After Trump fired Comey on May 9, 2017, Comey in a crazed rage gave several memos to a personal friend with instructions to leak details of one of the memos to The New York Times. Comey said he leaked the document in order to trigger a special counsel’s investigation of Trump.

Horowitz said Comey’s irresponsible actions set a “dangerous” precedent for FBI employees. He referred Comey to the Justice Department for investigation, but prosecutors declined to press charges.

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