Fact Checking Snopes

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A note before reading: throughout this piece you will see small raised numbers next to certain sentences, like this.¹ Those are citations. Each number points to a corresponding entry in the reference list at the bottom of the article, where you can see exactly what source the claim came from and click through to read it yourself. Some sentences carry more than one number because more than one independent source confirms the underlying fact. Where a primary source exists, including the federal statutes themselves and the disclosure forms Roberts signed, those documents are cited directly so anyone can verify the claim without going through me.

Snopes does important work. In an era when fabricated images circulate faster than corrections, when entire conspiracy theories travel from a Telegram channel to the front page of the New York Post in a weekend, having professional fact-checkers is one of the few institutional defenses ordinary readers have against being lied to. None of what follows is an attack on Snopes as an institution. The job they do matters, which is exactly why it has to be done well.

On May 1, Snopes published a piece by reporter Jack Izzo declining to rate the disbarment complaint I filed against Chief Justice John Roberts.² Izzo is a Northwestern-trained journalist who joined Snopes in 2023.³ That is a real credential. It is not, however, a credential in legal ethics, recusal law, or federal financial disclosure rules. The underlying complaint draws on Pace Law professor and former Manhattan prosecutor Bennett Gershman’s published legal memorandum,⁴ ⁵ ⁶ Richard Painter’s analysis at MSNBC (Painter served as chief White House ethics lawyer under George W. Bush from 2005 to 2007 and personally prepared Roberts for his Senate confirmation hearings on the very ethics issues now at the center of this controversy),⁷ ⁸ and the public statutory walkthrough by California trial lawyer Mitch Jackson, a forty-year courtroom litigator and former Judge Pro Tem who reached the same conclusion on the recusal statute that Gershman did.⁹ That asymmetry matters, because some of the conclusions in the Snopes piece would not survive a five-minute conversation with any of them.

So let me walk through what Snopes got right, what they got wrong, and why the difference matters.

Start with what they got right.

Snopes accurately summarized the 2022 whistleblower complaint filed by Kendal B. Price, a former managing director at the legal recruiting firm Major, Lindsey and Africa, where Jane Roberts worked from 2007 to 2014.¹⁰ ⁶ They correctly described Price’s spreadsheet showing Jane Roberts received $10,323,842.70 in commissions during that period, on $13.3 million in attributed firm revenue. The figure was reported first by Business Insider, then confirmed by the American Bar Association Journal, Common Dreams, Truthout, and other outlets working from the same whistleblower documents.¹⁰ ⁶ ¹¹ ¹² They correctly noted Price’s testimony that one of the placements was Ken Salazar, the outgoing Interior Secretary, who landed at WilmerHale, a firm the New York Times describes as having argued more than 125 cases before the Supreme Court.⁵ ¹³ They correctly cited the Ethics in Government Act,¹⁴ which requires federal judges to identify the source of any spousal income above one thousand dollars while not requiring them to disclose the dollar amount. They correctly identified that Roberts’ annual disclosure forms from 2007 through 2020 listed Major, Lindsey and Africa as his wife’s employer.²

All of that is fairly stated. None of it is in dispute.

Now to where the Snopes piece goes wrong.

The most important error is a sentence that sounds like a careful clarification but is actually backwards as a matter of law. Snopes wrote that the claim “misleadingly suggests that both John and Jane Roberts were taking money from law firms” because “only Jane Roberts earned money, as part of her recruiting role.”² A reader without legal training might come away thinking the household framing is somehow misleading or overstated.

It is not. Federal recusal law deliberately treats a married couple as one financial unit. The relevant statute is 28 U.S.C. § 455,¹⁵ and three pieces of it apply here. The first says a judge has to step off a case where his impartiality might reasonably be questioned. The second says a judge has to step off a case where his spouse holds a financial interest in one of the parties. The third says a judge has to step off where his spouse holds any other interest the outcome could affect. The whole structure exists because Congress understood, sensibly, that a paycheck going to the spouse is a paycheck arriving in the same household. If the law allowed judges to say the spouse took the money rather than the judge, the recusal rules would mean nothing. Lower court judges across the country recuse on spousal income grounds every week. The principle is routine. Gershman’s memorandum applies all three subsections to the Roberts arrangement and concludes that any one of them triggers the recusal obligation.⁴ ⁵ ⁶ Mitch Jackson, walking through the same statute publicly as a working trial attorney and former Judge Pro Tem, reached the same result, noting that these are the rules every working trial judge in America applies before taking the bench on a normal Monday morning.⁹ The Snopes framing reads as if the spousal-versus-judge distinction were a reasonable line to draw. In the eyes of the statute, it is not a distinction at all.

The second problem is that Snopes leaned heavily on a 2009 advisory opinion from the Judicial Conference,¹⁶ which a Court spokesperson cited in 2023 in a statement to the New York Times, saying that a judge whose spouse owns and operates a recruiting business does not automatically have to recuse just because a law firm appearing before the judge once hired that spouse.⁵ ¹⁷ ¹⁸ That opinion answers a much narrower question than the one Snopes used it to close. It does not address an employee paid by commission for specific placements at specific litigant firms. It does not address an equity stake in the recruiter’s parent company. It does not address a judge listing those commissions as salary on a federal form for over a decade. Citing the 2009 opinion to wave off this complaint is like citing the rules for parallel parking to settle a question about a hit-and-run. Same general topic, different question entirely.

The third problem shaped how Snopes ultimately presented the story. They focused on the projected total for the years 2015 through 2022, an estimated $11.8 million that brings the household figure above twenty million.² No one can independently verify that projection, because the Ethics in Government Act lets the Roberts household keep the dollar amount private.¹⁴ Roberts is the only person who can produce the exact figure, and he has not. Snopes is correct that the projected number is, in their words, unrateable.

What Snopes did with that observation, though, is treat the unverifiable projection as if it were the load-bearing claim, and use its unverifiability to decline rating any of it. The complaint does not depend on the projection. It rests on four things, all of them documented, all of them cited in the original article, and any one of them enough on its own to support the disbarment filing.

The first is the $10.3 million in commission income from 2007 to 2014.¹⁰ ⁶ ¹¹ ¹² Snopes accepts this number.

The second is the difference between salary and commission, and what Roberts wrote on the form. Salary means a fixed paycheck for being employed somewhere. Commission means a cut of each specific deal closed with a specific client. The disclosure form lists them in different places for a reason. Salary tells the public who employs the judge’s spouse. Commission tells the public which specific clients are paying the household every time a deal closes. For more than a decade of disclosures, Roberts described his wife’s earnings as salary.⁵ ¹⁹ Bennett Gershman wrote that the salary characterization was “incorrect as a matter of law.”⁴ ⁵ ⁶ Richard Painter, the chief White House ethics lawyer under George W. Bush who personally prepped Roberts for his confirmation hearings, wrote in MSNBC in 2023 that Roberts had “fudged the details” by misleadingly describing the income as salary.⁷ ⁸ Mark Jungers, a former managing partner at Major, Lindsey and Africa, told Politico that the firm hired Jane Roberts hoping to benefit from her being the Chief Justice’s wife, and that “her network is his network and vice versa.”²⁰ After Business Insider published the whistleblower documents in April 2023, Roberts amended the entry to read “base salary and commission.”²¹ ²² The amendment itself functions as the admission. Snopes did not address any of this.

The third is the equity stake. Jane Roberts joined the firm Macrae in 2019 to open its Washington office, and she held an ownership share in the company.²⁰ An ownership share is not a paycheck. It is a piece of the business itself. Roberts left the equity stake off his disclosure forms for three years running. The 2022 disclosure, signed and filed in May 2023, finally listed the equity holding and noted that the 2019 through 2021 reports had been amended to reflect the asset, with Roberts attributing the omission to inadvertence in the form itself.²¹ ²³ Snopes did not address this either.

The fourth is the recusal record. The New York Times reported in January 2023 that Roberts “has apparently never recused himself from a case because of his wife’s work.”⁵ Across two decades on the Supreme Court, that pattern has continued. The firms paying his household commissions include WilmerHale, Hogan Lovells, Davis Polk, and Robins Kaplan, all of which the New York Times and Politico documented as having Supreme Court practices, and at least one of which Politico identified as having retained Jane Roberts in part because of her status as the Chief Justice’s spouse.⁵ ²⁰ Roberts’ refusal to testify on Supreme Court ethics before the Senate Judiciary Committee in May 2023, citing separation-of-powers concerns, foreclosed the most obvious institutional venue in which these recusal questions could have been answered.²⁴ ²⁵ Snopes did not address them either.

So when Snopes says they cannot independently verify the dollar figure for the back half of Jane Roberts’ career, they are correct on a narrow point. The law keeps that figure hidden by design.¹⁴ The disbarment complaint, however, does not rise or fall on that figure. It stands on the documented commission income, the salary-to-commission mischaracterization, the concealed equity stake, and the failure to recuse. The original article cited each of these. None of them appear in the Snopes piece.

A more careful version of the Snopes article would have separated the documented elements from the projected total, rated the documented elements on their own terms, and explained to readers that the unverifiable figure is unverifiable by design rather than by accident. The version Snopes published treated the entire complaint as one undifferentiated claim, then declined to rate it. Readers searching Snopes for clarity walked away with the impression that nothing was conformable, when in fact the original article cites every relevant claim.

Fact-checking is hard. Fact-checking law is harder. The institutional answer, when this kind of question comes in, is to bring in someone who practices the law in question before publishing a piece that effectively dismisses a disbarment complaint. The disclosure forms Roberts signed sit in the federal record.²¹ The statute sits on the books.¹⁵ The whistleblower spreadsheet still says what it says.¹⁰ ⁶ ¹¹ None of that depends on how anyone frames it.

References, in order of first appearance:

1. This is a sample citation showing how the system works.

2. Izzo, J. (2026, May 1). Investigating claim Chief Justice Roberts, wife took $20M from law firms he ruled on. Snopes. https://www.snopes.com/news/2026/05/01/chief-justice-roberts-wife-law-firms/

3. Snopes. (n.d.). Jack Izzo, author at Snopes.com. Retrieved May 4, 2026, from https://www.snopes.com/author/jack-izzo/

4. Gershman, B. L. (2022). Memorandum on the recusal obligations of Chief Justice John G. Roberts Jr. under 28 U.S.C. § 455. Submitted in support of the whistleblower complaint of Kendal B. Price.

5. Eder, S. (2023, January 31). At the Supreme Court, ethics questions over a spouse’s business ties. The New York Times. https://www.nytimes.com/2023/01/31/us/john-roberts-jane-sullivan-roberts.html

6. Common Dreams. (2023, April 28). John Roberts’ wife made millions from elite law firms, major companies: Whistleblower docs. https://www.commondreams.org/news/jane-roberts-whistleblower

7. Painter, R. W. (2023, May 3). How the Supreme Court can finally get its house in order. MSNBC. https://www.msnbc.com/opinion/msnbc-opinion/supreme-court-can-finally-get-house-order-rcna82293

8. Painter, R. W. (2023, June 25). I did Alito’s ethics prep for his confirmation hearing. His new excuses are nonsense. MSNBC. https://www.ms.now/opinion/msnbc-opinion/alito-supreme-court-ethics-scandal-vacation-rcna90819

9. Jackson, M. (2026, April 29). The twenty million dollar secret: What the Chief Justice hoped you would never see. Uncensored Objection. https://mitchthelawyer.substack.com/p/the-twenty-million-dollar-secret

10. Schwartz, M. (2023, April 28). Chief Justice Roberts’ wife made $10.3 million in commissions from elite law firms, whistleblower documents show. Business Insider.

11. American Bar Association Journal. (2023, May 1). Wife of Chief Justice Roberts generated $10M in commissions in this job, whistleblower says. https://www.abajournal.com/news/article/wife-of-chief-justice-roberts-generated-10m-in-commissions-in-this-job-whistleblower-says

12. Sussman, S. (2023, May 2). Chief Justice John Roberts’s wife made $10M recruiting lawyers for top firms. Truthout. https://truthout.org/articles/chief-justice-john-robertss-wife-made-10m-recruiting-lawyers-for-top-firms/

13. WilmerHale. (n.d.). Supreme Court and appellate litigation practice. Retrieved May 4, 2026, from https://www.wilmerhale.com/

14. Ethics in Government Act of 1978, 5 U.S.C. ch. 131. https://www.law.cornell.edu/uscode/text/5/part-IV/chapter-131

15. Disqualification of justice, judge, or magistrate judge, 28 U.S.C. § 455. https://www.law.cornell.edu/uscode/text/28/455

16. Judicial Conference of the United States. (2009). Advisory opinion regarding disqualification when a judge’s spouse is engaged in legal recruiting. Guide to Judiciary Policy, Vol. 2B, Ch. 2. https://www.uscourts.gov/sites/default/files/guide-vol02b-ch02.pdf

17. Hopkins, S. (2023, February 3). John Roberts’ wife allegations spark call for Supreme Court scrutiny. Newsweek. https://www.newsweek.com/john-roberts-wife-allegations-call-supreme-court-scrutiny-1778411

18. Faulders, K. (2023, January 31). Ex-colleague of chief justice’s wife makes ethics claim. ABC News. https://abcnews.com/Politics/colleague-supreme-court-chief-justices-wife-makes-ethics/story?id=96804182

19. Salon. (2023, May 2). John Roberts’ wife made millions from elite law firms, major companies: Whistleblower docs. https://www.salon.com/2023/05/02/john-roberts-wife-made-millions-from-elite-law-firms-major-companies-whistleblower-docs_partner/

20. Fuchs, H., Gerstein, J., & Canellos, P. S. (2022, September 29). Justices shield spouses’ work from potential conflict of interest disclosures. Politico. https://www.politico.com/news/2022/09/29/justices-shield-spouses-work-from-conflict-of-interest-disclosures-00059370

21. Roberts, J. G., Jr. (2023, May 15). 2022 financial disclosure report [Form AO 10]. Administrative Office of the United States Courts. Retrieved from https://www.scotusblog.com/wp-content/uploads/2023/06/Roberts-Jr-John-G-Annual-2022.pdf and https://projects.propublica.org/supreme-connections/justices/john-roberts/2022/

22. Associated Press. (2023, June 7). Thomas, Alito delay financial disclosure reports. Yahoo News. https://www.yahoo.com/entertainment/thomas-alito-delay-financial-disclosure-214833964.html

23. Fuchs, H., & Gerstein, J. (2023, January 31). ‘They come to me’: Jane Roberts’ legal recruiting work involved officials whose agencies had cases before the Supreme Court. Politico. https://www.politico.com/news/2023/01/31/jane-roberts-legal-recruiting-work-agencies-cases-supreme-court-00080515

24. Howe, A. (2023, April 26). Roberts declines invitation to testify at Senate hearing. SCOTUSblog. https://www.scotusblog.com/2023/04/roberts-declines-invitation-to-testify-at-senate-hearing/

25. Totenberg, N. (2023, April 25). Chief Justice Roberts declines to testify before Senate panel. NPR. https://www.npr.org/2023/04/25/1172083875/chief-justice-roberts-declines-to-testify-before-senate-panel