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Pardons, Dropped Cases and Cover-Ups
The Adams Dismissal

Trump's Former Lawyer Ordered Eric Adams's Corruption Case Dropped, and Ten Prosecutors Resigned

Emil Bove, the acting deputy attorney general, ordered the New York mayor's case dropped to advance the administration's immigration agenda, without assessing the evidence, and sought to leave the charges revivable. A judge closed the case permanently so the charges could not be used as leverage. Trump later nominated Bove to a lifetime judgeship.

§ 1

A Corruption Case Dropped for Immigration Cooperation

On February 10, 2025, Emil Bove, the acting deputy attorney general and formerly Donald Trump's criminal-defense lawyer, ordered prosecutors to drop the five-count corruption case against New York City Mayor Eric Adams.12 The Department acted to advance its immigration agenda, and Bove's memo said it had reached the decision without assessing the strength of the evidence.1 It sought to leave the charges revivable after the November 2025 election, terms Judge Dale Ho concluded would expose the mayor and his city to federal leverage.13 Ten prosecutors resigned over the case.45 Ho closed it permanently.3 The prosecution ended without a trial, leaving allegations about foreign influence and taxpayer money untested before a jury.36

The President's Former Lawyer

The order ties to Trump through the man who gave it and through Trump's own words. Bove defended Trump in his criminal cases; Trump's administration then made him Acting Deputy Attorney General.2 His memo invoked Trump's executive order against government weaponization.17 CNN reported, citing people familiar with their thinking, that Bove and Todd Blanche, another former Trump defense lawyer, viewed dismissal as fulfilling that order and Trump's desire for partners in the states to advance his political agenda.42

Before he took office, Trump said he might consider pardoning Adams, CBS New York reported, adding, "I think he was treated pretty unfairly."8 He denied asking for the dismissal: "I know nothing about it. I did not."9 He later nominated Bove to a lifetime judgeship.2

The Charges No Jury Heard

The case Bove ended was unsealed on September 26, 2024: five felony charges against Adams, the first sitting New York City mayor to face a criminal charge, according to CBS New York.86 The counts were bribery, wire fraud, two counts of soliciting contributions from foreign nationals, and a conspiracy covering all three.6 Lead prosecutor Hagan Scotten said the case had been pursued under four different U.S. attorneys.10

Prosecutors alleged that for nearly a decade, starting after Adams became Brooklyn Borough President in 2014, he accepted luxury travel from wealthy foreigners and a Turkish official seeking influence over him.6 CBS New York's account of the indictment listed trips valued at more than $12,000 and one package of flights and a hotel stay at more than $41,000.8

The alleged harm reached city taxpayers.6 The city's program matched eligible residents' donations at up to eight times their value, to give ordinary New Yorkers a greater voice in elections.611 Prosecutors said Adams's campaigns disguised foreign donations through stand-in donors and claimed matching funds on them, as much as $2,000 for each improper contribution.611 They alleged that false certifications allowed his 2021 campaign to receive more than $10 million in public funds.611

The indictment alleged that, in exchange for free travel and other travel-related bribes arranged by the Turkish official, Adams pressed the fire department in September 2021 to let a 36-story Turkish consular building open without a fire inspection, when it would have failed one.6 Prosecutors alleged that the fire official responsible for assessing its safety was told he would lose his job if he did not acquiesce, and that the building opened as requested after Adams intervened.6

Adams pleaded not guilty and stayed in office despite calls to resign.8 He attended Trump's January 2025 inauguration.8

§ 2

Drop the Case, Keep the Charges Available

The Order and Its Reasons

Bove's February 10 memorandum, issued with the attorney general's authorization, would have ended the case and kept the charges available: it directed prosecutors to dismiss them without prejudice, meaning the government could bring them again.1 It required Adams's written consent, set a review by the confirmed U.S. attorney after the November 2025 mayoral election, ordered prosecutors to stop additional investigative steps until that review, and told them to take all steps within their power to restore Adams's security clearances.1 At the February 19 hearing, DOJ said the review was not a condition of dismissal and that it had no current plans for one; it made no commitment to halt further investigation.3 On the evidence, the memo was explicit:1

Memorandum to the Acting U.S. Attorney for the Southern District of New York, directing dismissal1

The Justice Department has reached this conclusion without assessing the strength of the evidence or the legal theories on which the case is based

Emil Bove, Acting Deputy Attorney General · February 10, 2025

Bove's first reason was impropriety: the timing of the charges and former U.S. Attorney Damian Williams's public actions threatened the proceedings and Adams's election campaign.1 His second was policy: the prosecution restricted the mayor's ability to help with immigration enforcement and violent crime.1 The same memo said the directive did not question the line prosecutors' integrity.1

On the first, Ho found no objective evidence of impropriety, no evidence of improper motives among the career prosecutors, and no support for calling charges brought nine months before the mayoral primary election interference; the rationale, he concluded, appeared pretextual.3 On the second, he found that the prosecution had not been shown to impair Adams's immigration work, but that DOJ's desire to advance immigration policy was a real basis for its request.3 He called that rationale unprecedented: DOJ cited no example, and he could find none, of charges against an elected official being dismissed to facilitate federal policy goals.3

DOJ later argued that the case's charging theory was weak, and CNN reported that Bove and Blanche had been skeptical from the outset about proving that Adams intentionally violated campaign-finance laws.34 Ho expressed no opinion on the merits and refused to base his decision on a rationale that DOJ had not asserted in its dismissal motion and that Bove's memo had disclaimed.31

Ho had already rejected Adams's motion to dismiss the bribery count under binding circuit precedent. He also said DOJ's reliance on that earlier ruling to question the charging theory was misplaced: the ruling did not concern the other four counts, and issuing the consular building's temporary certificate of occupancy could support a bribery charge under either legal theory discussed. Those rulings addressed legal sufficiency, not whether Adams was guilty.3

The Alleged Exchange

The allegation of a trade comes from Acting U.S. Attorney Danielle Sassoon, who met with Bove and Adams's lawyers on January 31.12 In her February 12 letter to Attorney General Pamela Bondi, she wrote that the lawyers "repeatedly urged what amounted to a quid pro quo," indicating that Adams could assist the Department's priorities only if the indictment were dismissed.12 She also alleged that Bove admonished a prosecutor for taking notes and had the notes collected when the meeting ended.12

Bove's memorandum said the government "is not offering to exchange dismissal of a criminal case for Adams's assistance on immigration enforcement"; Adams's lawyer Alex Spiro called the allegation "a total lie."113 Adams denied offering "any trade of my authority as your mayor for an end to my case" and, at the February 19 hearing, denied under oath entering any agreement beyond his written consent to dismissal.143

DOJ also argued that even an explicit trade of dismissal for immigration cooperation would be permissible.3 Ho rejected its comparison to ordinary political bargaining: ethics rules, he explained, prohibit political considerations in prosecutorial discretion.3

What happened in public gave Ho reason for concern.3 On February 10, the date of Bove's memo, Adams instructed top city officials not to criticize Trump or interfere with immigration enforcement, THE CITY reported, citing multiple sources at the meeting; he justified the instructions, the outlet said, as protecting the city's federal funding.15 On February 13, after DOJ's decision to seek dismissal but while the charges remained pending, Adams announced plans to let ICE return to Rikers Island.3 The next day, border czar Tom Homan appeared with him on Fox News and warned that if Adams did not come through, he would return to the mayor's office to demand delivery on their agreement.3

Ho made no conclusive finding of an explicit bargain and found further factual investigation unnecessary to decide the motion.3 He wrote:3

Opinion & Order (United States v. Adams, ECF No. 177)3

Everything here smacks of a bargain: dismissal of the Indictment in exchange for immigration policy concessions.

Judge Dale E. Ho · April 2, 2025
§ 3

Ten Prosecutors Resigned

Sassoon Refused to Sign

Sassoon was the Trump administration's own choice to lead the office, installed only weeks earlier: a Republican, according to Associated Press reporting published by PBS, and a former clerk to Justice Antonin Scalia.16124 She told Bondi she could not seek dismissal:12

Letter to Attorney General Pamela Bondi12

Because the law does not support a dismissal, and because I am confident that Adams has committed the crimes with which he is charged, I cannot agree to seek a dismissal driven by improper considerations.

Danielle Sassoon, Acting U.S. Attorney, S.D.N.Y. · February 12, 2025

Her team, she wrote, had proposed a superseding indictment adding an obstruction conspiracy count, based on evidence that Adams destroyed evidence, told others to destroy it, and instructed others to give false information to the FBI.12 She resigned on February 13.16

The Refusals Spread to Washington

Seven prosecutors resigned over February 13 and 14, CNN reported: Sassoon; Kevin Driscoll, a senior Criminal Division prosecutor; John Keller, the acting head of the Public Integrity Section; three more lawyers in that section; and Scotten.4

Scotten, an Army combat veteran who had clerked for Brett Kavanaugh and Chief Justice John Roberts, told Bove why:1710

Resignation letter to Emil Bove10

No system of ordered liberty can allow the Government to use the carrot of dismissing charges, or the stick of threatening to bring them again, to induce an elected official to support its policy objectives.

Hagan Scotten, Assistant U.S. Attorney, S.D.N.Y. (lead prosecutor) · February 14, 2025

After the refusals, Bove signed the February 14 dismissal motion himself, with Antoinette Bacon and Edward Sullivan.3 On April 22, trial-team prosecutors Celia Cohen, Andrew Rohrbach and Derek Wikstrom resigned after being placed on leave; CBS New York reported their allegation that Blanche had made expressions of regret and admissions of wrongdoing a condition of returning.5 They wrote, "We will not confess wrongdoing when there was none."5 Seven departures in February and three in April made ten.45

The Anti-Corruption Unit Shrank

The order to drop the Adams case prompted five senior Public Integrity officials to resign, the Brennan Center reported.18 Its October 20, 2025, report said DOJ leaders subsequently reduced the section, created after Watergate, from 36 career lawyers to two, suspended its authority to review potential public-official cases for political motivation, and stripped its authority to file new cases.18 That broader reduction followed the Adams confrontation; it cannot all be counted as resignations caused by this case.18

§ 4

Permanent Dismissal, a Blocked ICE Order, a Judgeship

What the Government Won and the Judge Refused

The Justice Department got the prosecution ended.3 With the government and Adams aligned and no one testing their position, Ho adjourned the trial and on February 21 appointed former U.S. Solicitor General Paul Clement to present arguments on the motion.1920 On April 2, Ho granted dismissal, accepting that a court cannot force DOJ to prosecute or appoint an independent prosecutor in circumstances like these.3

What he refused was the leverage. He dismissed with prejudice, barring the government from bringing these charges again, so that "the charges in the Indictment cannot be used as leverage over Mayor Adams or the City of New York."3 Adams had separately requested permanent dismissal, and DOJ had not opposed that request.3 Ho's ruling ended both the prosecution and the prospect of reviving these charges after the election.3

The Rikers Order Was Declared Illegal

Six days after dismissal, First Deputy Mayor Randy Mastro signed Executive Order 50 authorizing arrangements for federal law-enforcement office space at Rikers.21 On September 8, 2025, New York Supreme Court Justice Mary Rosado declared that order illegal and void under the City Charter's conflict-of-interest rule.21 She held that the appearance of Adams's conflict and his failure to recuse himself fully tainted the process; delegation to his subordinate did not cure it.21 She did not decide whether an actual conflict existed, and she preserved lawful city cooperation involving undocumented people covered by judicial warrants and orders signed by federal or immigration judges.21

The promised step toward immigration cooperation failed in court, after DOJ had already obtained dismissal.213

Trump Nominated Bove Anyway

Trump continued to support Bove after the dismissal and the prosecutors' resignations.2 On May 28, 2025, he announced Bove's nomination to the Third Circuit, praising him as "SMART, TOUGH, and respected by everyone," according to AP reporting carried by WESA.2

Democratic senators asked New York bar authorities to investigate their allegations that Bove had used prosecution power to coerce an elected official into serving Trump's political interests.22 Justice Connection said more than 900 former DOJ attorneys signed its July opposition letter, which cited the Adams dismissal and questioned Bove's impartiality.2324 On July 29, the Senate confirmed Bove to the lifetime seat, 50 to 49; Susan Collins and Lisa Murkowski were the only Republicans voting no, joining every Democrat.25 In September, Senators Sheldon Whitehouse and Richard Blumenthal renewed a separate complaint they had filed on February 27, after the grievance committee referred that matter to DOJ.26

§ 5

Prosecution Power Used for Policy Advantage

Power Does Not Settle the Impeachment Question

The strongest defense is that prosecution decisions belong to the executive branch, as the Supreme Court said in 2024 in Trump v. United States:27

Trump v. United States, 603 U.S. ___ (2024) (slip op.)27

And the Executive Branch has “exclusive authority and absolute discretion” to decide which crimes to investigate and prosecute, including with respect to allegations of election crime.

Supreme Court of the United States (majority opinion) · July 1, 2024

The Court barred inquiry into presidential motives when classifying conduct as official or unofficial and recognized absolute immunity for core constitutional powers, with at least presumptive immunity for other official acts.27 It held Trump himself absolutely immune from criminal prosecution for his alleged conduct involving discussions with Justice Department officials, despite allegations that the requested investigations were shams or proposed for an improper purpose.27 Federal law separately makes U.S. attorneys removable by the President.28

Those protections are substantial, and they concern criminal prosecution. Article II, Section 4 separately authorizes removal through impeachment for treason, bribery, or other high crimes and misdemeanors.2729 Hamilton argued in The Federalist that impeachment reaches abuse or violation of public trust.30 The House Judiciary Committee's 1974 article against Nixon alleged misuse of law-enforcement agencies for political ends, but Nixon resigned before a full House vote on impeachment.3132

The Charge Against This Administration

This was an abuse of prosecution power. Trump's Justice Department made its policy objectives a reason to end a public-corruption case, expressly without assessing the evidence, and sought to preserve charges that the court said could become leverage over a mayor and his constituents.13

It cost the public a trial on allegations involving more than $10 million in public funds, and it cost the Department ten prosecutors.6345 The promised Rikers measure was later declared illegal and void.21

Trump said publicly that Adams had been treated unfairly and that he might consider pardoning him.8 His administration gave Bove senior DOJ authority, and Trump later nominated him to the federal bench.2 That misuse of public power is the reason this conduct warrants Congress's impeachment scrutiny.2930

Full Source Index — The Adams Dismissal

Primary Sources

Secondary Sources