, he said he had 

previously talked with Mr. West about his potential resignation or 

termination, and had encouraged him to seek other employment.173

In his resignation letter, Mr. West asked Representative Meadows 

to pay him through August or July at a minimum.174 According to 

Representative Meadows and Mr. West, Mr. West continued to do 

some official work until mid-June 2015.175 Mr. West’s mileage reimbursements show he traveled on three occasions for official purposes after his resignation.176

From mid-June until August 15, 2015, Mr. West was kept on 

Representative Meadows’ House payroll, as ‘‘severance,’’ at the 

same rate of pay that he had received as Chief of Staff and Senior 

Advisor.177Representative Meadows said he paid the severance because he wanted a smooth transition, but also because he thought 

it would encourage Mr. West not to file an age discrimination lawsuit against his congressional office.178 Representative Meadows 

told the Committee he was not sure if Mr. West had actually obtained legal representation, but said that Mr. West had told him 

that he had talked to an attorney at some point.179 However, Representative Meadows did not make, or attempt to make, any legal 

agreement with Mr. West that he would waive any legal claims.180

When asked why he did not take any measures to protect himself 

or his office from a possible lawsuit, Representative Meadows said, 


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181 Id. 182 Ethics Manual at 268–69 (citing Bates at 8–10); see also Meritor Sav. Bank v. Vinson, 477 

U.S. 57, 67 (1986) (quoting Henson v. Dundee, 682 F.2d 897, 902 (11th Cir. 1982)) (‘‘Sexual harassment which creates a hostile or offensive environment for members of one sex is every bit 

the arbitrary barrier to sexual equality at the workplace that racial harassment is to racial 

equality. Surely, a requirement that a man or woman run a gauntlet of sexual abuse in return 

for the privilege of being allowed to work and make a living can be as demeaning and disconcerting as the harshest of racial epithets.’’) 183 Id. 184Gary v. Long, 59 F.3d 1391, 1395 (D.C. Cir. 1995) (citations omitted). 185 Harris v. Forklift Sys., Inc., 510 U.S. 17, 21 (1993). 

‘‘I felt like [Mr. West’s resignation] was his admission that he was 

going to go on, you know, and do other things. . . .’’ 181

M. SPECULATION ABOUT THE HIRING AND DELAYED TERMINATION OF

MR. WEST

Multiple witnesses told the Committee they had speculated, or 

heard speculation, that Mr. West possessed negative information 

about Representative Meadows’ personal affairs. Several witnesses 

thought that the negative information may have spurred Representative Meadows to hire Mr. West, or to keep him on staff even 

after the allegations about his inappropriate behavior surfaced. 

Both Representative Meadows and Mr. West flatly denied this, and 

the Committee found no credible evidence to support it. 

V. FINDINGS 

Discrimination against a House employee on the basis of sex or 

gender is strictly prohibited by the Code of Official Conduct as well 

as the CAA, which subjected Congress to a number of federal employment laws, including Title VII of the Civil Rights Act of 1964. 

During the period under review, House Rule XXIII, clause 9, stated 

that ‘‘[a] Member . . . may not discharge and may not refuse to 

hire an individual, or otherwise discriminate against an individual 

with respect to compensation, terms, conditions, or privileges of 

employment, because of the race, color, religion, sex (including 

marital or parental status), disability, age, or national origin of 

such individual.’’ Indeed, the Committee has long held ‘‘that sexual 

harassment is a form of sex discrimination,’’ and that such behavior violates the House Code of Official Conduct.182 In the Matter of 

Representative Jim Bates, the Committee expressly held that a 

Member who violates applicable sex discrimination and sexual harassment laws also violates House Rule XXIII, clause 9.183

Under Title VII jurisprudence, sexual harassment may be actionable ‘‘in either of two circumstances: the grant or denial of an economic quid pro quo in exchange for sexual favors, or discrimination 

that has created a hostile or abusive work environment.’’ 184 A hostile work environment is one where the ‘‘workplace is permeated 

with discriminatory intimidation, ridicule, and insult’’ and these 

behaviors are ‘‘sufficiently severe or pervasive to alter the conditions of the victim’s employment and create an abusive working environment.’’ 185

Even if discriminatory conduct does not meet the elements of 

sexual harassment under Title VII, it may nonetheless run afoul of 

clauses 1 and 2 of the Code of Conduct, which is also found in 

House Rule XXIII. Clause 1 provides that Members and employees 

of the House ‘‘shall behave at all times in a manner that shall reflect creditably on the House.’’ It is a ‘‘purposefully . . . . subjecVerDate Sep 11 2014 04:29 Nov 27, 2018 Jkt 089006 PO 00000 Frm 00028 Fmt 6659 Sfmt 6602 E:\HR\OC\HR1042.XXX HR1042

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186See Ethics Manual at 13 (citing 114 Cong. Rec. 8778 (1968)). 187 Ethics Manual at 17 (‘‘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.’’). 188 Ethics Manual at 17. 189 House Comm. on Standards of Official Conduct, Report under the Authority of H. Res. 418, 

H. Rep. 1176, 90th Cong., 2d Sess. 17 (1968). 190 House Rule XI, clause 3(a)(2) (‘‘The Committee may investigate . . .an alleged violation by 

a Member, Delegate, Resident Commissioner, officer, or employee of the House . . . .’’). 191 Contrary to Mr. West’s assertions, the Committee found no indication that the allegations 

about Mr. West’s behavior were rooted in a desire to get Mr. West fired, a dislike of Mr. West, 

or anything related to his age. The Committee’s credibility determination is the same as the 

credibility determination Gowdy Staffer made after her independent investigation in November 

2014, which she relayed to Representative Meadows at that time. 18(a) Interview of Gowdy 

Staffer; 18(a) Interview of Representative Meadows. 192See Tucker v. Johnson, 211 F. Supp. 3d 95, 101 (D.D.C. 2016) (citation omitted) (describing 

the legal standard for Title VII claims in the D.C. circuit as ‘‘demanding’’). 

tive’’ standard.186 Clause 2 requires adherence to ‘‘the spirit and 

the letter’’ of House Rules. While conduct may not violate the ‘‘letter’’ of federal sexual harassment law (and thus, clause 9, which incorporates that law), it may still be contrary to the spirit of the 

prohibition on discriminatory conduct in the form of sexual harassment.187 Clause 2 is a ‘‘genteel rule’’ 188 meant to emphasize ‘‘the 

importance of the precedents of decorum and consideration that 

have evolved in the House over the years.’’ 189

A. MR. WEST’S BEHAVIOR

Mr. West is no longer a House employee and thus, is no longer 

subject to the House Rules that prohibit sexual harassment, nor to 

this Committee’s jurisdiction.190 However, the Committee does not 

want to leave the impression that his behavior was appropriate in 

any way. In fact, his behavior toward the female staff was inappropriate in every sense of the word. The Committee found the witnesses who described Mr. West’s conduct to be credible and their 

testimony was consistent.191 There is no place in any congressional 

office for looking up skirts, or down shirts; staring at a woman’s 

chest; unwanted touching; or making sexual comments, even if subtle or in jest. The fact that Mr. West supervised the women he did 

these things to makes his behavior even more unacceptable. Just 

as between Members and their staff, a power imbalance exists between senior staff and junior staff in congressional offices. Those 

entrusted with supervisory responsibilities in the workplace must 

be sensitive to the potential for discrimination and for creating uncomfortable working conditions for staff. 

Mr. West’s behavior raises serious questions as to whether it constituted sexual harassment under the demanding legal standards 

in Title VII jurisprudence.192 Clause 9 of the Code of Official Conduct, House Rule XXIII, mirrors the language of Title VII, and conduct that constitutes a violation of Title VII and the CAA is thus 

also a violation of the House Rules. At a minimum, Mr. West’s actions violated the spirit of clause 9, because his actions were inappropriate and discriminatory, and would thus violate clause 2 of 

the Code. The Committee also found that Mr. West’s actions while 

employed by the House did not reflect creditably on Representative 

Meadows’ office or the House as a whole, in violation of clause 1 

of the Code. Such behavior has no place in the House of Representatives. The women that worked in Representative Meadows’ office 

deserved much better. However, because Mr. West is no longer a 


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193Faragher v. City of Boca Raton, 524 U.S. 775 (1998); Burlington Industries, Inc. v. Ellerth, 

524 U.S. 747 (1998). The Faragher and Ellerth decisions held that an employer is vicariously 

liable for actionable harassment by a supervisor but the employer may assert an affirmative defense to liability when no tangible employment action was taken. Faragher, 524 U.S. at 807; 

Ellerth 524 U.S. at 765. The affirmative defense requires the employer to show 1) ‘‘the employer 

exercised reasonable care to prevent and promptly correct any sexually harassing behavior,’’ and 

2) ‘‘that the plaintiff employee unreasonably failed to take advantage of any preventative or corrective opportunities provided by the employer or to avoid harm otherwise.’’ Faragher, 542 U.S. 

at 807. 194See Comm. on Ethics, In the Matter of Allegations Relating to Representative Laura Richardson, H. Rept. 112–642, 112th Cong. 2d Sess. 97 (hereinafter Richardson) (‘‘Members are responsible for violations that occur in their office, and cannot shield themselves from liability by 

using staff as a proxy for wrongdoing’’); Comm. on Ethics, In the Matter of Allegations Related 

to Representative Ed Whitfield, H. Rept.114–687, 114th Cong., 2d Sess. 44 (hereinafter Whitfield) (The Committee found that Representative Whitfield violated House rules ‘‘by fail[ing] to 

establish clear guidelines and limits for his staff, which resulted in numerous lobbying contacts 

between his staff and [his wife]’’); 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. 111–142, 111th Cong. 

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

Subcommittee finds that it would not well serve the House as an institution to allow its Members to escape responsibility by delegating authority to their staff to take actions and hide behind their lack of knowledge of the facts surrounding those actions . . .’’). 195 Comm. on Standards of Official Conduct, In the Matter of Representative E.G. ‘‘Bud’’ Shuster, H. Rept. 106–979, 106th Cong. 2d Sess. 64 (2000) (hereinafter Shuster). 196 Id. at 49. 197 House Comm. on Ethics, In the Matter of Allegations Relating to Representative Alcee L. 

Hastings, H. Rept. 113–663, 113th Cong. 2d Sess. 16 (2014) (hereinafter Hastings). 

House employee, the Committee does not have jurisdiction over 

him. 

B. REPRESENTATIVE MEADOWS’ RESPONSE TO MR. WEST’S BEHAVIOR

Under Title VII jurisprudence, employers may be held vicariously 

liable for sexual harassment by a supervisory employee.193 The 

Committee has also long held, in other contexts, that a Member is 

generally responsible for violations of the Code of Conduct that 

occur in their offices.194

For example, in The Matter of Representative E.G. ‘‘Bud’’ Shuster, 

the Committee issued a letter of reproval to Representative Shuster for a pattern of conduct that did not reflect creditably on the 

House, in violation of then-House Rule XLIII, clause 1 (the predecessor to House Rule XXIII, clause 1). Among other things, the 

Committee found that Representative Shuster was responsible for 

his staff’s performance of campaign work in his congressional office, 

despite not finding evidence that Representative Shuster himself 

was aware the activity was taking place.195 The Committee explained, ‘‘Members of the House are ultimately responsible for ensuring their offices function in accordance with applicable standards. In this regard, Members must not only ensure that their offices comply with appropriate standards but also take account of 

the manner in which their actions may be perceived.’’ 196 The Committee sees no reason the result should be different in this context. 

In fact, the Committee previously advised Members ‘‘to scrupulously avoid even the impression of a workplace tainted by 

sexism.’’ 197

The Committee’s investigation explored (1) when Representative 

Meadows knew about Mr. West’s inappropriate behavior toward 

women and (2) whether Representative Meadows exercised reasonable care to prevent and promptly correct Mr. West’s behavior once 

he learned of it. As to the first issue, the Committee reviewed allegations that Representative Meadows may have known prior to OcVerDate Sep 11 2014 04:29 Nov 27, 2018 Jkt 089006 PO 00000 Frm 00030 Fmt 6659 Sfmt 6602 E:\HR\OC\HR1042.XXX HR1042

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198 Ryan Grimm and Paul Blumenthal, Congressman Behind Planned Parenthood Assault 

Kept Paying Aide After Sexual Harassment Complaints, HUFFINGTON POST, (Oct. 5, 2015), 

https://www.huffingtonpost.com/entry/mark-meadows-sexual-harassment-kenny-west_us_ 560f06eae4b0af3706e0fa1b. 199 Email from Elliot S. Berke to Kathryn Lefeber Donahue (May 13, 2016). 200The Committee believes the source for this article was the person this Report refers to as 

Campaign Supporter, who spoke to the Huffington Post reporter about this same subject. See 

18(a) Interview of Witness P. But Campaign Supporter has denied making the statement, including the claim that ‘‘[t]there were a number of us who talked to him.’’ See 18(a) Interview 

of Witness P. Id. 201 18(a) Interview of Witness P. 202 18(a) Interview of Representative Meadows. Representative Meadows said that after the 

allegations about Mr. West were made public, Campaign Supporter reminded Representative 

Meadows that he had previously told him that Mr. West was someone who invaded people’s 

space. 203 Representative Meadows also told the Committee that he asked his daughter whether she 

had ever experienced or observed any inappropriate behavior by Mr. West. She told him she 

had not. 18(a) Interview of Representative Meadows. 

tober 2014 that Mr. West made women feel uncomfortable. A report 

published in the Huffington Post on October 5, 2015, stated: 

A person close to Meadows said he personally observed 

West’s behavior around women before he was offered the 

job, and warned Meadows about West. ‘‘There were a number of us who talked to him and basically said, ‘You have 

a problem here,’ before he ever got sworn into office,’’ he 

said.198

Representative Meadows has denied this account,199 and the 

Committee’s investigation did not substantiate this claim.200 As 

discussed previously, however, Campaign Supporter and Representative Meadows did have a conversation about Mr. West prior 

to Representative Meadows being sworn into office. Campaign Supporter described the conversation as follows: 

I did tell [Representative Meadows] that Kenny had— 

when he was in my business interviewing my employees, 

that after he left, I had two female employees come up and 

tell me that they didn’t ever want to be interviewed by 

him again, that he made them feel very uncomfortable. 

Now, Kenny is what I call a space invader. He’s very 

touchy. He likes to get really close to you when he talks. 

He likes to have his arm on you, I mean, if it’s a man or 

a woman. And I told Mark, I said, this guy, you know, he 

needs to understand space respect [sic]. And I told him 

about that. I felt like I had to.201

When asked about this conversation, Representative Meadows said 

he recalled having conversations with Campaign Supporter about 

Mr. West, but did not specifically remember Campaign Supporter 

saying Mr. West made females feel uncomfortable or that that he 

was a ‘‘space invader.’’ 202

The Committee found Representative Meadows’ testimony on 

this point to be credible. Representative Meadows explained that 

he had allowed his daughter to intern in his House office, which 

he would have never done if he believed Mr. West was a threat to 

the female staff.203 Even assuming that Campaign Supporter did 

tell Representative Meadows that Mr. West had made some women 

feel uncomfortable and was a ‘‘space invader,’’ the Committee does 

not believe that would have placed Representative Meadows ‘‘on 

notice’’ that Mr. West would behave inappropriately toward his female congressional staff. The Committee found no credible evidence 


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204 18(a) Interview of Gowdy Staffer; 18(a) Interview of Representative Meadows. 205 18(a) Interview of Representative Meadows. Representative Meadows told Mr. West that 

the only female employee he could have direct contact with was his scheduler because it was 

necessary for scheduling purposes. 206 Id. 

that Representative Meadows knew about Mr. West’s inappropriate 

behavior prior to receiving the complaints from female staff in his 

Washington, D.C., and district offices in October 2014. 

Turning to the second issue, whether Representative Meadows 

exercised reasonable care to prevent and promptly correct Mr. 

West’s behavior when he learned of it in October 2014, the record 

shows that Representative Meadows took some immediate steps to 

address the allegations, but ultimately did not do enough. The 

Committee did not find that Representative Meadows intentionally 

placed his staff at risk, but his failure to take appropriate and 

swift action did exactly that. 

One of Representative Meadow’s first measures was to prohibit 

Mr. West from the congressional offices and from directly contacting most of his female employees. Removing an alleged harasser from the workplace is an appropriate first step in response 

to allegations of inappropriate behavior or sexual harassment. Representative Meadows also sought guidance from Representative 

Gowdy, and asked Gowdy Staffer to conduct an investigation. Representative Meadows had the right idea to ask a neutral, third 

party to investigate the allegations. However, while Gowdy Staffer 

had substantial experience with investigations, as she was a former 

prosecutor, at the end of the day she was another Member’s employee. A Member should not ask another Member’s staff to investigate allegations of inappropriate behavior. It would have been 

more appropriate for Representative Meadows to have sought the 

assistance of an independent investigator specifically trained in 

workplace investigations. He could have done so through the House 

resources available, such as the Committee, OOC or OHEC. 

Regardless, Gowdy Staffer did conduct an independent investigation, as requested, which involved informal interviews of female 

staff in Representative Meadows’ Washington, D.C., office, but not 

of any district staff, male staff, or Mr. West. The result was unequivocal: she told him Mr. West ‘‘had to be let go.’’ 204 As discussed in Section IV.F., Gowdy Staffer explained to Representative 

Meadows that his staff was ‘‘not comfortable,’’ could not work for 

Mr. West, and that the female employees had ‘‘consistent’’ and ‘‘serious claims.’’ Gowdy Staffer also emphasized these claims could 

create ‘‘real problem[s]’’ for Representative Meadows, including possible claims of sexual harassment and a hostile work environment. 

Yet when Representative Meadows received the recommendation, 

in November 2014, he did not follow it. Instead, Representative 

Meadows merely formalized the measures he had previously taken: 

Mr. West (1) could have no contact with female employees other 

than the scheduler 205; (2) could not return to the Washington, 

D.C., or district congressional offices where female employees were 

present; and (3) should use the D.C. Deputy Chief and District 

Deputy Chief, both male employees, as a conduit for any supervisory interactions with female employees.206

This created several problems. First, it did not send a message 

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207 18(a) Interview of Representative Meadows. 208See Exhibit 10. 209 18(a) Interview of Representative Meadows. 210 18(a) Interview of Employee J. 211 Id. 

assment is not tolerated in the House. Certainly, Representative 

Meadows’ decision to initiate an independent investigation and 

then to leave the alleged harasser in a position of authority over 

the staff could be seen to communicate the opposite message, that 

Representative Meadows either did not believe the female staff or 

was not concerned enough to terminate Mr. West. 

The Committee asked Representative Meadows if he had any 

concern that his female staff would experience anxiety due to the 

uncertainty about Mr. West’s role and authority from October 2014 

until Representative Meadows announced he would replace Mr. 

West on April 1, 2015. He explained his view: 

I tried to assure them in any way while we were evaluating the whole deal that their personal contact with Mr. 

West—they would not have to make personal contact with 

him. So I felt like that would alleviate the concern. . . . I felt like they were protected because I think they knew 

that I was serious about not having him back. . . . I 

thought my staff, early on, trusted me enough to know 

that their health and wellbeing was my number-one concern. I was unequivocal in sharing that I wanted them to 

be protected.207

If this is the message Representative Meadows intended to send, 

it was muddled at best. The female staff’s concerns are demonstrated in a February 6, 2015, email to Gowdy Staffer, months 

after she completed her investigation. The female employee wrote, 

‘‘there are still talks of him coming back up. He is also still in control of the budget/salaries, which has many concerned. Mr. Meadows was adamant that it has been addressed, though.’’ 208

Second, Representative Meadows’ plan to prohibit contact between the female staff and Mr. West did not work. On several occasions, Mr. West intentionally disregarded the limits placed on him. 

In January 2015, after the independent investigation was completed, the D.C. Deputy Chief told Representative Meadows Mr. 

West was calling female staff.209 The D.C. Deputy Chief told the 

Committee that female staff felt they were in a bind: 

I think there was a bit of an expectation: He is still the 

chief; I don’t want to just hang up on him because I have 

been told otherwise, like I don’t know how to handle this. 

There was a concern of if Kenny calls me, what do I do? 

He is still the chief of staff, even though I have also been 

told . . . I am not going to be interacting with him. So I 

am not sure what to do because he is still in a managerial 

role, at least in title, but not in practice, at least according 

to what the Congressman had told them previously.210

Mr. West continued to flout the rules Representative Meadows 

put in place as late as mid-March 2015, when Mr. West called two 

female employees, multiple times.211 These continued contacts 

show that however genuine Representative Meadows’ intention to 

protect his staff, his ground rules were not working, and female 


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212Title VII jurisprudence also prohibits retaliation. See e.g., McGrath v. Clinton, 666 F.3d 

1377, 1380 (D.C. Cir. 2012). 213 18(a) Interview of Kenny West. 214 18(a) Interview of Representative Meadows. 

employees continued to feel uncomfortable in the work environment that Representative Meadows oversaw. 

Third, retaining Mr. West in his supervisory position created an 

environment ripe for retaliation. As mentioned previously, the CAA 

not only prohibits sexual harassment in the House, but also reprisal or intimidation against a person for reporting sexual harassment.212 The investigative record shows that Mr. West continued 

to provide Representative Meadows with evaluations of the congressional staff, in November 2014 and February 2015. In those 

evaluations, he was critical of the D.C. and District Deputy Chiefs 

and several of the female employees that raised the harassment allegations. The record also shows that Mr. West made recommendations for salary increases and promotion for two female employees 

in March 2015, which Representative Meadows ultimately put into 

place. As mentioned previously, a female employee raised a concern 

about Mr. West’s control over the salaries and budget in her email 

to Gowdy Staffer in February 2015. Representative Meadows also 

allowed Mr. West to secretly access the email accounts of the D.C. 

and District Deputy Chiefs. According to Mr. West’s testimony, it 

was ‘‘to see what was transpiring between [the Deputies],’’ because 

‘‘[i]t’s my opinion that them [sic] two were a main cause of what 

happened.’’ 213

The Committee asked Representative Meadows if he had any 

concern about keeping Mr. West in his supervisory role after the 

allegations. He said, ‘‘[b]ecause I had the ultimate responsibility of 

hiring and firing and payroll, it certainly did not create the type 

of elevated concern that, you know, that, all of a sudden he was 

going to let somebody go or there was going to be some issue where 

they didn’t get compensated properly. So, you know, in retrospect, 

maybe I should have looked at it differently.’’ 214

It is true, and significant, that neither Mr. West nor Representative Meadows took any formal adverse employment action against 

any of the female staff or the Deputies that reported the allegations, and several complainants were actually promoted or received 

raises while Mr. West was Chief of Staff. However, by allowing Mr. 

West to continue to evaluate employees and to secretly access the 

D.C. and District Deputy Chief’s email accounts, Representative 

Meadows fostered the potential for retribution by Mr. West. Representative Meadows could and should have done more to remove 

Mr. West’s supervisory authority and inform the staff that he had 

done so. He did not adequately protect his staff from the possibility 

of retaliation. 

It seems that Representative Meadows did not fully comprehend 

the ramifications of his decision to keep Mr. West as Chief of 

Staff—despite being told otherwise by Gowdy Staffer—until the office of the Speaker raised the issue with him, five months after the 

initial complaints about Mr. West and four months after the independent investigation was complete and recommended termination. 

Based on the entire record in this matter, the Committee found 

that, when he learned about allegations of sexual harassment by 

Mr. West, Representative Meadows took some immediate and apVerDate Sep 11 2014 04:29 Nov 27, 2018 Jkt 089006 PO 00000 Frm 00034 Fmt 6659 Sfmt 6602 E:\HR\OC\HR1042.XXX HR1042

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215 Id. 216 Id. 217Shuster at 49. 

propriate steps to separate Mr. West from his female staff and to 

request an independent investigation. However, these steps were 

insufficient. Mr. West retained his title and all the actual and apparent authority over staff that went with it. Further, Representative Meadows’ actions did not communicate to his staff that he had 

taken the complaints seriously, and it did not protect them from 

potential future harassment or retaliation. 

When asked if he was concerned about the impact this situation 

would have on his female staff, Representative Meadows stated ‘‘I 

think there was a bigger concern on my part, is making sure that 

in any evaluation of the truth [Mr. West] got a fair shake all the 

way around. And so, to just immediately terminate without hearing 

the facts was a concern.’’ 215 Due process is of course essential, and 

had Representative Meadows utilized House resources such as 

OHEC, the Committee, or OOC, Mr. West would have received it. 

Instead, Representative Meadows ignored the results of an independent investigation and did not remove Mr. West for five 

months. The Committee found this was not an adequate or timely 

response. 

Moreover, Representative Meadows’ attempt to fix the ‘‘pervasive 

problem’’ 216 of harassment in his offices by limiting Mr. West’s contact with female employees created a serious risk of gender discrimination. After the complaints came to him in October 2014, 

Representative Meadows cut off communications between Mr. West 

and all female staff, except one female scheduler. As a result, most 

of the female staff could not have any contact with the person who 

was supposed to be providing supervision and direction, and who 

had significant input into promotions, compensation and the office 

budget, among other things. Male staff were not limited in the 

same way. The Committee found Representative Meadows’ attempt 

to fix the problem risked subjecting his female employees to further 

discrimination. 

As described above, Members are ultimately responsible for ensuring their offices function in accordance with applicable standards and they also must ‘‘take account of the manner in which 

their actions may be perceived.’’ 217 Representative Meadows is responsible for ensuring that his office is free from discrimination 

and any perception of discrimination, and he failed to adequately 

or promptly do so after learning about the allegations involving Mr. 

West. As such, his actions were contrary to the spirit of the antidiscrimination provision of the Code of Official Conduct (clause 9), 

in violation of clause 2 of the Code (which requires Members to adhere to the spirit of the rules of the House). The Committee also 

found that Representative Meadows’ actions did not reflect 

creditably on the House, in violation of clause 1 of the Code of Conduct. Congressional offices should serve as an example of discrimination-free workplaces for the rest of the country. Members should 

never tolerate sexual harassment or any other discriminatory conduct in their offices, or give even the slightest impression that such 

conduct is acceptable in the congressional workplace. 

If Representative Meadows had sought assistance from any of 

the House resources available to him when he learned of the alleVerDate Sep 11 2014 04:29 Nov 27, 2018 Jkt 089006 PO 00000 Frm 00035 Fmt 6659 Sfmt 6602 E:\HR\OC\HR1042.XXX HR1042

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218 Code of Ethics for Government Service ¶ 3. 219 31 U.S.C. § 1301(a); see also Ethics Manual at 279. 220Members’ Handbook (2018) at 4; Exhibit 1 at 3–4. See also Ethics Manual at 277. 221 Ethics Manual at 267; see also Members’ Handbook (2018) at 4 (‘‘the Member determines 

the terms and conditions of employment and service for their staff.’’); Exhibit 1 at 3. 

gations, like the Committee, OOC or OHEC, and followed their advice, his actions would likely have complied with applicable House 

Rules. It is the best practice for a Member to utilize the appropriate independent House resources when faced with allegations of 

sexual harassment or discrimination in their offices. It is also a 

best practice for Members to follow recommendations after seeking 

appropriate outside assistance. Had Representative Meadows followed the recommendation from Gowdy Staffer and terminated Mr. 

West’s employment after the investigation, most of the violations 

discussed in this Report would have been avoided. 

Members and employees alike should be able to work free from 

sexual harassment or discrimination of any kind. The Committee 

notes that House Resolution 630, which was passed on November 

29, 2017, requires each Member, Officer, and employee of the 

House to complete an education program focused on workplace 

rights and responsibilities. The Committee is hopeful that this will 

increase awareness of sexual harassment and discrimination in the 

workplace, encourage Members and staff to identify any issues that 

may arise in their offices, and educate Members and staff about the 

range of resources available to them. 

C. MR. WEST’S REVISED DUTIES, COMPENSATION, AND SEVERANCE

Representative Meadows’ decisions to continue paying Mr. West, 

at his full salary, after he was (1) barred from working in the congressional offices and contacting most female staff; (2) demoted to 

Senior Advisor and lost his supervisory responsibilities; and (3) no 

longer serving in any position in Representative Meadows’ office, 

raise questions as to whether Representative Meadows violated 

House Rule XXIII, clause 8. 

1. House Rule XXIII, clause 8, and the Committee’s guidance and 

precedent 

Clause 8 states ‘‘[a] Member . . . of the House may not retain 

an employee who does not perform duties for the offices of the employing authority commensurate with the compensation such employee receives.’’ The Code of Ethics for Government Service further instructs every employee to ‘‘[g]ive a full day’s labor for a full 

day’s pay,’’ 218 and federal law requires that appropriated funds are 

to be used solely for purposes for which appropriated.219 CHA regulations require employing Members to submit monthly salary certifications for their staff to ensure compliance with applicable regulations.220

Notwithstanding these restrictions, the ‘‘general terms, conditions, and specific duties of House employees traditionally have 

been within the discretion of the employing Member.’’ 221 Accordingly, while a staffer is instructed to ‘‘give a full day’s labor for a 

full day’s pay,’’ the employing Member may dictate what a ‘‘full 

day’s labor’’ consists of. 

Clause 8 aims to prevent fraud or misuse of the House payroll, 

particularly the use of ‘‘ghost employee’’ schemes. In such schemes, 


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222See U.S. v. Robinson, 903 F. Supp. 2d 766, 791 (E.D. Mo. 2012) (‘‘[A]n employee who receives salary money for time in which he did not work or perform services is a ‘ghost’ employee 

who is not receiving bona fide salary or wages’’); U.S. v. Harloff, 815 F. Supp. 618, 619 

(W.D.N.Y. 1993) (citing U.S. v. Stout, 1990 U.S. Dist. LEXIS 12343 (E.D. Pa. 1990) (noting that 

18 U.S.C. § 666(c) authorizes prosecution based on ‘‘ghost employees,’’ or situations in which an 

employee ‘‘invents fictitious workers and collects their ‘wages’ for his/her own use’’). 223 Before the permanent Committee on Standards of Official Conduct was created in 1967, 

and before the existence of either Rule XXIII, clause 8, or Rule XLIII, clause 8, various subcommittees of the House investigated Representative Adam Clayton Powell, Jr. for expenditures 

he made as chairman of the Committee on Education and Labor, including salary payments he 

made to his wife over more than two years, even though she performed no official duties during 

that time. In the 90th and 91st Congresses, Representative Powell was removed from his chairmanship and fined, and an attempt was made to exclude him from the House. See Select Comm. 

Pursuant to H. Res. 1, In re Adam Clayton Powell, H. Rept. 90–27, 90th Cong., 1st Sess. 19– 

20, 31–32 (1967); see also Ethics Manual at 5. 224 Comm. on Standards of Official Conduct, In the Matter of Representative Charles H. Diggs, 

Jr., H. Rept. 96–351, 96th Cong., 1st Sess. 5–6, 44 (1979) (hereinafter Diggs). 225 Id. at 5. 226 Comm. on Standards of Official Conduct, Summary of Activities, One Hundredth Congress, H. Rept. 100–1125, 100th Cong., 2d Sess. 15–16 (In the Matter of Delegate Fofo I.F. Sunia and 

Matthew K. Iuli). 227 Id. at 15. 228 Id. at 15–16. 

an employee is recorded on the payroll, but—with the Member’s 

knowledge—does not perform official work equivalent to the earnings he or she collects. The ‘‘ghost employee’’ may be a real individual, or a fictitious person who is misrepresented on payroll 

records as a bona fide employee, whose wage or salary payments 

are then used for some impermissible purpose.222

Consistent with the animating purpose of House Rule XXIII, 

clause 8, and its predecessor, former Rule XLIII, clause 8, the Committee has historically found violations of the ‘‘ghost employee’’ rule 

in cases where Members have knowingly converted official funds, 

originally disbursed as staff compensation, for their personal financial benefit or other unauthorized use.223 For example, in The Matter of Representative Charles C. Diggs, Jr., the Committee found 

that Representative Diggs had inflated the salaries of several of his 

employees, beyond levels commensurate with their respective duties, to enable those employees to ‘‘kick back’’ the additional funds 

to Representative Diggs to pay certain personal and official expenses.224 The Committee also found that Representative Diggs 

had placed several individuals on his congressional payroll to compensate them for personal services they provided to him.225 On the 

basis of those findings, the Committee recommended censure to the 

House and required Representative Diggs to repay official funds for 

various violations of clause 8. 

Violations of clause 8 may also implicate federal criminal laws. 

During the 100th Congress, the Committee initiated an inquiry 

into allegations that Delegate Fofo I.F. Sunia authorized the disbursement of compensation to individuals who did not perform 

services for the House, in violation of Rule XLIII, clause 8.226 The 

Committee deferred its investigation at the request of the U.S. Attorney’s Office for the District of Columbia, which was actively investigating the matter.227 Delegate Sunia later pleaded guilty to 

having conspired to commit fraud in violation of 18 U.S.C. § 371 

(the criminal conspiracy statute) by submitting payroll forms and 

collecting salary checks for individuals who performed no work.228

Upon reviewing the evidence relating to the guilty pleas, the Committee found that Delegate Sunia had used the salary checks to 

pay for hotel and meal expenses for visiting constituents and staff, 

campaign expenses, and personal expenses of his family, in violaVerDate Sep 11 2014 04:29 Nov 27, 2018 Jkt 089006 PO 00000 Frm 00037 Fmt 6659 Sfmt 6602 E:\HR\OC\HR1042.XXX HR1042

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229 Id. at 16. 230 Id. 231 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). 232 Id. at 5. 233 Id. at 33. 234 Id. at 5. 235 Comm. on Standards of Official Conduct, In the Matter of Representative Barbara Rose Collins, H. Rept. 104–876, 104th Cong., 2d Sess. 35 (1997). 236 Id. at 35–36. 237 Comm. on Standards of Official Conduct, In the Matter of Representative Charles H. Wil- son, H. Rept. 96–930, 96th Cong., 2d. Sess. 2 (1980). 

tion not only of the conspiracy statute, but also of the Code of Official Conduct and the Code of Ethics for Government Service.229

However, Delegate Sunia resigned before the Committee could hold 

a disciplinary hearing to consider sanctions.230

The Committee has also found violations of the ‘‘ghost employee’’ 

rule where a Member did not profit or otherwise obtain a financial 

benefit from the misuse of official funds appropriated for staff compensation, but retained and paid an employee even though the 

Member knew the employee was not physically present to perform 

official work. 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 hiring and retaining an individual on his 

subcommittee staff who did not perform duties commensurate with 

the compensation he received.231 In that matter, the subcommittee’s staff director began to have frequent absences from work.232

Indeed, despite his position as staff director, and the management 

responsibilities associated with the position, his frequent absences 

left staff ‘‘wonder[ing] among themselves what [he] was doing.’’ 233

Given the nature of the employee’s responsibilities and the circumstances surrounding his absences, the Committee found that 

his attendance had deteriorated to the point that he was no longer 

performing the duties of his position and that Representative Murphy knew that the employee was not working, though he remained 

on the House payroll.234 Thus, the Committee concluded that Representative Murphy’s conduct violated House Rule XLIII, clause 8. 

In The Matter of Representative Barbara Rose Collins, the Committee found Representative Collins violated House Rule XLIII, 

clause 8, by providing several of her staff members with temporary 

salary raises that were not commensurate with official duties they 

performed.235 The Committee found that the pay increases—which 

Representative Collins was personally involved in implementing— 

were wholly unrelated to staff’s performance of official duties. 

Rather, the Committee found that the raises were paid to Representative Collins’ congressional staff to enable them to accompany her on a trip to Ghana that was personal in nature. Moreover, the Committee obtained evidence that Representative Collins 

had specifically linked payment of the salary increases to staff’s 

willingness to participate in the trip.236

Finally, in The Matter of Representative Charles H. Wilson, the 

Committee found Representative Wilson hired a person whose salary was not commensurate with duties performed, in violation of 

XLIII, clause 8, when he employed a friend and political supporter 

as a congressional staffer.237 The individual was hired for the stated purpose of advising Representative Wilson on postal matters, 

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238 Id. at 354–55. 239The D.C. Deputy Chief told the Committee that in 2014, Representative Meadows gave the 

staff bonuses in October so they could use them for the holidays. 18(a) Interview of Employee 

J. 240 Rate set by Order of the Speaker of the House of Representatives, pursuant to 2 U.S.C. 

§ 4532. 241 18(a) Interview of Representative Meadows. 

son with the California business community. However, the Committee found many of the duties for which the staffer was paid 

were incidental to his role as Representative Wilson’s personal confidant and campaign representative.238

2. Representative Meadows’ compensation of Mr. West 

Representative Meadows paid Mr. West a salary of at least $155,000 per year from the time he became a House employee on 

January 3, 2013 until the he left his employment with the House 

on August 15, 2015. In October 2014, Representative Meadows adjusted most of his employees’ salaries, including Mr. West’s salary, 

to a higher rate apparently for a year-end bonus.239 Representative Meadows adjusted Mr. West’s salary from $155,000 to $168,411, 

the maximum rate of pay at that time.240 The other staff who received the temporary pay increase in October had their pay adjusted back to their regular salary as of November 2014. Mr. West’s 

salary remained at $168,411 for November and December 2014, 

was moved to $157,400 in January 2015 and finally back to 

$155,000 in February 2015, where it remained until his employment ended on August 15, 2015. As a result, Mr. West received 

$3,552.74 of additional gross pay, apparently as a bonus, from October 2014 to January 2015, which coincides with when Mr. West 

began to be prohibited from entering the congressional offices and 

from contacting the female congressional staff. 

The Committee examined Mr. West’s duties and pay at the following junctures in his tenure with Representative Meadows: (1) 

Mid-October 2014 through April 1, 2015, when Mr. West was restricted from the congressional offices and from contacting most of 

the female employees, but still served as Chief of Staff; (2) April 

1, 2015 to mid-June 2015, when Mr. West held the title of ‘‘Senior 

Advisor’’ and lost his supervisory responsibilities; and (3) Mid-June 

2015 to August 2015, when Mr. West was paid ‘‘severance’’ and no 

longer served in any House position. 

i. Pay as Chief of Staff from Mid-October 2014—April 1, 2015 

Representative Meadows has asserted Mr. West maintained all 

of his supervisory and managerial responsibilities over the more 

than five month period following the initial complaints of sexual 

harassment until he demoted Mr. West on April 1, 2015. The Committee found it difficult to understand how a chief of staff could 

perform some of the core functions of that position, particularly supervising all staff, when he was unable to speak with over half of 

the employees (those who were female) and could not set foot in 

any of the congressional offices. In fact, Mr. West himself told Representative Meadows when he was barred from the offices, ‘‘I can’t 

even do my job.’’ 241

When asked how Mr. West could do his job, Representative 

Meadows explained that Mr. West could continue to have conversations with the Deputies. He said, ‘‘You know, to make the assumpVerDate Sep 11 2014 04:29 Nov 27, 2018 Jkt 089006 PO 00000 Frm 00039 Fmt 6659 Sfmt 6602 E:\HR\OC\HR1042.XXX HR1042

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242 18(a) Interview of Representative Meadows. 243 Ethics Manual at 267. 244 18(a) Interview of Representative Meadows. 245 Id. 246See Exhibit 13. 247See 18(a) Interview of Representative Meadows; 18(a) Interview of Kenny West. 248 18(a) Interview of Representative Meadows. 249 Id. 

tion that you have to have a personal interaction with a female employee to properly supervise would be to suggest that everything is 

a flat plane, and that you’ve got to have that. I mean, so he still 

had that same supervisory managerial role that he would have 

without the personal interaction . . .’’ 242

The Committee questions how this arrangement actually worked 

in practice and is concerned that Mr. West received an apparent 

bonus in the months following the allegations. However, the Committee has long held that Members have discretion over the terms, 

conditions and duties of House employees that they employ.243 Mr. 

West was still doing a ‘‘full day’s labor.’’ Even if the Committee believes the rate of pay he received was higher than what most Members would choose to pay an employee performing similar duties, 

it was still within the reasonable exercise of Representative Meadows’ discretion. Accordingly, the Committee found no violation of 

clause 8 from mid-October 2014 to April 1, 2015. 

ii. Pay as Senior Advisor from April 1, 2015—Mid-June 2015 

After Mr. West was demoted to Senior Advisor on April 1, 2015, 

Representative Meadows told the Committee Mr. West lost his supervisory responsibilities.244 While Representative Meadows said 

that Mr. West was still ‘‘operating,’’ he admitted that he considered 

this a ‘‘transition period’’ and he did not follow up with Mr. West 

as much as he should have to ensure that he was doing his job.245

The mileage reimbursements that Mr. West received when he was 

Senior Advisor show he traveled on 14 of 48 possible working days, 

approximately thirty percent of the time, presumably for constituent meetings.246 As demonstrated by Representative Meadows’ 

and Mr. West’s testimony, they were not on the same page as to 

what Mr. West’s responsibilities were as Senior Advisor.247 The 

rest of Representative Meadows’ congressional staff did not know 

that Mr. West was even on staff at this time, let alone what he was 

doing, which further suggests that Mr. West’s work during this 

time was infrequent and inessential. 

When asked why he did not change Mr. West’s pay when his responsibilities changed, Representative Meadows told the Committee, ‘‘if I was in the private sector, I would have left his pay the 

same and figured out a way to get him gone. . . . I had no idea 

that I was violating any kind of [rule]—in fact, quite the opposite.’’ 248 He elaborated, ‘‘I think that’s the normal way that you 

would do this in the private sector, and I assumed that that’s the 

way that we would do business, you know, in this environment.’’ 249

Representative Meadows does not work in the private sector, and 

the payments that he authorized despite the substantial decrease 

in work by Mr. West were made with public funds. The Committee 

credits Representative Meadows’ testimony that he did not intend 

to violate the rules regarding compensation for House employees. 

Nonetheless, Mr. West’s terms, conditions, and duties of his emVerDate Sep 11 2014 04:29 Nov 27, 2018 Jkt 089006 PO 00000 Frm 00040 Fmt 6659 Sfmt 6602 E:\HR\OC\HR1042.XXX HR1042

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250 Ethics Manual at 136. 251See e.g., Murphy at 5 (Member violated clause 8 by keeping the staff director of the Committee that he chaired on the payroll despite knowing he was not fulfilling the responsibilities 

of his position); Richardson at 91–92 (Member violated clause 8 by retaining a full time staffer 

who actually spent most of her time performing campaign work). 252Whitfield at 45 (‘‘a Member’s mistaken belief in their compliance with the rules does not 

excuse a violation of those rules’’). 253 18(a) Interview of Representative Meadows. 254Letter from Elliot S. Berke, Counsel to Representative Meadows, to Chairman Charles W. 

Dent and Ranking Member Linda T. Sa ́nchez, Committee on Ethics (May 10, 2016) (Appendix 

B). 255Supra Section V.C.2.ii. 

ployment drastically changed during this time period, but his compensation did not. The Committee has stated previously that when 

an employee’s time working in the congressional office substantially decreases, a corresponding decrease in pay is appropriate.250

The Committee has previously found Members to have violated 

House rules where they used official funds to compensate House 

employees who did not do work commensurate with their pay.251

Further, the Committee has long held that ignorance of a House 

rule is no excuse for violating it, or defense to an adverse action.252

Thus, the Committee found that Representative Meadows violated 

both the letter and spirit of House Rule XXIII, clause 8 during the 

two and a half months Mr. West was Senior Advisor. 

iii. Severance from Mid-June 2015—August 15, 2015 

After Mr. West completed his official work as Senior Advisor, 

Representative Meadows payed him ‘‘severance’’ by leaving him on 

House payroll for two months when he was not working. There is 

no dispute that Mr. West was not giving a ‘‘full day’s labor for a 

full day’s pay’’ for those two months. The Committee acknowledges 

that there was little and inconsistent guidance on severance payments available to the House community at the time Representative Meadows paid severance to Mr. West. That said, Representative Meadows sought no guidance from OHEC, the Committee, or 

any of the other appropriate source in determining the amount, 

terms, or conditions of the ‘‘severance.’’ 253 He has claimed that he 

consulted with OHEC after the fact and they told him that he handled the matter consistent with advice OHEC has offered in similar 

situations.254 However, the Committee was not privy to those communications. Representative Meadows also did not obtain anything 

of discernable value to the House in exchange for the ‘‘severance’’ 

he paid to Mr. West. For example, despite asserting that he paid 

the ‘‘severance’’ in part to avoid an age discrimination lawsuit, Representative Meadows did not obtain a waiver of legal claims 

against his office. By keeping Mr. West on the payroll without 

working, Representative Meadows retained an employee who did 

not perform duties commensurate with the compensation he received. As mentioned above, the Committee has previously found 

Members to have violated House rules where they used official 

funds to compensate House employees who did not do work commensurate with their pay.255 For this reason, the Committee found 

that Representative Meadows’ payment of ‘‘severance,’’ by keeping 

Mr. West on House payroll for two months without performing any 

work, violated the letter and spirit of House Rule XXIII, clause 8. 


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256Members’ Handbook (2018) at 2; see also Exhibit 1 at 2; Ethics Manual at 323 (‘‘Members 

may be personally liable for misspent funds or expenditures exceeding the MRA.’’). 257See, e.g., Comm. on Ethics, In the Matter of Representative Luis V. Gutie ́rrez, H. Rept. 115– 

617, 115th Cong. 2d Sess. 29 (2018) (hereinafter Gutie ́rrez) (Member was issued a reproval and 

required to repay $9,700 for misusing MRA funds to pay a contractor for services outside the 

scope of the contract and beyond permissible scope under CHA rules); Diggs at 17–18 (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); Powell at 19–20, 31–32 (Member was removed from his chairmanship, fined $40,000 and an attempt was made to exclude him from the House 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); 

Richardson at 15 (Member was reprimanded and fined $10,000 for her ‘‘misconduct,’’ which included retaining a full time staffer who did not perform the duties of her office commensurate 

with compensation received). 258Murphy at 5. 259 Id. at 4. 260See Members’ Handbook (2018) at 4; Exhibit 1 at 3. 261See, e.g., Gutie ́rrez at 29. 262See Comm. on Ethics, In the Matter of Allegations Relating to Representative Don Young, 

H. Rept. 113–487, 113th Cong. 2d Sess. 62 (2014) (ISC could not determine the precise value 

of lodging and hunting services given to a Member because the host ‘‘did not prepare an invoice 

D. REPAYMENT OF FUNDS TO THE U.S. TREASURY

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.’’ 256 Consistent 

with this guidance, where Members have used official funds for impermissible purposes, the Committee has frequently directed them 

to repay any misspent funds.257 There have, however, been instances where the Committee has sanctioned a Member but has 

not required repayment of misused funds. Most notably, In the 

Matter of Representative Austin J. Murphy, the Committee recommended and the House voted to issue a reprimand for various 

misuses of official resources, including paying an absentee employee.258 In the Committee’s discussion of the matter, it did not 

discuss repayment, and stated that, while Representative Murphy 

acknowledged misuse of official resources, he ‘‘either disclaimed his 

knowledge or approval of such activity, or asserted that such instances were de minimis.’’ 259

In this case, Representative Meadows cannot claim that he was 

unaware of Mr. West’s pay when he was Senior Advisor or while 

being paid ‘‘severance,’’ because he was the one who authorized it. 

Further, Mr. West’s pay was in no way de minimus: from April 1, 

2015 to June 15, 2015 he made $32,291.68 as Senior Advisor, and 

his two months of ‘‘severance’’ totaled $25,833.34. As such, reimbursement in this matter is appropriate, consistent with the Members’ Handbook 260 and the Committee’s more recent precedent.261

Accordingly, the Committee attempted to calculate the amount 

by which Representative Meadows overcompensated Mr. West during the time periods where he did not perform duties commensurate with his compensation, in violation of clause 8. As stated previously, when Mr. West was Senior Advisor from April 1, 2015 to 

June 15, 2015 he earned $32,291.68. Because the investigative 

record is inconclusive about the amount of official work Mr. West 

performed during that time period, it is difficult to estimate how 

much of that pay was commensurate with his duties. Even so, in 

recent matters, the Committee has directed Members to make repayments even where ‘‘estimating [a] value is imprecise,’’ 262 or deVerDate Sep 11 2014 04:29 Nov 27, 2018 Jkt 089006 PO 00000 Frm 00042 Fmt 6659 Sfmt 6602 E:\HR\OC\HR1042.XXX HR1042

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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). 263 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). 264 Representative Meadows asked the Committee whether Mr. West’s unused accrued leave 

was factored into the calculation of the amount of repayment to the U.S. Treasury. Representative Meadows did not, however, provide the Committee with any information regarding the 

amount of leave Mr. West may have accrued or the personnel policies in place in his office regarding accrual of leave. House regulations state that Members’ offices ‘‘may provide lump sum 

payments for accrued annual leave only if such leave was accrued in accordance with written 

personnel policies established prior to the accrual of such leave.’’ Exhibit 1 at 9; see also Members’ Handbook (2018) at 11. 

termining a valuation ‘‘is relatively complicated.’’ 263 In that vein, 

the Committee has opted to take a conservative approach to calculating an appropriate reimbursement. While Representative Meadows and Mr. West described the Senior Advisor role differently, 

they both mentioned that Mr. West performed some form of outreach in the district. Consequently, the Committee decided to compare Mr. West’s salary to the most senior employee in the district 

at that time, the District Deputy Chief, who had similar outreach 

responsibilities. The District Deputy Chief earned $14,791.68 less 

than Mr. West for the period from April 1, 2015 to June 15, 2015. 

While not an exact approach, the Committee believes that the difference between these salaries is a fair and reasonable amount for 

Representative Meadows to repay to the U.S. Treasury for the 

clause 8 violation related to the Senior Advisor role. 

The calculation for the repayment for Mr. West’s ‘‘severance’’ is 

much simpler. From June 15, 2015 to August 15, 2015, Mr. West 

earned $25,833.34. There is no dispute that this portion of his salary was ‘‘severance’’ and that he did not do any meaningful work 

during that time period. Thus, the entire amount should be reimbursed to the U.S. Treasury for the clause 8 violation related to impermissible severance. 

In sum, Representative Meadows must repay the U.S. Treasury a total of $40,625.02 for Mr. West’s pay that was not commensurate with his duties and thus, violated House Rule XXIII, clause 

8.264 The Committee directs Representative Meadows to repay that 

amount to the U.S. Treasury no later than May 15, 2020, and provide proof of repayment to the Committee by that date. 

E. REPRESENTATIVE MEADOWS’ CONDUCT MERITS REPROVAL BY THE

COMMITTEE

The Committee concluded that all of the violations detailed in 

this Report are sufficient to warrant a reproval by the Committee. 

Although the Committee accepts Representative Meadows’ assertions that his actions related to Mr. West’s harassment and his 

payments to Mr. West when he was Senior Advisor and as ‘‘severance’’ were never intended to violate House Rules, they did. He was 

ultimately responsible for ensuring that his office was free from 

discrimination and any perception of discrimination. He failed to 

adequately do so, in violation of clauses 1 and 2 of the Code of Official Conduct. Further, his attempts to transition Mr. West out of 

the office precipitated another violation of the Code of Official Conduct, by employing Mr. West when he was not performing duties 

commensurate with his pay, in violation of the letter and spirit of 

clause 8. The Committee has previously issued reprovals to Members who unknowing violated House Rules, but the Committee deVerDate Sep 11 2014 04:29 Nov 27, 2018 Jkt 089006 PO 00000 Frm 00043 Fmt 6659 Sfmt 6602 E:\HR\OC\HR1042.XXX HR1042

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38 

265See Whitfield at 45 (citing In the Matter of Allegations Relating to Representative Phil 

Gingrey, H. Rept. 113–664, 113th Cong. 2d Sess. 25 (2014) (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) (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.’’). 266 Hastings at 16. 

termined should have taken additional steps to ensure their conduct was consistent with the Code of Official Conduct.265

VI. CONCLUSION 

The Committee takes allegations of sexual harassment and discrimination extremely seriously. Mr. West’s behavior toward the female employees in Representative Meadows’ office, regardless of 

whether or not a federal court would consider it sexual harassment 

under Title VII, has no place in the House of Representatives. In 

2014, the Committee advised Members ‘‘to scrupulously avoid even 

the impression of a workplace tainted by sexism.’’ 266 The Committee emphatically reiterates that message again today. 

Representative Meadows could have and should have done more 

to ensure that his congressional office was free from discrimination 

or the perception of discrimination. While Representative Meadows 

did take some important immediate steps after learning of the allegations of sexual harassment by Mr. West, he did not do enough 

to address the allegations or to prevent potential further harassment or retaliation. His failure to take decisive action led to his retention of an employee who did not perform duties commensurate 

with his pay. Based on the totality of the circumstances, the Committee decided to reprove Representative Meadows for his conduct 

in this matter. Additionally, the Committee concluded that Representative Meadows must reimburse the U.S. Treasury in the 

amount of $40,625.02 for Mr. West’s salary that was not commensurate with his work. 

The Committee is conscious of the current climate, as the nation 

seeks a more full-throated societal condemnation of sexual harassment than what has been the norm of past generations. As representatives of the people, the House should be a leader in this national conversation. It is the Committee’s hope that this Report will 

not only hold Representative Meadows accountable for the inadequacy of his response to allegations of sexual harassment against 

someone under his supervision, but serve as a caution to the entire 

House community to be sensitive to the potential for sexual harassment and discrimination. Amid an evolving national conversation 

about sexual harassment, Members’ offices should serve as an example for the modern American workplace, and accordingly those 

offices should be professional and fair environments for all who 

work within them. 

Upon publication of this Report and Representative Meadows’ reimbursement of funds to the U.S. Treasury, the Committee considers the matter closed. 


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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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SSpencer on DSKBBXCHB2PROD with REPORTSInsert offset folio 241 here HR1042.197
237 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert offset folio 242 here HR1042.198
238 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert offset folio 243 here HR1042.199
239 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert offset folio 244 here HR1042.200
240 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert offset folio 245 here HR1042.201
241 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert offset folio 246 here HR1042.202
242 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert offset folio 247 here HR1042.203
243 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert offset folio 248 here HR1042.204
244 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert offset folio 249 here HR1042.205
245 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert offset folio 250 here HR1042.206
246 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert offset folio 251 here HR1042.207
247 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert offset folio 252 here HR1042.208
248 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert offset folio 253 here HR1042.209
249 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert offset folio 254 here HR1042.210
250 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert offset folio 255 here HR1042.211
251 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert offset folio 256 here HR1042.212
252 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert offset folio 257 here HR1042.213
253 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert offset folio 258 here HR1042.214
254 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert offset folio 259 here HR1042.215
255 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert offset folio 260 here HR1042.216
256 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert offset folio 261 here HR1042.217
257 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert offset folio 262 here HR1042.218
258 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert offset folio 263 here HR1042.219
259 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert offset folio 264 here HR1042.220
260 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert offset folio 265 here HR1042.221
261 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert offset folio 266 here HR1042.222
262 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert offset folio 267 here HR1042.223
263 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert offset folio 268 here HR1042.224
264 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert offset folio 269 here HR1042.225
265 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert offset folio 270 here HR1042.226
266 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert offset folio 271 here HR1042.227
267 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert offset folio 272 here HR1042.228
268 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert offset folio 273 here HR1042.229
269 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert offset folio 274 here HR1042.230
270 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert offset folio 275 here HR1042.231
271 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert offset folio 276 here HR1042.232
272 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert offset folio 277 here HR1042.233
273 


SSpencer on DSKBBXCHB2PROD with REPORTSInsert offset folio 278 here HR1042.234