Surviving Collapse

24 November 2025

The Regulatory Saboteur and the Looting of Consumer Protection: How the Loyalists’ Doctrine Seized the CFPB to Pay Back Wall Street

The Department of Homeland Security and the Department of Justice were merely the opening salvos. The Loyalists’ Doctrine—a calculated strategy to bypass the U.S. Senate’s constitutional oversight—found its most audacious and prolonged triumph at the Bureau of Land Management (BLM), an agency responsible for a staggering quarter-billion acres of America’s public lands, from pristine wilderness to resource-rich deserts.

Here, the administration deployed a new, more sophisticated weapon in its arsenal of constitutional fraud: the "delegation shell game." For over 424 days, the BLM was effectively commanded by William Perry Pendley, a vocal advocate for selling off public lands, who was installed as a "Deputy Director" but was, in practice, the "Ghost Director"—wielding immense power without ever once facing Senate scrutiny or even the pretense of a proper "Acting" appointment under the Federal Vacancies Reform Act (FVRA).

This was not a bureaucratic oversight; it was a deliberate, protracted act of administrative capture, orchestrated to push through a radical, anti-conservation agenda that would have been impossible under a Senate-confirmed leader. The BLM case exposes the full, terrifying flexibility of the Loyalists' Doctrine, proving that it can operate in plain sight, mocking the very laws designed to prevent such a takeover. The federal judiciary, once again, stepped in to confirm the extensive fraud, but not before immense damage had been inflicted upon the nation’s natural heritage.

I. THE STRATEGIC TARGET: CAPTURING AMERICA'S LANDSCAPE

The Bureau of Land Management is a federal behemoth, responsible for managing more land than the combined area of California and Texas. Its purview includes oil and gas leasing, mining, grazing, recreation, and wildlife protection. For those aligned with resource extraction industries, controlling the BLM is not merely a political victory; it is a gateway to unimaginable wealth.

This made the BLM a prime target for the Loyalists’ Doctrine. A Senate-confirmed Director, especially one with a balanced view of public land management, would face intense scrutiny from conservationists and local communities, likely slowing or stopping the radical pro-extraction agenda. The solution? Install a ghost.

William Perry Pendley: The Ideological Weapon

William Perry Pendley was not merely a political appointee; he was an ideological weapon. Before his arrival at the BLM, Pendley was a notorious figure in the conservative legal movement, having spent decades as a lawyer and activist advocating for the privatization of public lands and a dramatic reduction in federal environmental protections. He once famously claimed that the "founding fathers intended all federal land to be sold." His views were so extreme that his nomination as a confirmed Director would have been a non-starter in the Senate, guaranteeing a bruising, public confirmation battle he could not win.

This made Pendley the perfect loyalist. He possessed the radical zeal to execute the desired agenda, but lacked the public credibility to pass a Senate vote. The administration's challenge was simple: how to give him absolute power without ever putting him before Congress?

II. THE DELEGATION SHELL GAME: THE GHOST DIRECTOR'S ASCENSION

The answer was the "delegation shell game"—a sophisticated legal maneuver that outmaneuvered even the FVRA, which primarily governs acting appointments. Here, the administration exploited the inherent authority of agency heads to delegate their duties to subordinates, turning a ministerial function into a weapon of constitutional avoidance.

The Initial Setup: The FVRA Sidestep

When the BLM Director, Neil Kornze, resigned in April 2017, the administration made only temporary "acting" appointments, avoiding a permanent nominee. This immediately created a vacuum. In July 2019, William Perry Pendley was initially brought in as the Deputy Director for Policy and Programs, a position that did not require Senate confirmation.

The initial gambit was subtle:

No FVRA Appointment: Pendley was not initially designated as "Acting Director" under the FVRA. This immediately sidestepped the Act's time limits (210 days) and the qualifications for who could serve.
The "Succession Memo" Trick: Instead, the then-Acting Interior Secretary issued a series of "Succession Memorandums." These internal documents, often buried in bureaucratic filings, effectively delegated "all functions and duties" of the BLM Director to Pendley. This was the precise mechanism of the "shell game": Pendley held a lower-level, non-confirmable title, but possessed the full, unbridled authority of the top job.

The Constitutional Fallout: A "Matryoshka Doll of Delegated Authorities"

The administration tried to argue that this was a perfectly legal exercise of "delegated authority." However, the federal judiciary ultimately saw through the charade. This was not a routine delegation; it was a deliberate, long-term scheme to install an unconfirmed official in charge of a massive agency.

The Lawsuit: Conservation groups, spearheaded by Montana’s Governor Steve Bullock, sued to stop Pendley, arguing that his de facto directorship was unlawful.
The Judicial Hammer: On September 25, 2020, U.S. District Judge Brian Morris delivered a devastating ruling. He found that Pendley had been unlawfully serving for 424 days without Senate confirmation, exceeding any legitimate interpretation of a temporary appointment.
The Scathing Rebuke: Judge Morris’s language was unsparing, directly indicting the "delegation shell game": "The President cannot shelter unconstitutional 'temporary' appointments for the duration of his presidency through a matryoshka doll of delegated authorities." This was a direct judicial validation of the Muckraking Audit’s analysis of the "delegation of duties" loophole. The court found that this was not a simple delegation but a "structural constitutional infirmity," a direct assault on the Appointments Clause itself.

Pendley was a "Ghost Director"—invisible to Senate oversight but fully empowered to wreak havoc on public lands, proving that the Loyalists’ Doctrine was adaptable enough to bypass the FVRA entirely.

III. THE POLICY OF DESTRUCTION: PLUNDERING THE AMERICAN COMMONS

The purpose of installing the Ghost Director was to rapidly push through policies that would have been impossible under a Senate-confirmed leader, prioritizing resource extraction over conservation. The BLM’s core mission was perverted, its resources reallocated, and its long-standing policies overturned.

The Drilling Frenzy

Under Pendley's unlawful command, the BLM aggressively accelerated oil and gas leasing on public lands. This involved:

Massive Lease Sales: The agency fast-tracked lease sales across millions of acres, often in areas with significant wildlife habitat or recreational value, overriding environmental concerns and public opposition.
Streamlined Approvals: Environmental reviews were curtailed, and permits for drilling were pushed through at an unprecedented pace, all in the service of immediate extraction.
Dismantling Protections: Long-standing protections for endangered species, migratory birds, and cultural heritage sites were either ignored or significantly weakened in favor of industry demands.

The Headquarters Relocation: A Strategic Sabotage

One of Pendley's most controversial and disruptive actions was the relocation of the BLM headquarters from Washington D.C. to Grand Junction, Colorado.

The Stated Purpose: The administration claimed the move would bring the agency closer to the lands it manages.
The Real Purpose (Audited Motive): Critics, including former BLM officials, argued the move was a deliberate act of "brain drain"—forcing hundreds of experienced, career civil servants to either relocate to a remote location or retire. This effectively purged the agency of institutional memory and resistance to the pro-extraction agenda, replacing it with a more pliable, smaller workforce. This was administrative sabotage, designed to weaken the agency from within.

The Judicial Nullification: Policy as Void as the Appointment

Following Judge Morris’s ruling, a critical question arose: what happened to all the policies Pendley enacted during his 424 days of unlawful service?

The Cloud of Illegality: The court’s decision immediately cast a deep cloud over every major policy, lease sale, and regulatory change Pendley had authorized. Like the DACA policies under Wolf, all of Pendley’s directives were now vulnerable to being voided because they flowed from an official who lacked legitimate authority.
The Long-Term Damage: While the legal system eventually corrected the constitutional wrong, the damage to public lands was immediate and often irreversible. Oil and gas leases were already in place, pipelines were approved, and critical staff had already been forced out. The Doctrine succeeded in its goal of causing irreparable harm before the courts could intervene.

IV. THE ETHICAL PAYOUT: A REVOLVING DOOR TO THE ANTI-FEDERAL MOVEMENT

The Pendley case, more than any other, highlights the ultimate payoff of the Loyalists’ Doctrine: the rewarding of individuals who serve the political machine's agenda, particularly in dismantling federal power, with lucrative positions within the very movements dedicated to shrinking the government they once ostensibly served.

Pendley's Return: A Predictable Trajectory

William Perry Pendley’s post-government career trajectory was entirely predictable and further confirms the Tier 3 Revolving Door analysis. After being forced out of the BLM, Pendley immediately returned to the political-advocacy ecosystem. He did not seek a career in impartial land management; he sought a platform to continue his decades-long crusade against federal land ownership.

The Anti-Federalism Paycheck: Pendley’s career, both before and after his BLM tenure, has been intrinsically linked to organizations and movements that advocate for the transfer of federal lands to state control or outright privatization. His illegal directorship at the BLM served as a powerful credential, a badge of honor for successfully advancing this agenda from within.
The Ultimate Transaction: His appointment and subsequent actions confirmed that the "public service" offered by such loyalists is not to the nation, but to a specific, ideologically driven movement with a clear financial interest in resource extraction and deregulation. He was paid to dismantle, not to manage.

The BLM case clarifies the motive of the Loyalists’ Doctrine: it's not always about direct financial enrichment through personal deals (though that exists, as we saw in the EPA section). Often, it's about the strategic capture of agencies to achieve ideological goals that directly benefit powerful corporate and political factions, with the "reward" being continued prominence and funding within that ecosystem.

V. THE UNCHECKED POWER: THE DOCTRINE'S EVOLUTION AND CONGRESSIONAL COMPLICITY

The BLM case marks a significant evolution of the Loyalists’ Doctrine. It moved beyond simply challenging existing succession orders (as at DHS) or overriding specific statutes (as at DOJ). It demonstrated a willingness to circumvent even the FVRA entirely through the sophisticated "delegation shell game."

This highlights the alarming adaptability of the Doctrine and the inherent failures of the legislative branch to contain it. The judicial branch, in this instance, stepped in to apply the brakes, but not before 424 days of unlawful command had taken their toll on America's shared landscape.

The enduring lesson of the BLM crisis is this: Congressional inaction is complicity. While the courts can eventually declare an appointment unlawful, they cannot prevent the damage inflicted during the illegal tenure. The loopholes in the FVRA that allow for this "matryoshka doll" of delegated authorities remain, a clear invitation for the next administration to exploit. Until Congress clarifies the primacy of the Appointments Clause and explicitly closes these delegation loopholes, the Ghost Directors will continue to haunt America’s agencies, serving not the public, but the private interests that pay for their loyalty.

Our Muckraking Audit continues its relentless watch, because the price of liberty is eternal vigilance, and the price of unaccountable power is the systematic looting of the Republic.

The Capture of the Republic: How a Systemic Doctrine of Unlawful Appointments Dismantled Law and Policy

I. INTRODUCTION: THE WOLF AT THE GATES OF LAW

The Department of Homeland Security (DHS) is the nation’s largest law enforcement and security apparatus, a colossus encompassing everything from border control and immigration to disaster response and cybersecurity. Yet, for nearly two years, the agency was led by a pair of officials—Chad Wolf and Ken Cuccinelli—who were later determined by both a non-partisan government watchdog and multiple federal courts to be serving unlawfully.

This was not a bureaucratic clerical error. It was a calculated, sustained act of constitutional subversion: a deliberate scheme to circumvent the U.S. Senate’s "advice and consent" power, ensuring that the critical machinery of the state was commanded by political loyalists who could not survive public scrutiny or confirmation hearings.

The DHS succession crisis of 2019-2021 provides the definitive blueprint for the Loyalists' Doctrine—a systemic strategy to seize control of government agencies, not through legal means, but through the exploitation of obscure statutory loopholes. The corruption was three-fold:

Legal Fraud: The violation of the Homeland Security Act (HSA)’s explicit order of succession.

Political Weaponization: The use of unconfirmed power to enact radical, policy-altering edicts (DACA, asylum rules).
Ethical Payout: The transfer of the corrupt officials into lucrative post-government roles promoting the very policies they illegally enacted (The Revolving Door).

The consequences were profound. As we document below, every major policy enacted by these officials was nullified by judicial review, leading to a state of constitutional chaos and proving that the foundational corruption of appointment was merely the precursor to the wholesale corruption of policy.

II. THE ANATOMY OF A LEGAL FRAUD: SUBVERTING THE HOMELAND SECURITY ACT

The DHS succession crisis hinged on a meticulous defiance of the Homeland Security Act (HSA) and the Federal Vacancies Reform Act (FVRA). The administration did not run afoul of the law; it systematically bypassed it, creating an illegal chain of command that served only the Executive’s political will.

The Mandate vs. The Maneuver

When a Senate-confirmed Secretary of an Executive agency departs, two laws govern temporary succession:

The FVRA (5 U.S.C. § 3345 et seq.) allows the President to designate a temporary successor for up to 210 days.

Agency-Specific Succession Laws (like the HSA) can supersede the FVRA, setting an explicit, mandatory order of temporary succession.

The HSA, specifically 6 U.S.C. § 113(g)(1), contained a mandatory, statutorily mandated line of succession. Upon the resignation of Secretary Kirstjen Nielsen on April 10, 2019, the law dictated that the position should fall to the Under Secretary for Management, pending any further designation by the President.

The First Illegal Link: Kevin McAleenan

Instead of following the statute, the administration engineered a direct jump to Kevin McAleenan, who was the Commissioner of U.S. Customs and Border Protection (CBP).

The Violation: McAleenan was sworn in as Acting Secretary, circumventing the statutorily designated official. This move was based on an internal DHS order that the Government Accountability Office (GAO) would later rule was invalidly invoked.

The Power Grab: By ignoring the mandated line of succession, the administration secured a politically aligned official—the head of CBP—at the expense of the mandated career manager, setting the stage for aggressive immigration enforcement.

The Second Illegal Link: The Wolf-Cuccinelli Cascade

The entire subsequent chain of command was fatally poisoned by this initial illegal appointment. When McAleenan resigned in November 2019, the corruption cascade continued:

Invalid Amendment: While serving unlawfully, McAleenan issued a series of amendments to the DHS order of succession. Since he himself was illegally serving, he lacked the legal authority to rewrite the rules of his own succession.

The Wolf Appointment: The invalid amendment was used to install Chad Wolf, the Under Secretary for Strategy, Policy, and Plans, as the next Acting Secretary.

The Cuccinelli Appointment: Wolf then, using his own void authority, designated Ken Cuccinelli, a staunch political loyalist, as the Senior Official Performing the Duties of the Deputy Secretary.

The GAO’s Verdict: A Constitutional Finding

On August 14, 2020, the non-partisan Government Accountability Office (GAO) issued a devastating legal opinion (B-331650), unequivocally concluding that the appointments of both Wolf and Cuccinelli were unlawful because they were made "by reference to an invalid order of succession."

GAO Finding: "Because the incorrect official assumed the title of Acting Secretary at that time, subsequent amendments to the order of succession made by that official were invalid and officials who assumed their positions under such amendments, including Chad Wolf and Kenneth Cuccinelli, were named by reference to an invalid order."

This official finding by a government watchdog confirmed the core thesis of the Loyalists’ Doctrine: the Executive Branch deliberately created a fake chain of command to install unconfirmed political operatives.

III. THE POLITICAL WEAPONIZATION: CORRUPTION AS POLICY

The corruption was not about who got the title; it was about what they did with the power. The administration needed Wolf and Cuccinelli precisely because they were unconfirmed loyalists who would enact policies too radical or legally questionable to be approved by a Senate-confirmed official.

The Asylum and DACA Edicts

The officials' tenure was marked by a rapid-fire succession of high-impact policy changes, many of which targeted asylum seekers and long-term immigrants:

DACA Restrictions (Wolf): In July 2020, Chad Wolf issued a memo to restrict the Deferred Action for Childhood Arrivals (DACA) program, refusing to accept new applications and limiting renewal periods from two years to one year. This was a clear political victory for the administration’s anti-immigration agenda.

Asylum Limitations (Cuccinelli): Ken Cuccinelli, while serving as Acting Director of U.S. Citizenship and Immigration Services (USCIS), implemented various rules and memos that made it dramatically harder for Central American migrants to seek asylum and imposed a "clear and beyond doubt" standard for asylum applicants.
"Public Charge" Expansions: Both officials drove the expansion of the "Public Charge" rule, which sought to deny permanent residency to immigrants deemed likely to use certain public benefits, further constricting legal immigration channels.

These radical policy shifts—the explicit agenda of the loyalist faction—became the ultimate evidence of the corrupt motive. The officials who were serving unlawfully were used to execute the most controversial and legally vulnerable parts of the Executive's agenda.

IV. THE JUDICIAL RECKONING: VOID ACTIONS AND NULLIFIED POLICIES

The legal fraud inherent in the appointments meant that every non-delegable policy action taken by Wolf and Cuccinelli was subject to being voided. Federal judges, faced with the unambiguous evidence of the GAO report and statutory violation, began systematically dismantling the officials' work.

The Cuccinelli Precedent

The first major blow landed against Cuccinelli in the case of CASA de Maryland v. Wolf (D.D.C., March 2020).

The Finding: U.S. District Judge Randolph D. Moss ruled that Cuccinelli’s appointment as Acting Director of USCIS was unlawful. The judge focused on the novel position of "Principal Deputy Director" that Cuccinelli held, concluding that it did not qualify him as the "first assistant" under the FVRA.

The Consequence: The court voided the restrictive asylum policies Cuccinelli had enacted, specifically those relating to fee increases for asylum applications. This established the critical legal principle: unlawful appointment equals void policy.

The Wolf Catastrophe: The DACA Nullification

The most devastating judicial indictment came in Batalla Vidal v. Wolf (E.D.N.Y., November 2020), where a federal judge nullified Wolf’s central policy action on DACA.

The Finding: U.S. District Judge Nicholas G. Garaufis ruled that Chad Wolf was not lawfully serving as Acting Secretary, citing the GAO’s report and the invalid succession order.

The Consequence: The judge ruled that Wolf's July 2020 memo limiting DACA renewals and refusing new applications was an action taken "without legal authority." The court vacated the memo, forcing the DHS to reopen the DACA program to new applicants and revert renewals to the two-year term.

The Ratification Farce: In a desperate bid to save the DACA restrictions, DHS attempted to retroactively ratify Wolf's appointment. The courts rejected this maneuver, confirming that a constitutional violation cannot be erased by bureaucratic fiat. This judicial defiance confirmed the integrity of the judiciary against the executive's attempts at self-absolution.

These judicial rulings provided the ultimate, non-partisan validation of the Muckraking Audit's core finding: the Loyalists' Doctrine is legally unsound, and its policy outcomes are inherently illegitimate. The government chose to risk the rule of law to enact a political agenda, and the federal courts decisively rejected the gamble.

V. THE WIDER SCANDAL: A SYSTEMIC STRATEGY OF AVOIDANCE

The DHS fraud was not an isolated incident; it was the largest and most complex example of a systemic, national strategy that mirrored the U.S. Attorney violations found in Virginia, California, Nevada, and New Jersey.

The Common Thread: In every case—from the DHS Secretary to the U.S. Attorney—the objective was the same: circumvent the Senate to install an official whose primary qualification was political loyalty and willingness to enact the Executive's partisan agenda.
The Weapon: The tool was always the same: exploiting the complexity of succession laws (HSA, FVRA, or \text{28 U.S.C. } \$ 546) to keep an unconfirmed "Acting" official in place indefinitely.
The Goal: The ultimate goal was to establish a shadow government across the entire Executive Branch, led by political appointees who served at the pleasure of the President and who were immune from the constitutional oversight intended to ensure their independence and integrity.

The DHS case, with its high-profile officials and nationwide policy implications, became the undeniable proof that this was a national, concerted constitutional avoidance scheme orchestrated at the highest levels of the Executive Branch.

VI. THE ETHICAL PAYOUT: THE REVOLVING DOOR CONFIRMS THE MOTIVE

The corruption of process and policy found its ultimate justification in the ethical payout—the financial and political reward system that awaited the loyalists after their service. This is the final, undeniable link in the chain of corruption.

The Wolf Transition

Chad Wolf’s post-government career immediately confirmed the quid pro quo for his unlawful service.

Prior History: Wolf was a former lobbyist, having helped clients secure contracts from the Transportation Security Administration (TSA), an agency within DHS, prior to his appointment. This established his intimate, profitable relationship with the regulated industry.

The Payout: Upon his resignation, Wolf quickly became the Executive Director of the America First Policy Institute (AFPI). AFPI is a conservative think tank focused on promoting policies that directly align with the border and immigration restrictions Wolf illegally enacted at DHS. This move was not a simple career change; it was a direct transfer from implementing policies in government to advocating for them in the private, political sector. This is the Tier 3 Revolving Door Confirmation—the most lucrative reward for unconstitutional service.

The Cuccinelli Transition

Ken Cuccinelli, after his own appointment was ruled invalid by a federal judge, also successfully transitioned back into the political-advocacy ecosystem. He moved into a leadership role within a similar political action and advocacy space, continuing to champion the hardline immigration policies he unlawfully implemented.

The pattern is irrefutable: the Executive Branch utilized illegal appointments to enact radical policy; the courts voided the policy; and the officials responsible were immediately rewarded with high-level, high-paying advocacy roles. The entire process was a controlled exchange of public authority for private, political benefit.

VII. CONCLUSION: THE LOYALISTS' LEGACY AND THE NECESSITY OF AUDIT

The DHS succession crisis stands as the most critical case study in modern political corruption. It was a hostile takeover of a major security agency, executed not by brute force, but by the subtle, systematic manipulation of the Homeland Security Act's succession rules.

The findings of the GAO and the federal courts confirm that the administration did not accidentally fall into a succession hole; they deliberately dug it. By installing a series of unconfirmed officials, the Executive Branch successfully captured the DHS, deploying it to enact policies that Senate-confirmed leadership would likely have resisted or modified.

The legacy of Wolf and Cuccinelli is not one of effective policy, but one of voided legal acts and constitutional chaos. The ultimate corruption was not the money spent, but the destruction of the principle of accountability and the nullification of the Senate's constitutional role.

This exposé, built on the Muckraking Audit methodology, provides the necessary defense: by tracking the legal succession triggers (Phase I), confirming the political motive (Phase II), and charting the ethical payout (Phase III), we can identify and expose the next constitutional hostage crisis before it has the chance to infect the policies of the state. The DHS fraud proved that the Loyalists’ Doctrine is a clear and present danger; our ongoing audit is the only mechanism that can stand against it.

PLUNDER IN THE CABINET: The Real Cost of Letting the Wolves Guard the Hen House

The constitutional fraud detailed in the previous installments—the calculated subversion of the Justice Department’s appointment rules—was only half the racket. It addressed how the Executive Branch seized power. This installment details the other half: the plunder.

Once loyalists were illegally or improperly installed, the ethical floodgates opened. The system of checks and balances designed to prevent conflicts of interest and the misuse of public funds was deliberately, aggressively dismantled. The result was a political environment where over half of the president's own cabinet appointees were found to be embroiled in documented ethical controversies. This wasn't a series of unlucky personnel choices; it was a wholesale conversion of public service into a high-stakes, taxpayer-funded ATM.

The common denominator was simple: Loyalty was the only qualification. And the reward for that loyalty was the unfettered ability to treat government property as personal luxury, and public policy as a private business venture.

I. SWAMP AIRLINES: THE GREAT TAXPAYER TRAVEL HEIST

The most immediate and brazen form of corruption exposed was the use of taxpayer funds for staggering, unnecessary luxury travel. While career public servants flew commercial and abided by strict budgetary limits, the newly appointed elite treated the federal government like a private concierge service, running up bills that ran into the millions.

The Health and Human Services (HHS) Scandal: Former HHS Secretary Tom Price became the symbol of this brazen financial plunder. Investigations revealed Price had racked up more than $1 million in taxpayer funds for domestic and international air travel, including nearly two dozen domestic flights on private, chartered jets. During just one week, his private jet expenses reportedly exceeded $60,000. Price, who had previously criticized government officials for the "fiscal irresponsibility" of using private jets, was eventually forced to resign, a resignation triggered not by ethical integrity but by the sheer scale of the public financial abuse. Even then, he only promised to repay a fraction of the cost—a pittance compared to the total bill charged to the public.

The Treasury’s Military Jet Addiction: The scandal extended to the nation’s financial office. Treasury Secretary Steven Mnuchin was documented by ethics watchdog groups, after legal challenges forced the release of records, to have flown on military and noncommercial aircraft to the tune of over $1 million in a single year. This included unnecessary trips, such as the use of a government jet to visit the U.S. Bullion Depository in Fort Knox. Mnuchin’s wife, Louise Linton, famously used these subsidized trips to flaunt high-fashion brands on social media, treating the public’s resources as a backdrop for personal branding. Though the couple reimbursed a small portion for the wife’s travel, the pattern was clear: the appointed elite believed they were exempt from the commercial travel standards adhered to by their predecessors, citing vague "national security" concerns that career staff debunked.

The Environmental Racket: The plunder was systematic across the cabinet. Former Environmental Protection Agency (EPA) Administrator Scott Pruitt was scrutinized for spending over $160,000 on private, military, and first-class flights, all paid for by taxpayers. Interior Secretary Ryan Zinke was also caught using government planes for flights that cost tens of thousands of dollars, including a $12,375 trip from Las Vegas to his home state. The message was unmistakable: the taxpayer dime was now a personal expense account, reserved for the comfort and convenience of the loyalist class.

The cost of this "Swamp Airlines" program was not just monetary; it was the destruction of the public trust in the fiscal rectitude of the nation’s highest offices. The officials responsible for slashing their own agencies’ budgets were simultaneously feasting at the public trough, underscoring the cynicism of the entire administration.

II. THE CONFLICT OF INTEREST FACTORY: ETHICS AS AN OBSOLETE CONCEPT

The financial corruption of luxury travel was merely the visible sign of a far more dangerous ethical rot: the calculated destruction of the ethical vetting process and the willingness of appointees to use their public office to enrich themselves or their private business partners.

Federal ethics laws are clear: they prohibit government employees from participating substantially in official matters where they hold a private financial interest. These laws are the bedrock of integrity. For the loyalists, however, these laws were treated as suggestions to be legally circumvented or simply ignored.

Retained Business Ties: Numerous appointees entered office maintaining deep, complex financial or business ties to the very industries they were now tasked with regulating. This created an immediate, intractable conflict of interest, ensuring that regulatory decisions would be guided not by public health or safety, but by the bottom line of the appointee’s former or future employers.

The Disclosure Shell Game: When confronted by ethics watchdogs or congressional committees, many appointees offered a veneer of compliance, often stating they would divest their assets or recuse themselves from specific decisions. However, investigative reports revealed that this was often a financial shell game. Officials would arrange for the proceeds or benefits of those divested assets to flow to family members—spouses or minor children—thereby maintaining the lucrative financial interest while claiming "ethical" separation. This allowed them to participate in policies that inflated the value of their family’s investments, a deliberate deception that undermined the core purpose of financial disclosure.
The Emoluments Exposure: The highest office itself was repeatedly exposed for violating the Foreign Emoluments Clause of the U.S. Constitution, which bars officeholders from accepting presents or benefits from foreign states. Watchdog groups documented that foreign governments and officials were funneling money into the president's private businesses through hotel stays, leases, and real estate deals. The entire structure created an environment where foreign policy could be influenced by which foreign government was spending the most money at the president's hotels—a direct betrayal of the constitutional mandate.

This systemic corruption ensured that the Loyalists’ Handbook provided not just power, but staggering personal wealth.

IV. THE REVOLVING DOOR: CONVERTING PUBLIC SERVICE INTO PRIVATE PROFIT

The most enduring piece of corruption is the revolving door—the mechanism by which public service is immediately converted into massive private profit. The loyalists understood that their time in office, even if short and scandalous, was simply a down payment on a massive payout from the industry they had just served or deregulated.

The Cash-Out Cycle: High-level officials who had implemented massive deregulation, slashed environmental protections, or awarded lucrative contracts often resigned and immediately joined the boards of directors or consulting firms associated with the corporate entities that benefited from their public decisions.
The Vetting Failure as a Feature: The ethical vetting process, managed by the Office of Government Ethics (OGE), was repeatedly sidelined. Appointments were made without the necessary divestitures or compliance plans in place. This failure was not a bug; it was a feature of the system. By installing nominees with clear corporate conflicts of interest—stakes in Big Oil, long lobbying careers—the administration guaranteed that the agencies they led would prioritize corporate profit over public welfare.

The Long Game of Plunder: Unlike the single, dramatic collapse of a case in Virginia, the financial corruption of the cabinet is a quiet, ongoing transfer of wealth from the public to the private sector. The loyalists sacrificed public trust, the environment, and fiscal discipline in exchange for guaranteed post-service riches. The true corruption is not the cost of the private jet; it is the tens of billions in regulatory savings handed to their corporate patrons.

This installment proves that the unlawful seizing of power (Parts I & II) and the looting of public funds (Part III) are two sides of the same corrupt coin. The loyalists were installed to serve the Executive's political will and reward themselves in the process.

The investigation now turns to the future: how these architects of corruption are preparing to use these proven tactics—the legal loopholes and the ethical destruction—to launch the next and potentially more devastating wave of attacks on democratic accountability.

Source Material:

Treasury Secretary Mnuchin Accused of Luxury Travel on Taxpayer Dime - VOA [https://www.voanews.com/a/mnuchin-accused-luxury-travel-taxpayer-dime/4301243.html]

Lavish travel and questionable gifts loom over 6 Trump officials | PBS News [https://www.pbs.org/newshour/politics/lavish-travel-and-questionable-gifts-loom-over-5-trump-officials]

Swamp Airlines: Chartered Jets at Taxpayer Expense - American Oversight [https://americanoversight.org/investigation/swamp-airlines-private-jets-taxpayer-expense/]

Ethics experts worry about the implications of Trump accepting Qatar's luxury plane - OPB [https://www.opb.org/article/2025/05/12/qatar-s-plane-for-trump-fuels-ethical-concerns/]

The Hill: Democrats unveil bills to ban Cabinet members' private jet travel [https://lieu.house.gov/media-center/in-the-news/hill-democrats-unveil-bills-ban-cabinet-members-private-jet-travel]

Trump's 100 Days of Oligarchy and Conflicts of Interest - Public Citizen [https://www.citizen.org/news/trumps-100-days-of-oligarchy-corruption-and-conflicts-of-interest/]

More than half of Trump's 20-person Cabinet has engaged in questionable or unethical conduct - APM Reports [https://www.apmreports.org/story/2018/02/16/ethics-in-trump-cabinet]

THE ACTING RACKET: A National Constitutional Fraud Confirmed by Courts in California, Nevada, and New Jersey

The illegal installation of Lindsey Halligan to prosecute political enemies in Virginia was not an anomaly; it was a pilot program for the wholesale capture of the federal prosecutorial apparatus. The evidence, documented by federal judges across the American map, confirms a terrifying truth: the Executive Branch executed a deliberate, systemic strategy to bypass constitutional checks, ensuring that top law enforcement posts were filled by political loyalists who answered to a single man, not the rule of law.

What happened in Virginia was merely the tip of the iceberg—the moment the scam produced a politically inconvenient result (the indictments were tossed). The larger, more insidious story is the national blueprint deployed in major jurisdictions across the West and the Northeast, where judges found the administration had perfected the "Acting Racket" to run an unaccountable shadow government.

In the Central District of California, in Nevada, and in New Jersey, federal judges issued rulings that confirmed the same pattern of constitutional fraud. These are not isolated procedural blunders; they are the documented coordinates of an executive coup against the system of checks and balances.

I. THE WEST COAST END-RUN: LOYALISTS IN LOS ANGELES AND NEVADA

The Central District of California (CDCA)—the nation's largest federal district, encompassing Los Angeles—was a prime target for this constitutional subversion. Federal judges here recognized the same systemic abuse.

The California Case (Bill Essayli): U.S. District Judge J. Michael Seabright ruled that Acting U.S. Attorney Bill Essayli was unlawfully serving in his role in the CDCA. Essayli, a former federal prosecutor turned conservative California Assemblymember, was known for his aggressive stance against progressive state policies. The administration's choice was a known political warrior, not a neutral career servant. Judge Seabright found that the administration’s maneuver—which attempted to shift Essayli from one type of temporary appointment to another after his 120-day limit expired—was a blatant "end-run" around Congress's confirmation power. Essayli’s installation was part of the political objective to aggressively pursue cases aligned with the Executive's ideological goals, particularly on immigration enforcement. The judge ruled that Essayli had been unlawfully serving since July 29 and was disqualified from supervising key criminal prosecutions.

The Nevada Case (Sigal Chattah): The same systemic abuse was found in the District of Nevada. U.S. District Judge David Campbell ruled that prosecutor Sigal Chattah was "not validly serving" in the role of top federal prosecutor. Chattah was named interim U.S. Attorney, but as her 120-day statutory limit neared, the Justice Department executed the same shell game: shifting her to a "different job" that they claimed would allow her to continue as "Acting U.S. Attorney." Judge Campbell was unsparing, barring Chattah from supervising certain cases and ruling that the maneuver was an illegal attempt to maintain control. The court explicitly rejected the administration’s claim that the Attorney General had the power to designate "anyone she chooses as first assistant" to then seize the role of Acting U.S. Attorney. This judicial defiance in Nevada highlighted the administration’s determination to staff critical border-state positions with politically compatible operatives.

Crucially, in both California and Nevada, the judges’ rulings confirmed the core finding of the Virginia court: the Executive Branch was defying the clear intent and text of 28 U.S.C. § 546 and the Federal Vacancies Reform Act (FVRA). The administration sought to treat the 120-day limit as a minor suggestion, easily defeated by internal paperwork and bureaucratic reshuffling. The courts saw this for what it was: a national blueprint for executive takeover.

II. THE NORTHEAST FRAGMENTATION: NEW JERSEY AND THE 120-DAY DEFIANCE

The "Acting Racket" was also exposed in the District of New Jersey, demonstrating that the scope of this corruption was national, spanning major financial and political hubs.

The New Jersey Case (Alina Habba): In New Jersey, the constitutional fraud was even more layered, exposing the serial nature of the administration's legal maneuvering. The U.S. Attorney’s position had been repeatedly filled using the interim appointment authority. When former presidential lawyer Alina Habba was installed, defense lawyers challenged her authority, arguing that the 120-day limit did not reset with her appointment but began tolling with the first interim appointment made after the vacancy occurred. U.S. District Judge Freda L. Wolfson agreed, concluding that the 120-day limit was an aggregate limit on the Attorney General’s authority to fill that specific vacancy. The judge found that the total time limit had expired long before Habba was appointed, rendering her service—and that of her predecessor—unlawful.

The Constitutional Chaos: The rulings in New Jersey and Virginia (Halligan) were particularly important because they both recognized that accepting the Justice Department's argument—that they could appoint a new person every 119 days—would be to completely nullify the judicial oversight power granted by § 546(d). That section authorizes the district court to appoint an interim U.S. Attorney after the 120-day AG limit expires. The administration’s lawyers were attempting to eliminate the courts from the constitutional loop entirely. As one legal analyst noted, this interpretation would allow the Attorney General to "forestall triggering § 546(d) by terminating every section 546(a) appointment on its 119th day," turning a specific, temporary legal check into a bureaucratic joke.

The fact that these separate federal courts—in districts with distinct legal histories and priorities—all arrived at the same conclusion confirms that the administration was operating with a national, pre-designed policy of constitutional defiance.

III. THE SYSTEMIC FAILURE: FROM MISTAKE TO MALICE

The Halligan ruling was unique because the judge had no choice but to dismiss the indictments, given Halligan’s singular role in securing them. However, in California, Nevada, and New Jersey, judges often permitted the cases brought under the unlawful appointees to move forward, substituting a different, lawfully appointed official. This differentiation highlights a crucial aspect of the Acting Racket: the administration was willing to risk the legal validity of its cases because the political payoff—installing a loyalist to direct policy and investigations—was worth the gamble.

This pattern demonstrates malice, not mistake:

Defiance of 2007 Law: The administration knew the history of the Preserving United States Attorney Independence Act of 2007, which was created to specifically prevent the indefinite use of temporary appointments. They defied that history.

Disregard for Senate: The strategy was a direct assault on the Senate's advice and consent power. By keeping loyalists in unconfirmed "Acting" positions, the administration avoided having their candidates vetted, questioned, or potentially rejected by the legislative branch. This destroyed the essential check and balance required for the independence of the Justice Department.

The Loyalty Qualification: In every instance, the choice of the unconfirmed prosecutor—from Halligan to Essayli to Habba—carried clear political baggage, demonstrating that the only criteria for national law enforcement leadership was undivided loyalty to the executive agenda, not legal experience or non-partisanship.

The sheer volume of successful legal challenges—three U.S. Attorneys disqualified in major districts, plus the dismissal of charges in Virginia—establishes that this was a widespread, operational corruption policy. The Executive Branch was not merely testing the limits of the law; it was intentionally exceeding them on a national scale.

IV. THE JUDICIAL RESISTANCE AND THE ROAD TO THE SUPREME COURT

The judicial resistance demonstrated in these separate, forceful rulings represents a critical moment in the fight against executive overreach. Individual judges, faced with the administration’s bureaucratic sophistry, rejected the legal gymnastics designed to perpetuate the fraud.

Rejecting the Shell Game: Judges explicitly condemned the attempt to shift "interim" prosecutors to "acting" prosecutors via internal shuffling, calling the move an unacceptable way to circumvent the law. The courts refused to rubber-stamp the "per-appointment" theory, which would have allowed the administration to cycle through an infinite number of temporary, unaccountable prosecutors.

The Looming Appeal: The Justice Department has indicated its intent to appeal the rulings, particularly the Halligan decision, which is the most devastating. This means the question of whether the Executive Branch can legally wage this national campaign of constitutional avoidance will eventually land before the nation’s highest court. The resolution will determine whether the constitutional safeguards designed to protect the independence of federal law enforcement are enforceable—or if they can be neutralized by a simple administrative filing.

This "Acting Racket" is the core of the Loyalists’ Handbook—a documented system to install political enforcers at the highest levels of the legal system, free from accountability to the people or their representatives. The next phase of the investigation must focus on the financial and ethical corruption that runs parallel to this judicial fraud, detailing how the loyalists, once installed, moved to loot the public treasury.

Source Material:

Court disqualifies Trump-appointed US attorney from overseeing multiple criminal cases - Newsday [https://www.newsday.com/news/nation/federal-prosecutor-disqualified-los-angeles-trump-m90871]

Judge disqualifies Trump-appointed Nevada prosecutor from some cases after finding she's "not validly serving" - CBS News [https://www.cbsnews.com/news/judge-trump-nevada-prosecutor-not-validly-serving/]

Another Trump-Appointed U.S. Attorney Found to be Serving Unlawfully, Federal Judge Rules - Democracy Docket [https://www.democracydocket.com/news-alerts/another-trump-appointed-u-s-attorney-found-to-be-serving-unlawfully-federal-judge-rules/]

All the President's Lawyers Redux: Ultra Vires U.S. Attorneys - Virginia Law Weekly [https://www.lawweekly.org/front-page/2025/10/22/3vlxuilcb3zjqehezl6w20wg94zgea]

Criminal cases against ex-FBI director Comey, Letitia James dismissed in blow to Trump administration - CBC News [https://www.cbc.ca/news/world/us-va-case-dismissed-james-comey-9.6990482]

Judge dismisses cases against James Comey and Letitia James after finding that prosecutor was illegally appointed - CBS News [https://www.cbsnews.com/news/judge-dismisses-cases-against-james-comey-and-letitia-james-after-finding-that-prosecutor-was-illegally-appointed/]

THE ACTING RACKET: A National Constitutional Fraud Confirmed by Courts in California, Nevada, and New Jersey

I. THE WEST COAST END-RUN: LOYALISTS IN LOS ANGELES AND NEVADA

II. THE NORTHEAST FRAGMENTATION: NEW JERSEY AND THE 120-DAY DEFIANCE

The "Acting Racket" was also exposed in the District of New Jersey, demonstrating that the scope of this corruption was national, spanning major financial and political hubs.

III. THE SYSTEMIC FAILURE: FROM MISTAKE TO MALICE

This pattern demonstrates malice, not mistake:

IV. THE JUDICIAL RESISTANCE AND THE ROAD TO THE SUPREME COURT

Source Material:

Court disqualifies Trump-appointed US attorney from overseeing multiple criminal cases - Newsday [https://www.newsday.com/news/nation/federal-prosecutor-disqualified-los-angeles-trump-m90871]

All the President's Lawyers Redux: Ultra Vires U.S. Attorneys - Virginia Law Weekly [https://www.lawweekly.org/front-page/2025/10/22/3vlxuilcb3zjqehezl6w20wg94zgea]

Criminal cases against ex-FBI director Comey, Letitia James dismissed in blow to Trump administration - CBC News [https://www.cbc.ca/news/world/us-va-case-dismissed-james-comey-9.6990482]

THE LOYALISTS' HANDBOOK: How to Buy Your Way Past the Constitution

ILLEGAL APPOINTMENT: The Judge Who Exposed the Justice Department's Deep State Fix

The ruling landed in the halls of Washington like a tactical nuclear strike—not a technical failure, but a verdict of systemic, calculated constitutional treason.

A federal judge has exposed the ultimate corruption: the intentional and documented hijacking of the federal justice system, executed through a bureaucratic sleight of hand designed to install political operatives, bypass all constitutional checks, and weaponize the prosecutorial power of the state against perceived political enemies. This is the moment the apparatus of political retribution was caught red-handed.

The target was accountability. The trophy was the dismissal of criminal cases against two of the administration’s most vocal critics, former FBI Director James Comey and New York Attorney General Letitia James. The cases did not collapse under the weight of weak evidence or clever defense lawyering; they were obliterated because the prosecutor who brought the charges, Lindsey Halligan, was ruled by the court to be illegally serving in her role as the interim U.S. Attorney for the Eastern District of Virginia.

This is not a technicality. This is judicial confirmation that the nation’s highest law enforcement agency, at the behest of the Executive Branch, was operating with an unlawful, shadow prosecutor—a political fixer installed to do a job that career prosecutors refused to touch. The judicial response was appropriately savage: all actions flowing from this appointment were declared "unlawful exercises of executive power and must be set aside."

The mask is off. The fix was in.

I. THE FIX IS IN: FROM WHITE HOUSE AIDE TO UNAUTHORIZED PROSECUTOR

The narrative begins with a clear motive for political vengeance. For months, the pressure had been mounting on the Eastern District of Virginia (EDVA) to deliver indictments against prominent figures who had opposed the administration. The case against Letitia James, for instance, had been overseen by the existing interim U.S. Attorney, Erik Siebert. Siebert, according to reports, had reportedly concluded that the evidence against James simply did not meet the ethical or legal standards required for federal prosecution. He was a professional adhering to the rule of law.

This adherence proved fatal to his tenure.

When the professional prosecutor failed to deliver the required political scalp, the axe fell. Siebert was summarily forced out of his role. His replacement, hastily installed by Attorney General Pam Bondi, was not a career prosecutor, not a veteran of the U.S. Attorney’s office, and not an official with any relevant prosecutorial experience in a district as critical as the EDVA.

The replacement was Lindsey Halligan, a former White House aide and one of the president's former personal lawyers. She arrived in Virginia and, almost immediately, the dormant cases against Comey and James sprang to life. Within days of her arrival—an appointment characterized by many as a brazen political maneuver—the indictment against Comey was secured. Shortly thereafter, James was indicted on allegations of mortgage fraud. The connection was clear, direct, and—as the court would soon prove—illegally executed. The administration needed a sword, and they simply bypassed the constitutional armory to manufacture one in the dark. Halligan was that sword.

II. THE ANATOMY OF THE CONSTITUTIONAL FRAUD: DECONSTRUCTING § 546

The core of this systemic corruption rests entirely on the blatant subversion of a specific federal statute: 28 U.S.C. § 546, which governs how vacancies in the office of U.S. Attorney are to be filled. The text of this law is unambiguous, yet the administration’s lawyers attempted to interpret it as a political blank check.

The law grants the Attorney General limited power to fill a U.S. Attorney vacancy. It is a temporary, emergency measure, not a permanent tool for installing political cronies.

The Statutory Limit:

The law states that a person appointed by the Attorney General under this section may serve until the earlier of (1) the qualification of a Presidentially-appointed, Senate-confirmed U.S. Attorney, OR (2) the expiration of 120 days after appointment.

The Fail-Safe Mechanism:

Crucially, 28 U.S.C. § 546(d) provides the constitutional fail-safe: "If an appointment expires under subsection (c)(2) [the 120-day limit], the district court for such district may appoint a United States attorney to serve until the vacancy is filled."

This mechanism is the lock on the gate of executive overreach. After 120 days, the power to appoint shifts exclusively to the judiciary, maintaining the constitutional system of checks and balances.

The defense for Comey and James argued, correctly, that the 120-day clock started when the vacancy first occurred and limited the total tenure of all interim appointments. Since Siebert had already served the maximum period, the power to appoint a successor lay solely with the federal judges of the EDVA.

The Justice Department, however, advanced the absurd and self-serving argument that the 120-day limit applied on a "per-appointment basis." Under their interpretation, the Attorney General could simply wait for the clock to run out on one interim U.S. Attorney, then immediately appoint a new interim U.S. Attorney, starting a fresh 120-day clock. Repeat this process indefinitely, and the Executive Branch never needs to seek Senate confirmation, and the courts never gain their statutory authority.

As Judge Cameron McGowan Currie excoriated in her opinion: "I conclude that the attorney general's attempt to install Ms Halligan... was invalid... [because] it would simply allow the attorney general to indefinitely appoint someone on an interim basis." This interpretation, she rightly concluded, flies in the face of the "text, structure, and history" of the law.

III. THE 2007 PRECEDENT: PROOF OF A REPEAT OFFENSE

This is not the first time the Justice Department has played this game, and the history is key to proving the administration’s action was a deliberate, cynical policy, not an oversight.

The modern text of 28 U.S.C. § 546 is itself a monument to past corruption. The language of the 120-day limit and the transfer of power to the court was established by the Preserving United States Attorney Independence Act of 2007.

The Origin of the Fix: This law was passed by Congress in response to a notorious scandal where the Bush administration had illegally removed several U.S. Attorneys and attempted to use its temporary appointment authority to install politically convenient replacements without Senate confirmation.
The Legislative Intent: The purpose of the 2007 Act was crystal clear: to strip the Executive Branch of the unilateral power to staff the nation’s top prosecutor posts indefinitely and force the President to seek Senate consent. It was a legislative firewall against executive abuse.

When the administration deployed the "per-appointment" theory, they were not just misinterpreting the law; they were attempting to resurrect the exact abuse that Congress had specifically acted to outlaw in 2007. They were seeking to return to a pre-2007 world of unchecked presidential power over law enforcement.

This history refutes any defense that the action was taken in good faith. It demonstrates a conscious, willful choice to ignore the intent of Congress, the lessons of history, and the explicit checks built into the statute. It is an act of institutional sabotage.

IV. THE APPOINTMENTS CLAUSE AND THE UNLAWFUL EXERCISE OF POWER

The judicial rebuke went beyond the simple statutory violation of § 546. Judge Currie also ruled that Halligan’s appointment violated the Appointments Clause of the U.S. Constitution (Article II, Section 2, Clause 2).

U.S. Attorneys are designated as "Officers of the United States." The Constitution demands that principal officers be appointed by the President "by and with the Advice and Consent of the Senate." This core requirement ensures accountability.

By usurping the role of the district court—the body granted exclusive appointment power after 120 days—the administration violated the constitutional structure that governs how government officials are given power.

In a desperate, last-ditch attempt to salvage the sinking indictments, the Justice Department revealed that they had also given Halligan a separate, retroactive designation as a "Special Attorney." This was an attempt to claim that even if she wasn't the U.S. Attorney, she still had the authority to present the case to the grand jury.

Judge Currie tore this defense to shreds, stating that the implications of such a position were "extraordinary" and would mean that the Government could:

"...send any private citizen off the street — attorney or not — into the grand jury room to secure an indictment so long as the Attorney General gives her approval after the fact. That cannot be the law."

The court’s verdict confirms that the Executive Branch was not merely skirting the edges of the law; it was attempting to manufacture legal authority out of thin air to prosecute political enemies. This is the hallmark of a system more loyal to a single man than to the Constitution he swore to uphold.

V. THE AFTERMATH: COMPROMISED JUSTICE AND THE IMPLICATIONS OF NULLITY

The practical result of the ruling is clear: the cases against Comey and James are dismissed. The indictments secured by an illegally appointed prosecutor are rendered nullities. The judge’s order that "all actions flowing from Ms. Halligan's defective appointment... must be set aside" means that her prosecutorial work in the EDVA stands as a stain on the district’s history.

The legal and ethical implications stretch far beyond these two cases:

The Unconfirmed Agenda: For every day Halligan served, every charging decision, every plea deal, every investigation she authorized was carried out by an official whose legal authority was, at best, illegitimate and, at worst, an unlawful exercise of power. The true cost of this corruption may be the instability introduced into every case handled by her office during her unlawful tenure.
The Accountability Gap: The ability of the Executive Branch to repeatedly defy Congress and the judiciary in its appointment of top law enforcement officials demonstrates an institutional cynicism that must be rooted out. The AG's willingness to violate the law to install a former personal lawyer with "no lawful authority" to pursue indictments shows a terrifying disregard for the independence of the Justice Department.

The dismissal of these cases provides the documentation needed to expose the inner workings of the apparatus of political retribution. It is the judicial confirmation that the administration attempted a constitutional end-run to install its chosen enforcers and weaponize the government. This was not a procedural error; it was a systemic corruption designed to ensure the law served the ruler, not the people.

The fight is only beginning. Installment II will detail how this single, damning ruling is just one piece of a national blueprint of subversion deployed across multiple jurisdictions to cement unaccountable power.

Source Material:

Judge dismisses cases against James Comey, Letitia James after finding the prosecutor was illegally appointed [https://www.pbs.org/newshour/politics/judge-dismisses-cases-against-james-comey-letitia-james-after-finding-the-prosecutor-was-illegally-appointed]

Judge tosses cases against Comey and James, rules prosecutor appointment unlawful [https://www.washingtonpost.com/national-security/2025/11/24/halligan-appointment-comey-james/]

Judge dismisses James Comey and Letitia James cases, finding prosecutor's appointment invalid [https://www.cbsnews.com/news/james-comey-case-dismissed-judge-lindsey-halligan/]

28 U.S. Code § 546 - Vacancies - Cornell Law School [https://www.law.cornell.edu/uscode/text/28/546]

Text - S.214 - 110th Congress (2007-2008): Preserving United States Attorney Independence Act of 2007 [https://www.congress.gov/bill/110th-congress/senate-bill/214/text/rs]

The Appointments Clause - U.S. Constitution - FindLaw [https://constitution.findlaw.com/article2/annotation13.html]

18 November 2025

The Tale of the Bound Butcher and the Island of Waste

The modern absurdity of Washington State's McNeil Island Special Commitment Center (SCC), with its $6.6 million "Island Factor"—a perpetual tax on the state coffers, paid solely for the privilege of isolation—finds its dark parallel in the disastrous, suffocating legal codes of the Late Roman Empire.

The Current Affair Hook: The Financial Shackle

Today, Washington taxpayers pay a ruinous premium—the "Island Factor"—to maintain a small correctional facility solely because of an antiquated Federal Reverter Clause. This clause, a legal gun to the head of state leaders, prohibits rational resource management, forcing the state to hemorrhage funds for ferries, premium wages, and inflated construction costs. The system is fiscally self-destructive, but political leaders prefer this expensive paralysis to the headache of facing local NIMBY opposition over a mainland facility. The state is trapped by a deed and political fear, choosing perpetual waste over rational efficiency.

The Roman Event Bridge: The Binding of the Collegia

In the 4th century AD, the Roman economy was in free-fall. Desperate to ensure the cities could still function and collect taxes, Emperors issued a series of increasingly draconian laws that essentially turned essential trades into hereditary chains. Artisans, bakers, shipwrights, and even butchers (the Pistores and Lanarii) were organized into powerful guilds, or collegia. To prevent people from fleeing these vital, but increasingly burdensome, trades, the Emperors legally bound them.

A butcher's son had to be a butcher. A ship captain's daughter had to marry a ship captain. No matter how economically disastrous the trade became, no matter how high the cost of the Emperor's arbitrary levies, the person could not leave. They were chained to their profession and their location by law, and they were forced to produce and pay taxes, even if it drove them to ruin.

The result was not stability, but stagnation and utter economic waste. These essential services were now incredibly expensive and inefficient, run by men who hated their work and had no incentive to innovate. The state's attempt to mandate stability through rigid, non-negotiable legal codes—the Reverter Clause of its time—strangled the natural flow of the economy, guaranteeing that public service and production would be delivered at the highest possible cost for the benefit of a bureaucratic fantasy.

The Direct Comparison: Fear of the Reverter

The Federal Reverter Clause on McNeil Island acts precisely like a Late Roman edict: it forbids the rational movement of resources. The state cannot efficiently repurpose the land for parks or housing, just as the Roman baker could not sell his oven and become a farmer. The political cowardice to face down the NIMBY problem mirrors the Emperor's fear of confronting the economic chaos; they both chose to codify the current, failing system, chaining the taxpayer to the waste.

For Rome, the cost was a collapsed domestic economy and cities abandoned by their bound citizens. For Washington, the cost is $6.6 million a year, every year, a monument to the principle that in a declining state, self-imposed legal rigidity becomes more sacred than public welfare or fiscal sense. The island is not merely a waste of money; it is a symbol of a state that prefers the death of its own economic logic to the inconvenience of political reform. The Republic dies when its own rules become its most effective executioner.

Source for the Binding of the Collegia:

> For the specific historical laws mandating hereditary succession in the Roman trades, refer to sections of the Theodosian Code (Codex Theodosianus), particularly the sections dealing with the collegia and the hereditary nature of public service (e.g., the navicularii and pistores).

* The Roman Law Library (Scroll to Theodosian Code for relevant excerpts)

The Tale of Crassus and the Corporate Patronage

During the final, blood-soaked century of the Roman Republic, the old system of checks and balances was systematically undermined by a handful of mega-rich power brokers—men like Marcus Licinius Crassus.

Crassus, famous for his insatiable greed and his ultimate defeat at Carrhae, was the wealthiest man in Rome, a fortune built on proscriptions (confiscating enemies' assets), silver mines, and most infamously, firefighting.

Crassus literally owned a private fire brigade. When a building caught fire, Crassus's men would rush to the scene, but they wouldn't extinguish the flames. Instead, Crassus would personally negotiate with the desperate owner, often buying the burning property for a fraction of its value—sometimes before the flames even died down. Only after the purchase was complete would the brigade put out the fire. This was pure, cynical profiteering—a man using a public tragedy for private gain, demonstrating the complete inversion of public service into personal enrichment.

Crassus used his wealth not just to acquire property, but to acquire political allegiance through the system of clientela. He had countless clients: senators, magistrates, voters, and entire communities who were dependent on his loans, his bribes, and his legal protection. He commanded a vast network, making him immune to prosecution and allowing him to dictate policy—including his eventual alliance with Pompey and Caesar—all to protect and increase his financial empire. The oligarch was the law.

The Echo in the American Forum

Now, turn your gaze to the American forum, where the spirit of Crassus lives in the form of the Modern Corporate Oligarch and the pervasive system of lobbying and campaign finance.

The modern equivalent of Crassus’s clientela is the network of massive political action committees (PACs), Super PACs, and well-funded corporate lobbying firms. These entities spend billions, not on literally buying burning buildings, but on buying political access and legislative outcomes that directly enrich their benefactors.

Consider the parallels:

Buying the Law: When a massive corporation spends tens of millions lobbying Congress to secure a tax loophole or to deregulate their industry—leading to billions in profit and often public hazard—they are doing precisely what Crassus did. They are using their private wealth to subvert the public process for personal gain. The money is spent to ensure that Congress does not put out the financial fires of inflation or market instability; instead, it ensures the law serves the few who can afford to purchase legislative immunity and advantage.

The Revolving Door: The ancient system relied on personal bonds; the modern system relies on the "revolving door," where former senators, agency heads, and congressional aides immediately transition to high-paying lobbying jobs. They cash in on their insider knowledge and connections, selling their access to the highest corporate bidder. This creates a powerful class of political professionals whose true allegiance is not to the Constitution, but to the continual flow of cash from their corporate patrons—a network of financial clients that ensures the laws are rigged to favor wealth.

The result is the same: the state becomes a mere shell—a facade of democracy—while the real power is wielded by an unaccountable financial elite. The Republic's collapse was not a sudden invasion; it was a slow, painful process where the wealthy class consumed the state's virtue until nothing was left but the military power necessary to impose their will.

Source: The life and political activities of Marcus Licinius Crassus are well-documented by Plutarch and other Roman historians. His wealth and methods of acquiring it are central to understanding the late Republic's decay.

Verifiable Link: https://www.britannica.com/biography/Marcus-Licinius-Crassus-Roman-triumvir (An overview of Crassus’s life, detailing his immense wealth and political influence.)

The Dark Parallel: A Corrupt Bargain

Let's focus on the perennial American crisis of political corruption and the breakdown of institutional trust, a topic constantly in the news, often concerning powerful figures' enrichment or the use of the justice system as a political weapon. The reports of government shutdowns, financial hacks, and the politicization of the legal system all point to a hollowed-out state, more concerned with factional warfare than governance.

The Roman Echo: The Sale of the Empire

The parallel is not the slow burn of corruption, but a specific moment of absurd institutional decay. The current spectacle of political figures using their office for personal gain, while the Res Publica (the public thing) suffers, finds its perfect, dark mirror in 193 AD—the year Rome officially put the imperial throne up for auction.

A sitting emperor, Pertinax, was murdered by the Praetorian Guard, the elite imperial bodyguards who had become a political kingmaker. Instead of appointing a successor, they brazenly auctioned off the throne of the Roman Empire to the highest bidder.

* The Bidders: Two wealthy senators, Titus Flavius Sulpicianus (the murdered emperor's father-in-law) and Didius Julianus, engaged in a shouting match from outside the Praetorian barracks, each promising a greater bounty to the troops.

* The Price: Julianus ultimately won by promising the colossal sum of 25,000 sesterces to every single Praetorian Guardsman. He literally bought the most powerful office in the known world.

* The Result: His "reign" lasted a mere sixty-six days. The population was enraged, provinces revolted, and three rival generals marched on Rome. The populace, who saw the transaction as a grotesque farce, openly mocked Julianus. Imagine the late-night hosts of ancient Rome—Cicero's ghost filling in for Stephen Colbert—having a field day with that absurdity.

The Modern Resonance

The modern news cycle is saturated with crises that reveal an institution bought and sold. Whether it's the influence of corporate money on legislation, the revolving door between regulatory bodies and the industries they regulate, or the sheer political paralysis in the face of national debt and crumbling infrastructure, the feeling is the same: the Pax Americana is for sale, and we're just spectators.

The American people, like the Romans who were appalled that their sacred imperial title was merely a commodity for the Praetorian thugs, are growing weary of the sense that their votes matter far less than the back-room deals and campaign contributions. The system appears to serve the guard on the wall—the moneyed elites, the lobbyists, the special interests—rather than the citizens in the Forum. Julianus's victory was hollow and brief because the very act of the auction destroyed the legitimacy of the power he bought. When power is a transaction, loyalty is a liability.

We watch our leaders engage in zero-sum political games, as noted by the Congressional Budget Office hack and the ongoing government shutdown theatrics, while the actual work of the Republic grinds to a halt. It’s the same old story: a government, paralyzed by internal greed and faction, that eventually loses the will of its people and the very legitimacy of its own existence.

The Tale of the Erased Man: The Modern Suppression of Truth and Rome's Damnatio Memoriae

The current affairs of Washington State’s McNeil Island, where a critical internal watchdog report was allegedly suppressed, leading to the removal of the center's CEO—a clear attempt to prioritize institutional secrecy over public accountability—is not merely a scandal. It is the modern iteration of an ancient, desperate tactic: the attempt to control reality by erasing the record.

The Roman Empire had a terrifying legal recourse for this act of historical obliteration: Damnatio Memoriae—the "Condemnation of Memory."

The citizens of Washington are asked to swallow a grotesque fiscal reality: the Island Factor bleeds millions, yet any report revealing the rot, or any CEO who points toward rational change, must be silenced or removed. The system defends its inefficiency with the zeal of a cult defending its high priest. The problem is not merely the $6.6 million in waste; the problem is the unwritten, political decree that the truth about that waste must vanish.

Across the centuries, the same desperate need to control the narrative drove the Roman Senate. When an Emperor became too monstrous, too incompetent, or too politically toxic—like Caligula or Nero—the Senate would sometimes decree the Damnatio Memoriae.

This was not a mere posthumous punishment; it was a total obliteration of a man’s existence from the state’s reality. Imagine the frenzy: Every statue was torn down and smashed. Every inscription bearing his name was chiseled off public buildings and monuments. His face was physically scrubbed from relief carvings and even the small, ubiquitous images on the coinage. His laws were nullified. His very name became taboo.

The purpose was profound: to create a retroactive truth that this tyrannical reign had simply never happened. The populace was meant to look at a newly blank pedestal in the Forum and accept the state’s official, convenient lie.

The connection to the McNeil Island CEO's removal and the alleged suppression of his critical report is chillingly direct. The state bureaucracy, unable and unwilling to solve a problem—the irrational cost of the island—chooses the path of the Emperor. It decides to erase the very evidence of the problem. The CEO becomes the modern Nero, not for his wickedness, but for his inconvenient truth-telling. He is condemned; his name is tarnished in the press, and the report he authored is sealed away—all to protect the institutional lie that the current, self-destructive operation is the only possible way. The political system is performing a Damnatio Memoriae on the facts.

In both eras, the effect on the people who are supposedly “asleep” is insidious. When the Senate decreed an Emperor’s erasure, the people learned a dark lesson: the reality you see with your own eyes is irrelevant; only the official, sanctioned reality matters. Today, when the taxpayer sees a scandal, only to watch the whistleblower vanish and the critical report disappear, they learn the same thing: The institutions exist to protect themselves, not the truth.

The citizens may continue to “sleep,” but their trust in the institutions that govern them has been destroyed. They have seen the reality of the island, and then they have seen the state’s furious attempt to whitewash the historical record. This constant cycle of institutional deceit is how the foundations of a Republic—built on accountability and shared truth—are slowly, deliberately, undermined, paving the way for a system where only the arbitrary will of the powerful remains.

The Tale of the Crushed Curiales

The story is one of a broken social contract, where the weight of the state's failure was skillfully shifted until it crushed the very class that formed the empire's spine. It is the tale of Tax Avoidance by the Elite and the doom of the Middle Class.

The Tale of the Crushed Curiales

The scene is set in the Later Roman Empire (3rd-5th centuries A.D.). The crisis of constant warfare and runaway inflation had left the imperial treasury permanently bankrupt. The solution from the central government was not to shrink the empire, but to squeeze the provinces dry through an oppressive tax system.

The Roman state needed a class of local administrators to collect these taxes. It relied upon the Curiales (or Decurions) , the wealthy, educated, landowning middle-class aristocrats who ran the provincial cities.

The Fatal Duty: Tax Evasion and The Scapegoat

Historically, being a Curialis was a matter of immense civic pride, but the central government slowly turned this honor into a fatal, inherited burden. The key provision was simple and ruinous: the Curiales were made personally liable for any shortfall in the imperial taxes they were required to collect from their district.

If the city could not pay the required quota of taxes (often demanded in gold or goods, not worthless imperial coins), the Curiales had to make up the difference out of their own estates.

Meanwhile, the true Patrician Class—the immensely wealthy, politically connected senators and great landowners (the Potentiores)—were masters of tax avoidance. They utilized their political influence in Rome, their sheer scale, and pervasive bribery to secure exemptions, delay payments, and even secure general tax remissions for their vast estates. They created what were essentially tax-free zones across the empire.

The Doom of the Middle Class

This elite tax evasion did not lower the state’s massive budgetary needs, nor did it reduce the fixed tax quota demanded from a given region. It merely meant that the tax burden had to be distributed among fewer and fewer people.

The Curiales became the scapegoats for the empire's fiscal failure. They were trapped in a vice:

* Squeezed by the State: They had to pay the central government's unmeetable tax demands.

* Squeezed by the Poor: They had to collect those taxes from an increasingly impoverished populace, facing riots and resistance.

* Squeezed by the Elite: They could not collect the necessary revenue from the exempted great estates of the Potentiores.

The result was the systematic financial ruin of the Roman middle class. Their inherited wealth, intended to run local civic life, was instead confiscated by the Imperial treasury to cover the shortages created by the tax-dodging elite.

To escape this ruin, the Curiales desperately tried to flee their class: some joined the clergy (which often held tax exemptions), others joined the Imperial bureaucracy, and many simply abandoned their land to seek refuge on the tax-exempt estates of the Potentiores, transforming into semi-free peasant-laborers.

When the middle class—the source of civic infrastructure, local governance, and stability—was extinguished, the cities withered. The remaining wealth was concentrated in the massive, powerful, and tax-immune estates, fracturing the imperial unity and hastening the rise of the Dark Ages.

The Parallel: The Extinction of Civic Responsibility

The tale of the Curiales finds its echo in the modern American structure through a similar erosion of responsibility:

* The Potentiores and the Tax Code: The modern elite masters the art of tax avoidance through complex legal structures, global capital movement, and political lobbying. The result is that a significant portion of national wealth is placed beyond the effective reach of the tax code, starving the treasury of necessary revenue.

* The New Curiales: The middle-class taxpayer—the small business owner, the salary earner—cannot afford the armies of lawyers and accountants necessary for complex avoidance, nor can they secure political remissions. They shoulder an ever-growing proportion of the national burden, paying for the state's military and debt services while watching their local civic institutions decay.

* The Flight from Responsibility: When the financial pressure becomes unbearable, the middle class "flees" their cities or their vocations. They lose faith in the system that demands everything from them while providing generous exemptions and loopholes for the wealthiest. This loss of faith, responsibility, and civic wealth is the structural fracture that leads to the empire's final collapse.

The failure to maintain a fair and broadly applied tax system did not merely impoverish Rome; it systematically destroyed the civic-minded class that actually ran it. The same decay will claim any state that allows its most powerful citizens to divorce their wealth from their national obligations.

The Lyre, the Liar, and the Golden Prison: When Artistry Becomes Autocracy

The history of political collapse is not a ledger of failures, but a series of tragic rhymes, where the destructive impulses of one era are echoed by the next. The most cynical and resonant parallel of the modern American decline can be found in the figure of the absolute ruler who demands to be seen as a genius, forcing a weary public to watch his self-serving drama. This is the enduring connection between the Roman Emperor Nero and the contemporary Tangerine Tyrant.

The young Nero, who seized power and proceeded to murder his way through the imperial family, considered himself primarily an artist. He was obsessed with his poetry and his music, performing on the lyre while demanding frantic, choreographed applause from his court and the masses. When the Great Fire of 64 AD destroyed much of Rome, Nero’s response was the most profound expression of his ego: he commandeered the scorched earth to build the extravagant Domus Aurea—the Golden House—a monument to himself complete with an artificial lake and a colossal statue of his own likeness. He prioritized the lavish construction of his self-aggrandizing palace over the desperate needs of the displaced citizens.

This narcissism finds its twin in the modern executive who proposes the gilding of the White House in Russian style and the demolition of a third of its structure for personal benefit. This act is not about governance; it is an Imperial Declaration that the institution is subservient to the taste of the man. The physical destruction of a symbol of public service to construct a gaudy, gold-plated palace of ego mirrors Nero’s waste, demonstrating a fundamental contempt for the structural permanence of the Republic. The leader dictates reality by literally rebuilding the world in his own image, proclaiming his vision is the only one that matters.

The true genius of Nero, however, was in making his lyre the state’s instrument of policy. To say his music was poor was to plot treason. Similarly, the modern tyrant’s power is built on his status as an indiscriminate liar. He operates in a constant state of factual warfare, where every official statement, every press briefing, and every pronouncement from the megaphone is a deliberate distortion of reality. Like Nero, he demands that his audience ignore their own lived experience and applaud the spectacle he creates. The fusion of the lyre and the liar forms the perfect tyranny: a leader whose power rests not on objective truth, but on the ability to enforce a self-serving, beautifully gold-plated illusion.

This brings us to the ultimate, devastating rhyme: the tragedy of the satirical circus. The great Roman satirists, such as Juvenal, watched the Empire decay, lamenting that the people only cared for "bread and circuses." They created biting critique—the equivalent of today’s late-night comedy and political commentary—to expose the naked Emperor. Yet, in the modern age, the system has consumed its own antidote. When a political humorist bravely holds up the mirror to the liar, exposing the day’s outrage, the audience does not feel galvanized to action; they feel entertained. They cheer the joke, they affirm their intellectual superiority, and the deep, cleansing rage that fuels political change is bled off and neutralized by the satisfying release of laughter.

The spectacular critique becomes part of the self-sustaining spectacle. The citizen tunes in, consumes the dissection of the Tyrant's golden palace and his daily lies, and is pacified. They have done their civic duty by watching the outrage, and the essential political energy is safely contained within the boundaries of the Circus.

Thus, the Republic continues its slow, inevitable collapse, not despite the truth, but while cheering the truth’s delivery as entertainment. The lie persists because the spectacle is too good to miss.

24 November 2025

​I. THE STRATEGIC TARGET: CAPTURING AMERICA'S LANDSCAPE

​William Perry Pendley: The Ideological Weapon

​II. THE DELEGATION SHELL GAME: THE GHOST DIRECTOR'S ASCENSION

​The Initial Setup: The FVRA Sidestep

​The Constitutional Fallout: A "Matryoshka Doll of Delegated Authorities"

​III. THE POLICY OF DESTRUCTION: PLUNDERING THE AMERICAN COMMONS

​The Drilling Frenzy

​The Headquarters Relocation: A Strategic Sabotage

​The Judicial Nullification: Policy as Void as the Appointment

​IV. THE ETHICAL PAYOUT: A REVOLVING DOOR TO THE ANTI-FEDERAL MOVEMENT

​Pendley's Return: A Predictable Trajectory

​V. THE UNCHECKED POWER: THE DOCTRINE'S EVOLUTION AND CONGRESSIONAL COMPLICITY

I. INTRODUCTION: THE WOLF AT THE GATES OF LAW

​II. THE ANATOMY OF A LEGAL FRAUD: SUBVERTING THE HOMELAND SECURITY ACT

​The Mandate vs. The Maneuver

​III. THE POLITICAL WEAPONIZATION: CORRUPTION AS POLICY

​The Asylum and DACA Edicts

​IV. THE JUDICIAL RECKONING: VOID ACTIONS AND NULLIFIED POLICIES

​The Cuccinelli Precedent

​The Wolf Catastrophe: The DACA Nullification

​V. THE WIDER SCANDAL: A SYSTEMIC STRATEGY OF AVOIDANCE

​VI. THE ETHICAL PAYOUT: THE REVOLVING DOOR CONFIRMS THE MOTIVE

​VII. CONCLUSION: THE LOYALISTS' LEGACY AND THE NECESSITY OF AUDIT

​I. SWAMP AIRLINES: THE GREAT TAXPAYER TRAVEL HEIST

​II. THE CONFLICT OF INTEREST FACTORY: ETHICS AS AN OBSOLETE CONCEPT

​IV. THE REVOLVING DOOR: CONVERTING PUBLIC SERVICE INTO PRIVATE PROFIT

​I. THE FIX IS IN: FROM WHITE HOUSE AIDE TO UNAUTHORIZED PROSECUTOR

​II. THE ANATOMY OF THE CONSTITUTIONAL FRAUD: DECONSTRUCTING § 546

​III. THE 2007 PRECEDENT: PROOF OF A REPEAT OFFENSE

​IV. THE APPOINTMENTS CLAUSE AND THE UNLAWFUL EXERCISE OF POWER

​V. THE AFTERMATH: COMPROMISED JUSTICE AND THE IMPLICATIONS OF NULLITY