The purported emails referenced in the Russian memoranda were obtained in 2016 by Dutch intelligence after it hacked into Russian intelligence systems.[1] The material was shared with the U.S. intelligence community, which treated it with caution, citing the possibility that it had been exaggerated or deliberately mixed with disinformation.[1] Some of the material was later included in a classified annex to the Durham report, which was publicly released two years after the main report.[3][2] Durham's material included communications between two Russian intelligence officers discussing plans to create intelligence reporting underlying the alleged plan.[6]
In his 2023 final report, Durham investigated intelligence describing the alleged plan, acknowledging uncertainty about its accuracy but not establishing that Clinton or government officials coordinated a scheme to fabricate evidence against Trump.[7][8]The New York Times reported that Durham's discussion of the emails described them as likely composites derived from unrelated hacked material and characterized portions of his analysis as a "debunking" of the central allegation.[1][2]
The "Clinton plan" theory has been described as a right-wing[13][14][15]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[a] to fabricate an alleged "Russia collusion hoax"[1][4] by "falsely"[4] asserting that Donald Trump had improper ties[16] 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 cites then–Director of National IntelligenceJohn Ratcliffe's[17] original description of the alleged "Clinton plan", a wording that only mentions Putin and the hacking of the DNC, not other Russia-related objects of the alleged plan. It also includes the intelligence community's (IC) skeptical view of the allegation:[18]:81[19]: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".[12][20]
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'."[21][1][22] Elsewhere in the report, he referred to it as the "Clinton plan".[21][1]
Framing and characterizations
Durham's formulation of the "Clinton Plan Intelligence"
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'."[21][1] The alleged plan was further described in a classified 29-page annex to the Durham report,[9] which was not publicly released or declassified until July 31, 2025, two years after the publication of the main report.[3][2]
An analysis of evolving wording changes was made by Marcy Wheeler, who observed that Ratcliffe's original version of the alleged plan, which only mentioned Putin and the "Russians' hacking of the Democratic National Committee", was later broadened by Durham, who added the word "false", a claim absent from the Russian materials. Wheeler accused Durham of inventing "out of thin air that Hillary's plan included false information":[23]
First, it's not just that Durham focused his entire investigation on potential Russian disinformation with little worry about doing so. At least per what is in the unclassified report, Durham added something to the Russian intelligence product: That Hillary had a plan to spread 'false' information.
She then cited where Durham adds the word "false", explaining that "Durham's first paragraph explaining why the Russian intelligence claim about a Hillary plan is important claims":[23]
First, the Clinton Plan intelligence itself and on its face arguably suggested that private actors affiliated with the Clinton campaign were seeking in 2016 to promote a false or exaggerated narrative to the public and to U.S. government agencies about Trump's possible ties to Russia.[18]:82
Wheeler wrote how, even though he added "false", and that "false is nowhere in any of the three formulations of the intelligence Durham describes",[23] "Durham noted in a footnote to this paragraph — oppo research is not itself illegal. It only becomes illegal if you intentionally lie to the government about it." She then quotes Durham's Footnote 393:[18]:82 "To be clear, the Office did not and does not view the potential existence of a political plan by one campaign to spread negative claims about its opponent as illegal or criminal in any respect." She describes how Durham's effort was still an "attempt to criminalize Hillary's effort to hold Trump politically accountable":[23]
I'd like to talk about Durham's treatment of what he calls the 'Clinton Plan' in his report, an attempt to criminalize Hillary's effort to hold Trump politically accountable for his coziness with Russia.... Durham, however, names it the 'Clinton Plan,' accepting as given that the Russian intelligence product he bases it on is truthful, even while admitting that the intelligence community believes it may not be.
Described as a conspiracy theory
Several sources have characterized Durham's "Clinton plan intelligence" formulation as a conspiracy theory.[a]
Molly Roberts, a senior editor at Lawfare, wrote that Trump's "Grand Conspiracy" theory "fails on both the narrative and legal coherence fronts": "Its proponents allege a plot against Trump that somehow manages to connect Hillary Clinton, Barack Obama, and James Comey to Joe Biden, Merrick Garland, and Jack Smith." She frames the "Clinton plan" conspiracy theory as part of an alleged larger conspiracy against Trump.[24] She also noted a possible reason for the two-year delay:[24]
The Grand Conspiracy believers generally neglect to mention that Durham left this material out of his report because it was based on documents evaluated as likely forgeries. That truth, of course, would have risked interrupting the gripping tale of the Grand Conspiracy.
David Corn described expectations among Trump allies about the Durham special counsel investigation:[9]
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".[9] Savage described how Durham and Barr then changed their focus from attacking U.S. intelligence and "Deep Staters" to an attack on Hillary Clinton:[8]
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 the theory in 2020
In 2016, then-CIA director John Brennan briefed President Obama and other senior officials about the intelligence in August 2016 and referred it to the FBI.[25] Two FBI assessments from 2016 and 2020 then found the Russian materials were "likely not credible", according to Lawfare.[26]
Nevertheless, in October 2020, then–Director of National IntelligenceJohn Ratcliffe declassified portions of Brennan's handwritten notes from the 2016 briefing. Ratcliffe stated that the intelligence community was unable to corroborate whether Russia actually knew of such a Clinton plan or whether the information was fabricated.[27] He also declassified[1] some other information from the hacked Russian memos, which he described in a letter to Senate Judiciary Committee Chairman Lindsey Graham on September 29, 2020.[17] Graham released it the same day.[28]
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".[29]
A fact-check by the Associated Press noted how the letter's release "hours before the first presidential debate in the upcoming election sparked a flurry of posts on social media, many of them misrepresenting its contents as proof of wrongdoing by Democrats".[30]
Sonam Sheth reported that Ratcliffe's release of the material on September 29, 2020, appeared to "mirror Moscow's ongoing disinformation campaign against the former secretary of state".[31][b]
Vox reported that Ratcliffe was criticized for giving credibility to Russian material by declassifying and releasing the information against the advice of intelligence officials and "without knowing its veracity", in what critics described as an effort to hurt Clinton while helping Trump during his debate with Joe Biden:[32]
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".[12] Ratcliffe told CBS News that he had "declassified the additional documents 'at the direction of President Trump'".[33]
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".[12]
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."[33]
Former-CIA director John Brennan accused Ratcliffe of "selectively declassifying" information "to advance the political interests of Donald Trump", adding that even if the Russian allegations were accurate, there would be "nothing at all illegal" about Clinton highlighting Trump's reported connections to Russia.[25]
Senator Ron Wyden accused Ratcliffe of politicization of "unverified Russian information":[34]
'His politicization of intelligence, including through selective releases to political allies, damages the country and undermines the intelligence community he purports to lead,' Wyden said in a statement. 'Ratcliffe is even willing to rely on unverified Russian information to try to concoct a political scandal — a shocking abdication of his responsibilities to the country.'
Cathy Young wrote: "Outside the MAGA camp, most people were appalled that Ratcliffe and Graham were laundering unverified intelligence at best and Russian disinformation at worst."[35]
Career intelligence professionals expressed their concerns:[32]
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.
Several news outlets described the episode as reflecting concerns about the politicization of intelligence and the public dissemination of unverified or potentially misleading material.
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:[22]
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.
The New York Times described how the Trump administration and Republicans on the House Intelligence Committee ignored concerns that the Russian memos might contain misinformation:[2]
The Trump administration has also declassified and released a report by Republicans on the House Intelligence Committee that summarized unflattering claims about Mrs. Clinton from the Russian memos without flagging suspicions that the trove contained misinformation.
The hacked emails originated from a broader Russian government cyber-espionage campaign targeting Democratic Party organizations during the 2016 presidential election. Lawfare described this history:[26]
[T]hroughout 2015 and 2016, the Russian military intelligence agency the GRU hacked targets including the Democratic National Committee (DNC), the Clinton campaign, Open Society Foundations, the Carnegie Endowment for International Peace, and other think tanks seen as promoting liberal internationalism. Russian military intelligence then selectively leaked the hacked material, usually with the intent of embarrassing the target at a strategic time.
Then they manipulated[37] some of those emails to create an unproven "Clinton plan" conspiracy theory to again harm Clinton and help Trump,[36][32] and this disinformation[b] was then relaundered[38] to aid Trump's second election campaign.[30][29][33][25]
Provenance of the purported 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."[26]
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; and the Dutch later hacked them from the Russians and shared them with U.S. intelligence.[22]
The emails were subsequently released by Trump administration officials, who treated them as legitimate despite unresolved concerns about their handling and reliability,[14] given that it was possible the Russians had "deliberately mixed in disinformation".[1][b]
Authenticity and fabrication findings
Numerous reliable sources described the purported "Clinton plan intelligence" as likely Russian "disinformation"[b] treated with caution by U.S. officials, who warned it could have been exaggerated or deliberately seeded by Russian actors. Reporting by The New York Times, PBS, and other outlets said investigators and intelligence officials viewed the material as possible or probable Russian disinformation and criticized its public release and political use despite doubts about its authenticity. Journalists and analysts have also described how promotion of the alleged "plan" has amplified Russian disinformation in a politically motivated manner that supports Trump.[b]
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:[3]
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][2][22]
U.S. intelligence explained the reasons for their caution:[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.
Durham's report contains the hacked source material showing Russian planning. Marcy Wheeler cites part of that planning between two Russian spies who developed the material used for the "Clinton plan" conspiracy theory:[6]
This email between two Russian spooks says, let's do something 'about a task from someone, I don't know, some dark forces, like the FBI, or better yet, Clinton sympathizers in IC, Pentagon, Deep State (or somewhere else?), about American websites deploying a campaign to demonize the actions of Russia's GRU.' This email between two Russian spooks effectively says, 'Let's do something about a campaign to demonize Trump.'
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.'"[2]
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.'"[2] The Associated Press similarly reported that Benardo "told Durham's team he had never sent the email and the alleged recipient said she never recalled receiving it".[41]
CNN reported that Durham's report concluded 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".[37] The New York Times likewise reported 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.[2]
Nikki McCann Ramirez summarized that 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," adding that Durham's assessment was that the emails were likely "Frankenstein fabrications" and not authentic.[42]
Cathy Young, writing in The Bulwark, criticized coverage of the alleged plan by The Federalist, a conservative online magazine and podcast. She wrote that the Federalist had attacked a New York Times story that, in her view,[35]
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 argued that this assessment reflected an early stage of the Durham investigation and that later findings reached a different conclusion. She wrote: "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."[35]
Charlie Savage and Adam Goldman described how Durham, in his subsequent investigation, reported that Julianne Smith said[c] 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".[2]
Institutional and journalistic assessments
The Open Society Foundations rejected the allegations outright, calling the emails "crude forgeries"[43] and stating that claims it helped orchestrate an FBI investigation were "outrageous and false" and grounded in "malicious disinformation"[b] traced to Russian intelligence that was later used in a "politically motivated campaign".[37][39][3]
Savage and Goldman wrote that 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.[2]
Commenting on Durham's findings, The Guardian wrote that although the annex was released in "heavily redacted form" and Durham upheld Benardo's disavowal, the emails in the Russian material appeared to have "been cobbled together from other individuals' emails to produce something more incriminating than the actuality".[44]
Kept in a classified annex for two years
Timeline of classification and release
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."[45][18][7]
Two years later, the annex was declassified and released by Senator Chuck Grassley on July 31, 2025, following declassification approvals involving Pam Bondi, Kash Patel, and elements of the intelligence community.[3][2]
Findings revealed by the annex
On the day the annex was released, Charlie Savage and Adam Goldman reported that Durham's own findings undermined the claim that the Clinton campaign conspired[a] to frame Trump:[2]
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 similarly assessed that the material was likely kept classified because it was considered "highly likely a fabrication of Russian intelligence" intended to "create a false picture of the so-called Clinton plan", concluding that the document showed Russian operatives had forged material to implicate Clinton.[46]
Contemporary reactions and political framing
Following the annex's release, Kash Patel claimed that he found the document inside "burn bags" within a "secret room" at the FBI and delivered it to Senator Chuck Grassley, who posted it on his Senate website as newly declassified material.[26]
Lawfare described the rollout as "bizarre" and "pure political theater" designed "to conjure a little spy-movie mystique: burn bags, hidden rooms, Russian intrigue," and 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".[14][26]
Several sources discussed possible reasons Durham kept the material classified in an annex,[46][35] placed it in burn bags,[47] and did not include it in his final report, with one describing the underlying material as "so suspect that John Durham himself declined to include them in his final report".[26]
Cathy Young argued that there was a disconnect between Patel's claims and the contents of the Durham report, questioning why Durham would have confined supposedly explosive material to a classified annex.[35]
Marcy Wheeler wrote that Patel, Ratcliffe, and Durham appeared to recognize that the underlying intelligence was fabricated, yet they continued to act while knowing that:[47]
... you have evidence that Kash, Ratcliffe, and Durham himself knew the SVR intended to falsely accuse Hillary, then took investigative steps based on those allegations that were clearly fabricated. They took four whole years of investigative steps. No wonder Durham allegedly tried to bury all this in burn bags.
Earlier fact-checking had similarly questioned the underlying intelligence. Saranac Hale Spencer, writing for FactCheck.org, examined claims that the alleged plan to "vilify" Trump was part of a "Russian collusion hoax" designed to attack Trump:[48]
President Donald Trump and his supporters on social media are citing unverified 'Russian intelligence' from 2016 as evidence that Hillary Clinton 'was behind the entire Russian collusion hoax.' But that so-called intelligence is largely a reflection of publicly available information at the time. Federal investigations since then have documented multiple links between Trump associates and individuals tied to the Russian government.
Relitigation in 2025 of Russian interference investigation 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.[3] Those investigations had concluded that Vladimir Putin intervened in the 2016 contest to help Trump.[3] The July 31, 2025, release of material related to the alleged "Clinton plan" formed part of these renewed relitigation efforts.[3]
The Washington Post described the administration's actions as a series of "document dumps":[3]
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.
Charlie Savage described the 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]
Nikki McCann Ramirez similarly linked the renewed focus on the Russia investigation to controversy surrounding Epstein, writing:[42]
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 also noted a parallel set of accusations regarding motive. Trump's allies accused Clinton of advancing the alleged "Clinton plan" to distract from the scandal over her use of a personal email server while secretary of state,[1] while Democrats accused Trump and his allies of reviving and relitigating the allegation to distract from the furor surrounding the Jeffrey Epstein files.[2][42]
Nikki McCann Ramirez reported that several "MAGA Republicans immediately seized on the newly released annex as a smoking gun that proved their allegations." She cited 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".[42]
Ramirez also cited Senator Chuck Grassley, who said that "these intelligence reports and related records, whether true or false, were buried for years", and argued that they showed "the Clinton campaign may have been ginning up the fake Trump-Russia narrative for Clinton's political gain".[42]
John Solomon used his outlet Just The News[49] to promote claims related to the alleged "Clinton plan" and to criticize Biden. Solomon has been described by multiple news outlets as a longtime Trump ally and as having promoted conspiracy theories, including playing a central role in advancing the Biden–Ukraine conspiracy theory.[50][51][52]
Anadolu Agency reported that an August 1, 2025, Just The News article about the alleged "plan" "comes amid efforts by the Trump administration to say reports of these ties were in fact a plot to subvert democracy and that its perpetrators should be prosecuted". The outlet further noted that "The ties between Trump's campaign and Russia were later confirmed by multiple US intelligence reports and a bipartisan congressional committee chaired by Marco Rubio, currently Trump's US secretary of state."[49]
Denial of previous findings about Trump-Russia matters
While Donald Trump and his surrogates have consistently denied or sought to minimize findings that Vladimir Putin intervened in the 2016 contest to help Trump, the conclusions of multiple investigations have contradicted those denials.[3]
Trump and his supporters have sought to distance him, his campaign, and his election from Russian election interference, including allegations that his campaign cooperated with those efforts.[53]:943[d] He has repeatedly rejected the findings of investigations into those matters.
Reporting described these actions by Trump and senior intelligence officials as an effort to reinterpret or revise the public understanding of the 2016 election and the conclusions of the Mueller investigation and the FBI's Crossfire Hurricane inquiry.[10][11][12]
Eric Tucker and Chris Megerian described the Durham report and its declassified annex as the administration's latest attempt to revisit the history of the Russia investigation, writing that the report "downplayed the extent of Russian interference in the 2016 election...".[54]
Although the existence of the alleged plan had been publicly known since at least 2020,[3] in July 2025, senior administration officials renewed efforts to advance the alleged "Clinton plan" narrative, citing the disputed emails in an effort to relitigate the presidential election of nearly nine years earlier and refute prior investigative findings.[1][3]
John Durham sought to determine whether the alleged "plan" represented a Democratic effort to frame Trump and fabricate the "Russia collusion hoax", but his investigation did not substantiate those claims.[1][4]
Charlie Savage summarized the allegation as the theory that Clinton and her campaign knowingly put forward false information to frame Trump for collusion, thereby shifting blame for the suspicions that led to the Mueller investigation.[1]
Democrats argued that allegations advanced by Trump officials such as Tulsi Gabbard were rebutted by the findings of the Durham investigation, the Mueller special counsel, the Justice Department inspector general, and the Senate Intelligence Committee, all of which concluded that Russia interfered in the 2016 election to help Trump.[37]
These investigations found that Russia interfered in the 2016 election in a "sweeping and systematic fashion",[56] including an influence campaign personally ordered by Vladimir Putin,[36][57] and that the Russian government sought both to undermine public confidence in U.S. democratic processes and to favor Trump over Hillary Clinton.[36][58] Russia carried out cyberattacks targeting both major political parties, but selectively released material stolen from Democratic organizations in order to harm Clinton's campaign.[36] Several of these findings aligned with early reporting in the Steele dossier,[e] while other allegations were corroborated by separate investigations.
Investigations further documented secretive contacts between Trump campaign officials and Russian officials and agents,[60][61][62] and concluded that the campaign's interactions with Russian intelligence services posed a "grave" counterintelligence threat.[63][d] The Senate Intelligence Committee reported that members of the Trump campaign welcomed Russian election interference, expected to benefit from the Kremlin's help,[63] were receptive to Russian assistance,[64] and reacted by encouraging, exploiting, and coordinating with those efforts.[65][66][d]
The Democratic minority appendix to the Senate Intelligence Committee report stated:[d][53]
The Committee's bipartisan Report unambiguously shows that members of the Trump Campaign cooperated with Russian efforts to get Trump elected.[53]:943
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.[53]:948
Investigations and reporting also found that Trump and his associates made false or misleading statements about Russian election interference and their Russia-linked actions,[67][68][69][70][71] and that Trump later engaged in conduct that obstructed investigations into these matters, as described by Mueller.[56]PolitiFact named Trump's assertions "that Russia's meddling in the 2016 election is fake news, a hoax or a made-up story" as its "Lie of the Year" for 2017.[72]
Together, these findings document the scope and objectives of Russian interference in the 2016 election and describe how the Trump campaign responded to it, standing in contrast to subsequent denials and attempts to relitigate those conclusions.
Debate over characterization of Clinton campaign activity
Competing interpretations of campaign conduct
Clinton addressing email controversy with the media at the UN Headquarters on March 10, 2015
The "Clinton Plan" theory alleges that Hillary Clinton approved a campaign strategy to invent or amplify false claims tying Donald Trump to Russia and Vladimir Putin.[1][4]
Critics of the "plan" theory argue that it improperly recasts Clinton's campaign messaging about Trump and Russia as a covert and false conspiracy. They contend that her public highlighting of Trump's statements and conduct regarding Russia, including his rejection of U.S. intelligence assessments in favor of Putin's denials, was factual and ordinary political advocacy rather than evidence of a coordinated and false scheme.[73][74][5]
Trump did publicly express favorable views toward Russia and Putin,[75] and Andrew Prokop wrote that there were defensible reasons to question Trump's Russia connections during the 2016 campaign:[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.
Critics further noted that it was legal[25] and politically routine for Clinton, as Trump's opponent, to highlight the publicly reported Russia-related connections involving Trump and his campaign.[9] Clinton told 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."[18]
Former CIA director John O. Brennan similarly stated that even if Clinton sought to emphasize reported connections between Trump and Russia, "there is nothing at all illegal about that".[25] He said that efforts to portray such conduct as unlawful campaign activity were misplaced, adding: "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."[25]
David Corn described Clinton's actions as a "natural" reaction given the public evidence of Russian hacking of the Democratic Party, documented Russian interference in the 2016 election, Trump's favorable comments about Putin, and his denials that Russia interfered to help him:[9]
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.
Writing for FactCheck.org, Saranac Hale Spencer wrote: "She was responding to Russia's actions and Trump's words. There is no evidence that she was responsible for the federal counterintelligence investigation into the Trump campaign ties with Russia."[48]
The Washington Post reported that while the Durham annex contained emails among Clinton campaign aides discussing how Trump's Russia ties could serve as political messaging, it contained no proof that Clinton or senior Obama administration officials schemed to fabricate false links between Trump and Moscow:[3]
... 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.
Timing and investigative trigger
Commentators also examined the chronology of events, arguing that the timeline undercut these allegations. They noted that rather than a "plan" by Clinton triggering investigations into Trump's relations with Russia and Russia's efforts to help his electoral chances, her campaign was highlighting developments that were already underway and publicly known.
Philip Bump challenged the claim that linking Trump to Russia was itself a dishonest political tactic invented by Clinton's campaign. He presented a timeline showing that substantial public evidence of Trump-Russia connections already existed by the time the alleged "plan" was said to have been created.[40]The Washington Post similarly noted that by the time of the alleged plan, numerous events were already publicly known, including Trump's public appeal to Russia to find Clinton's emails,[76] Paul Manafort's hiring, Carter Page's Moscow visit, the hacking of the Democratic National Committee, and the release of stolen materials.[15]
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.
Dan Friedman also emphasized the timing, arguing that Durham's attempt to attribute the origins of the Russia investigation to Clinton's alleged July 26 approval was chronologically implausible.[22] He wrote that multiple factors prompting the FBI to open an investigation were already in motion before that date, concluding: "This isn't just false. It would require time travel. Durham himself confirms that the FBI launched its investigation into Trump and Russia based on events that occurred months prior to Clinton's alleged July 26 approval of the plan."[22] Friedman also criticized efforts to blame Clinton for noticing what Marcy Wheeler described as Trump's "coziness with Russia".[23]
Some Trump administration officials and conservative commentators have claimed that the alleged "Clinton plan" or the Steele dossier triggered the FBI's "Crossfire Hurricane" investigation into secretive contacts between Trump associates and Russian officials. Reporting has identified the investigation's trigger as a tip from the Australian government concerning comments by a Trump campaign adviser,[41] rather than the supposed "Clinton plan" conspiracy theory[a] or the Steele dossier.
Investigations and findings
The investigations by the FBI and by Special Counsel John Durham addressed the allegation separately and reached different procedural conclusions regarding its handling, though neither established evidence of a coordinated campaign plot.
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."[26]
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":[3]
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]
The Washington Post described how the Russian document had influenced the FBI's investigation into Clinton's use of a private server and was unreliable, possibly fake, and "bad intelligence":[78]
But according to the FBI's own assessment, the document was bad intelligence — and according to people familiar with its contents, possibly even a fake sent to confuse the bureau. The Americans mentioned in the Russian document insist they do not know each other, do not speak to each other and never had any conversations remotely like the ones described in the document. Investigators have long doubted its veracity, and by August the FBI had concluded it was unreliable.
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."[3]
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 president Obama and vice-president Biden about it,[80][4] but, because the FBI had investigated the allegation and was skeptical of the validity of the emails, it did not devote the same amount of effort to its investigation as it did to investigating the many sources of information documenting the Russian efforts to interfere in the election. Most FBI agents who were asked by Durham's team about the allegation said they were not aware of it,[80] 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 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][30]
Durham acknowledged that the intelligence was a "product of a foreign adversary" and cited DNI John Ratcliffe's warning that its accuracy was unknown and might reflect "exaggeration or fabrication",[28] but wrote that his office nevertheless investigated the bases for and credibility of the intelligence. He wrote:[18]:83
As was declassified and made public previously, the purported Clinton Plan intelligence was derived from insight that 'U.S. intelligence agencies obtained into Russian intelligence analysis.' Given the origins of the Clinton Plan intelligence as the product of a foreign adversary, the Office was cognizant of the statement that DNI Ratcliffe made to Senate Judiciary Chairman Lindsey Graham in a September 29, 2020 letter: 'The [intelligence community] does not know the accuracy of this allegation or the extent to which the Russian intelligence analysis may reflect exaggeration or fabrication.' Recognizing this uncertainty, the Office nevertheless endeavored to investigate the bases for, and credibility of, this intelligence in order to assess its accuracy and its potential implications for the broader matters within our purview.
Durham's investigation devoted "significant attention", spread across 17 pages,[81][18]:81–98 to the alleged plan.[22]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."[2][21] His report mentioned the phrases "Clinton Plan intelligence" (65 times[22]),[2] "Clinton campaign plan" (six times),[18]:81–98 and "Clinton plan" (or just "plan" when referring to it).[9]
In May 2022,[82] 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.'"[18][40] 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."[18]
Lawfare describes Durham's four reasons why the "memos were likely not credible":[26]
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
Trump-appointed special counsel John Durham also examined the alleged "plan", but his attempts failed to prove the alleged plan existed,[1][4][7][83][8][13] and rather than confirming the alleged plan, Durham's descriptions of the dubious nature of the hacked emails were characterized by The New York Times as a "debunking".[1]
Durham described the lack of evidence for FBI or CIA involvement:[18]: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.
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.
Jude Sheerin, writing for BBC News, stated 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."[43]
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."[2]
Criticisms of Durham
Criticizing John Durham and his investigation, David Frum described the alleged "Clinton plan" as part of Donald Trump's broader claims of "anti-Trump plotting", writing that "fossilized versions of this defunct counter-allegation can be found strewn through the text of the Durham report" and that Durham ultimately "reconciles himself to the delusionary nature of the so-called Clinton Plan" while acknowledging Russian interference in the 2016 election.[21]
Other commentators likewise argued that Durham's claims amounted to sweeping and unsubstantiated insinuations. Vox wrote that his claims of a vast conspiracy "fell flat" and amounted to "extremely weak stuff",[4] while The New York Times reported that Durham had relegated to a classified annex evidence supporting Clinton's rebuttal, including a conclusion that the purported "Clinton Plan intelligence" was almost certainly Russian disinformation.[2]
Lawmakers and analysts also said Durham suggested wrongdoing without producing charges. Representative Jerry Nadler stated that Durham accused the Clinton campaign of a conspiracy tying Trump to Russia yet "never found what he was looking for",[77] and reporting noted that Durham used court filings to insinuate a theory he did not ultimately charge, thus providing fodder for conservative media coverage.[22][8]
Some commentators further argued that Durham's conclusions relied on dubious or fabricated material. Marcy Wheeler wrote that composite emails attributed to Clinton-related figures appeared to have been fabricated by Russian intelligence,[47] yet were nevertheless treated as investigative leads, concluding that the premise of Durham's inquiry rested on misattributed intelligence claims: "Durham insanely judged that a hack victim, trying to find out if the FBI was investigating the hack, was part of a plot to frame Donald Trump."[84]
It's not just that John Durham never charged Smith in his conspiracy conspiracy theory. It's that his case was grotesquely stupid. And, he himself concluded that his conspiracy conspiracy theory was based on composite emails — pretending to be raw intelligence — that the SVR fabricated into an attempt to frame Smith. As I show here, even the premise of his investigation involved treating SVR claims as Smith's own.
Broader assessments of veracity
Multiple official reviews and independent news organizations evaluated the credibility of the purported Russian intelligence and the alleged "Clinton plan" and found no verified evidence that such a coordinated campaign plot existed.
The FBI assessed the underlying materials in both 2016 and 2020 and concluded the memos were likely not credible.[26] Reporting on the Durham report's declassified annex likewise noted that the FBI had investigated the allegation but was "ultimately unable to verify that such a plot existed".[3]
In 2020, Director of National Intelligence John Ratcliffe stated that U.S. intelligence agencies "do not know the accuracy of this allegation or the extent to which the Russian intelligence analysis may reflect exaggeration or fabrication".[28] Durham's own annex later acknowledged that his office could not "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".[37] Although Durham devoted significant attention to the allegation, he did not establish proof of a coordinated Clinton campaign conspiracy.[1][4]
News organizations similarly reported that Durham's findings did not substantiate the theory. The Washington Post wrote that the report "contains no proof" that Clinton or senior Obama administration officials schemed to fabricate false links between Trump and Moscow.[3] CNN reported that the emails central to the theory "appear to be faked".[37]The New York Times stated that Durham "was never able to prove any Clinton campaign conspiracy to frame Mr. Trump".[2]
In 2020, an Associated Press fact check rated as "False" claims that a declassified intelligence letter proved Clinton planned the so-called "Russia hoax", concluding that the letter "in no way proves it was 'Hillary's plan' to look into ties between Trump associates and Russian officials".[30]
Smith stated that she did not specifically remember proposing a plan to Clinton or other campaign leadership to try to tie Trump to Putin or Russia. Smith stated, however, that it was possible that she had proposed ideas on these topics to the campaign's leadership, who may have approved those ideas. Smith recalled conversations with others in the campaign expressing their genuine concerns that the DNC hack was a threat to the electoral system, and that Trump and his advisors appeared to have troubling ties to Russia. Smith said it was also possible someone proposed an idea of seeking to distract attention from the investigation into Secretary Clinton's use of a private email server, but she did not specifically remember any such idea.
12345Some points from the Democratic minority appendix to the Senate Intelligence Committee report:[53]: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.[53]:943
Candidate Trump and his Campaign responded to that threat by embracing, encouraging, and exploiting the Russian effort.[53]: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.[53]: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.[53]: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.[53]: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.
↑Young, 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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