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2 Chairman Phil Mendelson
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6 A PROPOSED RESOLUTION
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11 IN THE COUNCIL OF THE DISTRICT OF COLUMBIA
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17 To adopt the findings, conclusions, and recommendations from the Committee Report of the Ad
18 Hoc Committee In Re: Trayon White, Sr., and to expel Councilmember Trayon White,
19 Sr. from the Council for the conduct referenced in the Committee Report that violated
20 D.C. Official Code §1-1162.23 and D.C. Official Code §1-618.01, in addition to Council
21 Rule 202(a) and several provisions of the Council’s Code of Official Conduct, and the
22 District’s Ethics Act.
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24 RESOLVED, BY THE COUNCIL OF THE DISTRICT OF COLUMBIA, That this
25 resolution may be cited as the “Expulsion of Councilmember Trayon White, Sr. Resolution of
26 2024”.
27 Sec. 2. On August 18, 2024, the Federal Bureau of Investigation (“FBI”) arrested
28 Councilmember Trayon White, Sr. pursuant to a federal criminal complaint charging him with
29 one count of bribery in violation of 18 U.S.C. § 201(b)(2). A Grand Jury for the District of
30 Columbia returned an indictment charging Councilmember White with violating 18 U.S.C. §
31 201(b)(2) (bribery) on September 5, 2024. Councilmember White was arraigned on September
32 12, 2024, and entered a plea of not guilty. That charge remains pending, with a trial scheduled to
33 commence in January 2026.
34 Sec. 3. (a) An ad hoc committee (the “Committee”) was established by memorandum of
35 Council Chairman Phil Mendelson on August 23, 2024. Pursuant to Rule 651(c), the Committee
36 was charged with: (1) investigating allegations that Councilmember Trayon White, Sr. engaged
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37 in bribery and violated residency requirements, and (2) reporting its findings and penalty
38 recommendations, if any, to the Council within 45 days of being convened. Resolution 25-634,
39 the “Council Period 25 Rules of Organization and Procedure and Appointment of Committee
40 Chairpersons and Membership Amendment Resolution of 2024” authorized the Committee to
41 investigate “whether Councilmember Trayon White violated the law by residing in a ward other
42 than Ward 8 or violated the Code of Conduct, as that term is defined in section 101(7) of the
43 Board of Ethics and Government Accountability Establishment and Comprehensive Ethics
44 Reform Amendment Act of 2011, effective April 27, 2012 (D.C. Law 19-124; D.C. Official
45 Code § 1-1161.01(7)), or Council Rules, including those provisions of the Code of Conduct or
46 the Council Rules that relate to conflicts of interest, taking any action that adversely affects the
47 confidence of the public in the integrity of the District government, outside activities, use of
48 government resources, or acting solely in the public interest.”
49 (b) The Committee engaged outside counsel (“Latham and Watkins, LLP” or “Latham”)
50 to conduct an investigation. Councilmember White declined through counsel to be interviewed
51 by outside counsel. Councilmember White also declined through counsel to appear before the
52 Committee, both prior to and after the completion of outside counsel’s investigative report.
53 Sec. 4. (a) On December 16, 2024, the Committee unanimously approved to recommend
54 to the Council the sanction of expulsion of Councilmember Trayon White, Sr. and approved the
55 Committee Report.
56 (b) The Committee adopted the findings of the report prepared by outside counsel
57 retained in this matter, including the determination that substantial evidence in totality exists to
58 support violations of D.C. Official Code §1-1162.23 and D.C. Official Code §1-618.01,
59 magnified by violations of Rule 202(a) of the Rules of the Council for Council Period 25 and
60 various rules of the Council’s Code of Conduct.
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61 Sec. 5. D.C. Official Code Violations
62 (a) D.C. Official Code §1-1162.23 prohibits an employee from using his or her
63 official position or title, or personally and substantially participating, through decision, approval,
64 disapproval, recommendation, the rendering of advice, investigation, or otherwise, in a judicial
65 or other proceeding, application, request for a ruling or other determination, contract, claim,
66 controversy, charge, accusation, arrest, or other particular matter, or attempting to influence the
67 outcome of a particular matter, in a manner that the employee knows is likely to have a direct
68 and predictable effect on the employee’s financial interests or the financial interests of a person
69 closely affiliated with the employee. See also Rule I(a) of the Council’s Code of Conduct for
70 Period 25.
71 (b) D.C. Official Code §1-618.01 requires each employee, member of a board or
72 commission, and public official of the District government to at all times maintain a high level of
73 ethical conduct in connection with the performance of official duties, and to refrain from taking,
74 ordering, or participating in any official action which would adversely affect the confidence of
75 the public in the integrity of the District government.
76 (c) Councilmember White’s June 26, 2024 and July 17, 2024 meetings with an FBI
77 confidential human source (“CHS 1”) where Councilmember White accepted a $15,000 cash
78 payment from CHS 1, discussed plans to meet with District government employees based on
79 CHS 1’s payment, discussed other opportunities to help CHS 1 secure further business with
80 District agencies, accepted CHS 1’s offer of a 3% kickback of each contract or grant’s value that
81 Councilmember White assisted in securing, and discussing potential expansion of his and CHS
82 1’s enterprise into the mental healthcare and housing sectors are consistent with a violation of the
83 statutes in subsections (a) and (b) of this section as established by the Latham report.
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85 Sec. 6. Council Rules and Code of Conduct Violations.
86 (a) Rule I(e)(1) prohibits an employee from receiving any compensation, salary, or
87 contribution to salary, gratuity, or any other thing of value from any source other than the
88 District government for the employee’s performance of official duties.
89 (b) Rule II(a)(1) provides that no employee shall engage in outside employment or
90 private activities that conflicts or would appear to conflict with the fair, impartial, and objective
91 performance of the employee’s official duties and responsibilities or with the efficient operation
92 of the Council.
93 (c) Rule II(c)(1)(A) and (B) prohibits an employee from representing another person,
94 having a financial interest, or providing assistance in prosecuting a claim against the District of
95 Columbia before any regulatory agency or court of the District of Columbia, or from
96 representing another person before any regulatory agency or court of the District of Columbia in
97 a matter in which the District of Columbia is a party or has a direct and substantial interest.
98 (d) Rule III(e)(2) provides that, except as provided in Rule IV, no employee shall
99 directly or indirectly demand, seek, receive, accept, or agree to receive or accept anything of
100 value personally or for any other person or entity, in return for:
101 (1) Any official act performed or to be performed by the employee;
102 (2) Being influenced in the performance of any official act;
103 (3) Being influenced to commit or aid in committing, or to collude in, or allow, any
104 fraud, or make opportunity for the commission of any fraud, on the District of Columbia; or
105 (4) Being induced to do or omit to do any act in violation of the employee’s official
106 duty.
107 (e) Rule VI(b)(1) and (3) state that an employee may not knowingly use the prestige
108 of office or public position for that employee’s private gain or that of another, and that Council
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109 employees shall not use or permit the use of their position or title or any authority associated
110 with their public office in a manner that could reasonably be construed to imply that the Council
111 sanctions or endorses the personal or business activities of another, unless the Council has
112 officially sanctioned or endorsed the activities.
113 (f) (1) On 4 separate occasions between June 2024 and August 2024, Councilmember
114 White accepted cash payments from CHS 1.
115 (2) The cash payments described in paragraph (1) of this subsection totaled
116 $35,000.
117 (3) Councilmember White knew at the time of accepting these cash payments that
118 CHS 1 operated several businesses holding or seeking contracts or grants with the District of
119 Columbia, or that CHS 1 had received subcontracts or subgrants from businesses that contracted
120 with the District of Columbia.
121 (4) Councilmember White accepted those cash payments in exchange for agreeing
122 to meet with and influence various government officials to ensure the contracts of CHS 1’s
123 organizations would be renewed.
124 (5) Councilmember White agreed to accept $156,000 in undisclosed kickbacks
125 and cash payments in exchange for using his official position as a Councilmember to help
126 organizations obtain or retain contracts or grants with District agencies.
127 (6) Councilmember White reviewed a ledger with CHS 1 that outlined profits he
128 expected to receive for his continued work, including a 3% cut for grant renewals he helped
129 secure.
130 (7) Councilmember White confirmed that he had contacted government
131 employees to discuss contract renewal, and stated he discussed contracts over which CHS 1 had
132 a direct interest.
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133 (8) Councilmember White met with Department of Youth Rehabilitation Services
134 (“DYRS”) and Office of Neighborhood Safety and Engagement (“ONSE”) officials within days
135 of his multiple meetings with CHS 1 in July 2024 and he asserted to CHS 1 that he had held such
136 meetings and discussed with those DYRS and ONSE officials matters over which the CHS 1 had
137 a direct interest.
138 (9) The facts asserted above are consistent with a violation of the Council
139 Conduct Rules described in subsections (a) through (e) of this section as established by the
140 Latham report
141 Sec. 6. The Council adopts the findings and recommendations in the December 16, 2024
142 report of the Ad Hoc Committee.
143 Sec. 7. To maintain the confidence of the public in the integrity of the legislative branch of
144 government, the Council:
145 (1) Expresses its disapproval of the actions of Councilmember Trayon White, Sr.
146 as detailed in the December 16, 2024 report of the Ad Hoc Committee;
147 (2) Notes that the degree and severity of Councilmember White’s actions, including
148 his discussions of maintaining and his expressed desire to expand the activities detailed in the
149 Committee Report essentially amount to an attempt to defraud the government and demonstrates
150 a particularly callous disregard for the potential effect on the Council as an institution, as well as
151 the District government as a whole; and
152 (3) Hereby expels Councilmember Trayon White Sr. for committing acts in
153 violation of D.C. Official Code §1-1162.23 and D.C. Official Code §1-618.01, the gravity of which
154 is underscored by acts committed in violation of the standards specified in the Council’s Conduct
155 Rules and the District’s Ethics Act.
156 Sec. 8. The Council shall transmit a copy of this resolution, upon its adoption, to
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157 Councilmember Trayon White, Sr.
158 Sec. 9. This resolution shall take effect immediately.
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