Leon Black’s Frivolous Lawsuit

Earlier this month the billionaire Leon Black sued the House Committee on Oversight and Government Reform (COGR) in federal district court, seeking injunctive and declaratory relief regarding two subpoenas that the committee had served upon him. The subpoenas related to COGR’s investigation into the activities of Jeffrey Epstein, who was a longtime business associate of Black’s.

COGR informed Black that its investigation included the following:

(i) the alleged mismanagement of the federal government’s investigation into Mr. Jeffrey Epstein and Ms. Ghislaine Maxwell, (ii) the circumstances and subsequent investigations of Epstein’s death, (iii) the operation of sex-trafficking rings and ways for the federal government to effectively combat them, (iv) ways in which Epstein and Maxwell sought to curry favor and exercise influence to protect their illegal activities, and (v) potential violations of ethics rules related to elected officials.

Although Black emphasizes that COGR’s jurisdiction (which he concedes is “broad”) is “not unbounded” and must be “in furtherance of a valid legislative purpose,” he does not appear to contest that the investigation described falls within COGR’s jurisdiction and has a valid legislative purpose. He seems to accept that COGR is legitimately investigating matters involving Epstein and Maxwell, “including federal investigative decisions, federal records, sex-trafficking enforcement, victim protection, potential ethics issues involving elected officials, and related legislative reforms.” Complaint ¶ 77.

Nor does Black appear to claim that it is unreasonable for the committee to view him as a source of potentially relevant information for its investigation. Black does not dispute COGR Chairman James Comer’s statement that “Leon Black had an extensive personal and financial relationship with Jeffrey Epstein spanning decades and paid him at least $158 million after Epstein became a registered sex offender.” These facts alone would warrant inquiring of Black to determine what information he might have regarding the subjects of the committee’s investigation.

Indeed, although Black does not expressly admit this, his complaint suggests he had no objection to COGR’s inquiring of him regarding his financial relationship with Epstein and any knowledge he may have had regarding Epstein’s sex-trafficking and other illicit activities. (He claims to have “no knowledge of any of Epstein’s heinous conduct. Complaint ¶ 38.) Black stresses that he voluntarily appeared for an interview by the committee staff and was prepared to answer questions about “his prior professional relationship with Epstein.” Complaint ¶ 28. However, Black informed the committee through counsel that he would “decline to answer questions relating solely to his personal life and the personal lives of third parties.” Complaint ¶ 26.

Specifically, Black does not want to provide any documents or testimony to the committee regarding the subject of non-disclosure agreements (NDAs) that he has entered into with various women. How many such NDAs exist? Black explicitly acknowledges the existence of two. Complaint ¶ 30. He implicitly acknowledges the existence of multiple additional NDAs because he says that “[c]ounsel for certain of these individuals” have insisted that Black not provide information about “their clients” or the NDAs they signed. Complaint ¶ 33. However, at his voluntary interview Black declined to answer when staff asked “[h]ow many NDAs are you a party to?” Complaint ¶ 31. So we can assume the answer to that question is at least five, and maybe a lot more than that.

In Black’s view, the fact that he, billionaire benefactor and close personal friend of Jeffrey Epstein, entered into NDAs with multiple women has nothing to do with Epstein and therefore has no bearing on COGR’s investigation. This might be less than obvious to the committee in light of evidence such as that spelled out in Senator Ron Wyden’s March 20, 2026 letter to Black, which included the following passage:

[R]ecords unsealed by the DOJ indicate that Epstein may have served as a “fixer” regarding women who were paid tens of millions of dollars in exchange for their silence. Unsealed records indicate that you may have funneled hush money payments to women using Epstein as a middleman, raising concerns of potential money laundering. Epstein also provided the location of women on your payroll to a well-connected Russian government operative and asked for “suggestions” on how to deal with them.

This sounds to me like something COGR could reasonably inquire about and not, as Black argues, simply private information with no possible bearing on its investigation.

Legal Analysis

For purposes of our discussion, however, it makes little difference whether we accept Black’s characterization of COGR’s subpoenas. That is because the court does not need to, and almost certainly will not, reach the issue whether COGR is entitled to ask Black about the NDAs or any other particular subject. Instead, Black’s lawsuit must fail because it is well-settled that courts lack power to restrain congressional committees from issuing or enforcing a subpoena, regardless of the recipient’s claim that the subpoena violates constitutional privilege, was improperly motivated, or is otherwise unlawful. Continue reading “Leon Black’s Frivolous Lawsuit”