ABBE DAVID LOWELL

Partner
(202) 282-5000

April 24, 2023

VIA E-MAIL

Chairman Paul Vinovich

Co-Chairman Mike Barnes
Office of Congressional Ethics
U.S. House of Representatives
425 3rd Street, S.W. Suite 1110
Washington, D.C. 20024

Re: Request for Ethics Action Against Representative Marjorie Taylor Greene for Her
Statements and Conduct Regarding Robert Hunter Biden and Others

Dear Messrs. Vinovich and Barnes:

We write to request the Office of Congressional Ethics initiate a review of and take appropriate
action as a result of Representative Marjorie Taylor Greene’s (R-GA 14th C.D.) suspected violations of
House Ethics rules and standards of official conduct. Representative Greene’s unethical conduct arises
from her continuous verbal attacks, defamatory statements, publication of personal photos and data, and
promotion of conspiracy theories about and against Robert Hunter Biden. None of these could possibly be
deemed to be part of any legitimate legislative activity, as is clear from both the content of her statements
and actions, and the forums she uses to spew her often unhinged rhetoric.1

1. Conduct Not Reflecting Creditably on the House

House Rule XXIII (Code of Official Conduct), Clause 1, specifies that all members of the House
must conduct themselves at all times “in a manner that reflects creditably on the House.”2 This ethics
standard is considered the “most comprehensive provision” of the Code.3 Clause 2 likewise requires
members to “adhere to the spirit and the letter of the Rules of the House.”4

1
The Office of Congressional Ethics is certainly familiar with similar lapses and misconduct by Representative Greene, as
reflected in prior or pending ethics complaints made by others.
2
Rule XXIII, Cl. 1, Rules of the House of Representatives, 118th Cong. (Jan. 10, 2023), available at
https://rules.house.gov/sites/republicans.rules118.house.gov/files/documents/Rules%20and%20Resources/118-House-Rules-
Clerk.pdf (last accessed Apr. 20, 2023).
3
House Comm. on Ethics, House Ethics Manual (2022) at 12.
4
Rule XXIII, Cl. 2, Rules of the House of Representatives, 118th Cong. (Jan. 10, 2023).
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April 24, 2023
Page 2

In adopting this provision, the Select Committee on Standards of Official Conduct of the 90th
Congress noted that it was included in the Code to deal with flagrant violations of the law that reflect on
Congress as a whole, and that might otherwise go unpunished.5 The House Ethics Committee has relied
on this rule in several prior cases in which the Committee found ethical lapses or misconduct, including
when it found that Representative Matt Gaetz (R-FL) violated Clause 1 by threatening, intimidating,
harassing, or otherwise improperly influencing President Trump’s former attorney, Michael Cohen, in
connection with Mr. Cohen’s testimony before a congressional committee.6 The Committee found that
Representative Gaetz’s conduct, which included a tweet directed toward Mr. Cohen, did not reflect
creditably upon the House of Representatives.7 The Gaetz investigation, and many others before it, provide
the Office of Congressional Ethics with adequate precedent to initiate a review of Representative Greene’s
conduct here.

Since her election to Congress in 2020 (and before), Representative Greene has engaged in steady,
dogged verbal and defamatory attacks against Mr. Biden, and members of his family. Her online statements
and public appearances are neither legislative drafting, nor oversight, nor real congressional business—
they are a spray of shotgun pellets of personal vitriol that are the definition of conduct that does not reflect
“creditably on the House.” Her actions are not merely the expression of political views or private “free
speech” because she uses her official position to disseminate them and often expresses them in official
proceedings.

As outlined below, her public statements and related efforts on Twitter, Truth Social, Facebook,
and during public appearances attacking Mr. Biden sound and read like school-yard insults rather than the
work of a Member of Congress, and they fail to uphold the integrity and dignity expected of members of
the House of Representatives. We therefore respectfully request that the Office of Congressional Ethics
authorize an initial review of this conduct to determine the extent of Representative Greene’s violations,
which would then result in referring her conduct to the House Committee on Ethics.

2. Public Statements

Representative Greene’s violations of House Rule XXIII are numerous. Most recently, on April
18, 2023, on her new Twitter account (and surely not a congressional webpage), @battlegroundMTG,
Representative Greene released a video clip in which she stated, “Hunter Biden paid non-resident women
who were nationals of Russia or other eastern European countries, and who appear to be linked to an eastern
European prostitution or human trafficking ring. . . . He was engaged in an actual human trafficking ring.

5
House Comm. on Standards of Official Conduct, Report Under the Authority of H. Res. 418, H. Rep. No. 1176, 90th Cong.,
2d Sess. 17 (1968).
6
Comm. on Ethics, “In the Matter of Allegations Relations to representative Matt Gaetz,” H. Report 116-479, 116th Cong., 2d
Sess. 2 (Aug. 21, 2020), https://ethics.house.gov/committee-reports/matter-allegations-relating-representative-matt-gaetz.
7
Id. at 2.
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April 24, 2023
Page 3

And he was paying a lot of money for it.”8 Portions of this video were also retweeted by another of
Representative Greene’s Twitter accounts, @RepMTG, to her more than 2.1 million followers.

Similarly, Representative Greene released a video on her Twitter account, standing in front of the
Treasury building, in which she stated, “The Biden crime family participated in human trafficking by
soliciting prostitutes from the United States and abroad in countries like Russia and Ukraine.” She claimed
that it “extend[ed] past Hunter Biden and his immediate family.”9 She posted the same message and video
to her Truth Social account on April 19, 2023.10 Not only are these statements false, defamatory, and
malicious, but they are undignified from a Member of Congress and far beyond anything close to genuine
legislative activities or political advocacy.

On Truth Social, another one of her social media propaganda platforms for attacking Mr. Biden and
his family, Representative Greene (@RepMTG) “truthed” on July 28, 2022, “The crimes are so bad . . .
It’s not just Hunter and his drug use and sex with prostitutes & minors. Those were more like his
‘recreational activities’ that filled his data with filth.”11

There are additional untethered statements by Representative Greene. During an interview with
CBS’ 60 Minutes in April 2023, which she posted to her Twitter account, Representative Greene stated the
Democratic Party definitely “supports grooming children” and that President Biden “supports children
being sexualized . . . sexualizing children is what pedophiles do to children.”12 On her Truth Social account,
on April 12, 2023, she wrote “Democrats are the party of pedophiles” above a message criticizing the “so-
called Trans Bill of Rights.”13 How can there be a serious question that such comments do not reflect
creditably upon the House of Representatives and its Democratic members.14
8
Marjorie Taylor Greene, @battlegroundMTG, TWITTER (Apr. 18, 2023),
https://twitter.com/battlegroundMTG/status/1648403399875137537.
9
Marjorie Taylor Greene, @RepMTG, TWITTER (Apr. 18, 2023),
https://twitter.com/RepMTG/status/1648384048266354688?cxt=HHwWgICxpd6jnuAtAAAA.
10
Marjorie Taylor Greene, @RepMTG, TRUTH SOCIAL (Apr. 19, 2023),
https://truthsocial.com/@RepMTG/posts/110226041647744580.
11
Marjorie Taylor Greene, @RepMTG, TRUTH SOCIAL (July 28, 2022),
https://truthsocial.com/@MTG/posts/108725888754903675.
12
Marjorie Taylor Greene, @RepMTG, TWITTER (Apr. 3, 2023),
https://twitter.com/DailyCaller/status/1642904643226202116?cxt=HHwWiMCztbHE4swtAAAA.
13
Marjorie Taylor Greene, @RepMTG, TRUTH SOCIAL (Apr. 12, 2023),
https://truthsocial.com/@MTG/posts/110186330191099429.
14
Her outrageous claims of pedophilia are not limited to Democratic politicians or their family members. In a recent Oversight
Committee hearing exploring Twitter’s handling of an October 2020 New York Post story dealing with the contents of the so-
called ‘Hunter Biden laptop,’ Representative Greene used her line of questioning to smear Twitter’s former Global Head of
Trust & Safety, Yoel Roth, as a pedophile. Giving a voice to far-right conspiracy theorists, she stated, “[h]ere’s something that
disgusts me about you . . . in your dissertation entitled ‘Gay Data’ you argued that minors should have access to Grindr, an adult
male gay hookup app. Minors, really?” That intentional misinterpretation of Mr. Roth’s work had previously exploded in right-
wing media circles after Elon Musk tweeted a snippet of the paper saying, “Looks like Yoel is arguing in favor of children being
 Office of Congressional Ethics
April 24, 2023
Page 4

As a confirmation that the time has come for the House to take up a review of Representative
Greene’s conduct, just last week, during a House Homeland Security Committee hearing, Chairman Mark
Green (R-TN) barred Representative Greene from speaking further during the hearing after she called
Department of Homeland Security Secretary Alejandro Mayorkas a “liar” while questioning him.15 In
response, GOP Chairman Green rebuked Representative Greene before the Committee and ordered her
words struck from the record: “It’s pretty clear that the rules state you can’t impugn someone’s
character. Identifying or calling someone a liar is unacceptable on this committee, and I make the ruling
that we strike those words.”16 This is a stunning example of how Representative Greene’s extreme rhetoric
has led even members of her own party to reject her ad hominem attacks and shut her down.

3. Posting Photos

Representative Greene’s violations of House Rule XXIII are not just limited to her statements on
Twitter and in the House chamber. On Truth Social on January 19, 2023, she posted two photos of Mr.
Biden driving his niece and her cousin in his father’s convertible and captioned it, “Hunter was on crack
wheeling & dealing with CCP ties and prostitutes with classified documents laying around in the garage.”17
These were family members, not prostitutes as Representative Greene claimed. It is impossible that
Representative Green’s postings of this material could have a purpose other than one to cause a private
citizen harm.18

In summary, the unmoored verbal abuses and ad hominem attacks against Mr. Biden are just a
microcosm of Representative Greene’s numerous ethical violations and repeated lapses in ethical judgment,
all of which warrant a review of her conduct. Strong precedent exists for the Office of Congressional
Ethics, and ultimately the House Ethics Committee, to do so, and we urge this Office to initiate this review
as promptly as possible. Perhaps Representative Greene is beyond conducting herself properly. Many
have so concluded. However, the House has a duty to make loud and clear that it does not endorse,

able to access adults.” See Mack DeGeurin, 10 Wacko Moments from Republicans’ Hearing on Hunter Biden’s Laptop,
GIZMODO (Feb. 9, 2023), https://gizmodo.com/twitter-hunter-biden-laptop-hearing-wacko-moments-1850094948.
15
Melanie Zanona et al., Marjorie Taylor Greene silenced by GOP-led committee after calling Mayorkas a ‘liar’, CNN (Apr.
20, 2023), https://www.cnn.com/2023/04/19/politics/marjorie-taylor-greene-silenced-house-republicans/index.html.
16
See Matt Berg, House Republicans bash Mayorkas over Southern border, POLITICO (Apr. 19, 2023),
https://www.politico.com/news/2023/04/19/house-republicans-mayorkas-southern-border-00092808.
17
Marjorie Taylor Greene, @RepMTG, TRUTH SOCIAL (Jan. 19, 2023), https://truthsocial.com/@MTG/109717586399052808.
18
As with her public and online statements, Representative Greene’s use of salacious or edited images to attempt to disgrace
and defame people is not limited only to Mr. Biden. Most recently, she reposted on her official Twitter page a doctored image
of Senator Lindsey Graham holding a Bud Light can (alongside CNN anchor Dana Bash) sporting the image of a trans social
media influencer. Representative Greene’s post responds to Senator Graham’s criticism of her defense of the alleged Pentagon
document leaker on Twitter. Surely, retweeting doctored, undignified photos of a U.S. Senator (even one in her own party) does
not reflect creditably upon the House of Representatives and its members. See Sarah Polus, Marjorie Taylor Greene fires back
at Lindsey Graham by posting edited photo of senator hoisting a Bud Light with trans influencer’s image, THE HILL (Apr. 16,
2023), https://thehill.com/homenews/3953968-marjorie-taylor-greene-fires-back-at-lindsey-graham-by-posting-photoshopped-
pic-of-senator-hoisting-a-bud-light-with-trans-influencers-image/.
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April 24, 2023
Page 5

condone, or agree with her outrageous, undignified rhetoric and brazen violations of the standards of
official conduct that do not reflect creditably on the House of Representatives.

Sincerely,

Abbe David Lowell

Counsel for Robert Hunter Biden