The theory relies on hacked emails later assessed as a likely manipulated Russian production.[6] The emails were mentioned in Russian memos obtained in 2016 by Dutch intelligence after it hacked into Russian intelligence systems. This information was shared with U.S. intelligence,[8] but the Americans viewed the material "with caution" due to the "possibility the Russians had exaggerated things for their own purposes, or knew the server was compromised and deliberately mixed in disinformation".[1] Some coverage of these matters was kept in a classified annex to the Durham report, which was not released publicly until two years later and which commentators described as containing unverified or dubious intelligence.
In his final report, published in 2023, Trump-appointed special counsel John Durham unsuccessfully tried to prove the alleged "plan" existed.[9][10][11][12] The New York Times noted that Durham's descriptions of the dubious nature of the hacked emails sounded like he was "debunking" them;[1] that Durham had buried information favorable to Clinton; and that the emails were "almost certainly a product of Russian disinformation".[7]
Two years later, on July 31, 2025,[13] during Trump's second administration, the annex was declassified and released in an effort to revive and promote the "Clinton plan" theory.[1][2][14] The release publicly amplified dubious hacked Russian material,[1] using it as part of efforts to relitigate[13] and challenge prior findings that Russia interfered in the 2016 election in a "sweeping and systematic fashion",[15] that Trump's campaign welcomed[15][16]:944 the interference, and that Trump later obstructed investigations.[15] These actions by Trump and his intelligence chiefs have been described as an attempt to rewrite the history of the 2016 election[17][18] and the findings of both Mueller's Trump-Russia probe[18] and the FBI's Crossfire Hurricane investigation.[19]
The theory
The "Clinton plan" theory has been described as a right-wing[12][20][2] conspiracy theory[a] advanced by Trump and his associates. The theory accuses Hillary Clinton and senior officials in the Obama administration of engaging in a conspiratorial plan, plot, or scheme[b] to fabricate an alleged "Russia collusion hoax"[1][4] by "falsely" asserting that Donald Trump had improper ties to Russia and its interference in the 2016 United States elections.[1]The New York Times described the allegation as "a way to blame Mrs. Clinton for the fact that Mr. Trump's campaign came under suspicions that prompted the Russia investigation eventually led by Robert S. Mueller III, the special counsel".[1]
The Durham report's description of the alleged "Clinton plan" includes the intelligence community's (IC) skeptical view of the allegation:[25]:81[26]:19
In late July 2016, U.S. intelligence agencies obtained insight into Russian intelligence analysis alleging that U.S. Presidential candidate Hillary Clinton had approved a campaign plan to stir up a scandal against U.S. Presidential candidate Donald Trump by tying him to Putin and the Russians' hacking of the Democratic National Committee. The IC does not know the accuracy of this allegation or the extent to which the Russian intelligence analysis may reflect exaggeration or fabrication.
The theory stems from hacked and translated Russian intelligence memos and an accompanying Russian analysis based on portions of hacked American emails from July 2016, rather than on the full original messages.[1] The memos asserted that on July 26, 2016, Hillary Clinton approved a "plan" in the form of "a proposal from one of her foreign policy advisers to vilify Donald Trump by stirring up a scandal claiming interference by the Russian security service".[19]
Russian intelligence memos used the words "Clinton" and "plan" separately rather than as a single phrase or fixed label. In his 2023 final report, Durham combined those elements into a label, writing, "We refer to that intelligence hereafter as the 'Clinton Plan Intelligence'",[27][1][8] and also referring to it as the "Clinton plan".[27][1] Several sources have characterized that formulation as a conspiracy theory.[a]
The alleged plan was further described in a classified 29-page annex to the Durham report,[14] which was not publicly released or declassified until July 31, 2025, two years after the publication of the main report.[13][7]
David Corn described expectations among Trump allies regarding the Durham special counsel investigation:[14]
Durham, Donald Trump and his crew fervently hoped, was going to prove that Barack Obama, Hillary Clinton, former CIA director John Brennan, former FBI director Jim Comey, and other Deep Staters had conspired to cook up the Russia scandal to sabotage Trump. Within MAGA, it was widely assumed that Durham would get the goods, smash this cabal, and lock up all these wrongdoers.
According to David Corn and Charlie Savage, Durham had failed to prove "MAGA's conspiracy theories about the Russia investigation" or "Deep State skullduggery" by the aforementioned "Deep Staters".[14] Savage described how Durham and Barr then changed their focus from attacking U.S. intelligence and "Deep Staters" to an attack on Hillary Clinton:[11]
But by the spring of 2020, according to officials familiar with the inquiry, Mr. Durham's effort to find intelligence abuses in the origins of the Russia investigation had come up empty. Instead of wrapping up, Mr. Barr and Mr. Durham shifted to a different rationale, hunting for a basis to blame the Clinton campaign for suspicions surrounding myriad links Trump campaign associates had to Russia.
Ratcliffe and first appearance of theory in 2020
Two FBI assessments from 2016 and 2020 had found the Russian materials were "likely not credible", according to Lawfare.[28] Nevertheless, then–Director of National IntelligenceJohn Ratcliffe declassified[1] some information from the hacked Russian memos and turned it over to Senate Judiciary Committee Chairman Lindsey Graham, who released it on September 29, 2020.[29]
On September 29, 2020, according to CBS, "The unverified details contained in Ratcliffe's letter were released over the objections of senior intelligence officials from the CIA, NSA and Office of the Director of National Intelligence."[24]
Career intelligence professionals expressed their concerns:[30]
All of this is deeply troubling and threatens to politicize the intelligence community at a time when untainted, clear information is at a premium. 'He has declassified information for patently partisan reasons, and he has done so in an underhanded manner,' said John Sipher, who ran the CIA's Russia operations during a 28-year career in the agency's National Clandestine Service. In one fell swoop, then, Ratcliffe may have tainted the reputation America's spy agencies try so hard to build. 'The damage to US intelligence will be difficult to undo for years,' said Alina Polyakova, president and CEO of the Center for European Policy Analysis in Washington, DC.
The theory was first mentioned publicly by John Ratcliffe on September 29, 2020, near the end of Trump's first presidency,[1] and "mere hours before the first Trump-Biden debate", a timing that was described by Judy Woodruff as a "possible abuse of intelligence and the levers of government by the Trump administration".[31]
In a move that "appears to mirror Moscow's ongoing disinformation campaign against the former secretary of state",[32] that paragraph was first released by Director of National Intelligence, John Ratcliffe, on September 29, 2020. He was immediately criticized for using possible Russian disinformation in an effort to hurt Clinton while helping Trump during his debate with Joe Biden:[30]
In other words, Ratcliffe acknowledged he released material that would likely be harmful to Clinton and the Democrats — and helpful to Trump — without knowing its veracity. But it gets worse: Recent news reports have revealed that Ratcliffe declassified the intelligence against the advice of nonpolitical, career US intelligence officials who feared his doing so 'would give credibility to Kremlin-backed material,' according to the Wall Street Journal.... The letter went public mere hours before Trump and former Vice President Joe Biden squared off in the first 2020 presidential debate. And, intentionally or not, the disclosure had an immediate impact: During the debate, the president mentioned what Ratcliffe released. 'You saw what happened today with Hillary Clinton, where it was a whole big con job,' he said.
Politico reported that Trump took advantage of the situation, "weaponizing the releases to boost his reelection campaign".[19] Ratcliffe told CBS News that he had "declassified the additional documents 'at the direction of President Trump'".[24]
Politico also reported that Durham was "expected to refrain from releasing any conclusions before Election Day to avoid affecting the race", but that recent declassifications by Ratcliffe and Attorney General William Barr appeared to be "an effort to fill that void".[19]
In his 2023 final report, Durham created a label for the alleged Clinton plan: "We refer to that intelligence hereafter as the 'Clinton Plan Intelligence.'"[27][1] It was further described in a classified 29-page annex to the Durham report.[14] That classified annex was not publicly released and declassified until July 31, 2025, two years after the release of the main Durham report.[13][7]
Politicization concerns
In 2020, Nick Schifrin reported that the material had been rejected as possible Russian disinformation and that its release raised concerns about the politicization of intelligence that was disinformation:[31]
U.S. officials and former intelligence officials tell "PBS NewsHour" the FBI in 2016 considered it might be Russian disinformation. It was rejected by special counsel Robert Mueller and the bipartisan Senate Intelligence Committee. And Ratcliffe released the letter, over the objection of career CIA and NSA officials. Democrats accused Ratcliffe of politicizing intelligence.
Politico noted strong criticism from former senior intelligence officials following Ratcliffe's move, reporting that Democrats said the release "effectively put Russian disinformation into the public sphere in order to boost President Donald Trump's unsubstantiated claims" about investigations into Russian interference in the 2016 election, and that several former senior intelligence officials described Ratcliffe's action as "incendiary and irresponsible", given that he was "publicly releasing unverified information from a foreign adversary".[29]
Mother Jones highlighted what it described as an "irony" in Durham's report and criticized his reliance on a "sketchy intelligence product" that it said may itself have been "Russian disinformation to push a partisan political narrative". The article continues:[8]
Durham used possible Russian disinformation while attacking the FBI for using possible Russian disinformation. That may seem confusing, but it helps clarify what the special counsel has been up to for the last four years. Working to arm Donald Trump and his allies with talking points to fault what they call the 'weaponization of government,' Durham made himself their weapon.
But there is a bigger problem. Russian security services did hack Clinton's campaign to help Trump, according to the entire US intelligence community and the Senate Intelligence Committee. Yet Durham relies on those Russian spies for insight into how Clinton reacted to the hack. That is like the cops citing a bank robber who says the bank framed him.
On September 29, 2020, according to CBS, "The unverified details contained in Ratcliffe's letter were released over the objections of senior intelligence officials from the CIA, NSA and Office of the Director of National Intelligence." CBS cited former CIA director John O. Brennan when he condemned Ratcliffe's release as an "appalling" and "blatant act of politicization", by "'selectively' releasing information in an effort to fuel partisan objectives beneficial to President Trump".[24][33]
The hacked emails
Lawfare analyzed the provenance of the purported emails and the two related memos, describing how they were said to have been obtained and later transmitted to U.S. authorities. In early 2016, "The SVR supposedly also obtained an email about a plan Clinton had approved to link Putin and Russian hackers to then-candidate Trump in order to distract the public from her email server scandal." The Durham annex "centers on communications from a source—referred to as T1—who provided the FBI with two memos and a set of emails. The memos appear to be Russian-written summaries of U.S. political events, one from January 2016, and another from March,..."[28]
The emails were originally found in Russian intelligence memos in 2016 by Dutch intelligence hackers.[1] Reporting later clarified that their provenance, described as a "game of spy telephone", was complicated: Russian intelligence first stole the emails from American targets; the Dutch later hacked them from the Russians and shared them with U.S. intelligence.[8] The emails were subsequently released by Trump administration officials, who treated them as legitimate despite unresolved concerns about their handling and reliability,[20] given that it was possible the Russians had "deliberately mixed in disinformation".[1]
The Washington Post described how the memos obtained by Dutch intelligence hackers were accompanied by an "analysis by Moscow".[1] This Russian intelligence analysis described an alleged Clinton-approved plan "to smear Donald Trump by magnifying the scandal tied to" the Russian hacking of Democratic Party targets. In the memo, Russian analysts referred to Trump as "the Russian candidate" and framed the intrusion as benefiting him:[13]
A memorandum regarding those emails, apparently translated from Russian, reports that on July 26, 2016, Clinton approved a plan by a top policy adviser, Julianne Smith, 'to smear Donald Trump by magnifying the scandal tied to the intrusion by the Russian special services in the pre-election process to benefit the Russian candidate.' The 'intrusion' apparently referred to Russian spy agencies' hacks of computers belonging to the Democratic Party and Clinton's campaign.
The emails later cited in support of the alleged "plan" were treated with caution by U.S. intelligence and were subsequently scrutinized by journalists and investigators, who raised significant doubts about their authenticity.[1][7][8]
U.S. intelligence described why they were cautious:[1]
In 2016, a Dutch spy agency hacked a Russian spy agency and copied internal memos and messages by Russian intelligence analysts. The Russians were writing reports about various topics based on the emails of American victims of Russian hacking operations. The Dutch shared a copy of the trove with the United States. From the beginning, U.S. officials have said, they viewed the material with caution. Among other things, some reports were said to make inconsistent or false claims — raising the possibility that Russians had exaggerated things for their own purposes, or knew the server was compromised and deliberately mixed in disinformation.
The New York Times described how further examination of the emails themselves found additional problems. The Dutch hackers found the emails in a Russian intelligence memo. They were purportedly written by Leonard Benardo of the Open Society Foundations. The Russians used different names for the alleged recipient, a "Julie", "Julia", or "Julianne Smith", who was a foreign policy adviser for the Clinton campaign. A July 25, 2016, email mentioned Putin and "claimed that a Clinton adviser was proposing a plan 'to demonize Putin and Trump,' adding, 'Later the F.B.I. will put more oil into the fire.'"[7]
The reporting also noted that the Russians had "two different versions of the July 25 message — one that somehow had an additional sentence. And Mr. Benardo denied sending it, telling Mr. Durham's team that he did not know who 'Julie' was and would not use a phrase like 'put more oil into the fire.'"[7] The Associated Press reported that Benardo "told Durham's team he had never sent the email and the alleged recipient said she never recalled receiving it".[34]
CNN reported that Durham's report concluded that the purported emails at the heart of the theory "appear to be faked", and "that a portion of the alleged Benardo emails used verbatim lines from an entirely different email sent by a cybersecurity expert at a DC-based think tank".[6] The New York Times similarly reported that the emails were most likely a "composite of several emails" created by Russian spies using passages lifted from actual, unrelated hacked messages.[1]
According to The New York Times, Durham concluded that in 2016 the Russians had "probably faked the key emails," and that the office's "best assessment" was that the July 25 and July 27 messages attributed to Leonard Benardo were composites assembled from multiple hacked emails originating from U.S.-based think tanks, including the Open Society Foundations, the Carnegie Endowment, and others.[7]
The Open Society Foundations rejected the allegations outright, calling the emails "crude forgeries"[23] and stating that claims it helped orchestrate an FBI investigation were "outrageous and false" and grounded in "malicious disinformation" traced to Russian intelligence that was later used in a "politically motivated campaign".[6][35][13]
Charlie Savage and Adam Goldman described how Durham, in his subsequent investigation, reported that Julianne Smith said she did not recall proposing any Russia-related attack strategy to campaign leadership, but did recall discussions within the campaign expressing genuine concern that the D.N.C. hack threatened the electoral system and that "Trump and his advisers appeared to have troubling ties to Russia". Durham reported finding other materials using "the exact same or similar verbiage" as the questioned messages, including a July 25 email by a Carnegie Endowment cyberexpert expressing concern about the Russian hacking, language that was later "echoed, verbatim" in a message attributed to Benardo.[7]
Commenting on Durham's findings, The Guardian observed that although the annex was released in "heavily redacted form", Durham nevertheless upheld Benardo's disavowal, concluding that the material had "been cobbled together from other individuals' emails to produce something more incriminating than the actuality".[22]
Kept in a classified annex for two years
On May 12, 2023, Durham submitted to Attorney General Merrick Garland a 306-page unclassified report for public release and a 29-page classified appendix (annex). On May 15, Garland publicly released the unclassified Durham report without substantive comment or redactions, stating that "Arrangements will be made for review of the classified appendix."[36][25][9]
Two years later, the annex was declassified by Pam Bondi, Kash Patel, and elements of the intelligence community, and was released by Chuck Grassley on July 31, 2025.[13][7]
Contemporary commentary focused less on the annex's contents than on the circumstances and presentation of its release.
Following the annex's release, Kash Patel claimed that he found the document stashed inside "burn bags" within a "secret room" at the FBI, and that he delivered it to Senator Chuck Grassley, who posted it on his Senate website as "newly declassified" material.
The rollout of the "Durham Annex", including these claims, was described by Lawfare as "bizarre" and "pure political theater" designed "to conjure a little spy-movie mystique: burn bags, hidden rooms, Russian intrigue":[20][28]
By far the most bizarre chapter in this saga comes courtesy of Sen. Chuck Grassley (R-Iowa) and Patel, who jointly released what's now being called the 'Durham Annex.' The rollout was pure political theater: Patel claimed that he found the annex stashed inside 'burn bags' within a 'secret room' he discovered at the bureau, and delivered it to Grassley, who posted it on his Senate website as 'newly declassified' material. The implication? That these were suppressed documents of vital importance. The reality? These are plainly part of the Durham investigation, authored by Durham and marked with his classification authority. Electronic copies obviously exist. If this material was as sordid or meaningful as Patel and Gabbard claim, Durham could have included it in his final report. He didn't.
Cathy Young argued that a disconnect existed between Kash Patel's claims and the contents of the Durham report. Patel had asserted that the evidence was contained in the classified annex, yet simultaneously claimed that "his team had 'uncovered' long-ignored proof 'buried in a back room at the FBI.' It is a smoking gun: 'evidence that the Clinton campaign plotted to frame President Trump and fabricate the Russia collusion hoax.'"[21]
Young questioned that claim: "If this evidence is as potent as Patel says, then why would Durham—who was hired to blow the lid off the supposed 'Russiagate hoax'—have relegated it to a mere annex?"[21]
On the day the annex was released, Charlie Savage and Adam Goldman asserted that Durham's own findings undermined the claim that the Clinton campaign conspired[a] to frame Trump:[7]
The Trump-era special counsel who scoured the Russia investigation for wrongdoing gathered evidence that undermines a theory pushed by some Republicans that Hillary Clinton's campaign conspired to frame Donald J. Trump for colluding with Moscow in the 2016 election, information declassified on Thursday shows. The information, a 29-page annex to the special counsel's 2023 report, reveals that a foundational document for that theory was most likely stitched together by Russian spies. The document is a purported email from July 27, 2016, that said Mrs. Clinton had approved a campaign proposal to tie Mr. Trump to Russia to distract from the scandal over her use of a private email server.
Lawfare explained that the material was likely kept classified and confined to an annex because it was assessed as "highly likely a fabrication of Russian intelligence" released to "create a false picture of the so-called Clinton plan". The authors added that the document "shows that the Russians forged a document to slime Hillary Clinton with having a secret plan to steal the election".[37]
Lawfare wrote that "Durham was a partisan actor; it's unclear why he wouldn't have raised the 'Clinton Plan' to tie Trump to Russia in the court of public opinion if there was enough evidence for it." Lawfare also postulated that the emails upon which the "Clinton plan" theory are based were "so suspect that John Durham himself declined to include them in his final report".[28]
2025: Attempt to relitigate Russiagate scandal findings
In July 2025, senior Justice Department officials in the second Trump administration resumed efforts to relitigate and refute the findings of earlier investigations into the Russiagate scandal, which examined contacts involving Trump and Russia and Russia's interference in the 2016 United States elections. Those investigations concluded that Vladimir Putin intervened in the 2016 contest to help Trump.[13] The July 31, 2025, release of the alleged "Clinton plan" theory was part of the Trump administration's relitigation efforts.[13]
These efforts included what The Washington Post described as a series of "document dumps":[13]
In a half-dozen targeted document dumps over the past month, Director of National Intelligence Tulsi Gabbard, CIA Director John Ratcliffe and top Justice Department officials have sought to relitigate the presidential election of nearly nine years ago and refute earlier findings by multiple investigations that Putin intervened in the 2016 contest to help Trump.
Several motives have been described for this renewed effort:
An effort to "refute earlier findings by multiple investigations that Putin intervened in the 2016 contest to help Trump".[13]
An attempt by Trump and his allies "to distract from the administration's bungling of the Jeffrey Epstein case".[7][38]
Charlie Savage saw the Trump administration's declassification of a series of reports and documents as an attempt "to change the subject from its broken promise to release Jeffrey Epstein files".[1]
In the face of growing scandal over his relationship with Epstein, and his administration's refusal to release evidence and documents related to the dead sex offender's case, Trump is trying to redirect his base's attention to the nearly decade-old Russia investigation. Bringing up Obama, Clinton, and supposed deep-state plots is usually a reliable method to bury stories he'd rather not have under public scrutiny, even if nothing ever comes of it.
Writers for The New York Times have noted a parallel set of accusations about the motives of the other side. Trump's allies accused Clinton of hatching the alleged "Clinton plan" as a way of "distracting from the scandal over her use of a personal email server while secretary of state".[1] Democrats, in turn, accused Trump and his allies of reviving and relitigating the "Clinton plan" allegation to "distract from the furor surrounding the Jeffrey Epstein files". Senator Mark Warner stated:[6]
After years of investigation, John Durham confirmed what we already knew: There was no grand conspiracy to frame Donald Trump.... What we do know, from the bipartisan Senate Intelligence Committee report and multiple independent investigations, is that Russia interfered in our elections in order to help Trump win.
Trump-appointed special counsel John Durham was also involved, but his attempts to substantiate the existence of the alleged plan were unsuccessful.[1][4]
Denial of previous findings about Trump-Russia matters
While Donald Trump and his surrogates have consistently denied or sought to minimize "that Putin intervened in the 2016 contest to help Trump", the "findings by multiple investigations"[13] have contradicted those denials.
Trump and his supporters have tried to divorce him, his campaign, and his election from any connection to Russian election interference, including allegations his campaign cooperated with those Russian efforts,[16]:943[c] and he has rejected the findings of investigations into those allegations.
These actions by Trump and his intelligence chiefs have been described as an attempt to rewrite the history of the 2016 election[17][18] and the findings of both Mueller's Trump-Russia probe[18] and the FBI's Crossfire Hurricane investigation.[19]
Eric Tucker and Chris Megerian described the Durham report and declassified annex as the Trump "administration's latest attempt to rewrite the history of the Russia investigation": "The report, released Friday, downplayed the extent of Russian interference in the 2016 election..."[40]
Although the existence of the alleged plan has been "publicly known since at least 2020",[13] in July 2025, during Trump's second presidency, senior administration officials renewed these denialist efforts by advancing the alleged "Clinton plan" conspiracy theory narrative[a] that cited the dubious emails[1] in an effort to "relitigate the presidential election of nearly nine years ago and refute" those findings.[13]
John Durham unsuccessfully tried to prove the alleged "plan" was a Democratic plot to frame[1][4] Trump and "fabricate the Russia collusion hoax".[1] Durham's investigation followed claims by Trump and his allies that the FBI Russia investigation, code-named Crossfire Hurricane, was improperly predicated and motivated by political bias.[41] Trump characterized the FBI probe as a "hoax" and "witch hunt" initiated by his political enemies. The probe examined contacts between Trump associates and Russian officials and led to the Mueller investigation, which resulted in indictments of 34 individuals and guilty pleas from several Trump associates.[42]
Democrats argued that Gabbard's allegations "are rebutted by the investigations carried out by Durham, special counsel Robert Mueller, the Justice Department inspector general and the Senate Intelligence Committee, which all concluded that Russia interfered in the 2016 election".[6]
Findings contradicting those denials
The findings of the following investigations have contradicted the denials by Trump and his surrogates:
that Russia interfered in the 2016 election in a "sweeping and systematic fashion",[15] including an influence campaign personally ordered by Vladimir Putin;[43][45]
that Russia carried out cyberattacks targeting both major political parties, but selectively released material stolen from Democratic organizations in order to harm Hillary Clinton's campaign;[43]
that Vladimir Putin favored Trump over Hillary Clinton and that the Russian government worked to secure Trump's election;[43][46][d]
that Putin sought to undermine public confidence in the U.S. democratic and electoral processes;[43]
that the Russian government sought "to cultivate people in Trump's orbit";[d]
that the Trump campaign's interactions with Russian intelligence services posed a "grave" counterintelligence threat, as concluded by the Senate Intelligence Committee;[51][c]
that Trump's campaign welcomed the Russian election interference[15] because it "expected to benefit from the Kremlin's help",[51] was fine with the Russian assistance,[52] and reacted by encouraging, exploiting, and coordinating with those efforts;[53][54][c]
that Trump and his associates lied about Russian election interference and their Russia-linked actions.[55][56][57][58][59] Trump continually claims that Russian interference is a "hoax".[52]PolitiFact named Trump's assertions "that Russia's meddling in the 2016 election is fake news, a hoax or a made-up story" as their "Lie of the Year for 2017".[60]
that Trump later engaged in conduct that obstructed investigations into these matters, as described by Mueller.[15]
Together, these findings document the scope and objectives of Russian interference in the 2016 election and describe how the Trump campaign responded to it. In doing so, these findings stand in contrast to the denials by Trump and his surrogates.
Reframing of ordinary campaign activity
The "Clinton Plan" theory alleges a covert scheme by Clinton to invent falsehoods tying Trump to Russia and Putin,[1][4] instead of portraying her actions as pointing to Trump's positive statements and conduct regarding Russia and his expressed rejection of U.S. intelligence community assessments in favor of trusting Putin's denials,[61][62][63]
Critics of the theory have noted that it would have been legal[33] and natural for Hillary Clinton, as his political opponent, to publicly point out Trump and his campaign's known Russia connections during a presidential campaign,[14] and Clinton did tell Durham's office that "She had a lot of plans to win the campaign, and anything that came into the public domain was available to her."[25]
The Washington Post notes that the Durham report annex contains[13]
emails among Clinton campaign aides indicating that her team saw then-candidate Trump's ties to Russia as potential campaign fodder and discussed how to highlight the issue for political gain. But the report contains no proof that — as Trump officials and allies have alleged in recent weeks — Clinton and senior U.S. officials close to President Barack Obama schemed to concoct erroneous Trump links to Moscow, sullying his 2016 election victory and first term.
Philip Bump challenged the claim that dishonestly and unfairly linking "Trump to Russia was itself a political tactic by Clinton's campaign". He presented a timeline of events that he wrote showed the claim could not be true, because substantial public evidence of Trump-Russia connections already existed by the time the alleged plan was said to have been created.[64]
The Washington Post also noted the timing and how, at the time this alleged "plan" was concocted, there was already plenty of publicly verified evidence connecting Trump to Russia:[2]
By this point, you'll recall, all of the aforementioned factors were already in play: Trump asking the Russians to hack, his hiring Manafort, Page's Moscow visit, the hack of the DNC and release of material from it, the Australians getting their hackles up. If Hillary Clinton was behind the plan to link Trump to Russia, she had a lot of very unexpected allies in doing so.
Former CIA director John O. Brennan described how, even if "Hillary was trying to highlight the reported connections between Trump and the Russians, if that was accurate and a big if, there is nothing at all illegal about that."[33] He said that "John Ratcliffe and others are trying to portray this as unlawful activity that deserves follow-up investigation by the FBI. No. It was a campaign activity."[33]
Donald Trump did publicly express favorable views toward Russia and Vladimir Putin.[3] Andrew Prokop described why there were good reasons to wonder about Trump's Russia connections:[4]
Trump was notably more respectful of Putin and disdainful of NATO than typical Republicans. The Russian government really did hack Democrats' emails and have them leaked during the campaign. Trump viewed these leaks as highly beneficial to him, touting them constantly on the campaign trail, and even publicly calling on 'Russia, if you’re listening' to find more Clinton emails. There were defensible reasons to wonder about Trump-Russia connections.
David Corn described Clinton's actions as a "natural" reaction, in light of all the published evidence of Russian hacking of the Democratic Party, Russian interference in the 2016 elections, Trump's long history of friendly comments about Vladimir Putin, and Trump's denials that Russia was involved in interfering in the elections to help him:[14]
It would have been quite natural—and not at all inappropriate—for any candidate in Clinton's position to decide to push a narrative about Trump and Russia. Moreover, there was no evidence—Durham found none—that the supposed 'Clinton Plan' triggered the FBI investigation, the origin of which has been well documented.
Cathy Young, writing in The Bulwark, criticized the coverage of the alleged plan by The Federalist, a conservative online magazine and podcast. She wrote that the Federalist had criticized a New York Times story that Young said[21]
correctly notes that the declassified 'Durham annex' disproves the Clinton plan allegations. Look: Here's a passage that says some intelligence officers interviewed by Durham's team, 'well-versed in the Sensitive Intelligence assessment, said that their best assessment was that the Benardo emails were likely authentic'!
Young countered The Federalist's view of that "assessment": "That was early in the Durham investigation, before evidence to the contrary emerged.... In 2025, we know these messages were Russian fabrications, because they were partly patched together from identical passages lifted from real emails by other people."[21]
Jude Sheerin, writing for BBC News, wrote that "There is nothing illegal about a political smear, but Trump allies suggested the email, if genuine, showed that federal investigators could have been part of the scheme. Durham, however, found no proof of such an FBI conspiracy."[23]
Nikki McCann Ramirez described the reactions of several "MAGA Republicans [who] immediately seized on the newly released annex as a smoking gun that proved their allegations." As an example, she named White House Press Secretary Karoline Leavitt, "who told reporters that the documents were 'further evidence that Hillary Clinton approved the Russia Hoax against POTUS... and the FBI and the CIA were both weaponized to accelerate this hoax'."[38]
Ramirez quoted John Solomon, a known promoter of conspiracy theories[65][66][67] and a "longtime Trump ally", who "wrote on X that there is 'smoking gun evidence inside Durham annex. If it is authenticated by further investigation it means liberal mega donor George Soros' team knew the whole Clinton plan for Russiagate hoax.'"
'these intelligence reports and related records, whether true or false, were buried for years,' and in his view contained proof that 'the Obama FBI failed to adequately review and investigate intelligence reports showing the Clinton campaign may have been ginning up the fake Trump-Russia narrative for Clinton's political gain, which was ultimately done through the Steele Dossier and other means.'
In reality, the previously classified documents seem to suggest that some of the supposed 'evidence' Patel and others are touting as proof of their conspiracies was actually fabricated by Russian intelligence.... Durham's assessment is that the emails were likely Frankenstein fabrications, and thus not authentic.
Investigations and findings
FBI's investigation
Lawfare stated that the "FBI assessed these materials in 2016 and again in 2020. It concluded the memos were likely not credible."[28]
The New York Times described how the Durham report's declassified annex documented that the FBI investigated the alleged "Clinton plan" but was "ultimately unable to verify that such a plot existed":[13]
The FBI investigated intelligence reports alleging that 2016 Democratic presidential nominee Hillary Clinton approved a plan for her campaign to vilify opponent Donald Trump by tying him to Russian President Vladimir Putin, but it was ultimately unable to verify that such a plot existed, according to a document the Trump administration declassified and released on Thursday. [July 17, 2025]
Although the FBI investigated the allegation, John Durham was not satisfied with their efforts: "Durham's 2023 report chastised the FBI for not investigating the issue as aggressively as it had probed Trump's ties to Russia."[13]
The government's handling of the Clinton Plan intelligence may have amounted to a significant intelligence failure and a troubling instance in which confirmation bias and a tunnel-vision pursuit of investigative ends may have caused government personnel to fail to appreciate the extent to which uncorroborated reporting funded by an opposing political campaign was intended to influence rather than inform the FBI. It did not, all things considered, however, amount to a provable criminal offense.
The allegation was notable enough that CIA Director John Brennan briefed Obama about it,[69][4] but, because the FBI had investigated the allegation and was skeptical of its validity, it did not devote the same amount of effort to its investigation as it did to investigating the Russian efforts to interfere in the election. Most FBI agents who were asked by Durham's team about it said they were not aware of it,[69] and attitudes toward it varied among agents. One agent, who had not heard of the allegation, was visibly moved and expressed "a sense of betrayal that no one had informed him". Other agents "either didn't buy that the claim was accurate, or thought Durham's team was wildly exaggerating its importance. Another agent, who did recall seeing the intelligence, told Durham's investigators that it was 'just one data point.'"[4]
Durham's investigation
Durham's 2023 final report, and later-declassified 29-page annex to that report, reveal he investigated the alleged plan and was unsuccessful in his efforts to prove the alleged "plan" was a Democratic plot to frame[1][4] Trump and "fabricate the Russia collusion hoax".[1][70]
Durham's investigation devoted "significant attention", spread across 17 pages,[71][25]:81–98 to the alleged plan.[8]The New York Times mentioned the name given to it by Durham: "Among some Trump supporters, the message became known as the 'Clinton Plan intelligence,' as Mr. Durham put it in his final report."[7][27] His report mentioned the phrases "Clinton Plan intelligence" (65 times[8]),[7]"Clinton campaign plan" (six times),[25]:81–98 and "Clinton plan" (or just "plan" when referring to it).[14]
In May 2022,[72] Durham's office interviewed Clinton about the allegation, and when asked if she had reviewed the declassified information about her alleged plan, "She said that it 'looked like Russian disinformation to me; they're very good at it, you know.'"[25][64] She continued, saying that "She had a lot of plans to win the campaign, and anything that came into the public domain was available to her."[25]
Lawfare describes Durham's four reasons why the "memos were likely not credible":[28]
Page 5 of the annex gives four reasons why: hearsay, exaggeration, editorialization, and translation issues. The emails were additionally perceived as suspect. Durham notes that as he progressed through his investigation, there were disagreements about their authenticity among intelligence analysts who read them—some thought the emails might be real; others flagged inconsistencies. But, as the investigation continued, as the annex relates, the case for forgery grew stronger.
Failure to prove "plan" existed
Durham's investigation failed to prove the alleged plan existed,[9][10][11][12] and rather than confirming the alleged plan, Durham's descriptions of the dubious nature of the hacked emails was described by The New York Times as a "debunking".[1]
Durham described the lack of evidence for FBI or CIA involvement:[25]:98[4]
Although the evidence we collected revealed a troubling disregard for the Clinton Plan intelligence and potential confirmation bias in favor of continued investigative scrutiny of Trump and his associates, it did not yield evidence sufficient to prove beyond a reasonable doubt that any FBI or CIA officials intentionally furthered a Clinton campaign plan to frame or falsely accuse Trump of improper ties to Russia. Nor did it reveal sufficient evidence to prove that the mission of the Clinton Plan intelligence from applications to the FISC was a conscious or intentional decision, much less one intended to influence the Court's view of the facts supporting probable cause.
The New York Times cited a concern expressed by Durham: "'Whether or not the Clinton Plan intelligence was based on reliable or unreliable information, or was ultimately true or false,' Mr. Durham wrote, agents should have been more cautious when approaching material that appeared to have partisan origins."[7]
Criticisms of Durham
Criticizing John Durham and his investigation, David Frum described the alleged "Clinton plan" as part of Trump's broader claims of "anti-Trump plotting". He wrote that "Fossilized versions of this defunct counter-allegation can be found strewn through the text of the Durham report" and that "Durham turns over this fossil a few more times before reluctantly relinquishing it." Frum nevertheless emphasized that Durham stopped short of fully endorsing Trump's narrative:[27]
Yet, unlike Trump himself and many in the Trump mediasphere, Durham would not jettison the structure of reality altogether. His report eventually reconciles itself to the delusionary nature of the so-called Clinton Plan. It grudgingly and glancingly accepts that there really was Russian interference in the election of 2016, that it cannot be dismissed as merely the mewling of a scheming Clinton campaign.
Vox criticized Durham's actions when his efforts to "fabricate a scandal" fell "flat":[4]
With his claims of a vast conspiracy to fabricate a scandal falling flat, he's now claiming the Clinton team's criticism of things Trump said publicly is part of a dastardly 'Plan' to tarnish Trump. This is the best he's got, and it's extremely weak stuff. He's grasping at straws to argue that the intelligence that matched what he wanted to hear is true — which is just the behavior he criticized Trump-Russia investigators for.
The New York Times described how Durham buried information favorable to Clinton:[7]
Mr. Durham's report also mentioned that Mrs. Clinton and others in the campaign dismissed the allegation as ridiculous, positing that it was Russian disinformation. But Mr. Durham banished to the annex concrete details he had found that bolstered her campaign's rebuttal, burying until now the conclusion that the email he called the 'Clinton Plan intelligence' was almost certainly a product of Russian disinformation.
At the House Judiciary Committee hearing on the final report by Special Counsel John Durham (June 21, 2023), Representative Jerrold Nadler (D-NY) said:[5]
Mr. Durham similarly flouted guidelines designed to protect third parties from reputational injury when he used his two indictments to accuse the Clinton Campaign of a vast conspiracy that tied Trump to Russia. At the end of the day, Mr. Durham never found what he was looking for.
Broader assessments of veracity
The FBI, Ratcliffe, and Durham, were unable to confirm the authenticity or credibility of the hacked Russian memo, its claims, or the existence of the alleged "plan". Official findings and reliable secondary sources, including an Associated Press fact-check that rated claims by Trump administration officials as "False",[70] found the "Clinton plan" theory unsubstantiated.
The FBI was unable to verify the credibility of the memos or existence of the alleged plot:
Lawfare stated in 2025 that the "FBI assessed these materials in 2016 and again in 2020. It concluded the memos were likely not credible."[28]
The New York Times described in 2025 how the Durham report's declassified annex documented that the FBI investigated the alleged "Clinton plan" but was "ultimately unable to verify that such a plot existed".[13]
Ratcliffe wrote in his 2020 letter to Graham that U.S. intelligence "does not know the accuracy of this allegation or the extent to which the Russian intelligence analysis may reflect exaggeration or fabrication".[29]
Durham wrote in the annex that his office was unable to "determine definitely" whether the intelligence was "entirely genuine, partially true, a composite pulled from multiple sources, exaggerated in certain respects, or fabricated in its entirety".[6] Durham's attempts to substantiate the alleged existence of the alleged "plan" were unsuccessful.[1][4] Sources reported on Durham's findings:
The Washington Post reported in 2025 that Durham's "report contains no proof that — as Trump officials and allies have alleged in recent weeks — Clinton and senior U.S. officials close to President Barack Obama schemed to concoct erroneous Trump links to Moscow".[13]
CNN reported in 2025 that Durham's report concluded that the purported emails at the heart of the theory "appear to be faked".[6]
Mr. Durham was never able to prove any Clinton campaign conspiracy to frame Mr. Trump by spreading information that it knew to be false about his ties to Russia, but he nevertheless used court filings and his final report to insinuate such suspicions.
The Associated Press (AP) fact-checked assertions by Trump administration officials in 2020 and ruled "False" their claim that a declassified letter from the Director of National Intelligence proved Hillary Clinton planned the "Russia hoax" against Trump in 2016. The AP concluded that "[T]he letter in no way proves it was 'Hillary's plan' to look into ties between Trump associates and Russian officials."[70]
12345678Described as a "conspiracy" and "conspiracy theory". The theory has been described as a "vast conspiracy",[4][5] "grand conspiracy",[6] and "conspiracy theory".[14][7] Mother Jones wrote much about the conspiracy theory. Here are a few excerpts:[14]
So why have we returned to Durham's embarrassing failure to prove Deep State skullduggery? His final report—looking to salvage what he could of MAGA's conspiracy theories about the Russia investigation—referred to the "Clinton Plan intelligence."
Still, Durham put this conspiracy theory into play by including it in his report and provided fodder to MAGA conspiracy theorists looking to discredit the Russia investigation on behalf of Dear Leader.
Look at all this, the MAGA crowd exclaimed. It shows there was a Clinton conspiracy!
In this annex, Durham acknowledges that his investigators assessed that the two emails at the heart of this conspiracy theory were "a composite of several emails that were obtained through Russian hacking"...
So this is what we got: An email that was probably fabricated by the Russians cited by Solomon as a smoking gun of an evil Obama conspiracy,...
See also a related note[b] about the many descriptive terms that have been used for the alleged "plan" and its circumstances.
12Many descriptive terms have been used for the alleged "plan" and its circumstances. Here are some of them with the sources using those words, or forms of those words:
See also a related note[a] about how the alleged "plan" has been described as a "conspiracy", "conspiracy theory", and closely related terms.
1234Some points from the Democratic minority appendix to the Senate Intelligence Committee report:[16]:943,944,945,948
The Committee's bipartisan Report unambiguously shows that members of the Trump Campaign cooperated with Russian efforts to get Trump elected.:943
Candidate Trump and his Campaign responded to that threat by embracing, encouraging, and exploiting the Russian effort.:944
The Committee's Report clearly shows that Trump and his Campaign were not mere bystanders in this attack - they were active participants. They coordinated their activities with the releases of the hacked Russian data, magnified the effects of a known Russian campaign, and welcomed the mutual benefit from the Russian activity.:944
There may be some who attempt to minimize the seriousness of Trump's actions, or the actions of his associates, by arguing that these individuals were motivated simply by self-interest or self-promotion. This argument overlooks that when self-interest is intertwined with the goals of a malign Russian influence operation, and when self-interest promotes the known Russian effort while also being promoted by that same Russian effort, then self-interest and Russia's interest become one and the same. Moreover, this argument misunderstands the deep counterintelligence vulnerability that is created when those who seek positions of great power, or proximity to that power, are willing to trade away national security for personal gain.:945
It is our conclusion, based on the facts detailed in the Committee's Report, that the Russian intelligence services' assault on the integrity of the 2016 U.S. electoral process and Trump and his associates' participation in and enabling of this Russian activity, represents one of the single most grave counterintelligence threats to American national security in the modern era.:948
Parts of the dossier have proved prescient. Its main assertion – that the Russian government was working to get Mr. Trump elected – was hardly an established fact when it was first laid out by Mr. Steele in June 2016. But it has since been backed up by the United States' own intelligence agencies – and Mr. Mueller's investigation. The dossier's talk of Russian efforts to cultivate some people in Mr. Trump's orbit was similarly unknown when first detailed in one of Mr. Steele's reports, but it has proved broadly accurate as well.
12Young, Cathy (October 25, 2022). "No, 'Russiagate' Wasn't the Hoax That Team Trump Claims It Was". Cato Institute. Retrieved February 5, 2026. Yet the idea that the Mueller report exposed Russiagate as a 'hoax' rests on a false binary: either Trump and/or his associates actively conspired with Russia, or Trump has been the victim of a 'Russia, Russia, Russia' witch hunt. But there is also another scenario: that Trump ran as a Russia-friendly candidate, Russia interfered in the election to help Trump (as the Mueller report very clearly states), and Trump and his cronies were fine with that. And that scenario is not a hoax or a concoction of the Steele dossier.
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