H. Rpt. 119-219 addresses "In the Matter of Allegations Relating to Representative Alexandria Ocasio-cortez". It was prepared by the Ethics Committee as part of the committee's legislative and oversight work. Committee reports are among the most important primary sources in the legislative process. They explain what legislation does, why the committee believes it is necessary, what amendments were adopted, how much it costs, and what the committee's majority and minority members think. Courts and agencies refer to these reports for decades after enactment when interpreting how laws should be applied.
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House Report 119-219 - IN THE MATTER OF ALLEGATIONS RELATING TO REPRESENTATIVE ALEXANDRIA OCASIO-CORTEZ
[House Report 119-219]
[From the U.S. Government Publishing Office]
House Calendar No. 41
119th Congress } { Report
HOUSE OF REPRESENTATIVES
1st Session } { 119-219
_______________________________________________________________________
IN THE MATTER OF ALLEGATIONS
RELATING TO REPRESENTATIVE
ALEXANDRIA OCASIO-CORTEZ
__________
R E P O R T
of the
COMMITTEE ON ETHICS
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
July 29, 2025.--Referred to the House Calendar and ordered
to be printed
_______
U.S. GOVERNMENT PUBLISHING OFFICE
61-279 WASHINGTON : 2025
COMMITTEE ON ETHICS
MICHAEL GUEST, Mississippi, MARK DeSAULNIER, California,
Chairman Ranking Member
JOHN H. RUTHERFORD, Florida DEBORAH K. ROSS, North Carolina
ANDREW R. GARBARINO, New York GLENN F. IVEY, Maryland
ASHLEY HINSON, Iowa SYLVIA R. GARCIA, Texas
NATHANIEL MORAN, Texas SUHAS SUBRAMANYAM, Virginia
REPORT STAFF
Thomas A. Rust, Chief Counsel/Staff Director
Brittney Pescatore, Director of Investigations
Jordan Downs, Chief of Staff to the Chairman
David Arrojo, Counsel to the Ranking Member
Christine E. Gwinn, Counsel
Peyton Wilmer, Investigative Clerk
LETTER OF TRANSMITTAL
----------
House of Representatives,
Committee on Ethics,
Washington, DC, July 29, 2025.
Hon. Kevin F. McCumber,
Clerk, House of Representatives,
Washington, DC.
Dear Mr. McCumber: Pursuant to clauses 3(a)(2) and 3(b) of
Rule XI of the Rules of the House of Representatives, we
herewith transmit the attached report, ``In the Matter of
Allegations Relating to Representative Alexandria Ocasio-
Cortez.''
Sincerely,
Michael Guest,
Chairman.
Mark DeSaulnier,
Ranking Member.
C O N T E N T S
----------
Page
I. INTRODUCTION..................................................... 1
II. PROCEDURAL HISTORY............................................... 2
III. RELEVANT LAWS, RULES, AND OTHER APPLICABLE STANDARDS OF CONDUCT.. 2
IV. FACTUAL BACKGROUND............................................... 3
A. Invitation to the 2021 Met Gala..................... 4
B. Representative Ocasio-Cortez's Related Expenses..... 5
V. FINDINGS........................................................ 18
A. Representative Ocasio-Cortez Impermissibly Accepted
Gifts Related to her Attire at the 2021 Met Gala... 18
B. Representative Ocasio-Cortez Impermissibly Accepted
a Gift of Free Admission to the 2021 Met Gala for
her Then-Partner, Riley Roberts.................... 22
C. Representative Ocasio-Cortez Failed to Exercise
Proper Oversight Over Staff........................ 24
VI. CONCLUSION...................................................... 26
VII. STATEMENT UNDER HOUSE RULE XIII CLAUSE 3(c)..................... 26
APPENDIX A: REPORT AND FINDINGS OF THE OFFICE OF CONGRESSIONAL
CONDUCT........................................................ 27
APPENDIX B: REPRESENTATIVE OCASIO-CORTEZ'S SUBMISSIONS TO THE
COMMITTEE...................................................... 426
APPENDIX C: EXHIBITS TO THE COMMITTEE REPORT..................... 456
House Calendar No. 41
119th Congress } { Report
HOUSE OF REPRESENTATIVES
1st Session } { 119-219
======================================================================
IN THE MATTER OF ALLEGATIONS RELATING TO REPRESENTATIVE ALEXANDRIA
OCASIO-CORTEZ
_______
July 29, 2025.--Referred to the House Calendar and ordered to be
printed
_______
Mr. Guest, from the Committee on Ethics,
submitted the following
R E P O R T
In accordance with House rule XI, clauses 3(a)(2) and 3(b),
the Committee on Ethics (Committee) hereby submits the
following Report to the House of Representatives:
I. INTRODUCTION
On June 23, 2022, the Office of Congressional Conduct
(OCC), then known as the Office of Congressional Ethics,
transmitted a Report and Findings (Referral) regarding
allegations that Representative Alexandria Ocasio-Cortez may
have accepted impermissible gifts associated with her
attendance at the 2021 Met Gala.\1\
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\1\Report and Findings from the Office of Congressional Conduct
(Review No. 22-8546) (Appendix A) at 3 (hereinafter OCC Referral). The
Met Gala is a charity event organized by the Metropolitan Museum of Art
(the Met) in partnership with Conde Nast, publisher of Vogue.
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The Committee reviewed the allegations referred by OCC
pursuant to Committee Rule 18(a). The Committee found that
Representative Ocasio-Cortez proactively took steps to comply
with the Gift Rule, including by arranging to pay for various
services and to ``rent'' apparel out of her personal funds that
might normally be loaned or gifted to Met Gala participants.
Nonetheless, despite Representative Ocasio-Cortez's significant
attempts, the Committee found that she failed to fully comply
with the Gift Rule by impermissibly accepting a gift of free
admission to the 2021 Met Gala for her partner and by failing
to pay full fair market value for some of the items worn to the
event. The Committee did not find evidence that Representative
Ocasio-Cortez intentionally underpaid for any goods or services
received in connection with the Met Gala; in many instances,
the congresswoman relied on the advice of counsel in
determining appropriate payment amounts, and most discussions
about payment were handled through a campaign staffer. However,
the Committee did find evidence suggesting that the designer
may have lowered costs in response to statements from
Representative Ocasio-Cortez's staff, and that payments to
vendors were significantly delayed and, in several cases, did
not occur until after OCC initiated its investigation. The
Committee also found that Representative Ocasio-Cortez's staff
was overly reliant on the vendors themselves to ensure the
congresswoman's compliance with the Gift Rule, despite the
vendors' countervailing incentives to ensure she would be able
to promote their goods and services.
Based on its findings, the Committee determined that it
would be appropriate for Representative Ocasio-Cortez to make
additional payments of personal funds to compensate for the
fair market value of certain expenses. Upon confirmation of the
completion of those payments, the Committee will consider this
matter closed. Accordingly, on July 22, 2025, the Committee
unanimously voted to issue this Report.
II. PROCEDURAL HISTORY
OCC undertook a preliminary review of this matter on
February 19, 2022. On March 21, 2022, OCC initiated a second-
phase review of this matter. The Committee received the OCC
Referral on June 23, 2022. On December 7, 2022,\2\ the
Committee publicly announced that it was reviewing an OCC
Referral related to Representative Ocasio-Cortez. On February
28, 2023, the Committee determined to carry over the deadline
from the 117th Congress and release the OCC Referral two days
after the Committee's organizational meeting for the 118th
Congress, consistent with Committee precedent. That same day,
Representative Ocasio-Cortez submitted a written response to
the OCC Referral through her counsel. On March 2, 2023,
pursuant to House and Committee Rules, the Committee publicly
released the OCC Referral, along with a copy of Representative
Ocasio-Cortez's written response.
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\2\The counting of the 45 and 90-day deadlines related to OCC
referrals is tolled during the 60-day blackout period prior to any
elections in which the subject of the referral is a candidate.
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The Committee reviewed materials provided by OCC, including
the transcript of OCC's interview with Representative Ocasio-
Cortez. The Committee also requested and received information
from Representative Ocasio-Cortez, including documents and
narrative responses. In total, Committee staff reviewed over
12,100 pages of material and interviewed Representative Ocasio-
Cortez's then-campaign staffer (hereinafter, Former Campaign
Staffer), as well as several other individuals who were
involved in Representative Ocasio-Cortez's attendance at the
2021 Met Gala.
On July 22, 2025, the Committee unanimously voted to adopt
this Report with respect to Representative Ocasio-Cortez.
III. RELEVANT LAWS, RULES, AND OTHER APPLICABLE STANDARDS OF CONDUCT
A federal statute, 5 U.S.C. Sec. 7353, prohibits federal
officials, including Members of Congress, from soliciting or
accepting anything of value, except as provided in rules and
regulations issued by their supervising ethics office. For
House Members, either the Committee or the ``House of
Representatives as a whole'' is the ``supervising ethics
office.''\3\ Accordingly, the House, through House rule XXV,
clause 5 (the Gift Rule), has defined the gifts Members may
accept consistent with federal law. The Gift Rule prohibits a
Member from knowingly accepting a gift unless it fits within
one of the rule's enumerated exceptions.\4\ The Gift Rule
defines a ``gift'' broadly, as ``a gratuity, favor, discount,
entertainment, hospitality, loan, forbearance, or other item
having monetary value.''\5\ It includes ``gifts of services,
training, transportation, lodging, and meals, whether provided
in kind, by purchase of a ticket, payment in advance, or
reimbursement after the expense has been incurred.'' The gift
prohibition does not apply to anything for which the Member
pays the market value or does not use and promptly returns to
the donor.\6\
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\3\5 U.S.C. Sec. 7353(d).
\4\House rule XXV, cl. 5(a)(1)(A)(i). If no exception applies,
House Rules permit a Member to accept a gift not otherwise prohibited
if the Member ``reasonably and in good faith believes'' the gift has a
value of less than $50 and a cumulative value from one source during a
calendar year of less than $100. House rule XXV, cl. 5(a)(1)(B)(i).
\5\House rule XXV, cl. 5(a)(2)(A).
\6\House rule XXV, cl. 5(a)(3)(A). The Committee's Gift Guidance
provides that the ``[t]angible gifts are generally valued at the item's
fair market value, even if the item is not typically for sale. Fair
market value is the item's retail price, not the wholesale price, or
the reasonable estimate of an item's cost if it were available for
sale.'' Comm. on Ethics, Gift Guidance, https://ethics.house.gov/house-
ethics-manual/gifts (hereinafter House Gift Guidance) (citing House
rule XXV) (last visited July 24, 2025).
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There are exceptions to the Gift Rule for attendance at
``widely-attended'' events and ``charity'' events.\7\ The
widely-attended events exception provides that Members may
accept an unsolicited offer of free attendance for a widely-
attended event for themselves and any ``accompanying
individual.''\8\ ``Free attendance'' includes all or part of
the cost of admission, local transportation, food and
refreshments, entertainment, and instructional materials
provided to all event attendees.\9\ Similarly, a Member may
accept an unsolicited offer of free attendance for a charity
fundraising event.\10\ Though the Committee's guidance on this
subject has evolved in recent years, at the time of the event
in question, an unsolicited offer of free attendance could also
be accepted for a spouse or dependent child.\11\ The ``value of
tickets to charity or political fundraisers is the value of the
meal [. . .] not the ticket's value.''\12\
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\7\House rule XXV, cl. 5(a)(4)(A) and (C).
\8\House Gift Guidance.
\9\Id. Free attendance does not include entertainment collateral to
the event or food and refreshments outside the group setting of the
event, such as giveaways.
\10\Id.
\11\On September 19, 2022, the Committee issued a pink sheet with
new guidance regarding the House Gift Rule related to event attendance.
This guidance now permits the acceptance of an offer for free
attendance for any guest if attendance otherwise complies with the
rule. Comm. on Ethics, Guest Policy Change and Reminder of Gift Rules
for Attendance at Events (Sept. 19, 2022) (hereinafter 2022 Pink
Sheet), https://ethics.house.gov/gift-pink-sheets/guest-policy-change-
and-reminder-gift-rules-attendance-events/.
\12\House Ethics Manual (2022) at 26 (hereinafter Ethics Manual).
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Additionally, clauses 1 and 2 of the Code of Official
Conduct (House rule XXIII) provide that ``[a] Member . . . of
the House shall behave at all times in a manner that shall
reflect creditably on the House,'' and ``shall adhere to the
spirit and the letter of the Rules of the House.''
IV. FACTUAL BACKGROUND
Each year, the Metropolitan Museum of Art (the Met) hosts a
Costume Institute Benefit, commonly known as the Met Gala, to
raise funds for the museum's Costume Institute.\13\ The Met
Gala is the primary source of funding for the Costume
Institute, and the Met describes the event as ``one of the most
visible and successful charity events, drawing attendees from
the worlds of fashion, film, society, sports, business, and
music.''\14\ Conde Nast, ``renowned media compan[y]'' and
publisher of Vogue,\15\ partners with the Met in organizing the
event under the leadership of Anna Wintour, the Artistic
Director of Conde Nast, now-former Editor-in-Chief of
Vogue,\16\ and an Honorary Trustee of the Met.\17\ Ms.
Wintour's role in the gala included determining a significant
portion of the event's guest list.\18\ However, the Met has
also historically extended a limited number of invitations each
year, including to certain government officials, free of
charge.
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\13\The Met, The Costume Institute, The Met, https://
www.metmuseum.org/departments/the-costume-institute (last visited July
24, 2025) (hereinafter The Costume Institute).
\14\Id.
\15\Conde Nast, About, Conde Nast, https://www.condenast.com/about
(last visited July 24, 2025).
\16\The Costume Institute.
\17\Anna Wintour Elected Honorary Trustee, The Met (Jan. 12, 1999),
https://www.metmuseum.org/press/news/1999/anna-wintour-elected-
honorary-trustee.
\18\See Amy Odell, How Anna Wintour Wields Her Power, Time (April
25, 2022), https://time.com/6170179/anna-wintour-met-gala-amy-odell-
book/.
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Representative Ocasio-Cortez has served as a Member of the
House since 2019, representing the Fourteenth Congressional
District of New York. She received invitations to attend the
Met Gala in 2019, 2020, and 2021, but only attended in
2021.\19\ Her attendance at the Met Gala on September 13, 2021,
garnered extensive media attention in the days following the
event, including questions regarding whether her attendance met
ethics requirements.\20\
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\19\See e.g., Exhibit 1 (declining invitation to the 2019 Met Gala
due to prior commitments). The 2020 Met Gala was canceled due to the
COVID-19 pandemic. Stuart Emmrich, There Will Be No Met Gala This Year,
VOGUE (May 19, 2020), https://www.vogue.com/article/met-gala-has-been-
cancelled-2020.
\20\See e.g., Megan C. Hills, AOC caused a stir with her statement-
making Met Gala gown, CNN (Sept. 14, 2021), https://www.cnn.com/style/
article/aoc-met-gala-alexandria-ocasio-cortez-dress/index.html; Stuti
Mishra, AOC hit with ethics complaint over Met Gala appearance as she
fires back at critics `policing her body', Independent (Sept. 15,
2021), https://www.the-
independent.com/news/world/americas/us-politics/aoc-met-gala-dress-
criticism-b1920415.
html#comments-area.
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A. INVITATION TO THE 2021 MET GALA
On May 13, 2021, Conde Nast emailed Former Campaign Staffer
to extend an invitation to Representative Ocasio-Cortez and her
then-partner, Riley Roberts, for the 2021 Met Gala.\21\ The
invitation stated that ``Anna [Wintour] would be thrilled to
have you and Riley Roberts join us at the gala this September,
as guests of Vogue.''\22\ On June 24, 2021, Former Campaign
Staffer accepted the invitation on their behalf.\23\
---------------------------------------------------------------------------
\21\OCC Referral Exhibit 3.
\22\Id. (emphasis in original).
\23\Exhibit 2.
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On July 14, 2021, Ms. Wintour called Designer and asked her
to ``dress AOC for the Met[.]'' In discussing this request with
another individual, Designer noted that it was ``going to be a
lot of work because [she would] have to make a dress from
scratch.''\24\ She also referred to the request as ``insane''
and said that she ``do[es]n't make clothes;''\25\ Designer, and
her brand, Brother Vellies, are primarily known for their
``luxury accessories,'' including shoes and handbags.\26\ Later
in July, staff at Vogue connected Former Campaign Staffer with
Designer.\27\ Representative Ocasio-Cortez also agreed to
participate in a video for Vogue, which documented the creative
process around the design of her look, as well as her getting
ready to attend the Met Gala.\28\ Prior to attending the event,
Representative Ocasio-Cortez also engaged counsel to ensure her
attendance was compliant with House Rules.\29\
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\24\Exhibit 3.
\25\Id.
\26\Our Story, Brother Vellies, https://brothervellies.com/pages/
about-brother-vellies (last visited July 24, 2025).
\27\OCC Referral Exhibit 6.
\28\Sarah Spellings, Alexandria Ocasio-Cortez Sent a Message with
her First Met Gala Appearance, Vogue (Sept. 16, 2021), https://
www.vogue.com/article/alexandria-ocasio-cortez-met-gala-2021.
\29\OCC Interview of Representative Ocasio-Cortez.
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Although tickets to the Met Gala were sold for $35,000 each
that year, with proceeds benefiting the Met's Costume
Institute, Representative Ocasio-Cortez and Mr. Roberts
received free admission to the event. Representative Ocasio-
Cortez's counsel ``reached out to the Metropolitan Museum of
Art to confirm that the event met the criteria for a
permissible charity event under House [R]ules'' as part of
their due diligence prior to the event, ``and the general
counsel of the museum confirmed that it met those
criteria.''\30\ Representative Ocasio-Cortez's counsel thus
correctly understood that she could accept the offer of free
admission to the event, along with food and beverage, because
the invitation was extended by the Met as the charitable
sponsor of the event.\31\ Counsel also indicated that the
``Congresswoman was offered a guest ticket under the same
criteria, and her longtime partner attended the event as
well.''\32\
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\30\Letter from Counsel to Representative Alexandria Ocasio-Cortez
to Tom Rust, Committee on Ethics (July 8, 2022) (Appendix B).
\31\See OCC Referral Exhibit 11. Although Representative Ocasio-
Cortez's counsel has indicated that the invitation was extended by the
Met, OCC ``found significant documentary evidence suggesting that [her]
invitation is most appropriately characterized as an invitation from
Vogue'' and that there may have been ``some attempt to obfuscate
Vogue's role in the invitation process'' by counsel. Nonetheless, OCC
found that, even if Vogue invited the congresswoman, her attendance was
permissible under the charitable events exception to the Gift Rule
because ``Vogue is appropriately characterized as an event organizer
given the significant and active role it plays in organizing the Met
Gala.'' OCC Referral n. 46; see also OCC Referral Exhibit 14.
\32\OCC Referral Exhibit 11.
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B. REPRESENTATIVE OCASIO-CORTEZ'S RELATED EXPENSES
In addition to free admission, Representative Ocasio-Cortez
was provided with a designer gown, handbag, shoes, jewelry, and
a floral hairpiece, and hair, makeup, transportation, and
ready-room services for herself, as well as a bowtie, shoes,
and tailoring services for Mr. Roberts. These goods and
services were provided, or coordinated, by either Conde Nast or
Brother Vellies, both of which primarily communicated with
Former Campaign Staffer on Representative Ocasio-Cortez's
behalf.
According to Representative Ocasio-Cortez and her counsel,
they determined prior to the event that she would be paying for
the goods and services received and her ``staff explicitly told
vendors prior to the Met Gala that the Congresswoman would be
paying for many of the benefits provided personally.''\33\
Representative Ocasio-Cortez's staff directed vendors to ``keep
costs down'' in light of that, although her counsel
acknowledged that ``it proved to be exceptionally difficult to
educate vendors on the ethical requirements that the
Congresswoman is subject to,'' noting, ``multiple occasions
where the Congresswoman and her team were met with responses
from collaborators and involved companies to the effect of `Met
Gala attendees don't normally pay for this.'''\34\
Representative Ocasio-Cortez ultimately paid for most of the
goods and services received out of personal funds, although the
payments were significantly delayed and some payments fell
short of fair market value. Most payments occurred after OCC
initiated its review, ``[b]ut for'' which, OCC stated ``it
appears that [she] may not have paid for several thousands of
dollars'' worth of goods and services provided to her.''\35\
Additional details regarding the goods and services received,
the delays in completing payment, and fair market valuation are
discussed further below.
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\33\Letter from counsel to Representative Alexandria Ocasio-Cortez
to Tom Rust, Committee on Ethics (July 8, 2022) (Appendix B) (emphasis
in original). See also OCC Interview of Former Campaign Staffer.
Documents suggest some ambiguity about the source of payment in the
days leading up to the event. See e.g., Exhibit 4 (Sept. 11, 2021,
email thread between Conde Nast staff stating, ``Getting on a call with
AOC and they said that designers can't pay for stuff needs to be a
gift.''); OCC Referral Exhibit 10 (Undated text message from Former
Campaign Staffer to Designer stating, ``I don't want to do anything
that we find out later will need to be a personal expense for her'').
\34\Letter from counsel to Representative Alexandria Ocasio-Cortez
to Tom Rust, Committee on Ethics (May 16, 2025) (Appendix B).
\35\OCC Referral at 8.
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1. Services Provided or Coordinated by Conde Nast
Conde Nast assisted with the coordination of hair and
makeup services for Representative Ocasio-Cortez related to her
attendance at the Met Gala and production of the associated
``getting ready'' video for Vogue.\36\ Both vendors initially
billed Conde Nast for their services, but Conde Nast informed
them on September 21, 2021--approximately one week after the
event--that they had a ``small shift on our end with billing
and the talent's team will be handling directly.''\37\ Former
Campaign Staffer was identified as the point of contact for
Representative Ocasio-Cortez in both instances.\38\ As
discussed in further detail below, both vendors were unable to
collect payment on their invoices until months after the event
and after repeated attempts at collection.
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\36\See OCC Referral Exhibits 16, 20.
\37\OCC Referral Exhibits 16, 20. Representative Ocasio-Cortez was
the ``talent'' referenced.
\38\Id.
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Conde Nast also provided Representative Ocasio-Cortez with
transportation from her home to The Carlyle hotel, where she
got ready for the event. Conde Nast appeared to have initially
covered the cost of the transportation but provided Former
Campaign Staffer with an invoice for reimbursement after Former
Campaign Staffer reached out to them following the initiation
of OCC's review, which the congresswoman paid in May 2022.
a. Hair Styling
Representative Ocasio-Cortez received hair services for the
Met Gala from Hairstylist.\39\ The agency representing
Hairstylist sent an invoice for $477.73 to Former Campaign
Staffer on September 30, 2021, per Conde Nast's
instructions.\40\ The invoice noted that payment was due by
October 30, 2021.\41\
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\39\See OCC Referral Exhibit 16.
\40\Id.
\41\Id.
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On November 16, 2021, Hairstylist's agency emailed Former
Campaign Staffer about the past due payment and requested that
she provide proof of payment by the end of the week.\42\ Former
Campaign Staffer did not respond to the email, nor any of the
other emails sent by the agency throughout December.\43\ After
Conde Nast was looped back into communications on the issue in
mid-January 2022, the agency noted that Former Campaign Staffer
``has never responded to any requests for payment. Obviously it
would look terrible if we had to file a complaint with the NY
Dept of Labor against Alexandria Ocasio-Cortez for Congress. Do
you have an active contact on AOC's team who will pay for the
work done by our artist?''\44\ Former Campaign Staffer
responded to the email thread on January 26, 2022, and
requested a credit card authorization form. The agency provided
the form the same day, but Former Campaign Staffer did not
complete the payment.\45\
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\42\OCC Referral Exhibit 17.
\43\Id
\44\Id.
\45\See id.
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One month later, on February 23, 2022, the agency notified
Former Campaign Staffer and Conde Nast that they would be
filing a complaint against Alexandria Ocasio-Cortez for
Congress if payment was not deposited by the end of business on
the following day.\46\ Former Campaign Staffer requested a call
with Hairstylist's agency.\47\ On February 24, 2022, the
invoice was paid\48\ from Representative Ocasio-Cortez's
personal funds.\49\
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\46\Id.
\47\Id.
\48\OCC Referral Exhibit 18.
\49\OCC Interview of Representative Ocasio-Cortez.
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Former Campaign Staffer advised OCC that ``on one level
[the payment] did fall off my radar and I think I remember
getting e-mails from them usually when I was somewhere else
where I couldn't [] be at my laptop and focus on it.''\50\ She
also noted that there were some logistical issues in completing
the payment.\51\ The Committee did not receive any evidence
that Representative Ocasio-Cortez was personally made aware of
the communications from Hairstylist's agency regarding the late
payment. Representative Ocasio-Cortez testified to OCC that she
was not aware at the time how each good or service was to be
billed and believed that they would perhaps be reimbursing
Brother Vellies for all costs:
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\50\OCC Interview of Former Campaign Staffer.
\51\See id.
So I didn't know in terms of how it was structured if
we were paying each vendor individually, if it was
Brother Vellies covering the cost and then us--you
know, of all of these things because we hadn't shared,
or, you know, same provider, same vendor and that we
were reimbursing them. I also was under the impression
it was the latter, that we were reimbursing Brother
Vellies for the cost, but I really did not know the
details at the time of how things were itemized.\52\
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\52\OCC Interview of Representative Ocasio-Cortez.
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b. Makeup Services
Representative Ocasio-Cortez received makeup services for
the Met Gala from Makeup Artist.\53\ Several days after the
event, on September 17, 2021, the agency that represented
Makeup Artist in the transaction invoiced Conde Nast for
$344.85.\54\ On September 23, 2021, after receiving
instructions from Conde Nast to bill Representative Ocasio-
Cortez directly, Makeup Artist's agency asked Former Campaign
Staffer to provide the correct billing address for the
invoice.\55\ Former Campaign Staffer did not reply, and there
was no further communication between the parties until January
2022.
---------------------------------------------------------------------------
\53\OCC Referral Exhibit 19.
\54\Id.
\55\OCC Referral Exhibit 20.
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On January 10, 2022, Makeup Artist's agency emailed Conde
Nast another copy of the invoice, indicating that it was
outstanding and asking for payment ``as soon as
possible[.]''\56\ On January 13, 2022, Conde Nast rejected the
invoice noting that it was ``[t]o be paid out by AOC
team.''\57\ The notification also provided Former Campaign
Staffer's email address. Former Campaign Staffer replied to
further inquiry from the agency and advised them that ``we are
taking care of it, and apologies-this should have been taken
care of a while ago.''\58\ However, by January 25, 2022, Makeup
Artist had still not received payment, and the agency again
followed up with Former Campaign Staffer, who did not
respond.\59\
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\56\OCC Referral Exhibit 21.
\57\Id.
\58\Id.
\59\Id.
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Makeup Artist's agency followed up again on February 7,
2022, and noted that the ``invoice is still outstanding and
EXTREMELY overdue.''\60\ Former Campaign Staffer did not
respond. On February 11, 2022, the agency emailed Former
Campaign Staffer again and asked if the invoice needed to be
reissued to a different party so that it could be paid.\61\
Former Campaign Staffer apologized and indicated that they
believed payment had already been made, but that they would
issue payment the following business day.\62\ The agency
reached out to Former Campaign Staffer three more times in
February after not receiving payment.\63\ On February 24, 2022,
Former Campaign Staffer indicated to the agency that payment
had been completed.\64\ However, the agency informed her the
following day that the payment had been rejected.\65\ The
invoice was not successfully paid until March 16, 2022,
approximately two weeks after the congresswoman and her team
were informed of OCC's review.\66\ The invoice was paid from
Representative Ocasio-Cortez's personal funds.\67\
---------------------------------------------------------------------------
\60\Id.
\61\Id.
\62\See OCC Referral Exhibit 21.
\63\Id.
\64\OCC Referral Exhibit 22.
\65\Id.
\66\OCC Referral Exhibit 23.
\67\OCC Interview of Representative Ocasio-Cortez.
---------------------------------------------------------------------------
Former Campaign Staffer indicated to OCC that the delayed
payment to Makeup Artist's agency was due in part to issues in
completing the payment with the vendor and because ``other
things kind of took precedence[.]''\68\ The Committee did not
receive any evidence that Representative Ocasio-Cortez was
personally made aware of the communications from Makeup
Artist's agency regarding the late payment. As noted above,
Representative Ocasio-Cortez indicated she was under the
impression that Brother Vellies had paid the vendors and that
she would be reimbursing Brother Vellies.
---------------------------------------------------------------------------
\68\OCC Interview of Former Campaign Staffer.
---------------------------------------------------------------------------
c. Transportation to The Carlyle
Conde Nast coordinated transportation for Representative
Ocasio-Cortez from her home to The Carlyle (where she got ready
for the Met Gala). Two days prior to the event, individuals at
Conde Nast initially discussed renting a sprinter van, as ``AOC
team asked if we could have one that will transport crew and
AOC from location to location and then to the [hotel] and then
to The Met.''\69\ However, after estimating the van's potential
cost, individuals at Conde Nast instead internally proposed
renting two SUVs in an attempt to ``make it slightly more cost
effective.''\70\ In a later response to the same email thread,
Conde Nast staff said: ``Getting on a call with AOC and they
said that designers can't pay for stuff[, it] needs to be a
gift. So just double checking.''\71\ There is no indication
that Conde Nast provided Representative Ocasio-Cortez, or
anyone on her team, with an invoice for the transportation
costs until after OCC initiated its review.
---------------------------------------------------------------------------
\69\Exhibit 5.
\70\Id.
\71\Exhibit 4.
---------------------------------------------------------------------------
On March 16, 2022, approximately two weeks after OCC
notified Representative Ocasio-Cortez of its review, Former
Campaign Staffer was in contact with Conde Nast regarding
transportation costs.\72\ Conde Nast provided a receipt showing
that the total transportation cost was $586.84.\73\ However,
because there were four riders--three of whom were Vogue crew
members--Conde Nast suggested that it might be appropriate to
divide the hourly rate between the four individuals.\74\ Former
Campaign Staffer replied, ``Can we get an invoice for $180? We
can split this evenly.''\75\ An invoice in that amount was
provided to Former Campaign Staffer the following day on March
17, 2022.\76\ The invoice was paid in full almost two months
later, on May 10, 2022,\77\ from Representative Ocasio-Cortez's
personal funds.\78\
---------------------------------------------------------------------------
\72\OCC Referral Exhibit 34.
\73\Id.
\74\Id.
\75\Id.
\76\Id.
\77\OCC Referral Exhibit 35.
\78\OCC Interview of Representative Ocasio-Cortez.
---------------------------------------------------------------------------
2. Goods and Services Provided or Coordinated by Brother Vellies
Brother Vellies either directly provided or coordinated the
other goods and services received by the congresswoman and Mr.
Roberts related to their Met Gala attendance. Specifically,
Representative Ocasio-Cortez was provided with a gown, handbag,
shoes, jewelry, and a floral hairpiece, and ready-room services
for herself, and a bowtie, shoes, and tailoring services for
Mr. Roberts.
As discussed further below, Representative Ocasio-Cortez
and her team were provided with multiple invoices from Brother
Vellies which accounted for most, but not all, goods and
services received in connection with the Met Gala. Complete
payment to Brother Vellies for the invoiced costs did not occur
until May 10, 2022, nearly eight months after the event. During
its review, the Committee received information indicating that
the invoiced costs did not reflect the fair market value of the
goods and services provided.
a. Custom Designs by Brother Vellies
The gown, handbag, and shoes were all designed specifically
in contemplation of Representative Ocasio-Cortez's Met Gala
appearance, although some iterations of the handbag and shoes
were later sold at retail.\79\ Representative Ocasio-Cortez,
through Former Campaign Staffer and her counsel, communicated
to Brother Vellies at the outset that costs should be kept
down, although the Committee's record suggests that no specific
budget number was discussed.\80\
---------------------------------------------------------------------------
\79\See OCC Referral Exhibits 24, 25; see also Nile Bag in
Checkers, Brother Vellies, https://brothervellies.com/collections/bags/
products/checkers-nile-handbag (retailing at $1,195 and noting that
``Several customized versions were worn at the 2021 MET Gala.'') (last
visited July 24, 2025).
\80\See 18(a) Interview of Designer (Designer noted that
Representative Ocasio-Cortez's counsel asked her to ``keep a record,''
but when asked ``a record of what,'' she responded, ``I don't really
remember.'' She then explained, ``it was supposed to stay, like, cheap.
Q: Okay. Was there discussion of a specific budget? A: I don't
remember. Q: `Cheap' means different things to different people. Do you
have any sense of what that meant in this case? A: I don't remember. I
just remember, like, trying to keep it affordable.'').
---------------------------------------------------------------------------
Nonetheless, the record shows that Designer, and a team of
subcontractors, spent considerable time and effort in creating
custom apparel for the congresswoman's Met Gala appearance.
This process included drafting numerous sketches of possible
gown designs\81\ that were then narrowed down in lookbooks
presented to Representative Ocasio-Cortez (through Former
Campaign Staffer) seeking her feedback.\82\ Designer also
sought out Artist for paper flowers to be included in the
design of ``a pair of custom shoes[.]''\83\ When asked about
the budget for the shoes by another individual, Designer
indicated ``I don't know really. We are making 10 shoe options,
th[e paper flowers are] for one.''\84\
---------------------------------------------------------------------------
\81\See e.g., Exhibit 6.
\82\See e.g., Exhibit 7.
\83\Exhibit 8.
\84\Id. See also Exhibit 9 (noting multiple shoe and handbag design
options produced for Representative Ocasio-Cortez).
---------------------------------------------------------------------------
b. Invoices
On September 19, 2021, Publicist--who was associated with
Designer and Brother Vellies--provided Former Campaign Staffer
with an itemized invoice for rental of the gown and handbag, as
well as purchase of the shoes, in the amount of $2,283.93.\85\
---------------------------------------------------------------------------
\85\OCC Referral Exhibit 28.
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
The following day, on September 20, 2021, another invoice
was provided to Former Campaign Staffer, but with a reduced
total amount of $990.76.\86\ A jewelry rental had been added to
the invoice, but the prices listed for the gown and shoes
decreased significantly from $1,300 to $300 and $635 to $160,
respectively.
---------------------------------------------------------------------------
\86\OCC Referral Exhibit 29.
When asked about the revisions, Former Campaign Staffer
advised OCC that she spoke to Publicist after receiving the
first invoice because she noted some issues that she wanted to
address.\87\ Specifically, Former Campaign Staffer told OCC
that prior to the event, they had discussed the attire totaling
around one thousand dollars.\88\ Additionally, Former Campaign
Staffer's understanding was that the shoes were to be a rental,
rather than purchase as indicated in the invoice, because
Brother Vellies intended to use the shoes in other photo
shoots.\89\ Because of these discrepancies, Former Campaign
Staffer said that she wanted to confirm the bill's overall
accuracy.\90\
---------------------------------------------------------------------------
\87\OCC Interview of Former Campaign Staffer.
\88\Id.
\89\Id.
\90\Id.
---------------------------------------------------------------------------
Although Former Campaign Staffer indicated that the price
of the shoes was lowered to reflect that they were a rental,
the description in the revised invoice still indicated an
intent to purchase the shoes. The Committee found evidence that
the originally quoted price of $635 was a figure provided by
Designer to Brother Vellies' then-accountant, when he asked
Designer what she thought the fair market value would be for
the shoes.\91\ When asked to confirm whether the shoes were in
fact returned to Brother Vellies after the event, counsel for
Representative Ocasio-Cortez indicated to the Committee that
the ``shoes were returned September 15, 2021 (two days after
the Met Gala), in good condition (worn once).''\92\ However,
other evidence collected by the Committee suggests that the
return did not occur on the date provided by counsel and that
there was some intention to purchase the shoes--or at least
confusion between the parties around this point--in the weeks
following the event.
---------------------------------------------------------------------------
\91\Exhibit 10.
\92\Letter from counsel to Representative Alexandria Ocasio-Cortez
to Tom Rust, Committee on Ethics (July 29, 2024) (Appendix B).
---------------------------------------------------------------------------
For example, two days after the alleged return of the
shoes, Representative Ocasio-Cortez's counsel responded to
proactive outreach from Committee staff asking counsel if
``your client had any questions for us about the ethics rules
and how they apply to events like the Met Gala''--``something
we commonly do, particularly when there has been a high profile
matter and we don't have a record of the office seeking the
Committee's guidance on the issues involved''; in that
response, counsel asserted in relevant part that ``the
Congresswoman is paying personally for all other benefits,
including the rental value of her dress, handbag, and
accessories, as well as the full value for the shoes
worn.''\93\ In addition, on September 18, 2021, correspondence
between Conde Nast and Publicist noted that ``the pumps that
were worn by AOC haven't been returned yet.''\94\ Publicist
replied: ``The plan is for [Representative Ocasio-Cortez] to
keep the shoes since she can't rent them. She is planning to
pay in full.''\95\
---------------------------------------------------------------------------
\93\OCC Referral Exhibit 11 (emphasis added).
\94\Exhibit 11.
\95\Id.
---------------------------------------------------------------------------
An invoice produced to OCC also indicates that a courier
delivery to Brother Vellies was not scheduled until September
21, nearly a week after the Committee's September 15 outreach
(and the date counsel asserts that the return occurred).\96\
The timing of the delivery was also corroborated by
correspondence between Publicist and Conde Nast. In reply to
the previously discussed email thread about return of the
shoes, Publicist informed Conde Nast on September 27, 2021,
that ``[t]hey returned the dress last week but I know she
wanted to keep the shoes. I can help track them down if there
is still a need.''\97\ The Committee could not definitively
establish that the shoes were also included in the delivery (or
perhaps returned at a later date), but Representative Ocasio-
Cortez's counsel represented that the congresswoman ``no longer
has the shoes, and is unaware as to what may have happened to
them after they were sent back with the courier.''\98\
---------------------------------------------------------------------------
\96\Exhibit 12. Other documentation shows that the courier invoice
was paid by the campaign.
\97\Exhibit 13.
\98\Email from counsel to Representative Alexandria Ocasio-Cortez
to Committee staff, Committee on Ethics (Sept. 30, 2024) (Appendix B).
---------------------------------------------------------------------------
OCC also asked Former Campaign Staffer why the rental value
of the gown was reduced from $1,300 to $300 after she spoke to
Publicist, but Former Campaign Staffer said that she did not
know.\99\ OCC attempted to discuss these invoices (and other
matters) with Designer and Publicist, but they did not agree to
interviews; Designer and Publicist did, however, participate in
voluntary interviews with the Committee
---------------------------------------------------------------------------
\99\OCC Interview of Former Campaign Staffer.
---------------------------------------------------------------------------
Designer informed the Committee that she had no knowledge
about the prices included in the invoices nor why they might
have been changed.\100\ However, Publicist recalled that Former
Campaign Staffer asked for the costs provided in the original
invoice to be lowered and suggested specific prices that were
``[s]ignificantly lower numbers.''\101\ Publicist stated that
she was ``given guidance to adjust things as needed''\102\ by
Former Campaign Staffer and that there was some back and forth
between the teams to determine the pricing:
---------------------------------------------------------------------------
\100\ See 18(a) Interview of Designer.
\101\ 18(a) Interview of Publicist.
\102\ Id.
I mean, we would go back and forth on comparing items
to what she saw on Rent the Runway, and that was a big
comparison for [Former Campaign Staffer], which, you
know, could be a little offensive if I was [Designer].
Like, stuff is not intended to be on Rent the Runway.
This is very different, very different.\103\
---------------------------------------------------------------------------
\103\Id.
Brother Vellies' then-accountant similarly testified that
Representative Ocasio-Cortez's staff was part of a discussion
prior to the event about valuing the dress compared to services
like Rent the Runway.\104\ Former Campaign Staffer denied
requesting the prices to be lowered, stating that she ``only
asked that they confirm that [the invoice] was correct.''\105\
She also denied that she indicated to Publicist that she would
have expected the gown's rental cost to be lower than the
original quote based on a comparison to rentals featured on
Rent the Runway.\106\
---------------------------------------------------------------------------
\104\18(a) Interview of Former Accountant.
\105\18(a) Interview of Former Campaign Staffer.
\106\Id.
---------------------------------------------------------------------------
Although the revised Brother Vellies invoice was provided
to Former Campaign Staffer in September 2021, payment was not
made until the following year. Former Campaign Staffer told OCC
that payment was not made at that time because she ``didn't
consider it the final invoice because I knew we still had to
work through the hotel and so I did not treat it as a final
invoice.''\107\ She similarly informed the Committee that she
``would share with [Representative Ocasio-Cortez] that I got an
invoice from [Brother Vellies], that there were corrections
[that] needed to be made, and that we understood that it wasn't
the full scope of what we would need to pay out to Brother
Vellies.''\108\
---------------------------------------------------------------------------
\107\OCC Interview of Former Campaign Staffer.
\108\18(a) Interview of Former Campaign Staffer.
---------------------------------------------------------------------------
However, Publicist did contact Former Campaign Staffer
about collecting payment on the invoice in October 2021.
Specifically, on October 4, 2021, Publicist wrote to Former
Campaign Staffer, ``hi stranger! bumping this as we have yet to
receive payment. how are you doing over there?'' Former
Campaign Staffer replied, ``Trying! Is my answer to both of
your questions :D''\109\ The following day, Publicist contacted
Former Campaign Staffer again asking her to ``keep me posted on
that invoice so we can close that work out.''\110\ There was no
further correspondence regarding payment until after OCC
initiated its review.
---------------------------------------------------------------------------
\109\Exhibit 14.
\110\Exhibit 15.
---------------------------------------------------------------------------
On March 3, 2022, two days after OCC provided notice of its
review to Representative Ocasio-Cortez, Former Campaign Staffer
emailed Publicist ``to collect payment confirmation to process
for the Congresswoman and to `close the books' so to speak for
the event.''\111\ On March 7, 2022, Publicist responded that
``finance is saying they never received the payment via invoice
sent. Can you confirm when/how payment was made?''\112\ Former
Campaign Staffer indicated that they would ``have to take care
of this asap.''\113\ The invoice was paid in full on March 9,
2022.\114\
---------------------------------------------------------------------------
\111\OCC Referral Exhibit 30.
\112\Id.
\113\Id.
\114\OCC Referral Exhibit 31.
---------------------------------------------------------------------------
On April 15, 2022, counsel for Brother Vellies and Designer
contacted Representative Ocasio-Cortez's counsel in response to
their ``request for an invoice and supporting documentation for
any goods, services or amenities which Representative Ocasio-
Cortez and Mr. Riley Roberts may have received from your
clients in connection with the September 13, 2021, Met Gala''
that were as yet unpaid.\115\ In their response, Brother
Vellies and Designer's counsel identified six additional
expenses (car service, shared hotel rooms, and Mr. Roberts'
shoes and bow tie) requiring reimbursement in the total amount
of $5,579.99, and provided supporting documentation for the
expenses.\116\
---------------------------------------------------------------------------
\115\OCC Referral Exhibit 32.
\116\Id.
---------------------------------------------------------------------------
LV Services, Inc. (car service): $571.59.
Room 1122 at the Carlyle Hotel on September
12, 2021: $1,214.61.
Room 1122 at the Carlyle Hotel on September
13, 2021: $1,205.04.
Room 0911 at the Carlyle Hotel on September
13, 2021: $2,182.67.
Shoes for Mr. Roberts' attendance at the Met
Gala: $136.08.
Bow tie for Mr. Roberts' attendance at the
Met Gala: $270.00.
TOTAL: $5,579.99.
The Committee did not receive information about why Brother
Vellies did not initially seek repayment for these goods and
services. Representative Ocasio-Cortez's counsel referred to
the April 2022 invoice as ``new'' costs that make clear that
``[n]o one appeared to be thinking about the cost of anything,
despite the fact that they were told to keep the costs down by
the Congresswoman's staff because the Congresswoman had and has
limited financial means.''\117\
---------------------------------------------------------------------------
\117\Letter from counsel to Representative Alexandria Ocasio-Cortez
to Tom Rust, Committee on Ethics (May 16, 2025) (Appendix B).
---------------------------------------------------------------------------
The record suggests that Brother Vellies may have been
under the impression that the congresswoman did not have to pay
fair market value for the shoes and bow tie provided to Mr.
Roberts based on a text message exchange with Former Campaign
Staffer. Specifically, prior to the event, Former Campaign
Staffer sent text messages to Designer stating, ``Ah just
confirming you're thinking of providing Riley with a tie/
cummerbund? . . . There is no restriction on Riley btw[,]''
seemingly in reference to his ability to accept gifts.\118\
---------------------------------------------------------------------------
\118\Exhibit 16.
---------------------------------------------------------------------------
On May 10, 2022, the April 2022 invoice was paid in
full\119\ from Representative Ocasio-Cortez's personal
funds.\120\
---------------------------------------------------------------------------
\119\OCC Referral Exhibit 33.
\120\OCC Interview of Representative Ocasio-Cortez.
---------------------------------------------------------------------------
c. Additional Expenses
Although Representative Ocasio-Cortez ultimately completed
payment on both invoices provided to her by Brother Vellies,
two expenditures related to her and Mr. Roberts' Met Gala
appearance were not accounted for in the invoices.
First, Representative Ocasio-Cortez was provided with a
floral hairpiece by Brother Vellies. When asked about the
hairpiece by the Committee, her counsel indicated that the
flower ``was a live flower without future potential use'' so it
had not been returned; it was their ``impression that the cost
of this accessory was covered under either hair [or] makeup
vendor[.]''\121\ However, counsel provided no information
supporting this belief and there is no indication that the
accessory was covered under either vendor's invoices. Further,
evidence collected by the Committee--including the below social
media posts by Artist--suggests that the accessory was not a
live flower but rather a ``handmade and hand painted crepe
flower'' made by Artist that matched similar flowers that were
incorporated in the shoes designed by Brother Vellies.
Documents indicate Brother Vellies paid $1,000 for 28 ``Paper
Hibiscus'' flowers from Artist.\122\ Several of the flowers
were incorporated on the shoes that were designed for the
occasion, and the hair piece was selected to match the
shoes.\123\
---------------------------------------------------------------------------
\121\Email from counsel to Representative Alexandria Ocasio-Cortez
to Committee staff, Committee on Ethics (Sept. 30, 2024) (Appendix B).
\122\Exhibit 17.
\123\See Jessica Testa, A.O.C.'s Met Gala Designer Explains Her
``Tax the Rich'' Dress, New York Times (Sept. 16, 2021), https://
www.nytimes.com/2021/09/16/style/aoc-designer-tax-the-rich-dress.html
(``There was an artist . . . that I found through a friend who makes
these really beautiful flowers out of paper; she created the Flor de
Maga, which is the Puerto Rican national flower, for me in the very
beginning, and we designed the shoes around the idea of adorning them
with that flower.''); see also Brothervellies, Instagram (Sept. 14,
2021), https://www.instagram.com/p/CT0GjU3JUqk/.
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Second, Mr. Roberts received additional tailoring
services--separate from the Suit Supply tailoring related to
his tuxedo purchase--that were coordinated by Designer with
assistance from Former Campaign Staffer.\124\ When asked by OCC
whether Mr. Roberts received these services, Representative
Ocasio-Cortez stated: ``It never happened, but [Designer]
extended that offer [to have his suit tailored], yes.''\125\
When later asked the same question by the Committee,
Representative Ocasio-Cortez's counsel stated that ``[o]n
further discussion between the Congresswoman and Mr. Roberts,
she has learned that additional tailoring was done on his
tuxedo without her prior knowledge, that Mr. Roberts paid for
personally.''\126\ Counsel also produced a screenshot of a text
message indicating that Mr. Roberts received an invoice for
$103 for the alterations from Ignacio's Tailor.\127\ The
Committee asked counsel to clarify why Mr. Roberts provided the
receipt to Former Campaign Staffer and requested that they
provide documentation showing that Mr. Roberts paid for the
services personally.\128\ In response, counsel indicated that
``[a]ccording to Mr. Roberts' recollection, [Former Campaign
Staffer] told him to hold on to receipts related to the Met
Gala, so he sent to her for safe keeping, not to seek
reimbursement, approval, or the like.''\129\ Counsel also
provided a bank statement from Mr. Roberts indicating that he
withdrew cash to pay for the tailoring services.\130\
---------------------------------------------------------------------------
\124\Exhibit 18.
\125\OCC Interview of Representative Ocasio-Cortez.
\126\Letter from counsel to Representative Alexandria Ocasio-Cortez
to Tom Rust, Committee on Ethics (July 29, 2024) (Appendix B) (emphasis
in original).
\127\Id.
\128\Email from counsel to Representative Alexandria Ocasio-Cortez
to Committee staff, Committee on Ethics (Oct. 15, 2024) (Appendix B).
\129\Id. (emphasis removed).
\130\Id.
---------------------------------------------------------------------------
d. Fair Market Value of Goods and Services
According to Representative Ocasio-Cortez's counsel, ``[t]o
ensure that these costs invoiced were the `fair market value'
for rental of these items, the congresswoman and her team
conducted a separate analysis.''\131\ Counsel explained this
analysis as follows.
---------------------------------------------------------------------------
\131\Exhibit 19.
---------------------------------------------------------------------------
Brother Vellies had indicated to Representative Ocasio-
Cortez and her team that ``their costs to create the dress and
handbag were $1,000.''\132\ The Committee did not receive
information about how the $1,000 cost was conveyed. Based on
that figure, counsel calculated a $3,000 market value for the
dress and handbag, explaining that, according to Vogue, the
industry standard markup is approximately ``2.2 to 2.5 times
cost,''\133\ but counsel applied ``a greater markup [. . . (of
3 times cost)] given the time [Designer] spent on the dress and
handbag, time for fittings, and the like, and came to a $3,000
market value.''\134\ ``Publicly available data points'' were
then used to determine the rental cost, including comparisons
to Rent the Runway.''\135\ Based on this analysis, counsel
determined that the anticipated fair market value for rental of
the dress and handbag was $473.94 (15.80% of their calculated
$3,000 market value). Calculations for the other items were
performed using similar methods:
---------------------------------------------------------------------------
\132\Id.
\133\Emily Farra, What Is the Right Price for Fashion?, Vogue (June
29, 2020), https://www.vogue.com/article/what-is-the-right-price-for-
fashion (``The industry standard for a profit margin is between a 2.2
and 2.5x markup, meaning a dress that cost a designer $100 to produce
might be sold to a retailer for $220. That retailer has to mark it up
by 2.2x again to make its own profit, bringing the final price up to
$484.'').
\134\Exhibit 19 (emphasis in original).
\135\Id.
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Based on these calculations, Representative Ocasio-Cortez's
counsel determined that she was charged and paid ``greater than
the `fair market value' projections.''\136\
---------------------------------------------------------------------------
\136\Id.
---------------------------------------------------------------------------
However, the Committee received evidence that the Cost of
Goods (COGS) for Brother Vellies to create the dress was
$6,279.10, rather than $1,000.\137\ The invoice indicating the
COGS also noted, ``AOC Met Gala Rental Invoice Per Rent the
Runway $300.''\138\ When asked why the dress rental amount
invoiced was decreased from $1,300 to $300, as discussed above,
the former accountant for Designer stated, ``I don't know why
there was a reduction [. . .] this wasn't me making those
decisions; it was them telling me, `Here is what should be.' [.
. .] I presented to them what I had and then they made the
decisions off of that.''\139\ The accountant also explained
that he used the $300 valuation based on a chiffon gown
available on Rent the Runway at the time, which retailed for
$2,280 but was available to rent for $330.\140\ The Committee
did not receive any evidence that Representative Ocasio-Cortez
or her team received the invoice reflecting the true COGS or
otherwise had reason to know the actual design costs until the
Committee inquired about the information. When presented with
the documents reflecting the $6,279.10 COGS by the Committee on
May 5, 2025, counsel for Representative Ocasio-Cortez asserted
that the congresswoman was not aware of these costs and ``did
not authorize these costs.''\141\
---------------------------------------------------------------------------
\137\Exhibit 17.
\138\Id. (emphasis in original).
\139\18(a) Interview of Former Accountant.
\140\Unlike the new, custom-made gown worn by the congresswoman,
the comparator gown was a ready-to-wear item and a screenshot taken by
the accountant at the time indicates that dozens of renters had
previously rented the gown at the time it was renting for $330.
\141\Letter from counsel to Representative Alexandria Ocasio-Cortez
to Tom Rust, Committee on Ethics (May 16, 2025) (Appendix B).
---------------------------------------------------------------------------
Applying the methodology used by Representative Ocasio-
Cortez's team--multiplying the updated COGS by a markup of 3
times cost ($6,279.10), the retail value of the dress would be
$18,837.30. Applying the cited rental percentage of the retail
value (15.8%) results in a rental value of approximately
$2,976.29.
With respect to the shoes worn to the event, the full fair
market value for their purchase would be approximately
$635.\142\ As Representative Ocasio-Cortez's counsel noted,
``[t]here is no comparable market for shoe rental to compare
prices.''\143\
---------------------------------------------------------------------------
\142\Exhibit 10; but see OCC Referral Exhibit 25 (indicating that a
version of the shoes worn by Representative Ocasio-Cortez was later
sold at retail for $795).
\143\Exhibit 19 n.19.
---------------------------------------------------------------------------
The retail value of the jewelry listed in counsel's
calculations is consistent with listings on Mejuri's website
for the pieces worn by Representative Ocasio-Cortez.\144\
---------------------------------------------------------------------------
\144\OCC Referral Exhibits 26, 27.
---------------------------------------------------------------------------
Finally, a version of the handbag designed in contemplation
of Representative Ocasio-Cortez's Met Gala appearance was later
sold by Brother Vellies at retail for $995. This version did
not include the custom ``Tax the Rich'' slogan featured in the
design worn by the congresswoman, but the handbag's description
on the website noted its connection to the one worn at the
event.\145\ Applying 15.80% to a retail value of $995 produced
an approximate rental value of $157.21.
---------------------------------------------------------------------------
\145\OCC Referral Exhibit 24 (``The Nile Handbag is a beloved lady.
She enjoys skirt suits, candlelight dinners, and well thought out
plans. And an occasional Met Gala.'').
---------------------------------------------------------------------------
V. FINDINGS
A. REPRESENTATIVE OCASIO-CORTEZ IMPERMISSIBLY ACCEPTED GIFTS RELATED TO
HER ATTIRE AT THE 2021 MET GALA
Under federal law and House regulations, Members may not
accept gifts unless they meet certain requirements; gifts may
include any ``item having monetary value,'' a well as ``gifts
of services, training, transportation, lodging, and meals,
whether provided in kind, by purchase of a ticket, payment in
advance, or reimbursement after the expense has been
incurred.''\146\ This prohibition does not apply to anything
for which the Member pays the fair market value,\147\ which is
the item's retail price, or the reasonable estimate of an
item's cost if it were available for sale.''\148\
---------------------------------------------------------------------------
\146\House rule XXV, cl. 5(a)(2)(A); see also 5 U.S.C. Sec. 7353.
\147\Id. at cl. 5(a)(3)(A).
\148\House Gift Guidance.
---------------------------------------------------------------------------
As Representative Ocasio-Cortez's counsel acknowledged,
``[t]he Met Gala is primarily an event for celebrities, who are
not subject to any legal restrictions on acceptance of gifts
and who are routinely given complimentary benefits in
connection with their attendance.''\149\ Unlike many other
attendees at the Met Gala, Representative Ocasio-Cortez, as a
Member of Congress, could not accept gifts or loans of goods
and/or services associated with her attendance at the event,
although her personal attendance at the event otherwise
complied with House Rules.
---------------------------------------------------------------------------
\149\Letter from counsel to Representative Alexandria Ocasio-Cortez
to Tom Rust, Committee on Ethics (May 16, 2025) (Appendix B).
---------------------------------------------------------------------------
In recognition of that limitation, Representative Ocasio-
Cortez proactively took steps to ensure her compliance with the
Gift Rule, including by engaging counsel prior to her
attendance and by arranging to ``rent'' her apparel and to pay
for various services out of her personal funds. The Committee
acknowledges these significant attempts at compliance.
Nonetheless, Representative Ocasio-Cortez's attempt to
apply a retail rental cost to a handmade couture gown was
unrealistic.\150\ Although Representative Ocasio-Cortez relied
on the advice of her counsel and information provided by her
staff, and the designer of her attire, to calculate an
appropriate rental cost, those calculations did not fully
account for the true cost of the unique goods and services she
received, or the countervailing incentives of the vendors whose
good and services would be showcased.
---------------------------------------------------------------------------
\150\See Tahirah Hairston, Who Pays for Those $10,000 Met Gala
Dresses: Five Designers on the High, Unreimbursed Costs of Dressing a
Celebrity for the First Monday in May, The Cut (May 5, 2025), https://
www.thecut.com/article/met-gala-costs-designers.html (noting that
``[f]or independent designers, the cost of creating a single custom
look can range from $5,000 to more than $10,000.'').
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1. Delay in Payments
As OCC found, while Representative Ocasio-Cortez did
ultimately pay for most of the goods and services received,
``payment [. . .] did not occur until after the OC[C] contacted
her in connection with [its] review. But for [. . .which,] it
appears that [she] may not have paid for several thousands of
dollars'' worth of goods and services provided to her.''\151\
While forbearance may itself constitute a gift, and the
Committee has concerns about whether Representative Ocasio-
Cortez's delays in making payments for the goods and services
received is itself a violation of the Gift Rule, the Committee
did not find any indication that the delays in making payments
were intentional or that Representative Ocasio-Cortez was aware
of the extent to which they occurred.
---------------------------------------------------------------------------
\151\OCC Referral at 8.
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Her counsel noted, ``[h]owever, the delay in payment by
itself is not evidence that the Congresswoman did not intend to
pay for personal expenses related to Met Gala, especially given
the explicit, documented communications which took place prior
to OC[C]'s review that show she did intend to pay, and that her
staff was collecting invoices and consulting with Counsel to
that effect.''\152\ Nonetheless, Representative Ocasio-Cortez
stated to OCC that ``it is just a deeply regrettable
situation'' and that she ``feel[s] terrible for especially the
small businesses that were impacted.''\153\
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\152\Letter from counsel to Representative Alexandria Ocasio-Cortez
to Tom Rust, Committee on Ethics (July 8, 2022) (Appendix B) (emphasis
removed).
\153\OCC Interview of Representative Ocasio-Cortez.
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2. Fair Market Value
With respect to whether Representative Ocasio-Cortez paid
fair market value for the goods and services received, the
Committee acknowledges that she and her counsel took some steps
to determine fair market value. However, these efforts failed
to account for the true cost of such unique goods, particularly
considering that they were custom-made for the congresswoman
and likely had no further use after the event. The Committee
agrees with Publicist--the comparison of a one-of a kind,
custom-made designer gown to those sold commercially and rented
to numerous individuals on Rent the Runway is simply
inapposite.
Even so, there must be some method by which to determine
the rental value of the items received. The Committee finds it
appropriate to generally employ the methodology used by
Representative Ocasio-Cortez's counsel but with some adjustment
and acknowledgement of the difficulty of this endeavor for all
parties involved. Thus, using the revised cost of goods
provided to the Committee, the Committee finds that the true
retail value of the gown designed for Representative Ocasio-
Cortez was likely approximately $18,837.30, and $2,976.29 would
be a more reasonable fair market value for rental of the gown.
With respect to the shoes worn by Representative Ocasio-
Cortez, it seems the parties initially intended for the
congresswoman to pay full value for purchase of the shoes
($635). As her counsel previously noted, there is no comparable
market for shoe rentals.\154\ However, because the Committee
did not find evidence that the shoes are still in
Representative Ocasio-Cortez's possession, it finds that the
$160 already paid is sufficient fair market value for rental of
the shoes.
---------------------------------------------------------------------------
\154\Exhibit 19. See also 18(a) Interview of Publicist (Q. ``In
your response to him, you wrote that he should also include the price
of the shoes, too, since she has to buy them. So why did you say that
she needed to buy the shoes?'' A. ``I am trying to remember. I mean,
typically--again, I am not an expert even on the fashion side, but
typically, with shoes, you buy them. You should not be renting. That
would be a little nasty to rent shoes.'').
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A version of the handbag designed in contemplation of
Representative Ocasio-Cortez's Met Gala appearance was later
sold by Brother Vellies at retail for $995.\155\ This version
did not include the ``Tax the Rich'' slogan featured in the
design worn by Representative Ocasio-Cortez, but the handbag's
description on the website noted its connection to the one worn
at the event.\156\ Applying the 15.80% retail to rental
valuation used by counsel, with the retail value of $995,
produced an approximate rental value of $157.21. Representative
Ocasio-Cortez was initially invoiced $170 for rental of the
handbag. The Committee therefore finds the originally invoiced
$170 to be a reasonable approximation of fair market value.
---------------------------------------------------------------------------
\155\OCC Referral Exhibit 24.
\156\Id.
---------------------------------------------------------------------------
The Committee accepts counsel's determination of fair
market value for rental of the jewelry--totaling $78.47. As
noted above, Representative Ocasio-Cortez was not invoiced for
the handmade paper flower that was worn in her hair. Brother
Vellies was billed $1,000 for 28 flowers, so the per flower
cost was approximately $35.71. Accordingly, the Committee finds
the below to be an appropriate estimation of the fair market
value of the items provided to Representative Ocasio-Cortez by
Brother Vellies:\157\
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\157\The goods and services included in the April 15, 2022, invoice
were set at market value and require no additional consideration by the
Committee.
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Representative Ocasio-Cortez's counsel asserts that ``[i]t
would be nonsensical to suggest that the Congresswoman should
have been prepared to pay for aspects of items and services
that she didn't know about and didn't authorize,'' and
repeatedly invokes the ``due diligence'' conducted by her team,
which ``should be worth something.''\158\ Indeed, the Committee
has considered the efforts made as evidence that the
congresswoman did not intend to receive a significant discount
on the costs incurred in connection with her Met Gala
attendance. Nonetheless, the Committee's record indicates that
the ``due diligence,'' which was primarily done by Former
Campaign Staffer and the same counsel who represented her
before the Committee, fell short. Despite counsel's
characterization of the costs at issue as ``new,'' they are the
actual costs incurred by Brother Vellies in the making of a
custom-designed gown for an evening on the red carpet.\159\
Counsel's letter references Brother Vellies ``discovering'' new
costs, but the Cost of Goods was not provided to the Committee
by Brother Vellies, but instead by the accountant they
employed. Acting on the instruction of Brother Vellies, the
accountant did indeed generate an invoice that vastly
undervalued the apparel. Given the inherent value gained from
the exposure of a sitting congresswoman wearing their designs
to the Met Gala, it is not surprising that Brother Vellies did
not seek the congresswoman's ``authorization'' for the gift
they provided.
---------------------------------------------------------------------------
\158\Letter from counsel to Representative Alexandria Ocasio-Cortez
to Tom Rust, Committee on Ethics (May 16, 2025) (Appendix B).
\159\Counsel similarly described the April 2022 invoice as ``new''
and ``discovered'' costs, but those were also actual costs incurred at
the time and which Representative Ocasio-Cortez had reason to know
existed, as she herself was present in the cars and hotel rooms for
which she was later charged.
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Counsel has asserted that under the Committee's analysis,
there is no level of diligence that could have been done that
would have been sufficient but also rejects the argument that
the congresswoman ``just shouldn't have gone'' to the
event.\160\ The Committee does not take the position that the
congresswoman's attendance at the event was itself
impermissible, nor does it find that she necessarily should
have declined the opportunity to be dressed by a professional
designer. Once she accepted that opportunity, however, it was
unrealistic for her team to communicate a general desire to
keep costs down and then develop a price based on inapt
comparators and loose quotes from the designer. Counsel asks,
``What other due diligence could the Congresswoman and her
staff have done before the event that would have satisfied the
Committee?'' The answer is simple: they could have called the
Committee's staff for assistance.
---------------------------------------------------------------------------
\160\Letter from counsel to Representative Alexandria Ocasio-Cortez
to Tom Rust, Committee on Ethics (May 16, 2025) (Appendix B).
---------------------------------------------------------------------------
Representative Ocasio-Cortez has informed the Committee
through her counsel that she will pay ``amounts directed and
invoiced by Brother Vellies for services rendered,'' but the
burden of the House Gift Rule does not fall on those who would
seek to give the gifts; to suggest otherwise misses the point
of the rule, which serves to protect the integrity of the
House. Counsel argues that Representative Ocasio-Cortez
``cannot and should not be held to verifying the accuracy of
those invoices.''\161\ While the congresswoman's ethical
obligations do not require her to verify the accuracy of every
invoice she receives, they do require her to reject or repay
all improper gifts, regardless of whether she solicited them.
This obligation is not unique to Representative Ocasio- Cortez,
and she is not the first Member to receive a gift without
``authorization.''
---------------------------------------------------------------------------
\161\Letter from counsel to Representative Alexandria Ocasio-Cortez
to Tom Rust, Committee on Ethics (May 16, 2025) (Appendix B).
---------------------------------------------------------------------------
For example, in 2013, several House Members traveled to a
foreign country and found miscellaneous tangible gifts waiting
for them in their hotel rooms and received inconsistent answers
about the source of the gifts. In that matter, the Committee
noted its history of requiring repayment for improper gifts,
``even where the Member was initially unaware that they had
received an improper gift''; all Members complied with the
Committee's guidance to return the gifts or committed to take
the corrective action recommended.\162\ The Committee also
acknowledged the Members acted in good faith and imposed no
sanction, but nonetheless found that repayment was necessary.
In another matter reviewed by the Committee around the same
time, an investigative subcommittee determined that, due to the
``corrosion of evidence over time, it could not recommend a
finding that [the Member] purposefully or corruptly accepted
any of the gifts'' at issue, but that his ``state of mind at
the time he obtained the gifts did not impact whether he must
repay.''\163\ In that matter, which involved additional
allegations of misuse of campaign funds and tens of thousands
of dollars of gifts over several years, the Committee did
determine to reprove the Member, noting the ``lack of
appropriate safeguards and an inattention to the relevant
standards of conduct.'' Here, the Committee found
Representative Ocasio-Cortez's conduct with respect to the fair
market value discrepancy to be more akin to the foreign
travelers dealing with a dishonest trip sponsor. However, as
discussed further below, some of the actions of her staff,
acting under her supervision, exacerbated the situation.
---------------------------------------------------------------------------
\162\Comm. on Ethics, In the Matter of Officially-Connected Travel
by House Members to Azerbaijan in 2013, H. Rept. 114-239, 114th Cong.,
1st Sess. 25 (2015).
\163\Comm. on Ethics, In the Matter of Allegations Relating to
Representative Don Young, H. Rept. 113-487, 113th Cong., 2d Sess. 4
(2014).
---------------------------------------------------------------------------
Based on the above, the Committee finds that it would be
appropriate for Representative Ocasio-Cortez to remit payment
of an additional $2,733.28 for the goods that she received in
connection with her attendance at the 2021 Met Gala to comply
with the Gift Rule.\164\
---------------------------------------------------------------------------
\164\The total amount for repayment is based on a highly
conservative estimate of the actual value of the goods and services
that the congresswoman received. For example, the Committee could
reasonably have determined that applying a reduced ``rental'' value to
the retail cost was an undue discount considering the lack of market
for custom-made designs (as opposed to ready-to-wear designs). This is
even more true for the shoes, for which there is no rental market even
for ready-to-wear designs. The Committee also could have considered
whether the various designs sketched by Designer and not ultimately
used should have been separately valued.
---------------------------------------------------------------------------
B. REPRESENTATIVE OCASIO-CORTEZ IMPERMISSIBLY ACCEPTED A GIFT OF FREE
ADMISSION TO THE 2021 MET GALA FOR HER THEN-PARTNER, RILEY ROBERTS.
OCC found that Representative Ocasio-Cortez's acceptance of
free admission to the Met Gala for her then-partner, Mr.
Roberts, was permissible because it ``opted to treat a long-
term significant other as synonymous with a spouse'' which was
``[c]onsistent with prior decisions[.]''\165\ However, OCC's
decision to treat a long-term significant other as a spouse for
purposes of the Gift Rule is not based on any law or precedent
then in existence.\166\
---------------------------------------------------------------------------
\165\OCC Referral n.47.
\166\The Committee also found evidence that Representative Ocasio-
Cortez listed Mr. Roberts as her ``spouse'' on paperwork filed with the
House relating to privately sponsored travel, although the two were not
legally married at the time of the gifted travel. It is not clear
whether these misstatements were made on the advice of counsel; indeed,
counsel acknowledged in his May 16, 2025, letter that the Travel
Regulations provide that Mr. Roberts was not a ``relative'' under the
applicable regulations. The Committee further notes that at the same
time Representative Ocasio-Cortez was seeking to take advantage of
exceptions to the Gift Rule only applicable to spouses and/or certain
relatives, she was not disclosing Mr. Roberts' financial interests as
is required of Members who are legally married.
---------------------------------------------------------------------------
Under House Rules and guidance as applied at the time of
the event, a Member was only permitted to accept an unsolicited
offer of free attendance to a charity fundraising event--such
as the Met Gala--for themselves and either a spouse or
dependent child.\167\ The Ethics Manual defines ``spouse'' as
``someone to whom you are legally married.''\168\
Representative Ocasio-Cortez's counsel was also informed of
this guidance when Committee staff conducted outreach in the
days after the event; counsel was explicitly told that a Member
could only accept free attendance for a ``spouse,'' and that
``the Committee has taken a fairly narrow view of who counts as
a `spouse or dependent child.'''\169\ Representative Ocasio-
Cortez's counsel sought no additional clarification.
---------------------------------------------------------------------------
\167\House Gift Guidance.
\168\Ethics Manual at 39.
\169\OCC Referral Exhibit 11.
---------------------------------------------------------------------------
Representative Ocasio-Cortez's counsel later informed the
Committee that the ``Congresswoman chose to follow campaign
finance laws [. . . which] was and is a reasonable and logical
conclusion to make, and the Committee should not so brazenly
apply guidance limited to other sets of rules in other
contexts.''\170\ If counsel was unsure what guidance applied to
the situation, counsel (or the congresswoman herself) should
have contacted the Committee for advice, rather than
``choosing'' which law to apply. The Committee ``takes very
seriously its obligation to provide sound and dispassionate
advice to the Members of this House'' and would have informed
Representative Ocasio-Cortez and her counsel that Mr. Roberts
did not fit the definition of a ``spouse'' for purposes of the
Charitable Events Exception.\171\ Further, acting on the advice
of counsel does not excuse a Member from a long-held ``duty of
reasonable inquiry'' and ``even if Representative [Ocasio-
Cortez] believed h[er] actions were consistent with what the
law required, that belief was mistaken, as the Committee would
have informed h[er], had [s]he only asked.''\172\
---------------------------------------------------------------------------
\170\Letter from counsel to Representative Alexandria Ocasio-Cortez
to Tom Rust, Committee on Ethics (May 16, 2025) (Appendix B).
\171\Comm. on Ethics, In the Matter of Allegations Relating to
Representative David McKinley, H. Rept. 114-795, 114th Cong., 2d Sess.
18 (2016).
\172\Id. at 20-21.
---------------------------------------------------------------------------
While the Committee has since updated its guidance and now
permits the acceptance of an offer for free attendance for any
guest--as long as the attendance otherwise complies with the
Gift Rule--the Committee may not retroactively apply that
guidance to prior conduct.\173\ Accordingly, Representative
Ocasio-Cortez impermissibly accepted a gift of free admission
to the 2021 Met Gala for Mr. Roberts, even if she was acting on
the advice of her counsel. Per House Gift Guidance, the ``value
of tickets to charity or political fundraisers is the value of
the meal [. . .] not the ticket's value.''\174\ Therefore, the
Committee finds that Representative Ocasio-Cortez should donate
the per-person cost for Mr. Roberts' meal at the gala, which
the Met determined to be $250, to the Costume Institute.\175\
---------------------------------------------------------------------------
\173\See 2022 Pink Sheet.
\174\House Gift Guidance; Ethics Manual at 26.
\175\Exhibit 20 (noting that the ``goods and services are $250 per
ticket'' in response to a request from Representative Ocasio-Cortez's
counsel for the per-person cost of the meal at the event).
---------------------------------------------------------------------------
C. REPRESENTATIVE OCASIO-CORTEZ FAILED TO EXERCISE PROPER OVERSIGHT
OVER STAFF
The Ethics Manual also warns Members against actions that
``may create an appearance of impropriety that may undermine
the public's faith in government.''\176\ The Committee has
repeatedly cautioned that Members should avoid even the
appearance of impropriety, which undermines the public's
confidence in the integrity of government officials.\177\
---------------------------------------------------------------------------
\176\House Ethics Manual (2008) at 24.
\177\See, e.g., Comm. on Ethics, In the Matter of Allegations
Relating to Representative Cathy McMorris Rodgers, H. Rept. 116-359,
116th Cong., 1st Sess. 52 (2019) (``Nonetheless, the Committee cautions
Representative Rodgers and the whole House community to avoid even the
appearance of a conflict of interest when entering into relationships
with contractors on behalf of the House.'') (hereinafter Rodgers);
Comm. on Ethics, In the Matter of Allegations Relating to
Representative Thomas Garrett, Staff Rept. 115th Cong., 2d Sess. 38
(2019) (``However, Members have a duty to avoid even the appearance of
impropriety. When Members accept gifts from their employees, it can
lead to an appearance that the Member lacks impartiality and create an
environment in which staff attempt to win a Member's favor not based on
their work product or effort, but by offering to perform unofficial
favors for or providing gifts to the Member.''); Comm. on Ethics, In
the Matter of Allegations Relating to Representative Luis V. Gutierrez,
H. Rept. 115-617, 115th Cong., 2d Sess. 31 (2018) (``The Committee has
also long cautioned Members that when taking official actions, they
must `avoid situations in which even an inference might be drawn
suggesting improper action.''') (hereinafter Gutierrez).
---------------------------------------------------------------------------
The Committee found no evidence that Representative Ocasio-
Cortez was aware of Former Campaign Staffer's attempts to lower
the congresswoman's costs with respect to the Met Gala, but
those attempts nonetheless occurred. Former Campaign Staffer
was also tasked with making payments to the various vendors for
the goods and services received by Representative Ocasio-Cortez
and Mr. Roberts, and those payments were delayed well beyond
the date of the event. In fact, most payments were not made
until after repeated attempts at collection from unpaid
vendors, threatened legal action, or following the initiation
of OCC's review. While Representative Ocasio-Cortez may not
have been fully aware of these issues, she bears ultimate
responsibility for their occurrence. Had she more diligently
supervised a staffer working on her behalf, she may have
identified these issues prior to the initiation of OCC's review
nearly six months after the event. Nonetheless, the Committee
acknowledged Representative Ocasio-Cortez's general good-faith
efforts at compliance, as well as her reliance on the actions
of her staff and the advice of her counsel, in determining that
a sanction is not necessary.
The Committee has previously sanctioned Members in a
variety of recent matters, including: where a Member failed to
employ appropriate safeguards to prevent a pervasive and years
long misappropriation of resources;\178\ where a Member was
unaware of improper activity but failed to take appropriate
steps to address misconduct when it came to light;\179\ where a
Member engaged in repeated unwanted advances towards a woman
who was required to work with him;\180\ where a Member was
found to have unintentionally used MRA funds in a
``substantial, non-technical'' violation of House Rules;\181\
and where a Member accepted a substantial gift due to
inattention to the rules.\182\ In other recent matters,
however, the Committee has declined to recommend a sanction
where it found a violation to have occurred, including: where a
Member violated campaign finance restrictions but engaged in
good faith efforts to comply, did not seek to unjustly enrich
herself, and made required repayments;\183\ where a Member
showed poor judgment in his official communications, acted in a
manner that did not reflect creditably upon the House, but did
not intend to violate any laws or rules;\184\ and where a
Member engaged in an ``inadvertent, technical violation'' of a
House Rule.\185\
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\178\Rodgers.
\179\Comm. on Ethics, In the Matter of Allegations Relating to
Representative Mark Meadows, H. Rept. 115-1042, 115th Cong., 2d Sess.
(2018).
\180\Comm. on Ethics, In the Matter of Allegations Relating to
Representative Ruben Kihuen, H. Rept. 115-1041, 115th Cong., 2d Sess.
(2018).
\181\Gutierrez at 29.
\182\Comm. on Ethics, In the Matter of Allegations Relating to
Representative Bobby L. Rush, H. Rept. 115-618, 115th Cong., 2d Sess.
(2018).
\183\Comm. on Ethics, In the Matter of Allegations Relating to
Representative Rashida Tlaib, H. Rept. 116-473, 116th Cong., 2d Sess. 4
(2020).
\184\Comm. on Ethics, In the Matter of Allegations Relating to
Representative Matt Gaetz, H. Rept. 116-479, 116th Cong., 2d Sess.
(2020) (in that matter, the Committee did determine its report should
serve as an admonishment of the Member).
\185\Comm. on Ethics, In the Matter of Allegations Relating to
Representative Ben Ray Lujan, H. Rept. 115-272, 115th Cong., 1st Sess.
(2017).
---------------------------------------------------------------------------
Although Representative Ocasio-Cortez failed to exercise
proper oversight over a staffer working on her behalf, the
Committee did not find evidence that she intended to seek to
lower the cost of goods provided to her or to delay payment for
those goods and other services received by her and Mr. Roberts.
Communications about payments, or the lack thereof, were
handled solely by Former Campaign Staffer. Representative
Ocasio-Cortez and her counsel also made efforts to ensure her
compliance with House Rules and to pay fair market value for
the goods and services received. Although their efforts at
valuation fell short, and efforts to make appropriate payment
were delayed, the Committee nonetheless recognizes that those
efforts occurred, and that Representative Ocasio-Cortez sought
to act consistently with her ethical requirements as a Member
of the House. In light of this, the Committee determined that
no sanction was merited, provided Representative Ocasio-Cortez:
(1) donates the $250 value of Mr. Roberts' Met Gala meal to the
Costume Institute and (2) pays Brother Vellies an additional
$2,733.28 for the fair market value of the goods that she
received in connection with her 2021 Met Gala attendance.
The Committee also acknowledges Representative Ocasio-
Cortez's general cooperation in the matter. Counsel suggested
that Representative Ocasio-Cortez's cooperation ``increased the
scrutiny that the Committee has placed on this matter,''\186\
but the Committee credits the congresswoman for her
participation throughout its review. Most notably, the
Committee relied on the transcript of the congresswoman's
testimony to OCC rather than requesting she appear for an
additional interview before the Committee. When certain
inconsistencies were identified in the OCC testimony, such as
Representative Ocasio-Cortez's initial assertion that Mr.
Roberts did not receive tailoring services, the Committee
provided her with the opportunity to correct the record. While
counsel is correct that Committee staff conducted a thorough
investigation and ``rechecked'' OCC's work, such diligence is
in no way unique to this matter. The Committee independently
reviews all referrals from OCC.
---------------------------------------------------------------------------
\186\Letter from counsel to Representative Alexandria Ocasio-Cortez
to Tom Rust, Committee on Ethics (May 16, 2025) (Appendix B). Counsel
also seemed to suggest that it may not have been an actual coincidence
that the Committee sent correspondence to Representative Ocasio-Cortez
on the day of the 2025 Met Gala. The Committee generally does not track
when the annual Met Gala occurs, and the date was indeed a coincidence.
---------------------------------------------------------------------------
VI. CONCLUSION
The Committee determined that Representative Ocasio-
Cortez's conduct was inconsistent with House Rules, laws, and
other standards of conduct with respect to her acceptance of
certain goods and services associated with her attendance at
the 2021 Met Gala, and her delay in making appropriate payment
for their receipt. While the Committee did not find that
Representative Ocasio-Cortez's violations were knowing and
willful, she nonetheless received impermissible gifts and must
bear responsibility for the other conduct that occurred with
respect to the delays in payment.
The Committee also reminds all House offices that Members
and their congressional staff may always seek guidance from the
Committee and encourages them to do so proactively, even if
they are represented by counsel.
Following the publication of this Report and repayment of
the value of the improper gifts, the Committee will consider
this matter closed.
VII. STATEMENT UNDER HOUSE RULE XIII CLAUSE 3(c)
The Committee made no special oversight findings in this
Report. No budget statement is submitted. No funding is
authorized by any measure in this Report.
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