"Clinton plan intelligence" is an unproven conspiracy theory promoted as if true by the Trump administration. It is based on Russian intelligence material and hacked and manipulated emails described by journalists and investigators as likely Russian disinformation. It alleges that Hillary Clinton approved a plan to "falsely" link Donald Trump to Russian election interference. The phrase's wording, with his addition of "falsely", was coined by special counsel John Durham to describe allegations that Hillary Clinton, her 2016 presidential campaign, and senior Obama administration officials developed the purported plan to distract from Clinton's email controversy.
The purported emails were referenced in Russian memoranda obtained in 2016 by Dutch intelligence after it hacked into Russian intelligence systems. The material was shared with the U.S. Intelligence Community, which treated it with caution, citing the possibility that it had been exaggerated or deliberately mixed with disinformation. The material was kept in a classified annex to the Durham report, which was not publicly released until two years after the main report.
In his 2023 final report, Durham investigated the alleged plan, acknowledging uncertainty about its accuracy and finding no evidence that Clinton or government officials coordinated a scheme to fabricate evidence against Trump. The New York Times characterized portions of Durham's analysis as a "debunking" of the central allegation, noting that his discussion of the emails described them as likely composites derived from unrelated hacked material.
On September 29, 2020, near the end of Trump's first presidency, the annex was declassified and released "mere hours before the first Trump-Biden debate", a timing that was criticized and described as part of renewed efforts by Trump administration officials and allies to relitigate and challenge existing investigative findings regarding Russian interference in the 2016 election. Commentators described these efforts as attempts to rewrite the history of the 2016 election and to challenge the findings of both Mueller's Trump-Russia investigation and the FBI's Crossfire Hurricane investigation.
The theory
Definition and scope
The "Clinton plan" theory has been described as a right-wing conspiracy theory advanced by Trump and his associates. The theory accuses Hillary Clinton and senior officials in the Obama administration of engaging in a conspiratorial plan, plot, or scheme to fabricate an alleged "Russia collusion hoax" by "falsely" asserting that Donald Trump had improper ties to Russia and its interference in the 2016 United States elections. The New York Times described the allegation as "a way to blame Mrs. Clinton for the fact that Mr. Trump's campaign came under suspicions that prompted the Russia investigation eventually led by Robert S. Mueller III, the special counsel".
The Durham report cites then–director of national intelligence John Ratcliffe's original description of the alleged "Clinton plan", a wording that only mentions Putin and the hacking of the DNC, not other Russia-related objects of the alleged plan. It also includes the intelligence community's (IC) skeptical view of the allegation:
The theory stems from hacked and translated Russian intelligence memos and an accompanying Russian analysis based on portions of hacked American emails from July 2016, rather than on the full original messages. The memos asserted that on July 26, 2016, Hillary Clinton approved a "plan" in the form of "a proposal from one of her foreign policy advisers to vilify Donald Trump by stirring up a scandal claiming interference by the Russian security service".
Russian intelligence memos used the words "Clinton" and "plan" separately rather than as a single phrase or fixed label. In his 2023 final report, Durham combined those elements into a label, writing, "We refer to that intelligence hereafter as the 'Clinton Plan Intelligence'." Elsewhere in the report, he referred to it as the "Clinton plan".
Framing and characterizations
Durham's formulation of the "Clinton Plan Intelligence"
In his 2023 final report, Durham created a label for the alleged Clinton plan: "We refer to that intelligence hereafter as the 'Clinton Plan Intelligence'." The alleged plan was further described in a classified 29-page annex to the Durham report, which was not publicly released or declassified until July 31, 2025, two years after the publication of the main report.
She also cited a passage in which Durham characterized the intelligence as suggesting that individuals associated with Clinton's campaign sought to promote what he described as a misleading narrative about Trump's ties to Russia to both the public and U.S. government agencies.
"Durham noted in a footnote to this paragraph — oppo research is not itself illegal. It only becomes illegal if you intentionally lie to the government about it." She then quotes Durham's Footnote 393: "To be clear, the Office did not and does not view the potential existence of a political plan by one campaign to spread negative claims about its opponent as illegal or criminal in any respect."
Described as a conspiracy theory
Several sources have characterized Durham's "Clinton plan intelligence" formulation as a conspiracy theory.
Molly Roberts, a senior editor at Lawfare, wrote that Trump's "Grand Conspiracy" theory "fails on both the narrative and legal coherence fronts": "Its proponents allege a plot against Trump that somehow manages to connect Hillary Clinton, Barack Obama, and James Comey to Joe Biden, Merrick Garland, and Jack Smith." She frames the "Clinton plan" conspiracy theory as part of an alleged larger conspiracy against Trump. She also argued that proponents of the "Grand Conspiracy" theory often omitted that Durham had excluded the material from his report because it was assessed as likely based on forged documents, a fact she suggested would undermine the narrative.
David Corn described expectations among Trump allies and within MAGA that Durham's investigation would expose a broad deep state conspiracy involving Obama-era officials and Clinton's campaign to fabricate the Russiagate scandal, leading to prosecutions of those involved.
According to David Corn and Charlie Savage, Durham failed to substantiate claims of intelligence abuses or "Deep State" misconduct in the origins of the Russia investigation. Savage reported that, after failing to find such evidence, Barr and Durham shifted their focus toward seeking a basis to blame the Clinton campaign for the suspicions raised by the many secretive links that Trump campaign associates had to Russia.
Ratcliffe and first appearance of the theory in 2020
In 2016, then-CIA director John Brennan briefed President Obama and other senior officials about the intelligence in August 2016 and referred it to the FBI. Two FBI assessments from 2016 and 2020 then found the Russian materials were "likely not credible", according to Lawfare.
Nevertheless, in October 2020, then–director of national intelligence John Ratcliffe declassified portions of Brennan's handwritten notes from the 2016 briefing. Ratcliffe stated that the intelligence community was unable to corroborate whether Russia actually knew of such a Clinton plan or whether the information was fabricated. He also declassified some other information from the hacked Russian memos, which he described in a letter to Senate Judiciary Committee chairman Lindsey Graham on September 29, 2020. Graham released it the same day.
The theory was first mentioned publicly by John Ratcliffe on September 29, 2020, near the end of Trump's first presidency, and "mere hours before the first Trump-Biden debate", a timing that was described by Judy Woodruff as a "possible abuse of intelligence and the levers of government by the Trump administration".
Others also criticized the release. Senator Mark Warner said it disturbed him that Ratcliffe was releasing unverified Russian "rumint" (rumored intelligence) "35 days before an election". Senator Ron Wyden said that "DNI Ratcliffe is abusing his position exactly as I feared he would, and the abuse is accelerating as we near the election." The material had already been examined by the bipartisan Senate Intelligence Committee and determined to be "Russian disinformation".
A fact-check by the Associated Press noted how the letter's release "hours before the first presidential debate in the upcoming election sparked a flurry of posts on social media, many of them misrepresenting its contents as proof of wrongdoing by Democrats".
Sonam Sheth reported that Ratcliffe's release of the material on September 29, 2020, appeared to "mirror Moscow's ongoing disinformation campaign against the former secretary of state".
Vox reported that Ratcliffe was criticized for giving credibility to Russian material by declassifying and releasing the information against the advice of intelligence officials and "without knowing its veracity", in what critics described as an effort to hurt Clinton while helping Trump during his debate with Joe Biden.
Brian Greer, a former CIA lawyer, criticized Ratcliffe's declassification decision, arguing that it was politically motivated, risked benefitting Russia, and could harm U.S. intelligence capabilities while undermining a U.S. political figure who may have been targeted by a hostile intelligence service.
Politico reported that Trump took advantage of the situation, "weaponizing the releases to boost his reelection campaign". Ratcliffe told CBS News that the declassification occurred "at the direction of President Trump".
Politico also reported that Durham was "expected to refrain from releasing any conclusions before Election Day to avoid affecting the race", but that recent declassifications by Ratcliffe and Attorney General William Barr appeared to be "an effort to fill that void".
According to CBS, "The unverified details contained in Ratcliffe's letter were released over the objections of senior intelligence officials from the CIA, NSA and Office of the Director of National Intelligence."
The New York Times also reported that Dutch intelligence was infuriated by the disclosure of information it had provided in the strictest confidence.
Former-CIA director John Brennan accused Ratcliffe of "selectively declassifying" information "to advance the political interests of Donald Trump", adding that even if the Russian allegations were accurate, there would be "nothing at all illegal" about Clinton highlighting Trump's reported connections to Russia.
Senator Ron Wyden accused Ratcliffe of politicization of "unverified Russian information to try to concoct a political scandal — a shocking abdication of his responsibilities to the country".
Cathy Young wrote: "Outside the MAGA camp, most people were appalled that Ratcliffe and Graham were laundering unverified intelligence at best and Russian disinformation at worst."
Career intelligence professionals expressed their concerns:
Mother Jones highlighted what it described as an "irony" in Durham's report, criticizing his reliance on a "sketchy intelligence product" that it said may itself have been Russian disinformation used to advance a partisan narrative. It argued that Durham used material of uncertain provenance while accusing the FBI of similar conduct and, in effect, providing political support to Trump and his allies.
The New York Times reported that the Trump administration and Republicans on the House Intelligence Committee cited claims from the Russian memos without emphasizing concerns that the material might contain misinformation.
While Brian Greer acknowledges that many sources consider the Russian memos to be "disinformation", he does not agree. He considers the memos as something the Russians were guarding and did not want released. He believes this made Ratcliffe's declassification even worse.
The hacked emails