What Was Crossfire Hurricane? Origins, FISA, and Durham

The Crossfire Hurricane investigation was the FBI’s counterintelligence probe, opened on July 31, 2016, into whether people connected to Donald Trump’s presidential campaign were coordinating with Russian government efforts to interfere in the election. It focused on four campaign-connected individuals, was later folded into Special Counsel Robert Mueller’s inquiry, and produced two government reviews that reached sharply different judgments about whether the FBI had proper grounds to launch it and whether agents handled the surveillance honestly.

How the Investigation Began

In May 2016, George Papadopoulos, an unpaid foreign policy adviser to the Trump campaign, told an Australian diplomat in a London bar that Russia had damaging information about Hillary Clinton in the form of thousands of stolen emails. When hacked Democratic Party emails started appearing online that summer, Australian officials passed the Papadopoulos conversation to the United States. The FBI received the tip on July 28, 2016, and three days later opened Crossfire Hurricane as a full counterintelligence investigation.¹

Because it was a counterintelligence case, its purpose was to identify and counter a possible foreign threat, not to build a criminal prosecution. The FBI’s Counterintelligence Division opened individual cases on four people tied to the campaign: Papadopoulos, former adviser Carter Page, campaign chairman Paul Manafort, and incoming National Security Adviser Michael Flynn.²

Did the FBI Have Grounds to Open It?

Under FBI policy, opening a full investigation requires an “articulable factual basis” that a threat to national security may exist. The bureau treated the Australian tip about Papadopoulos as that basis. The Steele Dossier, often confused with the origin of the case, played no role in the decision to open it.²

Inspector General Michael Horowitz concluded in December 2019 that the FBI had “authorized purpose and adequate factual predication” to open Crossfire Hurricane and found no evidence that political bias drove the decision.³ Special Counsel John Durham disagreed. His 2023 report stated that the FBI possessed no “actual evidence of collusion” when it opened the case, and that launching an investigation of this magnitude on “raw, unanalyzed, and uncorroborated intelligence” was “a noticeable departure” from how the bureau handled comparable situations.¹

The gap between these two conclusions is partly a disagreement about the threshold itself. Horowitz measured the FBI against its own internal standard and found it met. Durham argued that meeting a technical threshold was not enough for an investigation this sensitive, and that agents should have paused to scrutinize the intelligence more carefully before proceeding.

The Carter Page FISA Warrants

The most consequential and controversial part of Crossfire Hurricane was the surveillance of Carter Page. Between October 2016 and June 2017, the FBI obtained four warrants under the Foreign Intelligence Surveillance Act to monitor his communications. Those applications relied in part on reports compiled by Christopher Steele, a former British intelligence officer whom the FBI treated as a confidential source.³

The Inspector General documented 17 “significant errors or omissions” across the four applications. Agents left out information that undercut their own case, overstated the reliability of their sources, and failed to update the court when new evidence contradicted earlier submissions.²

The Steele reporting sat at the center of the problems. The FBI had no independent corroboration for the specific allegations about Page in Steele’s reports when it filed the first application or any of the three renewals. The first application told the court that Steele’s past reporting had been “corroborated and used in criminal proceedings,” a characterization the Inspector General found overstated and not approved by Steele’s handling agent as internal procedures required.²

The problems deepened. When the FBI interviewed Steele’s primary sub-source in January 2017, that person made statements raising serious doubts about the reliability of the allegations in the FISA applications. The bureau did not share this with the court. The FBI also had an open counterintelligence case on another key Steele sub-source and knew Steele himself described that person as a “boaster” prone to “embellishment.” None of that reached the surveillance court either. A later internal review rated Steele’s past criminal reporting as only “minimally corroborated,” directly contradicting what the applications had told the judges.²

One error became criminal. FBI attorney Kevin Clinesmith altered an email from another government agency about Page’s prior relationship with that agency, inserting the words “not a source” before forwarding it to a colleague who relied on the email for a FISA renewal. Clinesmith pleaded guilty to making a false statement and was sentenced to 12 months of probation and 400 hours of community service.⁴

Beyond the FISA warrants, the FBI also used confidential human sources and undercover employees to interact with Papadopoulos, Page, and others. The Inspector General found no evidence that the FBI planted sources inside the Trump campaign or directed anyone to report on its internal operations.²

The Durham Investigation and Its Results

Attorney General William Barr appointed John Durham as Special Counsel in 2020 to examine the origins and conduct of Crossfire Hurricane. His final report, released in May 2023, concluded that the FBI should not have opened a full investigation based on the intelligence it had and that the bureau treated the Trump-related inquiry differently than comparable matters involving the Clinton campaign.¹

Durham’s courtroom results were thinner. Beyond the Clinesmith plea, he brought two other prosecutions: cybersecurity lawyer Michael Sussmann, charged with lying to the FBI about who he represented when he brought information about a possible Trump-Russia connection, and Igor Danchenko, a key source for the Steele Dossier, charged with false statements. Juries acquitted both. Durham’s three-and-a-half-year investigation produced one plea deal ending in probation and two acquittals.

Handoff to Mueller

Deputy Attorney General Rod Rosenstein appointed Robert Mueller as Special Counsel on May 17, 2017, with authority to investigate Russian interference in the 2016 election and related matters.⁵ Crossfire Hurricane’s files, personnel, and evidence moved to Mueller’s office, and the original FBI investigation was formally closed.

Mueller’s final report, submitted in March 2019, reached two headline conclusions. On conspiracy, the investigation “did not establish that members of the Trump Campaign conspired or coordinated with the Russian government in its election interference activities,” while confirming that Russia had interfered “in a sweeping and systematic fashion.” On obstruction of justice, Mueller did not reach a traditional prosecutorial judgment, citing a longstanding Justice Department opinion that a sitting president cannot be indicted, and stated explicitly that the report did not exonerate the president on obstruction.

What Happened to the Four Subjects

Carter Page was never charged with any crime. Despite four FISA warrants targeting his communications, the investigation produced no prosecution against him.

George Papadopoulos pleaded guilty in October 2017 to lying to the FBI about the timing and nature of his contacts with individuals connected to Russia. He served 14 days in federal prison, paid a $9,500 fine, and completed 200 hours of community service. Trump pardoned him in December 2020.

Paul Manafort’s case expanded well beyond the original counterintelligence questions. He was convicted of bank fraud, tax fraud, and failing to disclose a foreign bank account, receiving a combined sentence of roughly seven and a half years across two federal cases. Trump pardoned him in December 2020.

Michael Flynn pleaded guilty in December 2017 to lying to the FBI about his conversations with the Russian ambassador during the presidential transition. The Justice Department moved to drop the case in May 2020, and Trump pardoned Flynn in November 2020 before sentencing was finalized.

Reforms That Followed

The Inspector General’s findings drove both internal FBI changes and legislative action. FBI Director Christopher Wray accepted the OIG’s finding that personnel “did not comply with existing policies, neglected to exercise appropriate diligence, or otherwise failed to meet the standard of conduct that the FBI expects of its employees.” Wray ordered specialized semiannual training for all FBI personnel handling FISA and confidential source matters and reinstated an annual ethics training program that had lapsed. The bureau also committed to reviewing the conduct of employees involved in the 2016-2017 events, though many had already left.⁶

The FBI also revised its internal procedures to reduce the risk of inaccurate information appearing in surveillance applications, adding written justification and approval requirements for queries involving U.S. persons and stricter approval for sensitive categories such as elected officials, political candidates, and media organizations.⁷ On the legislative side, the Reforming Intelligence and Securing America Act, signed into law in April 2024, reauthorized Section 702 of FISA while adding new privacy safeguards and compliance requirements on the FBI’s surveillance authorities.⁸

1
U.S. Department of Justice. Report on Matters Related to Intelligence Activities and Investigations Arising Out of the 2016 Presidential Campaigns
2
U.S. Department of Justice. Review of Four FISA Applications and Other Aspects of the FBI’s Crossfire Hurricane Investigation
3
U.S. Department of Justice Office of the Inspector General. DOJ OIG Releases Review of Four FISA Applications and Other Aspects of the FBI’s Crossfire Hurricane Investigation
4
United States Department of Justice. FBI Attorney Admits Altering Email Used for FISA Application During Crossfire Hurricane Investigation
5
United States Department of Justice. Appointment of Special Counsel
6
Federal Bureau of Investigation. FBI Director Christopher Wray’s Response to Inspector General Report
7
Department of Justice Office of the Inspector General. A Review of the Federal Bureau of Investigation’s Querying Practices Under Section 702 of the Foreign Intelligence Surveillance Act
8
Congressional Research Service. FISA Section 702 and the 2024 Reforming Intelligence and Securing America Act