James Comey: A Higher Loyalty: Truth Lies and Leadership

By James Comey 

Not since J Edgar Hoover has a Director of the FBI been so visibly catapulted into the public spotlight as Jim Comey. Many Democrats, including Clinton herself, apportion responsibility to Comey as the man who cost her the 2016 Presidential election. Did Comey actually cost Clinton a historic turn as the first female President of the United States?  It is difficult to say for sure, but there has been no end of media commentary hypothesising why he acted as he did and what his true motivations are.

His detractors have speculated that they lie in his love of the spotlight; that he is driven by an insatiable appetite to satisfy his own ego. Comey admits early on in the book that he can be “stubborn, prideful, overconfident and driven by ego.” But he contends that when he has been thrust into the bright glare of the television cameras it has been due to the necessity of circumstance, not to elevate his public profile. In other words, he has an ego but tries to keep it in check.

The book guides the reader through Comey’s thought process as he makes difficult decisions in a highly partisan political environment. On this account, it is a useful and insightful book. A great deal of attention has been placed on smaller gossipy details such as unflattering descriptions of Donald Trump: “his face appeared slightly orange and, with bright half-moons under the eyes where I assumed he placed tanning goggles.” But the book does share some really compelling insights into a range of pivotal events in recent American political history.

Before being appointed by President Obama to run the FBI, Comey was at the centre of cases that have shaped American history. From his prosecutions against the Sicilian Mafia, leading the internal opposition to Bush administration torture and surveillance policies, to the investigations into Hillary Clinton’s handling of classified information. He has seen a lot and certainly knows a lot more than he is able to let on.

The book is not strictly a memoir, but a treatise on what it means to practice ethical leadership. Comey defines this as: “understanding the truth about humans and our need for meaning. It is about building workplaces where standards are high and fear is low.” The book interweaves political and biographical details with his views on how the leaders he has known have practised the values of ethical leadership.

Truth and Lies

For all the books merits, Comey does have a tendency to come across as quite self-righteous, if not a little grandiose at times. Luckily such passages do not detract too greatly from the overall narrative. What is clear is that Comey is a man who tries to think carefully about morality, about the kinds of ethical behaviour he expects from himself and from others. He is a man guided by his faith and the book is replete with religious quotes. This pious impulse inculcates a desire for the truth and a detestation for lies.

Comey has a lot to say about lies with respect to the 41st President, but there are other interesting examples of where he traces a seeding lie germinate into a full-blown scandal.

His account of the prosecution of the celebrity lifestyle guru Martha Stewart is gripping. Stewart claimed to FBI investigators that she did not know that a company called Imclone was about to be denied a license for a new “wonder drug” before she sold $50,000 worth of her stock in the company. Unfortunately for Martha, she let slip to a friend that she had been tipped off by her broker that the company was in trouble before selling her stake. In the end what did her in was not the fact that she was insider trading, $50k was surely a pittance to Martha Stewart. It was the fact that she had lied to the FBI in their investigations about her knowledge that the company had been denied the license. Comey was tasked with leading the case prosecuting Stewart and rationalised that if a non-celebrity would be prosecuted in the same situation then Stewart could not be exempted from the same fate. Protecting the integrity of the law and truth were of utmost importance. As Comey says:  “Martha Stewart lied, blatantly, in the justice system. To protect the institution, and reinforce a culture of truth-telling, she had to be prosecuted.”

The force of Comey’s ethical convictions is tested again during a fight with the Bush administration over the continuation of a covert surveillance programme known as “Stellar Wind.” In 2004 Comey was the Deputy Attorney General and the original warrant to authorise the programme, which was passed in the days after 9/11, was due to expire. Stellar wind was a programme of NSA surveillance activities conducted in the US against suspected terrorists and citizens without the need to obtain judicial warrants. The programme had been authorised on legally dubious grounds, and the NSA was actually collecting data and personal information that went far outside the scope of even the legally dubious warrant. In the face of huge opposition from then Vice-President Cheney and the Bush White House, Comey was able to persuade the Attorney General John Ashcroft that the programme should not be renewed. But suddenly Ashcroft fell ill with acute pancreatitis just before the resolution was due to expire. This resulted in a tense scene in which Comey and other FBI agents stormed the hospital room of the Attorney General to protect him for the Bush White House! He had got word that Bush’s Chief of Staff and White House Counsel were heading to the hospital to force Ashcroft to sign an extension of the programme. This resulted in a standoff in which Comey stood guard in Ashcroft’s hospital room as the two administration officials unsuccessfully attempted to coerce the AG into signing an extension. In the end, the administration accepted revised wording to the Stellar Wind Programme, but only after a very close call and with Comey standing strong against the pressure. 


Comey’s normative ethics underpins his conception of ethical leadership. He wants to create a reference point for the ways in which ethical leaders should conduct themselves. Along the way, he picks out examples from his life on where he has learned from others what it means to practice ethical leadership. He talks about his early life his grocery clerk boss took real pride in his work and inspired his employees to always do their best. Whilst Comey is a good storyteller and a very enjoyable writer, some parts of the book do feel a bit corny. Some of his points are genuinely insightful. But by writing a book on what makes good leadership he lands himself open to the accusation that he is not without the faults that he finds in others.

He is an institutionalist, and his sense of good leadership is tied to his ability to embody the values of the institution that he is working for. In Comey’s eyes, the institution of the FBI is held in a degree of reverence only superseded by God and his family. At crucial inflexion points, his chief concern is often how a major decision will impact the FBI. He refers to a deep “reservoir of trust” that exists between the FBI and the people the agency deals with. Any attempts to act in a way that breaks that trust is to deplete a reservoir built up by a long history of kept promises and fulfilled deeds. Comey’s reverence for the FBI and the integrity of the American judicial system does feel quite sanctimonious at times. If you were to ask the victims of the Cointelpro programme or the family and friends of Fred Hampton, they may argue the reservoir ran dry a long time ago.

Comey is not blind to this disjuncture and he makes a point in FBI training courses to offer a module on the FBI’s programmes of covert action against Martin Luther King. He does so hope that it will instil in new agents a deeper awareness and understanding of the difficult history that the bureau has to reconcile. Still, Comey remains a loyalist to the institutions he serves and is resolute in his view that the reputation of the FBI must be protected at all costs.

When contrasting leadership styles, Comey highlights interesting comparisons of the  Presidents that he has served under. He maintains the importance of a clear wall of separation between the Presidency and the FBI. Sometimes the FBI ends up investigating the conduct of officials close to the president and so this sense of distance needs to be maintained. Comey noted that whilst he did not have deep personal relationships with Presidents Obama and Bush, he found things in both of them he respected. Barack Obama in his empathetic skills and his natural humour, George Bush also had a natural sense of humour, if in a more derisory kind of way. He has less good things to say about Donald Trump and many of the descriptions of what good leadership is not can be read as a thinly veiled attack on Donald Trump.  

Comey draws frequent parallels between the members of the Manhattan “Cosa Nostra” crime family and the leadership of Donald Trump. It is a style of leadership that aims to implicate everyone in his illicit or immoral behaviour. There is one particularly striking description when Comey, joined with other senior intelligence officials are briefing Trump and his team on the full extent of the Russian interference in the American election. Rather than question the response the intelligence agencies will mount in retaliation, Trump appeared interested only in how the interference would impact him politically. He then proceeds to break the wall of FBI and political independence by breaking into an impromptu PR meeting about how the Trump team could best spin the scandal to avoid political damage. Comey recounts how the atmosphere reminded him of the old New York Mafia Social clubs. Trump, by blurring the lines between the intelligence agencies and politics was seeking to draw the agencies into their club, as a means of compromising their integrity later on. The juxtaposition of imagery between the future conduct of a sitting President and that of a Mafia boss is striking but is a frequent trope that Comey uses in the book.

2016 Election

Comey has clearly given a great deal of thought to what constitutes ethical leadership; there is no doubt that this is an issue he cares about very deeply. But whether this was his primary motivation for writing this book is doubtful. This is, after all, his chance to enter his perspective for the historical record.

Comey’s role in the 2016 election came under much criticism, particularly his handling of the investigation into whether Hillary Clinton mishandled classified information. The issue was not so much that Clinton was using a private email account to conduct State business, but that she was talking about topics that were highly sensitive on an insecure system. But if a criminal case were to be brought against her, the FBI would need her to prove that she knew that she was breaking the law.

On July 5th 2016, Comey decided to hold a solo press conference to announce the findings of the investigation. He did so, in part, to circumvent his boss Attorney General Loretta Lynch, Comey hits that Lynch may have been compromised in the Clinton investigation due to intelligence that is not currently in the public domain. The investigation found that Clinton was “extremely careless” with her handling of classified information, but the FBI was not recommending the filing of criminal charges.

Then in late October 2016, new emails were discovered on the computer of the former congressman Anthony Wiener which could be relevant to the now-closed Clinton investigation. Once the emails were found, Comey was faced with an impossible choice: he could choose to speak or conceal. By speaking he would break with a long-established rule that the FBI should not intervene in the election process. By concealing it could ruin the reputation of the FBI were Clinton to win the Presidency and the developments were to leak out subsequently. It was a choice with bad options on both sides. So on October 28th, Comey took the unusual step of sending a letter to Congress alerting them to the discovery of these new emails and the reopening of the Clinton investigation.

But he was also faced with a third option: to wait. Comey says that when he was first alerted to the existence of the emails his team originally suggested that it would take until after the election to read and sort through them all. But in the end, they were able to complete the review by November 5th. Comey sent a letter to Congress the next day notifying them that the investigation had concluded and there was no change to the earlier decision. Of course, the wait option becomes much clearer in hindsight, but when Comey makes clear demarcations, the choices are rarely as binary as he makes out.

Whether his October 28th letter to Congress really made a decisive impact on the election is difficult to say. There were certainly so many factors at play that being able to pinpoint one single cause is difficult. Comey clearly feels a sense of regret that his actions might have moved the needle, although he is reluctant to ascribe blame to himself.

The actual Clinton scandal was less about what she did, but about the fact that she was back in the headlines again for all the wrong reasons. It added to a general narrative around Hillary that she was corrupt and could not be trusted. Comey admits that he trusted the polls that Clinton was going to win. So he was concerned with the optics of the situation were it revealed, under President Clinton, that the FBI had deliberately concealed information that would have undermined the new President. For the loyal FBI institutionalist Comey, this would have been an incomprehensible disaster. The irony is that under Donald Trump, the reputation of the would-be tarnished far greater than under any other President in living memory.


Overall Comey’s book is an enjoyable read that paints a compelling story from a man who has been at the centre of significant events. It may feel a bit overly preachy, Comey is, after all, a man from the most upright of law schools. The attack that he has made decisions due to partisan inclinations seem a little baseless from reading the book. Of the mainstream establishment parties, it is difficult to tell who he is a partisan for! He is hated by the Democrats for costing Hillary the election. He then angered the Republican President for his investigation into Russian interference in the 2016 election. Comey is very traditional by the book, law and order kind of guy. And so if he is a partisan it is towards his notions of God, family, country and the institutional integrity of the FBI.



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