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AmeriCorps Inspector General Walpin Fired -- Some Preliminary Observations:

So President Obama has given notice that he's firing Gerald Walpin, the Inspector General of the Corporation for National and Community Service, which operates "AmeriCorps." Walpin, in the midst of a "noisy departure" from his post, alleges that he was fired for sniffing out wrongdoing of a politically connected former NBA player who has gone on to become mayor of Sacramento. The acting U.S. Attorney for the Eastern District of California, meanwhile, reportedly found that Walpin's conclusions seemed overstated and did not accurately reflect all the information gathered in the investigation. He reportedly has referred Walpin to the President's Counsel on Integrity and Efficiency (PCIE), a body established by executive orders 12301 and 12805 to handle investigations into the conduct of Inspectors General themselves.

Norm Eisen, Special Counsel to the President for Ethics and Government Reform, reportedly told Walpin last Wednesday that it was "time to move on" and he would be fired if he didn't resign. When Walpin refused to resign, the President fired him, presumably effective 30 days hence. The Inspector General Reform Act of 2008 provides that ''[i]f an Inspector General is removed from office or is transferred to another position or location within an establishment, the President shall communicate in writing the reasons for any such removal or transfer to both Houses of Congress, not later than 30 days before the removal or transfer." (Before the 2008 amendment, the IG Act of 1978 merely required notice of the reasons, not advance notice.)

In his letter to Speaker Pelosi and President of the Senate Joe Biden sent last Thursday, President Obama stated that "[i]t is vital that I have the fullest confidence in the appointees serving as inspectors general." The letter continued, "[t]hat is longer the case with regard to this inspector general." (I have not yet been able to find a PDF of the letter.) After Senator Grassley fired off a letter demanding information, Counsel to the President Gregory Craig responded that "We are aware of the circumstances leading to that [PCIE] referral and of Mr. Walpin's conduct throughout his tenure and can assure you that the president's decision was carefully considered."

The allegations of a politically motivated firing are getting all the attention, but being a Law Nerd, I wanted to focus briefly on, well, some of the nerdier aspects of the imbroglio. Some commentators have pointed to the bare statement of reasons in President Obama's letter as (1) an indication that he is hiding something, as though he could not give good reasons for the firing; and (2) questioned whether that spare statement of reasons complied with the terms of the Inspector General Reform Act of 2008, which Senator Obama cosponsored.

I suspect that a significant reason the President was very spare in his letter was to avoid setting the precedent of giving Congress detail about firing decisions. They may not admit it, but Presidents, Democratic and Republican, seek to safeguard the prerogatives of the office. They do not want Congress to expect detailed reasons for firing an IG, even if they have them. (Of course, it sometimes is advantageous as a practical matter to "keep your powder dry" so you don't have to walk back from previously proffered statements of reasons.)

Whether stating the IG lacks the President's confidence is a sufficient statement of the "reasons" for the firing is an interesting question. The Executive Branch undoubtedly construes the requirement narrowly to give the President maximum freedom of action, and so would not read the statute to require specificity in the absence of an explicit textual requirement. It would say that even a stripper statement of "reasons" such as apparently provided here gives some degree of confidence that the firing meets whatever minimal constitutional standards that govern such a decision and wasn't for a prohibited reason (race, sex, etc.). At the same time, the President's letter does not state the reasons he lacked confidence in Walpin. And saying only that the President doesn't have confidence in the official is almost tautological, because presumably the President has confidence in those officials he retains.

Related Posts (on one page):

  1. UPDATE -- The White House Provides Further Detail On Walpin Firing And Confirms Interpretation Of IG Act:
  2. AmeriCorps Inspector General Walpin Fired -- Some Preliminary Observations:
G Hamid (mail) (www):
So Obama's reason is "I felt like firing him". Lovely.
6.16.2009 12:30pm
Barbra:
I don't know any precedents re these things, (maybe there is not one because the law is so recent) but isn't it often the case that employers are intentionally vaugue about dismissal decisions? So, maybe they are copying that practice?
6.16.2009 12:31pm
Bob from Ohio (mail):
Statute says "reason", it does not say "good reason" or "cause". Lack of confidence is a rason.

Lack of confidence is also a "good reason".

It would be my view that the Inspector General Reform Act of 2008 is unconstitutional in the same way the Tenure in Office Act was in circa 1866.
6.16.2009 12:33pm
Mike& (mail):
Statute says "reason", it does not say "good reason" or "cause". Lack of confidence is a rason.

Is that what the case law says? If so, what are those cases? I'd like to read them.
6.16.2009 12:49pm
Cato The Elder (mail):
I'm not sure I understand this reasoning. Why would candidates for President, upon assumption of that office, necessarily be invaded with the urge to preserve its powers? Are you alluding to some sort of collective "mind" that is often found in large bureaucratic organizations? I mean, supposing Obama wanted to give up power, why would he suddenly change his mind after inauguration, are there some vital state secrets to protect or is it that perhaps every president comes to some weighty realization of the importance of their status as head of the Executive Branch?
6.16.2009 12:52pm
Kent Scheidegger (mail) (www):
FWIW, I have known acting US Atty Larry Brown for many years, and he is definitely not an Obama stooge. If he complained, then there is almost certainly something other than politics involved here.
6.16.2009 12:54pm
DangerMouse:
President HopenChange strikes again.
6.16.2009 12:56pm
Bob from Ohio (mail):

Is that what the case law says?


2008 act probably does not have any cases.

Maybe the 1978 act does but I was making a comment on the plain language.
6.16.2009 12:59pm
htom (mail):
Presumably, he thinks that the good reason is that "I won."
6.16.2009 1:04pm
donaldk2 (mail):
You can take the boy out of Chicago, but you can't take Chicago out of the boy.
6.16.2009 1:04pm
Melancton Smith:
Woops, you can't use that pronoun when referring to a member of that demographic.
6.16.2009 1:12pm
Steve:
Here are pdfs of Obama's letter to Pelosi and Greg Craig's letter to Sen. Grassley.

For additional information, here are the Acting US Attorney's letter of complaint about the IG and the IG's written response.

When I first read Craig's letter, the subtext that jumped out at me was "I don't want to put the reasons in writing, but call me and I'd be happy to chat." That could be total speculation on my part.

My view is that Obama's statement of the reason for the firing is inconsistent with the spirit of the law, but I can't really envision a court saying "sorry, that reason isn't detailed enough, you have to give the REAL reason." That said, I think Obama ought to supply Congress with a more descriptive reason, whether or not a court would require him to.

The IGs serve a special function in our system of government, and it's entirely appropriate for Congress to exercise a level of oversight due to the potential for political mischief. As a visceral matter, the number of actors independent of the White House who seem to agree that there was a problem with this IG leads me to believe that the firing was OK, but certainly if Bush had fired an IG who was looking into one of his political allies, I would have wanted Congress to have the ability to investigate. So too with Obama.
6.16.2009 1:18pm
Soronel Haetir (mail):
Cato,

I would figure the argument would come down to the sorts of people who seek high office. IE, the sorts of people who want the job are the most suseptible to the lure of power.
6.16.2009 1:18pm
rick.felt:
My view is that Obama's statement of the reason for the firing is inconsistent with the spirit of the law, but I can't really envision a court saying "sorry, that reason isn't detailed enough, you have to give the REAL reason." That said, I think Obama ought to supply Congress with a more descriptive reason, whether or not a court would require him to.

I think the law has accomplished its purpose. It has forced the president to make an attempt at explaining his reasoning to Congress. Obama has implicitly indicated to the other political branch that he has no good reason for this firing that he wants to share. Could there be an innocent explanation? Of course. But the accountability ball was in Obama's court, and he whiffed on it. Without the law, we wouldn't have even that, and that's enough for me.
6.16.2009 1:24pm
Hans Bader:
The firing is an effort to cover up waste of government funds and federal stimulus money, which is newsworthy regardless of whether the firing itself was legal.

Nixon acted legally in getting subordinates to fire the Watergate special prosecutors, but it still helped bring down his Presidency.

Obama is firing an inspector general who exposed wrongdoing by one of his supporters, and previously uncovered millions of dollars in waste and fraud in the troubled AmeriCorps program, whose budget is being dramatically increased by the Obama Administration.

Inspector General Gerald Walpin was fired after he uncovered misuse of federal "stimulus money," and insisted on not keeping mum about a sham settlement that allowed the misuse to go largely unremedied.

(The recently-passed stimulus package repealed welfare reform, and it subsidizes waste and corruption. Meanwhile, the Obama Administration's $787 billion stimulus package is actually killing jobs and shrinking the economy).

Walpin is the Inspector General for the Americorps program, which is riddled with waste, fraud, and ideological misuse of taxpayer funds. Walpin "has been doing a good job" and he has "identified millions of dollars in AmeriCorps funds that were wasted or misspent," notes Senator Grassley.

But when Walpin recently exposed wrongdoing by a prominent Obama supporter, Kevin Johnson, Obama moved to fire Walpin. Walpin protested the Administration's failure to hold Johnson, a liberal mayor, accountable for using taxpayer money to pay for "political activities" and pay volunteers to run "personal errands for" Johnson "and even wash his car."

Walpin notes that although he uncovered massive wrongdoing by Johnson, it has led only to a sham settlement: $350,000 that is supposed to be paid back to the taxpayers never will be, since the entity that Johnson used to receive taxpayer money and spend it on himself now "is insolvent," and its "settlement agreement was carefully drafted so that no obligation is imposed on" Johnson for that money, only the defunct entity he controlled. That's so even though it was Johnson who used Americorps money to pay volunteers to "wash his car" and run "personal errands" for him.
6.16.2009 1:27pm
Bpbatista (mail):

Obama lost confidence in Walpin just like Nixon lost confidence in Archibald Cox. So what's the big deal? ;-)
6.16.2009 1:30pm
Cato The Elder (mail):
Is there another side to this story, a defense or article somewhere?
6.16.2009 1:35pm
PersonFromPorlock:

President Obama stated that "[i]t is vital that I have the fullest confidence in the appointees serving as inspectors general." The letter continued, "[t]hat is longer the case with regard to this inspector general."

So, if it's "vital" that the president "have the fullest confidence" in the IG and he doesn't, doesn't the mere bald assertion of that lack argue as much for the removal of the President as for the removal of the IG?
6.16.2009 1:59pm
Blue:
Cato, the classic response to your initial question was given by Graham Allison--Where you sit is where you stand.
6.16.2009 2:44pm
Paul A'Barge (mail):
Congratulations. You just wrote 6 paragraphs and said pretty much nothing.
6.16.2009 2:49pm
Richard Souther:
The reasons provided by President Obama seems to gut the substance of the statute and reduces Inspector Generals to the level of all other political appointees, i.e. serving at the pleasure of the President.
6.16.2009 2:53pm
Hans Bader:
When I said "uncovered misuse of federal 'stimulus money,'" above, I should have said "uncovered misuse of federal AmeriCorps money."

The Administration prevented the Inspector General from ensuring that the Obama supporter who engaged in wrongdoing would not be able to misuse federal stimulus funds in the FUTURE.

But the PAST misuse of federal funds by the Obama supporter uncovered by the IG was AmeriCorps money, not stimulus money.
6.16.2009 3:23pm
CFG in IL (mail):
There is a nice rundown on this over at TPM.
6.16.2009 3:27pm
capitano:
I.G. Walpin's report reveals the reasons behind his firing. The Corporation for National and Community Service requested that Walpin look into news reports that Kevin Johnson's charity was misusing $800K in federal grant money. Walpin's investigators uncovered violations of the use of the funds and of the accounting procedures required by the grant documents. Furthermore, Johnson's attorney refused to allow Johnson to be interviewed by the investigators or by Walpin himself.

Logs and financial records required by the grant documents were incomplete or non-existent, plus there were clear violations of the scope of the work for which the grant money was used. Walpin had no choice but to report it and recommend sanctions. As part of the debarment order recommended by Walpin but issued by the Corporation's General Counsel, Kevin Johnson was barred from receiving any future federal funds.

Despite opportunities to provide any contrary evidence, Johnson essentially blew off the whole investigation and findings...until he was elected Mayor of Sacramento and the Federal Stimulus bill became law. The City of Sacramento hired outside counsel, who advised that the new Mayor's debarment order might disqualify Sacramento from receiving millions in stimulus money. Suddenly, the Mayor was too big to fail and accommodations were made by the acting U.S. Attorney.

And Walpin? When he refused to go along with the sham settlement without any consequences for Johnson, he was shut out and eventually fired -- his investigation was an inconvenient truth for a staunch Obama supporter.

Read the whole report.
6.16.2009 3:48pm
Uninterested Observer (mail):
It seems to me (again, without any case law on this 2008 act), that Obama's original letter re: confidence, was probably insufficient at providing a reason for the termination. Craig's follow-up letter, though, seems to implicitly incorporate by reference the facts included in the US Attorney's referral of the matter. To me (whatever that is worth), that satisfies the law.
As for whether it is pretextual, the story reported by Jake Tapper makes Walpin seem pretty out of control.
http://blogs.abcnews.com/politicalpunch/2009/06/ more-details-emerge-in-president-obamas- firing-of-inspector-general.html
My favorite is that Walpin (apparently) "didn't even audit" St. HOPE to determine whether/how much federal funds were misused and also deliberatley withheld important information, such as a sworn affidavit from an elementary school principal rebutting Walpin's claim that St. HOPE took money for tutoring elementary school students without ever tutoring.
Incidentally, does the 2008 Act provide any remedy/options if Congress disagrees witht he reasons for the firing? Other than giving reasons for firing an IG, is there limitations on what constitutes sufficient reasons?
6.16.2009 4:01pm
rarango (mail):
Blue--great reference to Graham Allison (what is he doing t these days?)--but isnt it the quote "where you stand depends on where you sit?"
6.16.2009 4:12pm
rarango (mail):
Obama has Monica Goodling working on his staff? Thank gaia this was just an IG and not a US Attorney! Now THAT would be a scandal.
6.16.2009 4:16pm
JM Hanes:
How does confirming the obvious in writing constitute "reasons" for firing Walpin? Even Craig's assertion that this was a "carefully considered" decision is essentially the same thing as saying "The President has his reasons"-- which were clearly not laid out in his letter to Congress.

Coming at it from a different direction, if the President has any (as yet unspecified) reasons for firing Walpin which he has failed to communicate in writing to Congress, is he not then in breach of the statute? Where the President is not required to submit "a reason," but rather "his reasons," how is the intent of the plural not plain?
6.16.2009 4:34pm
MartyA:
This is, indeed, strange. Obama's timing is terrible. Just today, Obama proposed some other power grab but guaranteed that it's "Czar" would be independent from the political system Who is dumb enough to put faith in such a hollow promise?
6.16.2009 5:51pm
RPT (mail):
At least Alice Martin is resigning.
6.16.2009 6:29pm
Eric Rasmusen (mail) (www):
Commentor Steve wrote: Here are pdfs of Obama's letter to Pelosi and Greg Craig's letter to Sen. Grassley.

For additional information, here are the Acting US Attorney's letter of complaint about the IG and the IG's written response.

Thank you, Steve! These 4 documents (you
need all of them) go to the heart of the matter.

(1) Has Obama satisfied the statutory requirement? The point of
such a statute is to force the President to come out and give a
reason for the firing so that reason can be publicly discussed. I
think it would be unconstitutional to require him to give a good
reason— he should be able to say, "I fired him because he's ugly,"
if he wants to. But the statute still has bite, because now people
can criticize the decision. In this case, we can say, "Obama
should not fire an IG just because he doesn't have the fullest
confidence in him. He admits that he isn't firing the IG because
the IG did anything wrong— it's just a matter of Obama's own
feelings. That's a stupid reason, and we think the real reason is
something else that Obama can't defend."


(2) The only reason not to think this isn't a gross scandal worthy
of impeachment is the strong approval of two other people:
Steve Goldsmith, former Indianapolis mayor, and the acting US
Attorney Larry Brown (if we do confirm that the President
firing an IG because the IG tried to make sure a political ally was
punished appropriately for fraudulent use of federal funds isn't
that worthy of impeachment?).

I don't know about Goldsmith, even though I'm from Indiana.
Any ideas, people? Commentor Kent Scheidegger said that he
knew Larry Brown, and that he is a good guy. Larry Brown is a
career prosecutor, apparently, not a real Bush appointee, so we
don't know his politics. Mr. Scheidegger, do you know if he's a
liberal? Does anybody know if he has local or national ambitions
that would be relevant? (becoming the actual US Attorney, for
example, instead of just Acting)

(3) Steve's last two links are great reading on the substance of the firing,
because they are pro- and con- documents by the people
involved. In particular, read Larry Brown's letter. After reading it,
I think more than ever that this is a major scandal, if that's the
best attack that can be mounted on the IG.

Brown's complaint boils down to saying that the IG has an
opinion on whether criminal and civil violations occurred, the IG
thinks the US Attorney's office is being slack, and the IG has
made public comment on the case instead of letting the US
Attorney keep it under wraps. Whether the IG is right or wrong,
I thought a big part of his job was to publicize wrongdoing
(though not to prosecute). He has no direct power, after all, just
the power to investigate, refer, and publicize. He couldn't even
suspend the culprit from getting money from his agency— all he
could do was recommend it to the Americorps political
leadership, who made the decision first to suspend and then to
unsuspend.

(Hi, JE— we last met while you were a law student.)
6.16.2009 6:33pm
cboldt (mail):
-- but guaranteed that it's "Czar" would be independent from the political system ... --
.
I believe that. Unaccountable, independent of Congressional oversight and any other political process that the people might use to obtain comfort and/or satisfaction.
6.16.2009 6:34pm
wm13:
I'm with Eric Rasmussen: the U.S. Attorney's complaint seems like pretty thin gruel. At most, it seems like two lawyers disagree about how serious something is, which doesn't mean that one of them is guilty of ethical violations. Walpin has a pretty distinguished career record:

http://www.innsofcourt.org/Content/Default.aspx?Id=343

And, to match another commentator, I knew Walpin myself, many years ago, when I was an associate at Rosenman &Colin. If I recall correctly, the litigation associates liked him okay. Walpin certainly went to a much better law school than Brown.
6.16.2009 7:13pm
Jim Rhoads (mail):
Brown as the acting US Attorney is in a political-executive branch position. Walpin is in a position which is designed to be insulated from undue political influence. From what I have read (all of the documents linked above), I think this was a bad move by BHO, although he has the authority to do it.

The "appearance of impropriety" problem is rearing its head, and it is as ugly as Nixon's Saturday night massacre and W's US Attorney replacements.

An adult in the WHC Office might have clued him in and strongly suggested this would hurt him politically.

Not the transparency that was promised.
6.16.2009 7:56pm
Dan Hamilton:
About $400K misspent.
Can't be paid back because they are insolvent.
NOTHING happens to Johnson who got most of the perks.

Brown didn't want to do anything to Johnson, the guy who wasted the money.

Brown made a deal that did absolutly NOTHING to anybody.

The guy who found that $400K was wasted is fired.

I am sorry this stinks to high heaven.

Half the money is just gone. NOTHING happens to those responsible and the only one punished is the guy who exposed the misspent money.

"appearance of impropriety" doesn't BEGIN to describe this.
6.16.2009 8:30pm
Jim Rhoads (mail):
But it's at least that, isn't it?
6.16.2009 9:09pm
Desiderius:
Steve,

Very fair comment, but this:

"As a visceral matter, the number of actors independent of the White House who seem to agree that there was a problem with this IG leads me to believe that the firing was OK"

Comes across too much like Rosen's initial article on Sotomayor. I'm afraid that the appearance of impropriety here will require a fuller accounting.
6.16.2009 9:30pm
Richard W. Painter (mail):
Why is the top White House ethics lawyer involved in this? When I served in that role, I was not involved in firing anybody, much less an inspector general. Regardless of the merits or lack thereof in the firing itself, having the White House ethics lawyer make the phone call seems to be very ill advised.

Richard Painter
6.16.2009 10:35pm
Eric Rasmusen (mail) (www):
I guess in the Obama administration there's not enough work for a full-time ethics lawyer, so they're using him to do things like get coffee and make phone calls.
6.16.2009 11:53pm
Bruce Hayden (mail):
I don't know this area of the law, at all, but doesn't the President have the absolute right to fire pretty much anyone appointed to a post in the Executive branch? I understood that Congressional power grabs in this area trying to usurp this power were thwarted by the courts.

I say this, as someone who did not, and does not, support President Obama. But I think that we, the citizens, got as much as we could out of him here, in his having to give a reason (even if a very weak one) to Congress for his firing of the IG. Anything more would usurp his Article II powers.
6.17.2009 12:18am
Guest12345:

Anything more would usurp his Article II powers.


Since he was one of the usurpers sponsors of the law that requires a reason be presented to Congress, I don't think he should get to change his mind now.


"Hey guys, you know that law I made? It's really inconvenient for me now, can we call a mulligan?"
6.17.2009 1:41am
ArthurKirkland:
I see many people firing furiously without aiming, and continuing to fire when any reasonable person would pause. In this thread, the more detailed and hyperlinked the contribution, the less sense it makes.

The circumstances associated with Mr. Walpin's departure (precipitated by the action of board members from both sides of the aisle) invite inquiry (as Senators from both sides of the aisle appear to recognize) and investigation (as appears to be underway).

That said, I assume that Mr. Bader is reloading.
6.17.2009 9:50am
SamW:
If I am reading these documents correctly, the claim that the settlement is worthless is untrue. Part of the settlement required the defendant personally to fund it by giving the money to the corporation.
6.17.2009 9:58am
Bob from Ohio (mail):

Since he was one of the usurpers sponsors of the law that requires a reason be presented to Congress, I don't think he should get to change his mind now


Why not?

He was a senator and now he is president. Circumstances change.

If you are a parent, is your point of view about drnking and sex now different than when you were a teenager?

Congress can investigate this if they want but the idea of a subordinate executive branch official being independent of presidential removal, even for thin reasons, is unconstitutional.
6.17.2009 10:56am
Dan Hamilton:

Congress can investigate this if they want but the idea of a subordinate executive branch official being independent of presidential removal, even for thin reasons, is unconstitutional.


Except when he is fired because he messed with an Obama supporter. Talk about a Chilling effect on the othe IGs.

BTW - how do you like the latest? Walpin is now demented. He was confused and unable to answer questions at a board meeting. After Walpin's TV interviews that's going to be real easy to sell.
6.17.2009 11:35am
Desiderius:
Dan Hamilton,

"Walpin is now demented."

Well, at least they can't be accused of being closet Marxists on this one. Good thing they didn't need the AARP on board for Health Care Reform or anything...

Seriously, is there something in Article II that mandates that all Executive Branch PR shall be conducted by Scott McClellan? Or is it some Ricci-style AA program for the tone deaf?

"He was confused and unable to answer questions at a board meeting."

The most plausible explanation for that is that he was bum-rushed there unexpectedly. Conservative crusaders like Walpin have a history of being naively trusting.
6.17.2009 1:38pm
Eric Rasmusen (mail) (www):
Possibly related: Acting US Attorney Brown initiated a special corruption process against Dem leader Don Perata and then pulled back in May, deciding not to file charges. This occurred after a strong and open campaign by Don Perata's people to lobby with AG Holder. See here for lots of details.


Note, too, that Mr. Brown is a temporary US Att., and unless he is appointed by Obama to be the permanent head, he goes back to being number 2 (I think) in August 2009
6.17.2009 1:41pm
wesmorgan1 (mail) (www):
(DISCLAIMER: I'm not an attorney, just an interested layman.)

What about the suggestion that Walpin excluded potential exculpatory evidence from his report to the US Attorney? I'm referring to the school principal telling Walpin that St.HOPE tutors did, indeed, show up at his school; Walpin judged it "irrelevant," apparently because the principal didn't say that he personally observed said tutoring firsthand. I didn't think it was the IG's job to decide what information is "relevant" to the prosecutor(s). Failure to inform the prosecutors of potentially exculpatory statements/evidence would seem a pretty major goof, especially in a politically charged matter.
6.17.2009 10:13pm

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