If Scott Lloyd didn’t break the law, he came perilously close to doing so. Since his appointment in March as director of the Office of Refugee Resettlement at the Department of Health and Human Services, Lloyd has prohibited undocumented minors in federal custody from obtaining abortions. He has instructed subordinates to prevent these minors from meeting with attorneys and from going to court to request permission to terminate their pregnancies. He has personally met with multiple minors to coerce them to carry their unwanted pregnancies to term.

A federal court ruled on Tuesday that Lloyd violated the Constitution when he refused to let an undocumented minor known as Jane Doe obtain an abortion. This ruling casts serious doubt on the constitutionality of ORR’s broader policy, which bars federally funded shelters from taking “any action that facilitates” abortion without approval from Lloyd (which he will never provide). The Jane Doe case also raised questions about the broader legality of Lloyd’s actions. An ethics watchdog group and two congressional representatives are now looking into whether Lloyd should be charged with abuse of public office.

Lloyd was selected to run ORR precisely because of his culture warrior bona fides. He vigorously opposes abortion and has argued that pregnant women should be legally required to receive consent from their partners before terminating a pregnancy. Lloyd also opposes contraception which, he claims, has an extremely high failure rate. (The science does not back up this allegation.) He helped Terri Schiavo’s parents fight to keep their daughter on artificial life support and co-founded an anti-abortion law firm called LegalWorks Apostolate. This work experience made Lloyd an obvious candidate for the Trump administration, although his specific placement was initially puzzling: As ORR director, Lloyd is tasked with helping new refugees though he has no real experience in refugee resettlement.

It is now quite clear why Lloyd was selected for this position: to halt the Obama administration’s practice of allowing undocumented, unaccompanied minors to obtain abortions upon request. Emails obtained by the American Civil Liberties Union show that Lloyd immediately imposed an absolute bar on abortion services and began monitoring pregnant minors at federally funded shelters. Via email, he directed shelters not to let these women meet with attorneys regarding termination—or to go before judges to receive judicial bypasses, as required under Texas law. Instead, he provided them with a list of approved “crisis pregnancy centers” to which minors could be brought for anti-abortion “counseling.”

Lloyd also repeatedly met with pregnant minors to urge them not to terminate and called their parents—without their consent—to inform them that their daughters were pregnant. He prioritized placing these teenagers with sponsors who opposed abortion. And although Lloyd took keen interest in these minors’ fetuses, his emails reflect a blasé attitude toward the women themselves. In one email, he noted that a pregnant minor denied abortion access had “mentioned suicide”; in response, he urged more anti-abortion counseling. In another email, he advised that a shelter staffer should “keep a close eye” on a pregnant teen in case she began to demand an abortion, which “these girls” often “regret.”

Does Lloyd have the authority to micromanage these minors’ medical decisions and deprive them of legal representation? He does not, argues the Campaign for Accountability, which has called on the Virginia State Bar to investigate whether Lloyd’s actions violated rules of professional conduct. (Lloyd is a member of the Virginia bar.) CFA alleges Lloyd may have engaged in interference with the administration of justice by preventing minors from attending court hearings. Moreover, he may have “misused his position” by “personally visiting unaccompanied immigrant minors, pressuring them regarding personal healthcare decisions, and providing individualized, detailed, and at times illegal direction to grantee shelters regarding their care.” Lloyd is not authorized to perform any of these tasks under federal law.

In a letter to the HHS inspector general, CFA also claims Lloyd may have committed contempt of court by violating state confidentiality rules regarding judicial bypass. Under Texas law, court records of bypass proceedings are confidential, and the court is authorized to enforce this confidentiality. Lloyd plainly violated those rules by calling at least one minor’s parents following her bypass hearing and divulging information regarding her pregnancy.

Perhaps most damningly, Lloyd may have flouted the terms of a long-standing federal settlement agreement—behavior that could put him in contempt of federal court. In 1997, the federal government entered a settlement in the long-running Flores v. Reno lawsuit, which involved the rights of undocumented, unaccompanied minors. Under the agreement, the government is legally obligated to provide these minors with emergency health care, family planning services, “a reasonable right to privacy,” and “legal services.” As CFA explains:

Mr. Lloyd appears to have violated the Flores settlement in a number of ways. He withheld family planning services from [Jane Doe], who was blocked from obtaining an abortion for weeks as Mr. Lloyd directed the grantee shelter to refuse to let her leave for her scheduled appointments. He has blocked at least one unaccompanied immigrant minor from seeking and receiving legal assistance. He has suggested circumventing the placement priorities of the Flores agreement in an apparent attempt to prioritize ideological opposition to abortion over the goal of placing unaccompanied immigrant minors with their family members. He has also potentially deprived unaccompanied immigrant minors of their reasonable right to privacy by notifying their parents or sponsors of their pregnancies, and has forced them to undergo “counseling” at crisis pregnancy centers.

On Oct. 16, Reps. Beto O’Rourke and Zoe Lofgren sent a letter to Acting HHS Secretary Eric Hargan expressing concern about many of these issues. O’Rourke and Lofgren asked Hargan to clarify HHS policy regarding its compliance with Flores as well as Lloyd’s possible abuse of office. The letter requested a “prompt response to this urgent matter.” As of Friday afternoon, HHS has not responded. O’Rourke’s office informed me that the congressman has sent a follow-up note “communicating the urgency of their expected response.”

CFA’s complaints to the Virginia State Bar and the HHS inspector general are not likely to spur immediate repercussions for Lloyd. If the bar does move to sanction Lloyd—which is no sure thing, as state bars are hesitant to punish powerful members for their official actions—those proceedings will take quite a while. And while HHS Inspector General Daniel R. Levinson is fairly independent, his office typically focuses on combating fraud and waste of federal funds. Lloyd’s behavior does technically fall under Levinson’s purview, but he may view it as a fundamentally political matter. And even if Levinson does launch an investigation, it could drag on for months or even years. In the meantime, Lloyd can continue to impose his unlawful policies on thousands of undocumented minors.

Lloyd should face consequences for his misconduct. He probably won’t. Like so many Trump administration officials, Lloyd behaves as though he is above the law—an attitude that obviously starts at the top. He has imposed his beliefs on those in his care with little regard for their own well-being. He has exceeded the authority of his office and disregarded both state and federal law. He has, in other words, acted exactly as we have come to expect a Trump appointee to act. Lloyd’s ethical breaches should be a scandal. But in this administration, they’re just business as usual.