What We Did — And What We Found
An open-source investigation. 205 entities tracked. 76 verified findings. Every claim sourced, every dataset downloadable, every conclusion testable.
The Investigation
This project is an open-source forensic investigation into potential fraud in the California High-Speed Rail project. It examines whether officials knowingly made false representations to voters, federal agencies, and the legislature — not merely whether the project has been mismanaged.
The answer required pulling together public records, government audits, FRA compliance reviews, state auditor reports, court filings, and investigative journalism — sources that exist in scattered locations and have never been systematically cross-referenced. We built a typed knowledge graph tracking 205 entities and connected them through 136 documented relationships.
Every claim cites a source, tiered by reliability. Where the evidence is ambiguous, we say so. Where counter-arguments have merit, we present them. The full datasets and findings and entity graph are freely available.
The Fraud Standard
Fraud is not waste. Fraud is not mismanagement. Fraud requires all five elements:
- Material misrepresentation — A false statement of fact
- Knowledge or recklessness — They knew or were recklessly indifferent
- Intent to induce reliance — Made to get someone to act
- Reasonable reliance — The recipient reasonably relied on it
- Damages — Someone suffered actual harm
Without all five, we have a finding, not fraud. Findings are still valuable — we label them honestly.
Evidence Hierarchy
- Tier 1: Primary documents — contracts, financial filings, audit reports, sworn testimony
- Tier 2: Official government reports — FRA, GAO, State Auditor, LAO, OIG
- Tier 3: Major investigative journalism with named sources and documents
- Tier 4: Think tank analysis with cited methodology
- Tier 5: Opinion, social media, anonymous claims
We never build conclusions on Tier 5 alone. All findings are triangulated across multiple sources where possible.
The Steel-Man Rule
Before attacking any position, we construct the best innocent explanation first. Both sides are spinning — the Trump DOT, CHSRA, CA Democrats, and CA Republicans all have agendas. We document what was ruled out alongside what was found.
What We Brought Together
The bulk of this investigation is synthesis. The individual facts exist in public records — audit reports, compliance reviews, financial filings, board minutes. What didn't exist was a structured, cross-referenced account connecting them.
For example: the Reason Foundation published a $65–81 billion cost estimate using only publicly available data one month before the 2008 vote. CHSRA’s ballot materials said $33 billion. Both facts are public. But connecting them establishes the knowledge element — that the true cost range was knowable at the time of the promise.
Similarly, mapping WSP’s 25-to-1 staffing ratio alongside the State Auditor’s 79% false task completion rate alongside the $288 million in disputed invoices tells a story that no single audit report tells alone. Scattered facts don’t make the case. The connections do.
Original Analysis
In the course of this investigation, we identified connections, patterns, and legal frameworks that — to our knowledge — have not been documented in published analysis of California High-Speed Rail. We present these not as conclusions but as evidence chains and questions that merit further scrutiny. Each item links to the primary evidence and the relevant deep-dive article.
CEO bonus tied to low bid, 65 days before procurement rule change
Resolution #1228 contractually linked CEO Jeff Morales’s bonus to “getting a bid at or below estimates.” Sixty-five days later, the 4th RFP Addendum reversed the Board-approved two-step selection process to favor lowest price over technical competence. The Board was not notified of the change.
Internal memo documents potential criminal change order splitting
A CHSRA regional director’s August 2018 memo explicitly planned splitting a $20.8 million scope into four to five change orders of roughly $5 million each — keeping each below the threshold requiring higher-level review. California Public Contract Code Section 20116 makes splitting work orders to evade oversight a criminal violation.
Threshold-adjacent change order at 251% of independent estimate
An $18.6 million change order was approved at 251% of the pre-construction manager’s independent cost estimate, positioned just below the $20 million Board Operations Committee review trigger. The pricing was not questioned.
Independent PM oversight eliminated during procurement changes
TY Lin International’s independent program management oversight role was terminated in the same period as the CP1 procurement rule change, removing the one entity positioned to flag irregularities in the process.
CP4 as natural experiment isolating governance failure
CP4 had an independent construction manager and a contractor with 722km of Spanish HSR experience. Same state, same project, same era — but 86% growth vs. 290% for the worst package. The comparison isolates procurement and oversight as the variable, not "inherent" US cost factors.
Seven named WSP employees held titled positions within CHSRA
Tony Daniels, Gary Griggs, Kristina Assouri, Hans Van Winkle, Brent Felker, Jim Van Epps, and Daniel Horgan held official agency titles while employed by WSP. Daniels signed CHSRA technical memos. Griggs presented to the Board as staff. Horgan, as Deputy COO, co-authored budget memos with spending authority.
Untested legal precedent for challenging WSP embedding
Professional Engineers in California Government v. Department of Transportation (1997) established that state agencies cannot delegate inherently governmental functions to private contractors. This framework has never been applied to the CHSRA-WSP relationship, despite WSP staffing the unit tasked with overseeing WSP.
13-year knowledge chain establishes reckless disregard
UC Berkeley (2010), the Peer Review Group (2010), and CHSRA’s own reviewer (2022) all called the ridership model unreliable. CHSRA submitted projections based on the same model in the 2024 FSP Agreement. Under the False Claims Act, this chain establishes “reckless disregard” without needing to prove any individual intended to deceive.
Electrification budget at 22% of the same state’s actual costs
CHSRA budgets $11.8 million per mile for electrification. Caltrain — same state, same regulatory environment, same era — spent $53.3 million per mile. The budget is 22% of comparable actual costs. The FRA flagged it as unrealistic in its compliance review.
Post-peer-review model changes went undisclosed
After independent peer reviewers flagged concerns with the ridership model, Cambridge Systematics made undisclosed changes to the methodology. The version submitted for peer review was not the version used to generate the numbers voters saw. No one outside the firm reviewed the final version.
Progressive records shielding across a decade
AB 1889 (2016) was gut-and-amended in the final hour of the legislative session — no video, no public notice, no registered opposition — to redefine standards for bond spending. AB 1608 (2026) would let the new IG withhold records describing “weaknesses,” including fraud-detection controls. The pattern: each legislative intervention weakened oversight, with procedural moves designed to minimize public scrutiny.
What We Haven’t Found
Intellectual honesty requires documenting the gaps. We looked for the following and did not find them:
- No direct evidence of personal enrichment by named officials beyond standard compensation. The revolving door pattern is structural, not a story of individual corruption.
- No smoking-gun communication — no email or memo in which someone says “we know these numbers are wrong, use them anyway.” The knowledge case is built from circumstantial evidence: timing, external publications, and the mathematical implausibility of the claims themselves.
- No evidence the FBI investigation has resulted in charges as of February 2026. Three concurrent federal investigations are underway, but outcomes are unknown.
- No forensic statistical analysis of change order distributions. Tests like McCrary density estimation or Benford’s Law analysis have never been applied to the 1,584 change orders. These could either strengthen or weaken the threshold-avoidance hypothesis.
How to Verify Our Work
Every claim is testable. The source documents are linked. The datasets are downloadable. If we got something wrong, we want to know.