Oppose DOJ Rule Delaying State Bar Ethics Investigations

I am writing to urge you to oppose the Department of Justice's proposed rule under Docket No. OAG199, which would allow DOJ to delay state bar ethics investigations into its own attorneys. This rule would require DOJ to review state bar complaints against its attorneys first and request that state bars suspend their investigations until DOJ completes its internal review. State bar discipline is fundamentally different from internal DOJ review or congressional oversight because it attaches directly to an attorney's license. An attorney can leave a job or outlast an administration, but a state bar complaint follows their law license permanently. State bars operate independently, outside the chain of command, and don't report to DOJ or the White House. This independence is precisely what gives them power as a check on attorneys acting in the name of the federal government. Delay is not neutral in oversight processes. When investigations are delayed, they lose momentum, witnesses become harder to reach, and evidence becomes neglected or ignored. The attorney in question stays active and insulated during the critical window. A complaint that takes three years to investigate doesn't have the same impact as one that takes six months. Even if state bars retain final authority, the damage occurs long before any final decision is made. The proposed rule applies to allegations tied to a DOJ attorney's official federal duties. While DOJ claims this doesn't strip state bars of authority, the delay itself undermines accountability. This creates a procedural choke point that sounds reasonable on paper but makes consequences structurally impossible to deliver on time. I ask that you publicly oppose this rule and submit comments to Regulations.gov under Docket No. OAG199 before the 30-day comment period closes. I also urge you to encourage your constituents to submit their own comments on this docket. Independent oversight of federal attorneys is essential to maintaining the rule of law, and this rule would fundamentally weaken that oversight.