Based on the review of Crossfire Hurricane and related intelligence activities, we conclude that the Department and the FBI failed to uphold their important mission of strict fidelity to the law in connection with certain events and activities described in this report. As noted, former FBI attorney Kevin Clinesmith committed a criminal offense by fabricating language in an email that was material to the FBI obtaining a FISA surveillance order. In other instances, FBI personnel working on that same FISA application displayed, at best, a cavalier attitude towards accuracy and completeness. FBI personnel also repeatedly disregarded important requirements when they continued to seek renewals of that FISA surveillance while acknowledging -- both then and in hindsight -- that they did not genuinely believe there was probable cause to believe that the target was knowingly engaged in clandestine intelligence activities on behalf of a foreign power, or knowingly helping another person in such activities. And certain personnel disregarded significant exculpatory information that should have prompted investigative restraint and re-examination.
-- Special counsel John Durham, in the conclusion to his "Report on Matters Related to Intelligence Activities and Investigations Arising Out of the 2016 Presidential Campaigns" (12 May 2023)
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