View source for White House FBI files controversy

{{Short description|Political scandal of the Clinton administration}}
{{good article}}
{{Infobox event
| title                    = White House FBI files controversy
| date                     = Originating events 1993–1994; investigations 1996–2000
| place                    = Washington, D.C., United States
| also known as            = Filegate
| outcome                  = Clinton, Nussbaum, and other White House officials exonerated by Independent Counsel; <br/> Head of White House Office of Personnel Security resigned
| accused                  = First Lady [[Hillary Rodham Clinton]] <br/> White House counsel [[Bernard Nussbaum]] <br/> several other White House officials
| charges                  = Improper use of confidential information; <br/> Testifying falsely about White House hiring
}}
The '''White House FBI files controversy''' of the [[Clinton Administration]], often referred to as '''Filegate''',<ref name="cnn040198">[http://www.cnn.com/ALLPOLITICS/1998/04/01/filegate/index.html "'Filegate' Depositions Sought From White House Aides"], [[CNN]], April 1, 1998. Accessed June 5, 2007.</ref> arose in June 1996 around improper access in 1993 and 1994 to [[Federal Bureau of Investigation|FBI]] security-clearance documents. Craig Livingstone, director of the [[White House]]'s Office of Personnel Security, improperly requested, and received from the FBI, background reports concerning several hundred individuals without asking permission.  The revelations provoked a strong political and press reaction because many of the files covered White House employees from previous [[Republican Party (United States)|Republican]] administrations, including top presidential advisors.  Under criticism, Livingstone resigned from his position.  Allegations were made that senior White House figures, including First Lady [[Hillary Rodham Clinton]], may have requested and read the files for political purposes, and that the First Lady had authorized the hiring of the underqualified Livingstone.

The matter was investigated by the [[United States House Committee on Oversight and Government Reform|House Government Reform and Oversight Committee]], the [[Senate Judiciary Committee]], and the [[Whitewater (controversy)|Whitewater]] [[Independent Counsel]].  In 1998, Independent Counsel [[Kenneth Starr]] exonerated President [[Bill Clinton]] as well as the First Lady of any involvement in the matter.  In 2000, Independent Counsel [[Robert Ray (prosecutor)|Robert Ray]] issued his final report on Filegate, stating that there was no credible evidence of any criminal activity by any individual in the matter and no credible evidence that senior White House figures or the First Lady had requested the files or had acted improperly or testified improperly regarding Livingstone's hiring.  A separate lawsuit on the matter brought by [[Judicial Watch]], a [[American conservatism|conservative]] [[watchdog group]], lingered on for years and was dismissed by a federal judge in 2010.

==Improper use of files issue==
[[File:Seal of the Federal Bureau of Investigation.svg|thumb|left|Improper use of [[Federal Bureau of Investigation]] background reports was at the heart of the "Filegate" affair.]]

"Filegate" began on June 5, 1996, when Republican [[Pennsylvania]] Congressman [[William F. Clinger, Jr.]], chair of the [[United States House Committee on Government Reform and Oversight|House Committee on Government Reform and Oversight]], announced that the committee had found, during their ongoing "[[Travelgate]]" investigations, that FBI background reports on Travelgate figure Billy Dale had been delivered to the White House.<ref name="ray-marceca">[[Robert Ray (prosecutor)|Robert Ray]], [http://www.gpoaccess.gov/icreport/marceca/sec1-2.pdf "Final Report of the Independent Counsel ... of the Investigation In Re: Anthony Marceca"] {{Webarchive|url=https://ghostarchive.org/archive/20221009/http://www.gpoaccess.gov/icreport/marceca/sec1-2.pdf |date=2022-10-09 }}, [[United States Government Printing Office]], March 16, 2000.</ref> The following day, the White House delivered to the committee hundreds of other such files related to White House employees of the [[Reagan Administration]] and [[George H. W. Bush Administration]],<ref name="ray-marceca"/> for which Craig Livingstone, director of the [[White House]]'s Office of Personnel Security,<ref name="time062496">Eric Pooley, [https://web.archive.org/web/20090417233009/http://www.time.com/time/magazine/article/0,9171,984729,00.html "Man Behind the Mess"], ''[[Time (magazine)|Time]]'', June 24, 1996. Accessed June 5, 2007.</ref> had improperly requested and received background reports from the FBI in 1993 and 1994, without asking permission of the subject individuals.<ref name="wapoww">[https://www.washingtonpost.com/wp-srv/politics/special/whitewater/whitewater.htm "Untangling Whitewater"], ''[[The Washington Post]]'' special report, 2000. Accessed June 5, 2007.</ref>
Estimates ranged from 400 to 700 to 900 unauthorized file disclosures.<ref name="wapo091905">Christopher Lee, [https://www.washingtonpost.com/wp-dyn/content/article/2005/09/18/AR2005091801019.html "Flops Are No Fluke in the Annals of Political Payback"], ''[[The Washington Post]]'', September 19, 2005. Accessed June 7, 2007.</ref><ref name="cnn1997">[http://www.cnn.com/ALLPOLITICS/1997/gen/resources/fbi.files "FBI Files Fiasco"], [[CNN]], 1997. Accessed June 5, 2007.</ref><ref name="cnn072596">[http://www.cnn.com/ALLPOLITICS/1996/news/9607/25/livingstone.hrc/index.shtml "Documents Suggest Hillary Knew Craig Livingstone"], [[CNN]], July 25, 1997. Accessed June 5, 2007.</ref><ref name="cnn072800">[http://archives.cnn.com/2000/ALLPOLITICS/stories/07/28/clinton.filegate/ "Independent counsel: No evidence to warrant prosecution against first lady in 'filegate'"] {{webarchive|url=https://web.archive.org/web/20100529015957/http://archives.cnn.com/2000/ALLPOLITICS/stories/07/28/clinton.filegate/ |date=2010-05-29 }}, [[CNN]], June 3, 2000. Accessed June 5, 2007.</ref> The incident caused an intense burst of criticism because many of the files covered White House employees from previous [[Republican Party (United States)|Republican]] administrations, including top figures such as [[James Baker]], [[Brent Scowcroft]], and [[Marlin Fitzwater]].<ref name="cnn1997"/>

Initial White House explanations for what had happened varied,<ref name="gro-interim">[https://fas.org/irp/congress/1996_rpt/fbirep.htm "Investigation Into the White House and Department of Justice on Security of FBI Background Investigation Files – Interim Report"], [[United States House Committee on Government Reform and Oversight]], September 24, 1996.</ref> but generally characterized it as a series of mistakes made without bad intent and offered apologies to those affected.<ref name="nyt061096"/><ref name="nyt061196"/>  President Clinton said that, "It appears to have been a completely honest bureaucratic snafu."<ref name="nyt061096">Brian Knowlton, [https://www.nytimes.com/1996/06/10/news/10iht-fbi.t_0.html "White House Apologizes For Collecting FBI Reports: But Dole Cries Foul, And Republicans Call for Hearings"], ''[[The New York Times]]'', June 10, 1996. Accessed June 12, 2011.</ref> However, his Republican opponent in the ongoing [[1996 United States presidential election|1996 presidential election]], Senator [[Bob Dole]], compared it to [[Nixon's Enemies List|the enemies list]] kept by the [[Nixon administration]].<ref name="nyt061096"/>  Republicans made other charges, including that the White House was trying to dig up damaging information about Republicans in general<ref name="nyt061196"/> and that the file transfer was motivated by a desire to slander Dale and other White House Travel Office officials in order to justify their dismissal.<ref name="encyclo-ic">Gerald S. Greenberg, ''Historical Encyclopedia of U.S. Independent Counsel Investigations'', [[Greenwood Press]], 2000. {{ISBN|0-313-30735-0}}. pp 124-125.</ref>

On June 18, 1996, Attorney General [[Janet Reno]] asked the FBI to look into it;<ref name="encyclo-ic"/> FBI Director [[Louis Freeh]] acknowledged that both the FBI and especially the White House had committed "egregious violations of privacy"<ref name="time062496"/><ref name="encyclo-ic"/> (in some cases the background reports contained information about extramarital affairs, trangressions with the law, and medical issues).<ref name="nyt011598">[[David Stout]], [https://query.nytimes.com/gst/fullpage.html?res=9F05E1DB1E39F936A25752C0A96E958260 "Starr Questions Hillary Clinton on F.B.I. Files"], ''[[The New York Times]]'', January 15, 1998. Accessed June 16, 2007.</ref> On June 21 Reno decided it was a conflict of interest for the [[U.S. Department of Justice]] to further investigate the matter, and thus recommended that it be folded into the overall umbrella of [[Whitewater (controversy)|the Whitewater investigations]], under charge of Independent Counsel [[Kenneth Starr]].<ref name="ray-marceca"/><ref name="cnn072596"/> In any case, Starr had already begun looking into it.<ref name="nyt061196">Neil A. Lewis, [https://www.nytimes.com/1996/06/11/us/whitewater-counsel-examining-use-of-fbi-to-get-gop-files.html "Whitewater Counsel Examining Use of F.B.I. to Get G.O.P. Files"], ''[[The New York Times]]'', June 11, 1996. Accessed June 12, 2011.</ref>

[[File:BillClinger.jpg|thumb|upright|Republican Congressman [[Bill Clinger]]'s [[United States House Committee on Oversight and Government Reform|House Government Reform and Oversight Committee]] discovered Filegate in 1996 and held hearings on it.]]
On June 26, 1996, Clinger's Government Reform and Oversight Committee held hearings on the matter.<ref name="wapo062796">George Lardner Jr., Susan Schmidt, [https://www.washingtonpost.com/wp-srv/politics/special/whitewater/stories/wwtr960627.htm "Livingstone Resigns, Denying Ill Intent"], ''[[The Washington Post]]'', June 27, 1996. Accessed June 7, 2007.</ref>  Livingstone, who announced his resignation at the start of his testimony that day, and his assistant, Anthony Marceca, insisted during the committee's hearings that the mishandled files were a result of a bureaucratic mixup and that no improper motivations were behind it.<ref name="wapo062796"/>  They said that when the George H. W. Bush administrative staff left the White House in January 1993, they had taken all the files of the Office of Personnel Security with them for use in the Bush Library, as they were permitted to do under law.  The OPS staff were trying to rebuild these records to include those of permanent White House employees who remained to work in the Clinton administration; Marceca, a civilian investigator for the [[United States Army|Army]], had been hired for this task.<ref name="time062496"/> In doing so, they received an outdated list from the Secret Service of White House employees, which included many names who were no longer employees. This list was then given to the FBI and the personnel background files returned as a result.<ref name="wapo062796"/>  Lisa Wetzl, another assistant, testified that she discovered the mistake in mid-1994 and destroyed the request list.<ref name="wapo062796"/>

Also called to testify were former [[White House counsel]] [[Bernard Nussbaum]] and former associate counsel [[William H. Kennedy III]].<ref name="wapo062796"/>  Livingstone, Nussbaum, and Kennedy all offered apologies to those whose files had been obtained.<ref name="encyclo-ic"/> On September 24, 1996, the Government Reform and Oversight Committee approved, on party lines, an interim report on the affair, blasting the Clinton Administration for a "cavalier approach" towards sensitive security procedures and saying that further investigation was necessary to determine if the events surrounding the files handling were "a blunder, the result of colossal incompetence, or whether they are established to be more serious or even criminal."<ref name="gro-interim"/><ref name="wapo092596">George Lardner Jr., [https://www.washingtonpost.com/wp-srv/politics/special/whitewater/stories/wwtr960825.htm "GOP Slams White House in FBI Files Report"], ''[[The Washington Post]]'', September 25, 1996. Accessed June 9, 2007.</ref>  The Committee does not seem to have ever issued a final report.<ref name="gpo-list">[http://www.gpoaccess.gov/congress/house/govreform/index.html "House Committee on Oversight and Government Reform: Main Page"] {{webarchive|url=https://web.archive.org/web/20070521023750/http://www.gpoaccess.gov/congress/house/govreform/index.html |date=2007-05-21 }}, [[United States Government Printing Office]]. Accessed June 9, 2007. A search of reports, prints, etc. turns up nothing further related to the Security of FBI Background Files matter.</ref>

The [[Senate Judiciary Committee]] was also involved in investigating the matter, holding hearings beginning June 29, 1996,<ref name="nyt062996">Francis X. Clines, [https://query.nytimes.com/gst/fullpage.html?res=9A00EED61239F93AA15755C0A960958260 " Key Witness Asserts His Right to Silence In Inquiry on Files"], ''[[The New York Times]]'', June 29, 1996. Accessed April 6, 2008.</ref> and focussing on allegations that White House was engaged in a "dirty tricks" operation reminiscent of the [[Nixon administration]].<ref name="nyt062996"/> Looking into accusations that senior White House officials or the First Lady may have inappropriately perused the files, in October 1996, Republican committee chair [[Orrin Hatch]] requested that the FBI do a [[fingerprint analysis]] of them.<ref name="nyt110396">David Johnston, [https://query.nytimes.com/gst/fullpage.html?res=9803EEDC1738F930A35752C1A960958260 " Tests Find No Proof First Lady or Top Aides Touched F.B.I. Files"], ''[[The New York Times]]'', November 3, 1996. Accessed July 15, 2007.</ref>  On November 3, 1996, the FBI informed the committee that no fingerprints of either the First Lady or any other named senior official were on the files.<ref name="nyt110396"/>

==Who hired Livingstone issue==
[[File:Hrcgarden.jpg|thumb|First Lady [[Hillary Rodham Clinton]] came under examination regarding whether she had had any role in hiring for the White House's Office of Personnel Security (photo taken at the [[Jacqueline Kennedy Garden]]).]]

A secondary question of the Filegate controversy revolved around what the Office of Personnel Security was, who had authorized the hiring of Livingstone, and whether he was qualified for the job.  The Office was not responsible for actual White House security, as that was the charge of the [[United States Secret Service]],<ref name="time062496"/> nor did it perform background checks on potential White House employees, a task done by the FBI,<ref name="pbs062696">[[The NewsHour with Jim Lehrer|Online News Hour]], [https://www.pbs.org/newshour/bb/white_house/june96/files_hearings_6-26.html "FBI files hearing heats up"] {{Webarchive|url=https://web.archive.org/web/20140121014620/http://www.pbs.org/newshour/bb/white_house/june96/files_hearings_6-26.html |date=2014-01-21 }}, [[Public Broadcasting Service|PBS]], June 26, 1996. Accessed June 7, 2007.</ref> nor did it keep the regular personnel files of employees, which were held in a different office within the White House.<ref name="gro-interim"/> Rather, its role was to keep track of who was employed by the White House, make sure their security clearances were up to date, and give security briefings to new hires.<ref name="lh">[[Hillary Rodham Clinton]], ''[[Living History (book)|Living History]]'', [[Simon & Schuster]], 2003, {{ISBN|0-7432-2224-5}}, pp. 371–372.</ref>  

Nevertheless, Livingstone seemed to lack qualifications for even this position; he had worked on a number of [[Democratic Party (United States)|Democratic Party]] campaigns and transitions,<ref name="pbs062696"/> including being an advance man for the Clinton-Gore 1992 campaign,<ref name="time062496"/> and his only prior job in the "security" field was that of a local [[bar (establishment)|bar]] [[bouncer (doorman)|bouncer]]<ref name="wapo091905"/> at a [[Washington, D.C.]], [[night club]]. (At the congressional hearings, Livingstone objected to "false and unfair caricatures of who I am. [...] I have worked hard for little or no pay in political campaigns for candidates who I felt would make this country a better place to live."<ref name="pbs062696"/>) Initially, White House officials could not explain why Livingstone was hired, nor who had hired him.<ref name="wapo062796"/> After a week of uncertainty, Clinton aide [[George Stephanopoulos]] told [[ABC News (United States)|ABC News]] that White House deputy counsel [[Vince Foster]] had initially hired Livingstone on a temporary basis, and that after Foster's death, associate counsel Kennedy had taken Livingstone on.<ref>[https://www.latimes.com/archives/la-xpm-1996-07-01-mn-20259-story.html "Vincent Foster Hired Livingstone, Stephanopoulos Says"], ''[[Los Angeles Times]]'', July 1, 1996. Accessed October 9, 2021.</ref>

An FBI document suggested that Livingstone had been given his position because First Lady Hillary Rodham Clinton was a friend of Livingstone's mother and recommended him.  Hillary Clinton stated that while she was once photographed with the mother in a large group, she did not know her.<ref name="lh"/> Hillary Clinton was briefly deposed at the White House by the Independent Counsel regarding this matter on January 14, 1998.<ref name="nyt011598"/><ref name="gormley">[[Ken Gormley (academic)|Ken Gormley]], ''The Death of American Virtue: Clinton vs. Starr'', [[Crown Publishers]] (New York), 2010. {{ISBN|978-0-307-40944-7}}. pp. 324–325, 658.</ref>  (That same day, the same [[United States Office of the Independent Counsel|Office of the Independent Counsel]] staff were listening to taped conversations of [[Linda Tripp]] and [[Monica Lewinsky]]; the [[Lewinsky scandal]] was soon to break.<ref name="gormley"/>)  In 1999, Clinton gave a sworn statement that she had nothing to do with Livingstone's hiring.<ref name="cnn072800"/> Livingstone also stated under oath there was no truth to the supposed hiring relationship.<ref name="cnn072800"/> Hillary Clinton would later refer to the whole files matter as a "pseudoscandal".<ref name="lh"/>

==Official findings==
[[File:Kenneth W. Starr.jpg|thumb|upright|Independent Counsel [[Kenneth Starr]] exonerated both the President and the First Lady with respect to the FBI files matter in 1998.]]

On November 19, 1998, Independent Counsel Starr testified before the [[House Judiciary Committee]] in connection with the [[Impeachment of Bill Clinton]] over charges related to the Lewinsky scandal.  Here, for the first time, Starr exonerated both President Clinton and the First Lady of complicity in the FBI files matter, saying "while there are outstanding issues that we are attempting to resolve with respect to one individual [we] found no evidence that anyone higher [than Livingstone or Marceca] was in any way involved in ordering the files from the FBI. Second, we have found no evidence that information contained in the files of former officials was used for an improper purpose."<ref name="wapo111998">Ruth Marcus, Peter Baker, [https://www.washingtonpost.com/wp-srv/politics/special/clinton/stories/impeach111998.htm "Clinton 'Thwarted' Probe, Starr to Say"], ''[[The Washington Post]]'', November 19, 1998. Accessed June 12, 2007.</ref>  (Starr also chose this occasion to clear President Clinton in the Travelgate matter, and to say that he had not committed impeachable wrongdoing in the Whitewater matter; Democrats on the committee immediately criticized Starr for withholding all these findings until after the [[United States House elections, 1998|1998 Congressional elections]].<ref name="nyt112098">[[Don Van Natta, Jr.]], [https://query.nytimes.com/gst/fullpage.html?res=980DE7DB1230F933A15752C1A96E958260 "Democrats Challenge Starr on Delayed Exoneration"], ''[[The New York Times]]'', November 20, 1998. Accessed June 12, 2007.</ref>)

In March 2000, Independent Counsel [[Robert Ray (prosecutor)|Robert Ray]], Starr's successor, issued the office's final report on the matter, as part of a concerted effort to wrap up all Whitewater-related cases before the end of Bill Clinton's term.<ref name="gormley"/>    Ray determined that there was no credible evidence of any criminal activity by any individual in the matter.<ref name="nyt031700">Neil A. Lewis, [https://query.nytimes.com/gst/fullpage.html?res=9806EED8173AF934A25750C0A9669C8B63 "Report Clears White House In Inquiry Over F.B.I. Files"], ''[[The New York Times]]'', March 17, 2000. Accessed June 9, 2007.</ref>  It attributed the improper collection of the files by Marceca due to his having an outdated Secret Service list of White House passes, as Marceca had originally claimed.<ref name="nyt031700"/> It stated that even though Marceca's statements were sometimes "contradictory and misleading",<ref name="ray-marceca"/> they were "sufficiently transparent"<ref name="ray-marceca"/> and there was insufficient evidence to prove that Anthony Marceca had made false statements to Congress during his testimony.<ref name="cnn072800"/>  The report ascribed the FBI files matter to "a failure of process at many levels," saying that the Secret Service had provided critically erroneous data,<ref name="ray-marceca"/> and that this was compounded by the White House's informal process of requesting sensitive information by "inexperienced, untrained, and unsupervised personnel with backgrounds as political operatives."<ref name="ray-marceca"/>

Based on an investigation that included the prior fingerprint analysis,<ref name="nyt031700"/> the report further stated that:

{{Quote|text=there was no substantial and credible evidence that any senior White House official, or First Lady Hillary Rodham Clinton, was involved in seeking confidential Federal Bureau of Investigation background reports of former White House staff from prior administrations of President Bush and President Reagan.|sign=Independent Counsel Robert Ray|source=<ref name="cnn072800"/>}}

Ray's report also concluded that there was no credible evidence that Bernard Nussbaum testified falsely about not having discussed Livingstone's hiring with the First Lady, and found as well that there was no personal relationship between the First Lady and Livingstone that had formed the basis for his hiring.<ref name="cnn072800"/>

==Judicial Watch lawsuit==
[[File:Royce Lamberth Official Photo 2009.jpg|thumb|left|upright|140px|For over a decade, Federal Judge [[Royce C. Lamberth]] presided over a civil lawsuit emanating from the Filegate matter.]]

Separately from the Independent Counsel investigation, [[Judicial Watch]], a conservative watchdog group, engaged in long-running litigation over the White House personnel file controversy.<ref name="jw-filegate">[http://www.judicialwatch.org/alexander-et-al-v-fbi-et-al "Alexander, et al. v. FBI, et al."], [[Judicial Watch]]. Accessed June 8, 2011.</ref>  It was initially filed in September 1996 and sought $90&nbsp;million in damages.<ref name="lat-jw">[https://www.latimes.com/archives/la-xpm-1996-09-14-mn-43735-story.html "Ex-White House Employees Sue Hillary Clinton, FBI Over Files"], [[Associated Press]], ''[[Los Angeles Times]]'', September 14, 1996. Accessed September 7, 2019.</ref>  Judicial Watch's ''Cara Leslie Alexander et al. vs. Federal Bureau of Investigation et al.'' [[class action]] lawsuit, filed on behalf of five low-level former members<ref name="lat-jw"/> of the Reagan and George H. W. Bush Administrations,<ref name="jw-alexander">[https://web.archive.org/web/20100830122659/http://www.judicialwatch.org/alexander.shtml "Alexander et al. v. FBI, et al."], [[Judicial Watch]]. Accessed June 9, 2007. Archived August 30, 2010 and accessed there June 12, 2011.</ref> alleged that Livingstone, along with Anthony Marceca and William Kennedy, obtained the files and then rifled through them. Judicial Watch in particular alleged that Kennedy had abused the FBI background report process.<ref>James Freeman, [https://www.forbes.com/2000/11/07/1107freeman.html "Technology Heralds End Of Clinton Era"], ''[[Forbes (magazine)|Forbes]]'', November 7, 2000. Accessed July 2, 2022.</ref> Judicial Watch founder and Clintons antagonist suprême<ref>[https://www.washingtonpost.com/wp-srv/politics/special/clinton/players/klayman.htm "Key Player: Larry Klayman"], ''[[The Washington Post]]'', October 2, 1998. Accessed January 30, 2010.</ref> [[Larry Klayman]] attracted enough attention with the case to have the recurring [[List of characters in The West Wing|Larry Claypool character]] modeled after him on the television series ''[[The West Wing]]''.<ref name="pol030910"/>  As late as January 2000, Judicial Watch was filing affidavits in the [[United States District Court for the District of Columbia]] under Judge [[Royce C. Lamberth]] related to the case.<ref name="novak">[[Robert Novak]], "Clintons Still Haunted by FBI Files Scandal", ''[[Chicago Sun-Times]]'', January 20, 2000. Accessed June 5, 2007.</ref>  In December 2002 Judicial Watch obtained a ruling from Judge Lamberth that recently uncovered White House [[e-mail]]s be searched for possible evidence in the lawsuit.<ref name="jw-email">[https://web.archive.org/web/20100228215832/http://www.judicialwatch.org/emailsearch.shtml "Clinton-Gore White House E-mail Ordered Searched by Federal Judge"], [[Judicial Watch]], December 16, 2002. Accessed June 9, 2007. Archived August 30, 2010 and accessed there June 12, 2011.</ref>  Klayman said, "Hillary Clinton was the mastermind of Filegate. She will not escape justice."<ref name="jw-email"/>  Klayman and Judicial Watch had a severe falling out in 2003,<ref name="klayman">[http://www.savingjudicialwatch.org/ "Saving Judicial Watch" home page]. Accessed June 9, 2007.</ref> however, and several years went by with little or nothing happening in the lawsuit.<ref name="jw-alexander"/><ref name="leg030910"/>  

On March 9, 2010, Judge Lamberth dismissed the case.<ref name="wapo030910">Al Kamen, [https://web.archive.org/web/20120924135539/http://voices.washingtonpost.com/44/2010/03/clinton-era-filegate-case-toss.html "Clinton-era 'Filegate' case tossed out"], ''[[The Washington Post]]'', March 9, 2010. Accessed March 9, 2010.</ref>  The judge asserted that the plaintiffs, despite years of opportunity, had failed to provide any evidence that the affair was a grand conspiracy rather than a bureaucratic mistake, and said that "this court is left to conclude that with the lawsuit, to quote Gertrude Stein, 'there's no there there.{{'"}}<ref name="wapo030910"/>  Nussbaum, one of the defendants, derisively said "No kidding" when informed of the dismissal.<ref name="leg030910">Jordan Weissman, [http://legaltimes.typepad.com/blt/2010/03/filegate-suits-against-clinton-white-house-finally-dismissed.html "Filegate Suits Against Clinton White House Finally Dismissed"], ''[[Legal Times]]'', March 9, 2010. Accessed March 13, 2010.</ref>  Media reports concluded that, fourteen years after the initial events were set in motion, Filegate was finally over.<ref name="pol030910">Josh Gerstein, [https://web.archive.org/web/20100312082117/http://www.politico.com/blogs/joshgerstein/0310/Judge_kills_off_filegate_suits_14_years_on.html "Judge kills off Filegate suits, 14 years on"], ''[[Politico]]'', March 9, 2010. Accessed March 13, 2010.</ref><ref name="leg030910"/><ref name="wapo030910"/> In May 2010, Judicial Watch filed an appeal of the dismissal with the [[United States Court of Appeals for the District of Columbia Circuit]],<ref>[http://www.judicialwatch.org/files/documents/2010/alexander-v-fbi-noticeofappeal-05072010.pdf "''Alexander v. FBI'' Notice of Appeal"], [[Judicial Watch]], May 7, 2010. Accessed June 8, 2011.</ref> but the Court of Appeals affirmed the dismissal on November 14, 2011,<ref>[https://web.archive.org/web/20160701223003/https://casetext.com/case/alexander-v-federal-bureau-of-inve "Alexander v. Federal Bureau of Investigation, 10-5140 (D.C. CIR. 11-14-2011)"], Casetext. November 14, 2011.  Accessed May 31, 2016.</ref> thereby bringing the case to an end.
{{-}}

==References==
{{Reflist|30em}}

==External links==
{{Portal|United States|Politics|1990s}}
* [https://fas.org/irp/congress/1996_rpt/fbirep.htm Investigation Into the White House and Department of Justice on Security of FBI Background Investigation Files – Interim Report – ... by the Committee on Government Reform and Oversight September 1996]
* [https://web.archive.org/web/20091103174455/http://icreport.access.gpo.gov/marceca.html Final Report of the Independent Counsel ... of the Investigation In Re: Anthony Marceca March 2000]
* [https://web.archive.org/web/20091103175026/http://icreport.access.gpo.gov/nussbaum.html Final Report of the Independent Counsel ... of the Investigation In Re: Bernard Nussbaum March 2000]
* [http://legaltimes.typepad.com/files/lamberth_decision_filegate.pdf  ''Cara Leslie Alexander et al. v. Federal Bureau of Investigation et al.'' March 2010 ruling by the United States District Court for the District of Columbia]

[[Category:1996 in American politics]]
[[Category:Clinton administration controversies]]
[[Category:Presidential scandals in the United States]]
[[Category:Hillary Clinton controversies]]
[[Category:1996 scandals]]
[[Category:1996 controversies in the United States]]
[[Category:Hillary Clinton's tenure as First Lady of the United States]]