Watchdog Files Bar Complaint Against Wray Over Arctic Frost Role

A good government group filed a formal bar complaint against former FBI Director Christopher Wray on Thursday for his role in greenlighting the Biden administration’s Arctic Frost lawfare against Donald Trump, The Federalist has learned. The complaint asks the D.C. Bar to investigate the former director for potential violations of existing bar rules governing licensed D.C. attorneys.

“The common theme of those targeted by Arctic Frost was their connection to President Trump, the chief political rival to Joe Biden at the time. Wray’s involvement warrants further inquiry to determine if any professional conduct rules were violated during the course of his oversight,” Center to Advance Security in America (CASA) Director James Fitzpatrick said in a statement to The Federalist.

The complaint obtained by The Federalist cites an April 2022 Justice Department memo previously released by Sen. Chuck Grassley, R-Iowa, that shows Wray as one of several high-ranking intel officials to sign off on Special Counsel Jack Smith’s Arctic Frost probe. As The Federalist previously reported, the expansive investigation — which also targeted numerous GOP members of Congress and Republican-affiliated individuals and organizations — ultimately became Smith’s elector lawfare against Trump.

In the complaint, Fitzpatrick argued that the actions taken by Smith and his team “were likely performed at the behest of Wray and others.” “At the very least,” he wrote, “they were performed as a result of [Wray’s] recommendations.”

“Indeed, Wray authored the memo requesting that the [Arctic Frost] investigation be initiated,” Fitzpatrick wrote. “He wrote that the Washington Field Office (WFO) needed approval ‘as soon as possible’ to investigate supposed ‘fraudulent certificates of electors’ votes’ and identified as the subject of the investigation as ‘individuals who were closely associated with the Trump Campaign [that] have made public statements implicating themselves in a conspiracy to obstruct Congress’s [sic] certification of the Electoral College.’”

The CASA director went on to note Smith’s eventual indictments against Trump leading up to the 2024 presidential election. He also cited numerous instances throughout the probe that he said show how Smith and Co. attempted to “hinder President Trump’s candidacy and, where possible, those of other Republicans too, perhaps as intended by Wray and Garland.”

Fitzpatrick’s complaint additionally flagged recent revelations showing how the Wray-led FBI furthered “this political targeting” by subpoenaing the phone records of now-FBI Director Kash Patel and White House Chief of Staff Susie Wiles in their capacities as private citizens. The subpoenas covered phone calls from 2022 and 2023, with Patel claiming that Smith’s collection of Wiles’ phone records “extended into [her] time as Trump’s co-campaign manager, though he did not say when exactly the record collection began or ended,” according to Reuters.

[Watch: Margot Cleveland Breaks Down 5 Ways Jack Smith’s Witch Hunt Ripped Up The Constitution]

Fitzpatrick noted that while it’s currently “unclear the extent to which Wray was involved in the day to-day of the Arctic Frost investigation … at the very least, he greenlit Smith’s overall effort.” Such actions alone, he argued, “warrant an investigation” by the D.C. Bar — of which Wray is reportedly a licensed member — “to determine the depth of his involvement.”

“But even if his only effort was only to give general direction to potentially violate the First Amendment rights of free speech and free association, he likely violated Rule 8.4” of the D.C. Bar’s Rules of Professional Conduct, Fitzpatrick wrote. “[A]ny attorney, including Wray, involved in the Arctic Frost investigation would have potentially conspired to deprive the subjects of that investigation of their constitutional rights of free speech and free association.”

The CASA director contended that, in the realm of government prosecution, “a decision to prosecute which is motivated by a possible desire to discourage protected speech or expression violates the First Amendment,” and that it doesn’t “matter if the prosecution was ultimately successful, but rather the effort itself violates the First Amendment.” He added that “criminal prosecution due to affiliation with a political party or movement” also violates free association.

“Here, the subjects of the Arctic Frost investigation were exclusively Republican elected officials, members of the first Trump administration, and conservative voices, non-profits, and/or policy organizations. The primary aim was to pick apart and pry into the finances of each of these people, which the Supreme Court has explicitly stated violates the First Amendment,” Fitzpatrick wrote.

Given these potential First Amendment violations by Smith and his team, CASA has requested the D.C. Bar’s Office of Disciplinary Counsel to investigate Wray to determine “the scope of his involvement and, if appropriate, bar discipline.”

CASA Bar Complaint_Christopher Wray by The Federalist

Shawn Fleetwood is a staff writer for The Federalist and a graduate of the University of Mary Washington. He is a co-recipient of the 2025 Dao Prize for Excellence in Investigative Journalism. His work has been featured in numerous outlets, including RealClearPolitics and RealClearHealth. Follow him on Twitter @ShawnFleetwood