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Investigations

When judges get free trips to luxury resorts, disclosure is spotty.

Tom Dreisbach

Tom Dreisbach

Carrie Johnson 2016 square

Carrie Johnson

joint travel regulations resort fee

Many federal judges receive free rooms and subsidized travel to luxury resorts for legal conferences. NPR found that dozens of judges did not fully disclose the perks they got. Chelsea Beck for NPR hide caption

Many federal judges receive free rooms and subsidized travel to luxury resorts for legal conferences. NPR found that dozens of judges did not fully disclose the perks they got.

Dozens of federal judges failed to fully disclose free luxury travel to judicial conferences around the world, as required by internal judiciary rules and federal ethics law , an NPR investigation has found. As a result, the public remained in the dark about potential conflicts of interest for some of the United States' top legal officials.

Federal judges — occasionally with family members or even their dog in tow — traveled to luxury resorts in locations as far-flung as London; Palm Beach, Fla.; Bar Harbor, Maine; and the outskirts of Yellowstone National Park for weeklong seminars. The judges received free rooms, free meals and free money toward travel expenses, together worth a few thousand dollars.

Victims of harassment by federal judges often find the judiciary is above the law

Victims of harassment by federal judges often find the judiciary is above the law

At one event, a far-right German politician with a history of racially inflammatory and anti-immigrant statements made a presentation to dozens of judges. At others, judges heard from an advocacy group that uses lawsuits in federal court to change environmental policy, as well as from corporate CEOs in the oil and pharmaceutical industries.

For almost two decades, the federal judiciary has recognized that the combination of apparent luxury and ideological content can present the appearance of undue influence on the courts. In response, the judiciary has required more transparency in the form of public disclosure.

An NPR investigation found that the disclosure systems often fail to give the public timely information about the outside benefits that judges receive and from whom.

As a result, judicial ethics experts say, people with cases before these judges lack important information about a judge's potential biases. That information, if received in time, could be used to request that a judge recuse from a particular case.

"It also matters to the public, even if someone never shows up in a courtroom, to believe in the integrity of our judiciary and to trust in the decisions that are issued by judges," said Renee Knake Jefferson, a professor at the University of Houston Law Center. "Having disclosures of judicial financial interests goes directly to the public having confidence in the outcomes of the decisions — that they are free of any bias or influence."

Many judges defend these events as helpful forums to discuss important issues, and they reject criticism that a stay at a fancy hotel could influence their decisions. Critics call them "junkets" and glorified vacations that reward ideological allies.

Both sides agree that disclosure is needed.

There are two primary ways the public can view information about judicial education events and see which judges attended: One disclosure is filed soon after the event, and the other is submitted much later.

First, within 30 days of an event, judges are required to file a form that details the host of the event and the entities that provided funding, as well as the speakers and topics of discussion. This form, called a " Privately Funded Seminar Disclosure Report ," is posted on every federal court's website.

Second, federal law requires that judges report the reimbursements they received for the events on an annual financial disclosure report. That report also includes information like alternate sources of income (such as a book deal or teaching job) and what stocks a judge might own. Those reports are eventually posted on a centralized online database maintained by the Administrative Office of the U.S. Courts.

By closely examining the portion of these events subject to public records laws, NPR identified problems with both systems.

In nearly 40 instances, judges attended events at luxury resorts but failed to properly file a report within 30 days. In fact, the forms were uploaded months or even years late and only after NPR began asking questions.

In 13 cases, NPR found that judges failed to declare the benefits they received on their annual financial disclosure forms.

NPR contacted all those judges for comment.

And in another dozen cases, judges' financial disclosures for 2021 or 2022 were simply unavailable to the public. By all accounts, judges are filing those annual disclosure reports on time. The Administrative Office of the U.S. Courts bears responsibility for posting those reports online and has acknowledged delays in getting the system up to date.

There is no indication that the judges intentionally withheld information in order to deceive the public. And the office that administers the annual financial disclosure website told NPR that it struggles to work through a backlog of reports, as well as requests for redactions to protect judges' safety, but is making progress.

Ethics experts said delays and omissions in these reports undermine the entire purpose of the transparency rules.

"That information loses most of its value if it's a year and a half later," said Kedric Payne, the senior director of ethics at the nonprofit watchdog Campaign Legal Center. "It's just too distant from the potential conflict of interest."

Regardless of intention, the result is that the public is kept in the dark. And NPR's findings likely represent an undercount of the larger problem.

Events with ideological presentations and a side of luxury

Nonprofits, legal organizations and private universities all host judicial education events around the world. But those groups are generally not subject to public records laws. As a result, their full attendee lists are shielded from public scrutiny.

When it comes to the hosts of these events, George Mason University in Fairfax, Va., is exceptional in two ways.

joint travel regulations resort fee

George Mason University's campus in Fairfax, Va., in 2018. Education Images/Universal Images Group via Getty Images hide caption

George Mason University's campus in Fairfax, Va., in 2018.

For one, GMU — particularly the university's conservative-leaning Law & Economics Center — has long stood out as one of the most prolific hosts of judicial education events. Collectively, hundreds of judges have attended the university's events at luxury resorts over the years. GMU is quick to point out that the events are paid for by private donors. The Law & Economics Center's website lists donors that include major corporations like Amazon, Pfizer, Google and Facebook, as well as the business lobby group the U.S. Chamber of Commerce. According to the New York Times , conservative activist Leonard Leo helped gather $30 million in donations to rename the law school after late Supreme Court Justice Antonin Scalia.

GMU is a public university in Virginia, which means it is subject to the state's Freedom of Information Act. NPR requested attendee lists for eight of its judicial education events from 2021 to 2023. By comparing attendee lists with the publicly available records, NPR was able to identify dozens of missing disclosures.

That missing information may be relevant to both the public at large and people with cases in front of these judges.

For example, dozens of judges took part in a 2022 event that featured a speaker from the far-right Alternative für Deutschland (Alternative for Germany) political party. Germany has been rocked by massive protests in recent months over revelations about AfD's ties to right-wing extremism. A regional AfD leader is facing charges in Germany for allegedly using Nazi slogans, which he denies.

Gunnar Beck, a member of the European Parliament and an AfD member, spoke to the group of American federal judges about "European Jurisprudence." Beck has a history of anti-immigrant and racially inflammatory statements.

In 2021 — the year before his presentation to the judges — Beck took multiple photos of Black families, including young children in strollers, and posted them on social media. In one of the posts, he used the photo to criticize what he called the Afrikanisierung (Africanization) of Germany. (This post was deleted after NPR contacted Beck.) In another, Beck wrote that due to immigration, "Germany has no future as an industrial and cultural nation, but it does have a future as a welfare office."

Beck told NPR in an email that "each country and its people have a right to control their border with a view to safeguarding their maintenance of their national culture and identity" and that "I do not think these views are either fascist or racist."

The GMU events have also featured presentations from a nonprofit that says it uses lawsuits to promote a pro-market, as opposed to pro-regulation, approach to environmental policy; the CEO of a U.K.-based pharmaceutical company ; and the CEO of an energy company that is currently suing the federal government over financial regulations.

One recent event included a reading assignment on the "worst decisions ever handed down by the Supreme Court" as defined by conservative and libertarian legal scholars. Roe v. Wade , which established a constitutional right to abortion, was No. 2. Landmark cases establishing rights to same-sex marriage and the use of birth control also appeared among the top 10 "worst" decisions.

Given the power of judges to affect Americans' lives on issues from guns to abortion, the environment and crime, transparency about these events is critical, said Gabe Roth of the nonprofit watchdog group Fix the Court.

"The public has a right to know whether or not its top legal officials have any potential conflicts going into hearing cases," said Roth. "Sometimes they're small bore, but a lot of the times they have major national impact."

The agendas for the GMU events showed that the event programming often ended around noon, followed by a five- or six-hour "study break." In some instances, the agendas leave days completely free.

It's unclear exactly how judges spent that time. But attendees had the opportunity to enjoy the Ritz-Carlton's clay tennis courts, the Alyeska Resort's Nordic Spa or the short walk to Buckingham Palace from the May Fair Hotel in London. The agenda for GMU's 2022 Bar Harbor Colloquium in Maine reserved 90 minutes for a wine tasting .

joint travel regulations resort fee

The Alyeska Resort in Girdwood, Alaska, in 2009. John Greim/LightRocket via Getty Images hide caption

The Alyeska Resort in Girdwood, Alaska, in 2009.

A spokesperson for GMU did not respond to NPR's specific questions for this story.

"Topics are selected based on foundational concepts in the economic analysis of law relevant to judges and other areas of interest to the judiciary," wrote Ken Turchi, associate dean of GMU's Antonin Scalia Law School, in an email. "Every judge who attends has the option to complete and submit a disclosure form detailing expenses incurred and reimbursed."

Which judges have disclosure problems?

Problems plagued the paperwork for judges appointed by presidents of both major parties going back decades, including Presidents Ronald Reagan, George H.W. Bush, Bill Clinton, George W. Bush, Barack Obama and Donald Trump.

And the judges who failed to fully comply with the disclosure requirements include some notable names.

joint travel regulations resort fee

In this screenshot, Aileen Cannon speaks during a Senate Judiciary Committee nomination hearing to be a U.S. district judge for the Southern District of Florida on July 29, 2020. She was appointed to the position later that year. U.S. Senate via AP hide caption

In this screenshot, Aileen Cannon speaks during a Senate Judiciary Committee nomination hearing to be a U.S. district judge for the Southern District of Florida on July 29, 2020. She was appointed to the position later that year.

Judge Aileen Cannon of the Southern District of Florida is presiding over former President Donald Trump's criminal trial for allegedly mishandling classified documents. Cannon, herself a Trump appointee, attended two seminars at a luxury resort in Montana, but the privately funded seminar disclosures for both events were not posted online until NPR began making inquiries. Clerk of court Angela Noble told NPR in an email that the absence of the disclosures was due to technical issues and that "Any omissions to the website are completely inadvertent."

joint travel regulations resort fee

Judge Robert Conrad is the director of the Administrative Office of the U.S. Courts. U.S. Courts hide caption

Judge Robert Conrad is the current director of the Administrative Office of the U.S. Courts, which implements the policies of the federal judiciary. Conrad, who was appointed by George W. Bush to the Western District of North Carolina, attended three privately funded seminars from 2021 to 2023. He later included the events on his annual financial disclosure but did not file a publicly available disclosure for any of those events within the required 30-day time limit. "He inadvertently did not make the additional disclosure in the separate system for private seminar attendance," said Peter Kaplan, a spokesperson for the Administrative Office. "Judge Conrad appreciates your bringing this oversight to his attention."

Judge Leslie Gardner of the Middle District of Georgia, who is the sister of prominent Georgia Democrat Stacey Abrams, also failed to file a privately funded seminar disclosure on time. Additionally, NPR found that Gardner omitted the reimbursements she received for lodging, meals and travel on her annual financial disclosure. In a phone call to NPR, clerk of court David Bunt said that Gardner, an Obama appointee, was updating her annual financial disclosure and privately funded seminar disclosure, which were incomplete due to an "oversight."

"I don't have really an excuse for it, and I'm going to correct it"

Judges contacted by NPR largely described the issues with their disclosures as the result of an "inadvertent oversight" or an "accident." In a handful of cases, court clerks blamed technical issues with the online system for uploading paperwork. One judge appeared to be unaware of the requirement to file a disclosure report within 30 days. Several judges thanked NPR for contacting them and prompting them to update their disclosure reports.

"It looks like we blew it," said Judge Philip Gutierrez of the Central District of California in a phone call to NPR. Gutierrez failed to file a disclosure within 30 days of attending a judicial seminar at The Breakers, a resort in Palm Beach, Fla., in 2021. "I apologize. It's important. I'm embarrassed."

Gutierrez immediately uploaded the missing disclosure.

Judge Gary Fenner of the Western District of Missouri attended the same GMU 2021 seminar in Palm Beach but failed to file a privately funded seminar disclosure and omitted the event from his annual financial disclosure that year.

"I am really surprised that I did not report that," said Fenner, an appointee of Bill Clinton, in a phone message to NPR. "I'm going to rectify it. I'm embarrassed about the fact that somehow that was overlooked by me. But I don't have really an excuse for it, and I'm going to correct it."

Judge Keith Starrett of the Southern District of Mississippi, a George W. Bush appointee, said he had thought he marked his attendance at GMU's seminar at the Park Hyatt Beaver Creek Resort and Spa in Colorado in 2021 on his annual financial disclosure. He acknowledged that it was missing from the forms due to an "oversight."

"I'm going to do whatever I need to do to get it right," he said by phone.

In the District Court for the Southern District of Texas, NPR found three judges — Jeffrey Brown, Andrew Edison and Charles Eskridge — who had not filed the required privately funded seminar disclosure forms. After NPR contacted the court, the judges uploaded the forms, and clerk of court Nathan Ochsner said in an email, "At the direction of Chief Judge Randy Crane, my office will routinely remind all [Southern District of Texas] judges of this reporting requirement."

Meanwhile, the delays in getting access to annual financial disclosure reports appear to be the result of the time limits built into the transparency laws, as well as a combination of long processing times for redactions requested by judges and, in some cases, security concerns.

The law requires that judges file their annual financial disclosure reports for the previous year on May 15. Many judges request and receive a 90-day extension, pushing that deadline to mid-August. Judges can then request that the judiciary redact "personal or sensitive information that could directly or indirectly endanger" the judge or the judge's family, but then a committee has to review the request.

"So if you're a judge that asked for a 90-day extension and then, on top of that, you're asking for redactions," said Roth, of Fix the Court, the public release of the annual disclosure is "already well into the following year."

Former federal Judge Jeremy Fogel, who is now the executive director of the Berkeley Judicial Institute, evaluated some of these redaction requests when he served on the judiciary's Committee on Financial Disclosure.

"I don't think that the problem you described is one where the judiciary doesn't want to share the information," said Fogel. "I think the problem is that they have not been able to put the resources in place to get the information online and available to the public in a timely manner."

joint travel regulations resort fee

The Thurgood Marshall Federal Judiciary Building in Washington, D.C., houses the Administrative Office of the U.S. Courts. Andrew Harnik/AP hide caption

The Thurgood Marshall Federal Judiciary Building in Washington, D.C., houses the Administrative Office of the U.S. Courts.

NPR sent a list of judges to the Administrative Office of the U.S. Courts and asked why their annual financial disclosures for 2021 or 2022 were still unavailable. Kaplan, the Administrative Office spokesperson, said he "could not comment on specific judges' filings." In general, Kaplan blamed missing disclosures on backlogs in the system and reviews of filings for possible security issues.

"Currently, nearly all filings from 2021 and more than 80% of the filings from 2022 are available on the database," said Kaplan. "We are continuing to cut into the backlog of reports."

An ongoing debate over judges and luxury trips

Even if judges universally filed their disclosure reports on time and if the federal judiciary sped up the release of information, it would likely not end the ongoing debate over judges getting thousands of dollars in free perks, especially at ideologically slanted conferences.

Fogel said that in his time as a judge, he tended to avoid events that might be perceived as ideological.

"I wouldn't go so far as to say that it's unethical," said Fogel. "But I think it's better — it's a best practice — for judges to avoid programs that have a particular philosophical or ideological viewpoint."

Judge Starrett, of the Southern District of Mississippi, has attended five GMU legal events in the last three years and even brought his German shepherd to one of them.

He rejected the idea that his views could be swayed by a certain speaker's agenda or free perks.

"I've been called a liberal judge. I've been called a conservative judge. I've been called a son of a bitch. That comes with the territory," said Starrett. "I pay close attention to speakers that are politically biased one way or another. I listen to them, and I challenge some of them. I ask pointed questions."

Judge Gutierrez, of the Central District of California, has attended three GMU events in the last three years.

"Certainly, I think people have a slant. But for the most part, I found them to be interesting and educational," he said. He added that a group of federal judges will always tend to ask tough questions and get into spirited debates — whether in court or in a legal seminar.

"We want our judges out in the world learning and teaching. And we want our judges to have friendships. We want our judges to be able to travel," said Jefferson, the legal ethics expert at the University of Houston Law Center. "It's the disclosure that matters."

Nick McMillan and Hilary Fung contributed reporting and visuals, with graphic editing by Alyson Hurt. This story was edited by Barrie Hardymon with research by Barbara Van Woerkom. Photo editing by Emily Bogle.

  • Leonard Leo
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  • financial disclosure

COMMENTS

  1. Joint Travel Regulations

    Joint Travel Regulations. The Joint Travel Regulations (JTR) implements policy and law to establish travel and transportation allowances for Uniformed Service members (i.e., Army, Navy, Air Force, Marine Corps, Space Force, Coast Guard, National Oceanic and Atmospheric Administration Commissioned Corps, and Public Health Service Commissioned Corps), Department of Defense (DoD) civilian ...

  2. Miscellaneous Expenses (FMR Part 301-12)

    Lodging taxes as prescribed in § 301-11.27 . Laundry, cleaning and pressing of clothing expenses as prescribed in § 301-11.31 . Energy surcharge and lodging resort fee (s) (when such fee (s) is/are not optional). Note to § 301-12.1: You should use Government provided services for all official communications.

  3. PDF Per Diem, Travel, and Transportation Allowance Committee

    These changes are scheduled to appear in the Joint Travel Regulations, dated November1, 2023. 4. This revision is effective when printed in the Joint Travel Regulations. ... tourism, safe, service, or resort fees, the AO may authorize or approve reimbursement for them.conventional lodging (i.e., hotel and motel lodging establishments.) 3 the ...

  4. PDF UNIFORMED SERVICE MEMBERS AND DOD CIVILIAN EMPLOYEES

    THE JOINT TRAVEL . REGULATIONS (JTR) UNIFORMED SERVICE MEMBERS . AND . DOD CIVILIAN EMPLOYEES . MAJOR GENERAL ROY J. MACARAEG ... Medical Specialty Care Travel of More Than 100 Miles ; 033008. Medical and Dental Care for an Injury, Illness, or Disease Incurred or Aggravated in the ;

  5. Other Commercial Lodging

    The Joint Travel Regulations (JTR) [PDF] require DoD travelers on temporary duty (TDY) to an Integrated Lodging Program (ILP) site or surrounding metro area to book DoD Preferred commercial lodging before other commercial lodging options. If DoD Preferred commercial lodging is not available, the Federal Travel Regulation (FTR) §301-11.11 ...

  6. Lodging

    Policy & Regulations. Joint Travel Regulations. JTR Chapters 1-6 & Appendices ↗ Changes Supplements Computation Examples Archive Travel Policy Compliance DoD Instruction 5154.31 Defense Travel System Regulations ↗

  7. PDF Integrated Lodging Program Traveler Fact Sheet

    Joint Travel Regulations (JTR) par. 020303, requires that travelers who are TDY to program sites stay in Government (DoD), Public-Private Venture (also known as "privatized" and "PPV"), or DoD Preferred comme rcial ... cancellation, no resort fees, etc.) but is not mandatory. • If used, booking in DTS is required . ILP Traveler Fact ...

  8. Federal Travel Regulation (FTR); Corrections and Additions

    Section 301-12.1 clarifies that energy surcharges and lodging resort fees (when not optional) are considered reimbursable as a miscellaneous travel expense. ... Columbia are not eligible to use the contract city-pair fares, even though they may otherwise be covered by the Federal Travel Regulation. Note 2 to § 301-10.107:

  9. Frequently asked questions, per diem

    The Federal Travel Regulation Chapter 300, Part 300-3, under Per Diem Allowance, describes incidental expenses as: Fees and tips given to porters, baggage carriers, hotel staff, and staff on ships. How often is a study conducted on the M&IE expense rates? An M&IE study has traditionally been conducted every three to five years.

  10. PDF Uniformed Service Members and Dod Civilian Employees

    033203. Travel of a "Designated Individual" for the Health and Welfare of a Wounded or Ill Civilian Employee . PART E: LEAVE IN CONJUNCTION WITH TDY . 0333 LEAVE AND TDY . 033301. Leave or Personal Travel Combined with Official Travel 033302. Leave Taken while on a TDY with Long-Term Lodging 033303. Ship Relocated During Authorized Absence ...

  11. PDF DEPARTMENT OF THE AIR FORCE

    increasingly charging fees variously termed "resort fees," "amenity fees," "urban destination fees," "facilities fees" and "daily destination fees," among others. The JTR states that these fees may be reimbursed as a miscellaneous expense, but they must be authorized on the member's authorization before the travel begins.

  12. Actual Expense Allowance

    If a traveler must spend more than the lodging rate in a locality, then the traveler may receive an actual expense allowance for lodging. The traveler's authorizing official may authorize or approve actual expense allowance up to 300 percent of the locality per diem rate, and the traveler will be reimbursed for actual expenses up to that amount.

  13. PDF THE JOINT FEDERAL TRAVEL REGULATIONS

    Joint Federal Travel Regulations Cover Letter Change 286 CL-ii 10/01/10 . U4171. Adds CBCA decision to JFTR, par. U4171 and JTR, par. C4554-D, reinforcing that complimentary meals provided by a lodging establishment do not affect per diem as long as the room charge is the same with or without meals. U4600-B and U5630-B16.

  14. PDF DTS Expenses Screen for Travelers

    expenses and mileage allowances per the Joint Travel Regulations (JTR). If you incur an approved travel expense that is not in the expense listing, you can use Other Expenses > Other - Create Your Own to enter your expense. Note: Manually entering an expense causes DTS to trigger a Pre-Audit flag requiring justification.

  15. Federal Travel Regulation: Reimbursement of Fees for Nonconventional

    SUMMARY: Per the Federal Travel Regulation (FTR), agencies may reimburse employees for the use of nonconventional lodging "when there are no conventional lodging facilities in the area ( e.g., in remote areas) or when conventional facilities are in short supply.". As the use of nonconventional lodging amongst Federal travelers has grown, so ...

  16. PDF Federal Travel Regulation Overview

    Travel Policy Mission. Ensure Federal agencies spend travel dollars wisely, efficiently, and effectively while accomplishing their missions. Committed to ensuring that government travel policy follows all relevant laws, while applying innovative technology and implementing industry best practices. Federal Government is among the largest travel ...

  17. PDF VOLUME 12, CHAPTER 32

    1.1 Purpose. This chapter establishes the policies to be followed by Department of Defense (DoD) Components to account for conference fees that are collected by the Department of Defense to cover DoD costs. The conference fees are used in accordance with statutory authority in Title 10, United States Code, § 2262 (10 U.S.C. § 2262) which ...

  18. Federal travel regulation

    Subscribe to changes in the regulations. The Federal Travel Regulation summarizes the travel and relocation policy for all federal civilian employees and others authorized to travel at the government's expense. Federal employees and agencies may use the FTR as a reference to ensure official travel and relocation is conducted in a responsible ...

  19. PDF Per Diem, Travel, and Transportation Allowance Committee 4800 Mark

    These changes are scheduled to appear in the Joint Travel Regulations, dated May 1, 2022. 4. This revision is effective on April 13, 2022, when it was approved by the Chair. ... Late payment fee on the Government Travel Charge Card (GTCC*), incurred through no personal fault of the traveler, due to a mission-critical status (for example, when ...

  20. DoD Announces Revision to Joint Travel Regulations Authorizing

    Today, the Department of Defense announced that effective May 2, 2022, the Joint Travel Regulations (JTR) will allow service members to ship empty gun safes, not to exceed 500 pounds, in addition ...

  21. JTR Changes

    Extends the TLE extension recertification dates for the Palmdale/Edwards AFB CA. 8/7/2023. UTD for MAP 21-23 (R), Increase Recruiter Expenses. This item edits Joint Travel Regulations (JTR), pars. 020605 and 020606 to incorporate an increase to the reimbursement limits for recruiting expenses and monthly parking expenses. 8/2/2023. Page 4 of 11.

  22. Many judges fail to fully disclose free luxury trips, NPR finds : NPR

    Many federal judges receive free rooms and subsidized travel to luxury resorts for legal conferences. NPR found that dozens of judges did not fully disclose the perks they got.

  23. JTR Changes

    This change applies to travel and relocation performed on or after January 1, 2024. ... Changes to the Joint Travel Regulations (JTR). The JTR contains extended guidance and decision-making tools related to travel and transportation policies allowances established for Service members, DoD civilian employees, and others traveling at the DoD's ...