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A RESOLUTION
26-17
IN THE COUNCIL OF THE DISTRICT OF COLUMBIA
February 4, 2025
To adopt the findings, conclusions, and recommendations from the Committee Report of the Ad
Hoc Committee In Re: Trayon White, Sr., and to expel Councilmember Trayon White,
Sr. from the Council for the conduct referenced in the Committee Report that violated
D.C. Official Code § 1-1162.23 and D.C. Official Code § 1-618.01, in addition to
Council Rule 202(a) and several provisions of the Council’s Code of Official Conduct,
and the District’s Ethics Act.
R ESOLVED, BY THE COUNCIL OF THE DISTRICT OF COLUMBIA, That this
resolution may be cited as the “Expulsion of Councilmember Trayon White, Sr. Resolution of
2025”.
Sec. 2. On August 18, 2024, the Federal Bureau of Investigation (“FBI”) arrested
Councilmember Trayon White, Sr. pursuant to a federal criminal complaint charging him with
one count of bribery in violation of 18 U.S.C. § 201(b)(2). A Grand Jury for the District of
Columbia returned an indictment charging Councilmember White with violating 18 U.S.C.
§ 201(b)(2) (bribery) on September 5, 2024. Councilmember White was arraigned on September
12, 2024, and entered a plea of not guilty. That charge remains pending, with a trial scheduled to
commence in January 2026.
Sec. 3. (a) An ad hoc committee (the “Committee”) was established by memorandum of
Council Chairman Phil Mendelson on August 23, 2024. Pursuant to Rule 651(c), the Committee
was charged with: (1) investigating allegations that Councilmember Trayon White, Sr. engaged
in bribery and violated residency requirements, and (2) reporting its findings and penalty
recommendations, if any, to the Council within 90 days of being convened. The Council Period
25 Rules of Organization and Procedure and Appointment of Committee Chairpersons and
Membership Amendment Resolution of 2024, effective September 17, 2024 (Res. 25-634; 71
DCR 11536), authorized the Committee to investigate “whether Councilmember Trayon White
violated the law by residing in a ward other than Ward 8 or violated the Code of Conduct, as that
term is defined in section 101(7) of the Board of Ethics and Government Accountability
Establishment and Comprehensive Ethics Reform Amendment Act of 2011, effective April 27,
2012 (D.C. Law 19-124; D.C. Official Code § 1-1161.01(7)), or Council Rules, including those
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provisions of the Code of Conduct or the Council Rules that relate to conflicts of interest, taking
any action that adversely affects the confidence of the public in the integrity of the District
government, outside activities, use of government resources, or acting solely in the public
interest.”
(b) The Committee engaged outside counsel, Latham and Watkins, LLP ( “Latham”), to
conduct an investigation. Councilmember White declined through counsel to be interviewed by
Latham. Councilmember White also declined through counsel to appear before the Committee,
both prior to and after the completion of Latham’s investigative report.
Sec. 4. (a) On December 16, 2024, the Committee unanimously approved to recommend
to the Council the sanction of expulsion of Councilmember Trayon White, Sr. and approved the
Committee Report.
(b) The Committee adopted the findings of the report prepared by Latham and
determined that substantial evidence in totality exists to support violations of D.C. Official Code
§ 1-1162.23 and D.C. Official Code § 1-618.01, magnified by violations of Rule 202(a) of the
Rules of the Council for Council Period 25 and various rules of the Council’s Code of Official
Conduct.
Sec. 5. D.C. Official Code violations.
(a) D.C. Official Code § 1-1162.23 prohibits an employee from using his or her official
position or title, or personally and substantially participating, through decision, approval,
disapproval, recommendation, the rendering of advice, investigation, or otherwise, in a judicial
or other proceeding, application, request for a ruling or other determination, contract, claim,
controversy, charge, accusation, arrest, or other particular matter, or attempting to influence the
outcome of a particular matter, in a manner that the employee knows is likely to have a direct
and predictable effect on the employee’s financial interests or the financial interests of a person
closely affiliated with the employee. See also Rule I(a) of the Council’s Code of Official Conduct
for Council Period 25.
(b) D.C. Official Code § 1-618.01 requires each employee, member of a board or
commission, and public official of the District government to “at all times maintain a high level
of ethical conduct in connection with the performance of official duties, and [to] refrain from
taking, ordering, or participating in any official action which would adversely affect the
confidence of the public in the integrity of the District government.”
(c) Councilmember White’s June 26, 2024, and July 17, 2024, meetings with an FBI
confidential human source (“CHS 1”) where Councilmember White accepted a $15,000 cash
payment from CHS 1, discussed plans to meet with District government employees based on
CHS 1’s payment, discussed other opportunities to help CHS 1 secure further business with
District agencies, accepted CHS 1’s offer of a 3% kickback of each contract or grant’s value that
Councilmember White assisted in securing, and discussed potential expansion of his and CHS
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1’s enterprise into the mental healthcare and housing sectors are consistent with a violation of the
statutory provisions identified in subsections (a) and (b) of this section as established by the
Latham report.
Sec. 6. Council Code of Official Conduct violations.
(a) Rule I(e)(1) provides that “[a]n employee shall not receive any compensation, salary,
or contribution to salary, gratuity, or any other thing of value from any source other than the
District government for the employee’s performance of official duties.”
(b) Rule II(a)(1) provides that “[n]o employee shall engage in outside employment or
private activity that conflicts or would appear to conflict with the fair, impartial, and objective
performance of the employee’s official duties and responsibilities or with the efficient operation
of the Council.”
(c) Rule II(c)(1)(A) and (B) prohibit an employee from representing another person,
having a financial interest, or providing assistance in prosecuting a claim against the District of
Columbia before any regulatory agency or court of the District of Columbia, or from
representing another person before any regulatory agency or court of the District of Columbia in
a matter in which the District of Columbia is a party or has a direct and substantial interest.
(d) Rule III(e)(2) provides that, except as provided in Rule IV, no employee shall
“[d]irectly or indirectly demand, seek, receive, accept, or agree to receive or accept anything of
value personally or for any other person or entity, in return for:
“(A) Any official act performed or to be performed by the employee;
“(B) Being influenced in the performance of any official act;
“(C) Being influenced to commit or aid in committing, or to collude in, or allow,
any fraud, or make opportunity for the commission of any fraud, on the District of Columbia; or
“(D) Being induced to do or omit to do any act in violation of the employee’s
official duty.”
(e) Rule VI(b)(1) and (3) state that “[a]n employee may not knowingly use the
prestige of office or public position for that employee’s private gain or that of another[,]” and
that “Council employees shall not use or permit the use of their position or title or any authority
associated with their public office in a manner that could reasonably be construed to imply that
the Council sanctions or endorses the personal or business activities of another, unless the
Council has officially sanctioned or endorsed the activities.”
(f)(1) On 4 separate occasions between June 2024 and August 2024, Councilmember
White accepted cash payments from CHS 1.
(2) The cash payments described in paragraph (1) of this subsection totaled
$35,000.
(3) Councilmember White knew at the time of accepting these cash payments that
CHS 1 operated several businesses holding or seeking contracts or grants with the District of
Columbia, or that CHS 1 had received subcontracts or subgrants from businesses that contracted
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with the District of Columbia.
(4) Councilmember White accepted those cash payments in exchange for agreeing
to meet with and influence various government officials to ensure the contracts of CHS 1’s
organizations would be renewed.
(5) Councilmember White agreed to accept $156,000 in undisclosed kickbacks
and cash payments in exchange for using his official position as a Councilmember to help
organizations obtain or retain contracts or grants with District agencies.
(6) Councilmember White reviewed a ledger with CHS 1 that outlined profits he
expected to receive for his continued work, including a 3% cut for grant renewals he helped
secure.
(7) Councilmember White confirmed that he had contacted government
employees to discuss contract renewal, and stated he discussed contracts over which CHS 1 had
a direct interest.
(8) Councilmember White met with Department of Youth Rehabilitation Services
(“DYRS”) and Office of Neighborhood Safety and Engagement (“ONSE”) officials within days
of his multiple meetings with CHS 1 in July 2024 and he asserted to CHS 1 that he had held such
meetings and discussed with those DYRS and ONSE officials matters over which the CHS 1 had
a direct interest.
(9) The facts asserted above are consistent with violations of the Council Code of
Official Conduct described in subsections (a) through (e) of this section as established by the
Latham report.
Sec. 7. The Council adopts the findings and recommendations in the December 16, 2024,
report of the Ad Hoc Committee, which include the findings and recommendations in the
December 10, 2024, Report of Investigation of Councilmember Trayon White, Sr. Pursuant to
September 17, 2024 D.C. Council Resolution 25-634 prepared by Latham.
Sec. 8. To maintain the confidence of the public in the integrity of the legislative branch of
government, the Council:
(a) Expresses its disapproval of the actions of Councilmember Trayon White, Sr. as
detailed in the December 16, 2024, report of the Ad Hoc Committee;
(b) Notes that the degree and severity of Councilmember White’s actions, including his
discussions of maintaining and his expressed desire to expand the activities detailed in the
Committee Report essentially amount to an attempt to defraud the government and demonstrate a
particularly callous disregard for the potential effect on the Council as an institution, as well as the
District government as a whole; and
(c) Hereby expels Councilmember Trayon White Sr. for committing acts in violation of
D.C. Official Code § 1- 1162.23 and D.C. Official Code § 1- 618.01, the gravity of which is
underscored by acts committed in violation of the standards specified in the Council’s Code of
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Official Conduct and the District’s Ethics Act.
Sec. 9. The expulsion of Councilmember Trayon White, Sr. creates a vacancy in the
Ward 8 member seat on the Council of the District of Columbia.
Sec. 10. The Council shall transmit a copy of this resolution, upon its adoption, to
Councilmember Trayon White, Sr and the District of Columbia Board of Elections.
Sec. 11. This resolution shall take effect immediately.