The Federal Layer

The public record suggests that the case against retired Per Diem Judge Wilson M.N. Loo presents a narrow set of factual questions that standard investigative steps could confirm or falsify. It would require one witness, two questions, and a federal agent willing to knock on a door. The statute of limitations on the applicable federal statutes — including 18 U.S.C. § 242 (deprivation of rights under color of law) and potentially 18 U.S.C. § 1622 (subornation of perjury) — runs five years from the date of the act.¹ The act occurred on December 2, 2022. The clock has been running for more than three years. Roughly twenty months remain.

There is no public indication that any investigative contact has been made, and no such contact has been communicated to the author.

This investigation began, as these things often do, with a simpler question: why not? The relevant conduct is documented in public filings, the complainant’s firsthand account, and sealed exhibits referenced herein. The witness is identified in the public record. The referral has been filed with the Department of Justice’s Public Integrity Section, which acknowledged receipt.² The prosecution roadmap has been published at this outlet in enough detail that any competent federal prosecutor could use it as a briefing memo.³ And still nothing moves.

The answer, it turns out, is not corruption in the Hollywood sense — no envelopes, no phone calls, no made men. The answer is architecture. In a state this small, the family of the man whose conduct triggered this investigation has spent four decades constructing an institutional presence so dense, so cross-stitched through the federal establishment’s own infrastructure, that an investigation the public record suggests could be resolved through standard steps appears crowded out before it begins — not by any one relationship, but by their cumulative weight.

That family is the Lukes. And at the center of it is Warren K.K. Luke.

Read Next

• Series: The Architecture of Access
• Part I (this page): The Federal Layer
• Read Part II: The Bridges (international / PRC-facing)
• Read Part III: The Ledger (funding pathways and disclosure surfaces)
• The Two Questions: federal investigative roadmap in the Wilson M.N. Loo matter
• The Closed Loop: oversight and self-investigation series hub
• Investigations index

Core Claims and Primary Sources

• Warren Luke served as FRBSF Director (1990–92, 1996–2001) and Audit Committee Chair — PBEC official biography⁴; FRBSF Annual Reports⁵
• Wilson Loo married into the Luke family; held 11,265 HNB shares as a sitting judge — SEC DEF 14A proxy filing, 1996⁶⁷
• Loo and Chief Justice Recktenwald both clerked for Judge Harold Fong — Loo mediation.com biography⁸; Recktenwald legislative confirmation records⁹
• Warren Luke is APCSS Foundation trustee and Pacific Forum board governor — APCSS Foundation Form 990¹⁰; Pacific Forum 2020 Annual Report¹¹
• Bryan Luke chaired the Campaign Spending Commission while serving as HNB CEO — CSC meeting minutes¹²; Star-Advertiser¹³
• DOJ Public Integrity Section reduced from 30+ to ~5 attorneys; FBI corruption squad disbanded — Reuters, June 9, 2025¹⁴¹⁵

Federal Jurisdiction

The primary federal theory against Loo is 18 U.S.C. § 242 — deprivation of rights under color of law. The statute is purpose-built for state officials who abuse their authority to deny constitutional rights. The Supreme Court unanimously confirmed its application to state judges in United States v. Lanier, 520 U.S. 259 (1997), in which a Tennessee state judge was convicted under § 242 for abuse of judicial power. Judicial immunity — a defense to civil suits under 42 U.S.C. § 1983 — has no application to criminal prosecution under § 242. It is settled that judges can be prosecuted under § 242; the harder question is whether these specific facts meet § 242’s willfulness requirement and Lanier’s fair-warning standard — that the unlawfulness of the conduct must be “apparent” in light of pre-existing law.

The conduct captured on the sealed audio recording — Loo cutting off the petitioner’s objection when the petitioner attempted to place the judge’s behavior on the record — is evidence from which a jury could infer that Loo willfully deprived a party of the right to be heard in a meaningful manner, a “basic requirement of due process.” In re Murchison, 349 U.S. 133, 136 (1955); Mathews v. Eldridge, 424 U.S. 319 (1976). The audio does not depend on any witness’s cooperation, though it is sealed and investigators would need to obtain it through appropriate legal process.

The series has previously framed this case under 18 U.S.C. § 1622 — subornation of perjury. That statute remains an alternative theory, but its jurisdictional reach to perjury committed in state court (rather than in a federal proceeding) is a genuine legal question this investigation acknowledges. Section 242, by contrast, requires no federal proceeding and no jurisdictional workaround. It applies to any person acting “under color of any law” who willfully deprives another of constitutional rights. A presiding judge in a state courtroom satisfies the color-of-law element; the contested questions are willfulness and whether the specific rights at issue meet Lanier’s fair-warning standard.

Federal law also provides heightened protections for individuals who provide information to law enforcement about federal offenses. See 18 U.S.C. § 1513(e). The complainant’s documented contacts with the FBI and DEA preceded the hearing at which the alleged perjury and due process deprivation occurred. If the adverse actions documented in this series were taken because of those reports — that is, with retaliatory intent — then § 1513(e) would place this matter within a broader federal framework that extends beyond the courtroom conduct itself.

This article is a public-record brief. It relies only on materials that are publicly accessible or publicly quotable. The author may possess additional non-public information that is not included to protect sources, safety, or lawful investigative constraints. Where sealed or non-public material is mentioned, it is described conditionally. The conclusions in this article do not depend on accepting any undisclosed evidence as true. The purpose of this brief is to document the public record and identify the investigative questions that a competent federal investigation would confirm or falsify.

The Banker and the Federal Reserve

Warren Luke has been Chairman and CEO of Hawaii National Bank since 1980.⁴ That alone is unremarkable. What is not unremarkable is what he did with that position over the following four decades.

For nine years — documented in two confirmed periods, 1990-1992 and 1996-2001 — Warren Luke served as a Director of the Federal Reserve Bank of San Francisco.⁵ He was, according to his own official biography at the Pacific Basin Economic Council, only the second Hawaiian ever to hold the position.¹⁶ He served as Chairman of its Audit Committee — the committee responsible for overseeing the financial integrity of the Reserve Bank itself.¹⁷

Regional Federal Reserve banks are governed by nine-member boards of directors. Three seats (Class A) are reserved by statute for representatives of member banks — banker participation is structural, not anomalous. The relevant question is not whether a community banker served on a Reserve Bank board, but what specific oversight functions he held during that service and what cumulative institutional density that service represents alongside his other positions.

In Luke’s case, the answer is the Audit Committee chairmanship. A community bank CEO in Honolulu chaired the audit function of the federal institution that operates within the same supervisory architecture as his own bank. The Federal Reserve System, of which the FRBSF is a regional arm, participates in supervisory coordination with the Office of the Comptroller of the Currency, which regulates national banks including Hawaii National Bank.¹⁸ Luke was simultaneously inside the federal banking establishment’s audit oversight and running a bank that existed within that same establishment’s regulatory reach — for nine years, across two confirmed periods.

No publicly accessible recusal log was located in FRBSF annual reports, the PBEC biographical record, or SEC proxy filings reviewed for this investigation. Federal Reserve director conflicts of interest are governed by 18 U.S.C. § 208 (the federal criminal conflicts-of-interest statute) and the Board’s Guide to Conduct for Directors of Federal Reserve Banks; the specific recusal processes applicable to Luke during his 1990–2001 tenure were not determinable from these public sources. No FOIA request was filed with the FRBSF for this article.

The FRBSF president during part of Luke’s tenure was Robert T. Parry, a voting member of the Federal Open Market Committee from 1986 through 2004.¹⁹ Among Luke’s co-directors during documented periods was A.W. “Tom” Clausen, former CEO of Bank of America and former President of the World Bank.²⁰ The audit committee of this federal institution was chaired by the brother-in-law of the judge who allegedly directed a witness to commit perjury in open court. This is documented governance density — not an allegation of obstruction.

The Judge and His Family’s Bank

Wilson M.N. Loo married into the Luke family. His wife, Janice Luke Loo, is the daughter of K.J. Luke, who founded Hawaii National Bank in 1960.²¹ She is Warren Luke’s sister.

According to a 1996 SEC proxy filing — a primary source document submitted to federal regulators — Janice Luke Loo held 47,858 shares of Hawaii National Bancshares stock, beneficially, at a time when the bank’s total outstanding common shares were approximately 715,000.⁶ Of those 47,858 shares, 11,265 were owned directly by Wilson Loo himself.⁷

This matters because Loo, by 1996, was already serving as a Per Diem District Judge in the First Circuit.²² A judge with personal equity in a bank holding company can be expected to encounter — across thirty years on the bench, cycling through District and Family Court calendars — matters involving that bank’s borrowers, tenants, and counterparties. No recusal records for any such matters have been found in the public record. Because Loo’s cases were largely per diem assignments through a system that does not generate easily searchable recusal histories, absence of records does not mean absence of conflicts. It means opacity.

His 2019 judicial financial disclosure — the last filed before he retired in July 2024 — shows a judge with more than one million dollars in K.J.L. Associates, a family commercial real estate limited partnership; additional shares in Hawaii National Bancshares; shares in Loyalty Enterprises, Ltd.; and directorships in the K.J. Luke Foundation and REHAB Hospital of the Pacific.²³ He was not a man estranged from his wife’s family’s money. He was embedded in it.

Wilson Loo served as a Commissioner on the Hawaii Supreme Court Commission on Judicial Conduct.²⁴ The Commission is the body tasked with investigating complaints against judges. He was, in other words, both subject to oversight and participant in it — while the financial entanglements above remained in place.

The Clerkship That Binds

Before he was a judge, Wilson Loo was a lawyer’s lawyer. He graduated from Rutgers School of Law, passed the Hawaii bar in 1980, and went to work as a Deputy Prosecuting Attorney in the Organized Crime Unit under Honolulu’s famously aggressive Prosecuting Attorney Charles Marsland.²⁵ In 1982, he left the DA’s office to clerk for Chief U.S. District Judge Harold M. Fong at the federal courthouse in Honolulu.⁸

Judicial clerkships create bonds. They are apprenticeships of a particular intimacy — a year or more in daily proximity to a federal judge, absorbing how law is practiced at the highest available level. They also create networks. The people who clerk for the same judge share an institutional ancestor and tend to remain professionally and socially connected across careers.

Another Harold Fong clerk, who served approximately three to four years after Loo, went on to become Chief Justice of the Hawaii Supreme Court.²⁶ His name is Mark Recktenwald. He was confirmed as Chief Justice in 2010.²⁷

As Chief Justice, Recktenwald held administrative authority over per diem judge appointments in the state court system — including, after 2010, the appointments of Wilson M.N. Loo.²⁸

Two men who clerked for the same federal judge: one became a per diem judge whose continued service depended on the other’s administrative authority. The connection is confirmed through Loo’s own professional biography and through Recktenwald’s legislative confirmation records.⁹ No public recusal record referencing this shared clerkship was located in the materials reviewed for this investigation. Whether the connection required formal disclosure or recusal under applicable judicial conduct rules is a question this article does not resolve; what is documented is the relationship itself and the administrative authority it intersected.

The Fong connection runs a second, more recent thread. Harold Fong — not to be confused with Judge Arthur S.K. Fong, a separate figure — was Chief Judge through 1991.²⁹ Arthur S.K. Fong was a Hawaii First Circuit judge who simultaneously served as a Director of Hawaii National Bank.³⁰ He died in March 2020; his Star-Advertiser obituary confirmed both his judicial career and his bank board service.³¹

Arthur S.K. Fong’s son is Daniel Fong. Since July 1, 2019, Daniel Fong has served as Senior Vice President, General Corporate Counsel, Compliance Administrator, and Assistant Secretary of Hawaii National Bancshares and Hawaii National Bank.³² He is, to be precise, the person responsible for ensuring that Hawaii National Bank operates within the law.

The man running compliance at the bank central to this investigation is the son of a judge who sat on that bank’s board. Whatever the intent, the effect is replication: governance roles and institutional affiliations tend to concentrate across a small set of families and institutions, generation after generation.

Where the Admirals Gather

In 2020, Pacific Forum — a Honolulu-based foreign policy research institute with close ties to the U.S. security establishment — published its annual report. The document is a primary source, retrieved directly.¹¹ Warren K.K. Luke appears on the Board of Governors.

So do the following:

Karl W. Eikenberry — Lieutenant General, U.S. Army (Retired); former U.S. Ambassador to Afghanistan; at the time of the report, affiliated with Stanford University’s Shorenstein Asia-Pacific Research Center.³³

Ronald J. Hays — Admiral, U.S. Navy (Retired); former Commander-in-Chief, U.S. Pacific Command — CINCPAC, the position now known as INDOPACOM commander.³⁴

Ronald “Zap” Zlatoper — Admiral, U.S. Navy (Retired).³⁵

Robert P. Girrier — Rear Admiral, U.S. Navy (Retired); serving at the time as President of Pacific Forum itself.³⁶

Lauren Kahea Moriarty — former U.S. Ambassador to the Asia-Pacific Economic Cooperation forum.³⁷

Charles B. Salmon — former U.S. Ambassador to Laos; Adjunct Senior Fellow, East-West Center.³⁸

Gerald Sumida — Partner, Carlsmith Ball LLP, Honolulu.³⁹

Pacific Forum conducts what the security establishment calls Track 1.5 diplomacy — dialogue between governments and non-governmental actors, involving people with current or recent access to classified information and policy processes. Its work is oriented toward INDOPACOM’s theater of operations. Several of its programs receive U.S. government funding, though Pacific Forum’s own website is careful to specify that government grants represent “a small percentage” of its annual budget.⁴⁰

The important point is not the funding percentage. The important point is the board.

Warren Luke — the banker whose brother-in-law is the judge whose prosecution this investigation is urging — sits in sustained governance proximity to two retired Pacific Fleet commanders and a former Afghanistan ambassador. They are not his acquaintances. They are his co-governors. They meet. They discuss programming. They represent an institution to funders and policymakers together.

INDOPACOM is headquartered at Camp Smith on Oahu’s Aiea Heights, approximately seventeen miles from the stretch of Kamehameha Highway where the FBI’s Honolulu Field Office operates. The FBI field office, which would conduct any criminal investigation of Wilson Loo, is staffed by agents who live and work in the same geographic and institutional environment where Warren Luke co-governs an Indo-Pacific security policy institution with retired PACOM commanders.

No reasonable person should read this as evidence that those admirals are protecting Wilson Loo. There is no evidence of that, and this article makes no such claim. The point is subtler and more durable: the ambient professional density of Hawaii’s federal and security establishment creates conditions in which a retired per diem judge earning pocket change — whose prosecution would require examining a network that includes people connected to that establishment — does not feel like a priority to anyone whose career requires navigating the same environment.

The DOD Connection Nobody Mentions

Warren Luke’s most direct connection to the federal national security apparatus is not Pacific Forum. It is a smaller institution with a more specific mission.

The Daniel K. Inouye Asia-Pacific Center for Security Studies — APCSS — is a U.S. Department of Defense institution. It operates under INDOPACOM at Fort DeRussy in Waikiki, providing professional military education and security studies to military and civilian officials from across the Indo-Pacific.⁴¹ It is, in the formal bureaucratic sense, a DOD entity: federally funded, federally staffed, reporting through the Pacific Command chain.

The APCSS Foundation, EIN 99-0350533, exists to support the DOD institution’s programming.⁴² Warren K.K. Luke is a Trustee.¹⁰

His fellow trustees on that foundation include Duane Kurisu, who for sixteen years — from 2008 through 2024 — served as a Director of Hawaii National Bancshares, and who simultaneously chairs the aio Group, the media company that controls Pacific Business News, Honolulu’s leading business newspaper.⁴³ The trustee serving as Foundation President is Gerald Sumida — the same Gerald Sumida who sits on the Pacific Forum board alongside Luke.⁴⁴

Also on the APCSS Foundation board: Constance Lau, former CEO of Hawaiian Electric Industries, who served as Chairman of the Department of Homeland Security’s National Infrastructure Advisory Council under the Obama administration.⁴⁵ And W. David Carey III, current Chairman of the Punahou School Board of Trustees.⁴⁶

Three of the six documented APCSS Foundation trustees — Luke, Kurisu, and Lau — simultaneously served as Punahou trustees or chairs during overlapping periods.⁴⁷

For the purposes of this investigation, “institutional capture” describes the condition in which the same small set of individuals occupy governance positions across the institutions that would need to act independently to produce accountability. It is not a claim of illegal coordination. It is a description of structural inertia through interlocking directorates.

This is that architecture in its mature form. It is not one person with power in one place. It is the same small set of people in every place that matters, simultaneously: the bank, the DOD-adjacent foundation, the security policy think tank, the leading private school, and the leading business press. They do not need to coordinate. They share the same interests, the same social world, and the same professional horizon.

The Man Who Regulated Campaign Finance

Bryan Luke became President and CEO of Hawaii National Bank on July 16, 2019.¹³ He had been serving since July 1, 2015, as a Commissioner of the Hawaii Campaign Spending Commission — the state body that regulates political money for every election in Hawaii.⁴⁸ He was elected Chair in May 2016 and served in that role through at least September 2021.¹²

For approximately four years, the CEO of Hawaii National Bank simultaneously chaired the body that enforces campaign finance law for the elections that determine who controls Hawaii’s judiciary appointment process, who sits on the legislative committees that oversee banking regulation, who runs the Office of the Attorney General, and who appoints the judges before whom the bank’s clients and counterparties appear.

The Commission records show two disclosed conflicts during Bryan Luke’s tenure — February 14, 2018, and August 12, 2020 — both involving attorney relationships connected to his family.⁴⁹ In both instances, he disclosed the conflict but continued participating after no party objected.⁵⁰

What the records do not show is any formal docket entry during his tenure involving Sylvia Luke, Ty Cullen, or Tobi Solidum — despite the fact that $10,000 in coordinated contributions from Solidum and Pae to Sylvia Luke’s campaign, received on January 20-21, 2022, went unreported to the Commission for nearly four years, and were only disclosed in February 2026 after Civil Beat inquired about them.⁵¹ Sylvia Luke, the Lieutenant Governor of Hawaii, is not a member of the HNB Luke family by blood, having married into the surname. The overlap between the unreported contributions and Bryan Luke’s Commission chairmanship is documented, but causation is not alleged. This episode illustrates the limits of CSC enforcement capacity and disclosure latency — structural governance questions that exist independently of any individual’s intent.

The Oversight Vacuum

When I filed a formal complaint against Wilson Loo with the Hawaii Supreme Court Commission on Judicial Conduct, I received a letter dated March 13, 2025, signed by Commission Chair Dickson C.H. Lee.⁵² The letter informed me that the Commission had previously — on March 22, 2023 — found “insufficient evidence” to proceed. It then invoked Rule 8.2(b) of the Hawaii Supreme Court Rules, which bars the Commission from accepting complaints against a judge submitted more than ninety days after that judge leaves office.⁵³

Loo retired in July 2024. By February 2025, when my renewed filing arrived, the ninety-day window had closed. The letter instructed me not to contact the Commission again about anything I had raised to date.⁵⁴

The Commission on Judicial Conduct received, in the fiscal years for which data is available, a total of more than a thousand public inquiries and filed seven formal complaints — all of which were dismissed.⁵⁵ The Commission’s membership is appointed by the Supreme Court it is tasked with overseeing.⁵⁶ It has one staff member. It operates under total confidentiality, which means there is no public record of what evidence was considered, by whom, under what standard, and with what conflicts of interest among the commissioners themselves.⁵⁷

Wilson Loo was a Commissioner on this body while serving as a per diem judge.⁵⁸ He was subject to oversight and participant in it simultaneously. He retired before the ninety-day clock on any final complaint could be meaningfully adjudicated. The Commission closed the door.

The DOJ Public Integrity Section, as of this writing, has acknowledged receipt of the referral and communicated nothing further.⁵⁹ The Section, which once employed more than thirty attorneys, has been reduced to approximately five, and its authority to file new cases and its gatekeeping role over public-corruption prosecutions have been suspended or constrained under the current administration.¹⁴ The FBI’s elite public corruption squad has been disbanded.¹⁵ The Honolulu Field Office operates in an environment shaped by the professional network that passed through Charles Marsland’s Organized Crime Unit in the early 1980s — the same unit where Wilson Loo built his prosecutorial career alongside colleagues who subsequently occupied every major prosecutorial position in the state, including Edward Kubo Jr., who served as U.S. Attorney for the District of Hawaii from 2001 through 2009.⁶⁰

Individuals from the same prosecutorial cohort, in other words, later held senior roles in Hawaii’s federal prosecutorial ecosystem, including the U.S. Attorney’s Office for the District of Hawaii.

What Non-Action Means

There is a version of this story in which nothing I have documented is sinister. Federal law enforcement is understaffed, politically constrained, and perpetually triaging. A retired per diem judge who made somewhere between ten and twenty-five thousand dollars a year in judicial work is not the kind of target that moves any field office’s metrics. The DOJ Public Integrity Section has been gutted. The elite corruption squad is gone. These are structural conditions that produce inaction across many cases, not just this one.

That version of the story is probably true in part. It is not the whole story.

Because the whole story includes this: the public record suggests the case against Wilson Loo presents an unusually narrow set of factual questions. The witness is identified in the public record. The prosecution theory is published in sufficient detail to serve as a briefing memo. The documentary evidence — a text message reading “I took the acid,” admitted into the December 2, 2022 proceeding before Loo himself — is in a sealed court file.⁶¹ Two prior law enforcement reports, one from the DEA and one from the Honolulu Police Department’s Narcotics and Vice Division, documented the factual predicate before the trial date.⁶² Standard investigative steps — interview the witness, obtain the sealed audio, evaluate the evidence — would confirm or falsify the relevant legal theories.

One or two FBI agents. A car. A door.

The question this investigation poses — the one that three years of federal silence has opened — is not whether the Luke network is actively protecting Wilson Loo. The question is whether the network’s density in every institution that would need to act is itself the protection. Whether anyone in the relevant institutional chain has looked at this case, traced the edges of what prosecuting it would require, understood whose names would eventually have to be written on reports and subpoenas and grand jury exhibits, and decided — without anyone asking them to decide — that it was not worth the friction.

That is how institutional capture produces impunity. Not through conspiracy. Through the quiet, cumulative weight of knowing who sits on which board, who chaired what committee, who governs alongside whom on the body that advises the DOD institution down the road from your field office.

What This Investigation Cannot Establish

This investigation presents a structural argument. It does not — and cannot, from public records alone — establish that any individual acted to obstruct or delay prosecution. The following alternative explanations deserve genuine engagement:

1. The federal theory may be incomplete. The series previously relied on 18 U.S.C. § 1622 (subornation of perjury) as its sole federal theory. That statute’s jurisdictional reach to state-court perjury is a genuine legal question — which is why this investigation now identifies § 242 (deprivation of rights under color of law) as the primary theory. But a reader would be justified in noting that the legal framework has shifted, and in asking whether the current framework will prove more durable than the last.

2. DOJ may have evaluated the referral and declined on the merits. The Section could have assessed the evidence, concluded the case was not prosecutable — understaffing, evidence quality, witness cooperation uncertainty — and declined without communicating reasons. Non-communication is standard DOJ practice for declined referrals.

3. A defense attorney would challenge the audio-only limitation. The nod occurred in a courtroom with sworn officers present — court reporter, clerk, and potentially a bailiff — but the hearing was recorded audio-only, producing no video. A defense attorney would argue that the absence of video makes the nod harder to prove at trial, and that Loo’s interruption of the objection was a routine exercise of courtroom control rather than evidence of rights deprivation. The sealed audio of the cut-off and the testimony of everyone present in that room would be weighed by a jury.

4. Network density may correlate with but not cause inaction. The Luke family’s institutional footprint is documented. The inference that this footprint produces ambient impunity is structural, not proven. Correlation between institutional density and prosecutorial non-action is not evidence of causation.

5. Triage alone may be a sufficient explanation. A retired per diem judge earning between ten and twenty-five thousand dollars a year in judicial work is low-priority by any field office’s metrics. The DOJ Public Integrity Section has been gutted. The FBI’s elite corruption squad is disbanded. These resource constraints produce non-action across many cases, not just this one.

This investigation argues that the structural explanation — while not excluding any of these alternatives — is the most complete account of the evidence. But the reader should weigh all five.

Warren Luke served nine years on the Federal Reserve Bank of San Francisco’s board and chaired its audit committee.⁶³ He is a trustee of a Department of Defense foundation.⁶⁴ He governs a security policy institution alongside two retired Pacific Fleet commanders.⁶⁵ His son ran Hawaii’s campaign finance enforcement body for years while simultaneously running the family bank.⁶⁶ His sister’s husband clerked for the same federal judge as the man who became Chief Justice of the state supreme court and held appointment authority over the judge’s continued service.⁶⁷ The family’s general counsel is the son of a former judge who sat on the bank’s board.⁶⁸ The chairman of Honolulu’s leading business newspaper sat on the bank’s board for sixteen years.⁶⁹

None of that is necessarily a crime. All of it is a structure.

None of the individuals named in this article are accused of wrongdoing. Their board memberships, professional relationships, and institutional roles are matters of public record, disclosed and lawful. The argument here is structural, not personal: legitimate relationships, in sufficient density, produce institutional inertia without any individual needing to act corruptly.

The structure is this investigation’s subject. The structure is, the public record suggests, why there is no indication that standard investigative steps have been taken. And the clock is still running.

The statute of limitations on 18 U.S.C. § 242 (deprivation of rights under color of law) and 18 U.S.C. § 1622 (subornation of perjury) expires approximately December 2027, based on the date of the alleged conduct. Prosecutions under § 242 are handled by the DOJ Civil Rights Division, Criminal Section, with the FBI as the primary investigative agency. A referral has been filed with the DOJ Public Integrity Section, Criminal Division, Washington D.C. The referral has been acknowledged. No further communication has been received.

The full prosecution roadmap is published at: The Two Questions

Timeline

Date	Event
Jul 5, 1995	Loo appointed Per Diem District Judge, First Circuit
Dec 2, 2022	The hearing — alleged subornation of perjury / deprivation of rights
Mar 22, 2023	CJC: “insufficient evidence”
Jul 2024	Loo retires from per diem service
Oct 2024	90-day CJC window closes
Mar 13, 2025	CJC: “no jurisdiction” — permanent closure
Jul 12, 2025	DOJ referral filed
Feb 28, 2026	This article published
~Dec 2027	Statute of limitations expires (5 years from act)

Disclosure and Scope: No comment was requested from individuals or institutions named in this article prior to publication; outreach was deferred due to safety and source-protection constraints. Institutions and individuals may respond at [email protected]. This investigation is based entirely on public records, government filings, and primary-source documents. The author may possess additional non-public information that is not included to protect sources, safety, or lawful investigative constraints. Where sealed or non-public material is mentioned, it is described conditionally. The conclusions in this article do not depend on accepting any undisclosed evidence as true.

What Would Falsify This: If the Department of Justice has investigated the referral and declined on the merits, confirmation of that fact would materially alter this investigation’s structural thesis. If recusal or safeguard records exist for any of the institutional overlaps documented here — FRBSF board service, judicial appointments, Commission on Judicial Conduct participation — their production would narrow or resolve specific claims. If any individual named herein can demonstrate that the relationships described were subject to appropriate disclosure or ethics review, this outlet will publish corrections. The purpose of this investigation is to identify questions the public record leaves open; answers that close them are invited.

Sources and Notes