BY KEVIN R. BROCK, OPINION CONTRIBUTOR
\nThe Hill
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James Comey<\/a><\/span>\u2019s planet is getting noticeably warmer. Attorney General\u00a0William Barr<\/a><\/span>\u2019s emissions are the suspected cause.<\/p>\n Barr has made plain that he intends to\u00a0examine carefully<\/a>\u00a0how and why Comey, as FBI director, decided that the bureau should investigate two presidential campaigns and if, in so doing, any rules or laws were broken.<\/p>\n In light of this, the fired former FBI director apparently has decided that\u00a0photos of him on Twitter<\/a>\u00a0standing amid tall trees and in the middle of empty country roads, acting all metaphysical, is no longer a sufficient strategy.<\/p>\n No, Comey has realized, probably too late, that he has to try to counter, more directly, the narrative being set by the unsparing attorney general whose words in front of the Senate Judiciary Committee last week landed in the Trump-opposition world like holy water on Linda Blair. Shrieking heads haven\u2019t stopped spinning since.<\/p>\n And so we\u2019ve seen Comey get real busy lately. First he penned\u00a0a curious op-ed<\/a>\u00a0in The New York Times. Then a Times reporter, with whom Comey has cooperated in the past, wrote a news article exposing an early, controversial investigative technique against the Trump campaign in an attempt to get out front and excuse it. Next, Comey is scheduled to be encouraged on a friendly cable news \u201ctown hall<\/a>.\u201d<\/p>\n In the op-ed, Comey trotted out his now-familiar St. James schtick, freely pronouncing on the morality of others. He sees himself as a kind of Pontiff-of-the-Potomac working his beads, but comes across more like an unraveling Captain Queeg working his ball bearings.<\/p>\n Comey adjudged the president as \u201camoral.\u201d He declared the attorney general to be \u201cformidable\u201d but \u201clacking inner strength\u201d unlike \u2014 the inference is clear \u2014 Comey himself. A strategy of insulting the executioner right before he swings his ax is an odd one but, then, Comey has a long record of odd decisions and questionable judgment.<\/p>\n \u201cAmoral leaders [referring to the president] have a way of revealing the character of those around them,\u201d wrote Comey without a hint of irony or self-awareness. Those whom the former FBI director assembled around him probably rue the day they ever met the man. Most are now fired or disgraced for appalling behaviors that Comey found easy to manipulate to advance his decisions.<\/p>\n Then, just to make sure his op-ed was odd-salted to the max, Comey mused that the president \u201ceats your soul in small bites.\u201d OK, let\u2019s step back for a moment: James Comey appears to be in trouble. His strange, desperate statements and behaviors betray his nervousness and apprehension. In a way, it\u2019s hard to watch.<\/p>\n Comey will claim that everything he did in the FBI was by the book. But after the investigations by Department of Justice Inspector General\u00a0Michael Horowitz<\/a>\u00a0and U.S. Attorney\u00a0John Huber<\/a>, along with Barr\u2019s promised examination, are completed, Comey\u2019s\u00a0mishandling of the FBI and legal processes likely will be fully exposed.<\/p>\n Ideally, Barr\u2019s examination will aggregate information that addresses three primary streams.<\/p>\n The first will be whether the investigations into both presidential nominees and the Trump campaign were adequately, in Barr\u2019s words, \u201cpredicated.\u201d This means he will examine whether there was sufficient justification under existing guidelines for the FBI to have started an investigation in the first place.<\/p>\n The Mueller report\u2019s conclusions make this a fair question for the counterintelligence investigation of the Trump campaign. Comey\u2019s own pronouncement, that the\u00a0Clinton email case<\/a>\u00a0was unprosecutable, makes it a fair question for that investigation.<\/p>\n The second will be whether Comey\u2019s team obeyed long-established investigative guidelines while conducting the investigations and, specifically, if there was\u00a0sufficient, truthful justification<\/a>\u00a0to lawfully conduct electronic surveillance of an American citizen.<\/p>\n The third will be an examination of whether Comey was unduly influenced by political agendas emanating from the previous White House and its director of national intelligence, CIA director and attorney general. This, above all, is what\u2019s causing the 360-degree head spins.<\/p>\n There are early indicators that troubling behaviors may have occurred in all three scenarios. Barr will want to zero in on a particular area of concern: the use by the FBI of confidential human sources, whether its own or those offered up by the then-CIA director.<\/p>\n Without diving into the weeds, it\u2019s important to understand that FBI counterintelligence investigations generally proceed sequentially from what is called a preliminary investigation or inquiry (PI) to a full investigation (FI). To move from a PI to an FI requires substantial information \u2014 predication \u2014 indicating investigative targets acted as agents of a foreign power.<\/p>\n This is problematic for Comey in light of Mueller\u2019s findings. There are strict guidelines governing when the FBI can task a confidential source or a government undercover operative to collect against a U.S. citizen. Normally this is restricted to a full investigation, and normally restricted to the United States, not overseas.<\/p>\n There is a sense that Comey\u2019s team was not checking the boxes, did not have adequate predication, and may have tasked sources before an investigation was even officially opened. \u00a0Barr should pull case files and dig in on this.<\/p>\n In addition, the cast of characters leveraged by the FBI against the Trump campaign all appear to have their genesis as CIA sources (\u201cassets,\u201d in agency vernacular) shared at times with the FBI. From Stefan Halper and possibly Joseph Mifsud, to Christopher Steele, to Carter Page himself, and now a mysterious \u201cgovernment investigator\u201d posing as Halper\u2019s assistant and cited in The New York Times article, legitimate questions arise as to whether Comey was manipulated into furthering a CIA political operation more than an FBI counterintelligence case.<\/p>\n Some in the media have suggested that the Times article was an attempt by the FBI to justify its early confidential source actions. But current FBI Director Christopher Wray has shown that he would like to excise the cancerous tumor that grew during Comey\u2019s time and not just keep smoking. It\u2019s hard to imagine current FBI executives trying to justify past malfeasance.<\/p>\n James Comey is right to be apprehensive. He\u00a0himself ate away at the soul of the FBI, not in small bites but in dangerously large ones. It was a dinner for one, though: His actions are not indicative of the real FBI. The attorney general\u2019s comprehensive examination is welcome and, if done honestly and dispassionately, it will protect future presidential candidates of both parties and redeem the valuable soul of the FBI.<\/p>\n Kevin R. Brock, former assistant director of intelligence for the FBI, was an FBI special agent for 24 years and principal deputy director of the\u00a0National Counterterrorism Center<\/a>\u00a0(NCTC). He is a founder and principal of NewStreet Global Solutions<\/a>, which consults with private companies and public-safety agencies on strategic mission technologies.<\/em><\/p>\n