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