On September 17, I filed a sworn complaint with the House Committee on Ethics against Rep. Lauren Boebert. I signed it under penalty of perjury. Its central allegation is that Boebert carried on a relationship with her District Director, Clarice Navarro, while Navarro worked under her supervision. That is something the House banned outright after #MeToo.
Boebert’s office called the complaint “utterly false.” Her spokesperson said there was no truth to it whatsoever. That’s her right. The Committee, not her press shop and not me, will decide what the evidence shows.
What she did next is a different matter, and it’s why there is now a Second Amended Complaint. Here is what changed, and why.
Addition 1: Jasmine B. Higgs and the family payroll
The most significant addition is a new count on nepotism, and it centers on a part-time employee most people have never heard of.
Jasmine B. Higgs has been on Boebert’s House payroll since August 25, 2022. Before that, by her own résumé, she was a server and then a manager at Shooters Grill, Boebert’s restaurant in Rifle, until July 2022. She lives in Fruita, outside the district Boebert now represents.
Higgs also lives with Boebert’s brother, Dylan.
Federal law, 5 U.S.C. § 3110, bars a Member of Congress from employing or advancing a relative. “Sister-in-law” is on that list. Colorado recognizes common law marriage, under which two people are legally married if they mutually agree to be married and openly hold themselves out as married. If Higgs and Dylan Boebert meet that test, she is Lauren Boebert’s sister-in-law under federal law, and her employment falls squarely within the statute.
I don’t know whether they’re married, and the amended complaint says so plainly. That’s why the count has a second part that doesn’t depend on the answer. House Rule XXIII requires that staff pay match the work performed. Taxpayers have paid Higgs $282,833.18 through June 2026, at a rate that climbed toward what senior full-time staff earn, for a part-time job. If that pay is tied to a family relationship rather than to the duties, it violates the House rule whether or not there’s a marriage license.
We asked the Committee to do what only it can do: determine Higgs’s marital status and the basis for every raise she received.
There’s an irony here worth noting. Boebert spent 2023 on the Oversight Committee demanding that federal agencies account for employees working from home. She accused federal bureaucrats of “lounging at home.”
Her own constituent services aide lives more than six hours from much of the 4th District. Who supervises her, and how are her hours verified? The Committee should ask.
Addition 2: The protection order, and interference with a House proceeding
Seven days after I filed, Boebert went to Weld County Court and filed for a civil protection order against me. It’s case 2026C1286.
The timing speaks for itself. A Member of Congress who is the subject of a sworn ethics complaint went to court to restrain the person who filed it.
Congress protects its own proceedings by law. Under 18 U.S.C. § 1505, it is a federal crime to corruptly influence, obstruct, or impede, or try to, any inquiry or investigation by either House or any of its committees. Federal law also protects witnesses and complainants from retaliation.
The amended complaint asks the Committee to examine the protection order filing under those standards. It also asks the Committee to examine the public statements from Boebert’s office accusing me of crimes I didn’t commit. The question is simple: were these legal and public attacks aimed at the person who brought the matter to the Committee, and at the people who might testify?
The House cannot police its own members if the people who report misconduct can be dragged into court for doing it, or smeared in the press until they back off. That principle doesn’t depend on whether you like me, or her. It’s how the system protects every complainant, from either party.
Addition 3: The “restraining order” that doesn’t exist
After the complaint became public, a story spread that I was under a restraining order. The New York Post ran it. CBS Colorado aired it, after I had told its reporter in writing that it was false.
It is false. Colorado court records show the 2022 order sought against me was dismissed and vacated. The link the Post used actually points to a court record involving Jayson Boebert, not me.
The amended complaint documents how that falsehood moved from Boebert’s camp into the press. It also documents her office’s public statements accusing me of breaking the law. A Member using her office to smear a complainant goes to whether her conduct reflects creditably on the House. That is the standard Rule XXIII sets.
Addition 4: More witnesses and more records
The amended complaint adds witnesses with direct knowledge of the events it describes. It also adds a compiled exhibit volume built from public records: House Statements of Disbursements, FEC filings, and Colorado court dockets. Where the evidence is video, it is linked directly.
Every new factual claim was checked against an official source before it went into a sworn filing. Where I couldn’t verify something, I left it out or said so.
What happens now
The Committee decides. I’ve done what a citizen can do: put my name on a sworn document, given everyone named a chance to respond before publication, and published the one response I received in full and unedited.
Boebert has a choice too. She can answer the complaint on the merits. Or she can keep doing what she’s done so far.
If you have tips, contact david@americanmuckrakers.com.
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About the Author
David B. Wheeler is the president and co-founder of American Muckrakers, the Western North Carolina accountability organization best known for helping end Madison Cawthorn’s congressional career in 2022, the rare instance in modern politics of a sitting incumbent losing his own primary because somebody bothered to do the homework. Since then, American Muckrakers has turned its attention to Lauren Boebert, Ken Paxton, and a growing roster of politicians who confuse public office with a personal ATM. He publishes accountability journalism at Muckrakers.Today.
Wheeler co-hosts the MUCK YOU! podcast with Col. Moe Davis, the retired Air Force colonel and former chief prosecutor at Guantanamo Bay. He is the author of Color the Crooks, Case File #001: Lauren Boebert, the coloring book James Carville endorsed with the words “She earned every damn page. Buy it.” *He is also the founder of VoteROI.com, a political data company built on 86.9 million FEC records that helps donors figure out where their money actually goes, which, as this essay makes clear, is a question more people should be asking.
Before all that, Wheeler spent three decades in politics, elections, and event production in more than 50 countries on all seven continents. Along the way he lowered the Mississippi River, produced the first professional sports event ever held in Moscow, and produced the first marathon ever run on Antarctica. His political education started early: Page for the Iowa House of Representatives, intern in the United States Senate, and National Committeeman for Iowa on the Young Democrats of America national committee. David was the lead advance guy for then Senator Obama in Iowa City, Iowa, in October of 2006, and then again during his presidential announcement in Waterloo, Iowa, in February 2007. And, he has some good stories from both experiences.
An Iowa native and proud Hawkeye, Wheeler is a father of three and lives in the mountains of Western North Carolina, in the district Chuck Edwards is currently failing. He believes sunlight is the best disinfectant, filings don’t lie, and the loudest guy in the room is usually the one with the most to hide.
And, Beetlejuice Boebert claimed she was going to sue him. She never did, so David sued her in Federal Court in Denver and partially won.
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This publication is First Amendment protected speech and commentary on matters of public concern. All individuals referenced are presumed innocent unless and until proven guilty in a court of law. No portion of this publication may be used for commercial purposes without the written consent of American Muckrakers PAC, Inc. and David B. Wheeler.