President Donald Trump is clearly James Comey’s No. 1 target in his new book, but the fired FBI director also paints a highly unflattering picture of another of his previous bosses, Rudy Giuliani.

In “A Higher Loyalty,” Comey repeatedly invokes Giuliani’s craving for publicity during his tenure as New York’s most famous federal prosecutor in the 1980s, before he became mayor, and paints his flaws almost as a biblical allegory about the dangers of excessive pride and ego.


“There was something of an unwritten code about working in the office of Rudy Giuliani,” Comey observed. “In his case, the message was that Rudy was the star at the top and the successes of the office flowed in his direction. You violated this code at your peril.”

Comey acknowledges that he was initially thrilled by the cult of personality surrounding Giuliani. Comey says he considered it his “dream job” when he was hired by the U.S. Attorney’s Office in Manhattan in 1987.

“Giuliani had extraordinary confidence, and as a young prosecutor I found his brash style exciting, which was part of what drew me to his office,” the ex-FBI chief says. “I loved it that my boss was on magazine covers standing on the courthouse steps with his hands on his hips, as if he ruled the world. It fired me up.”

However, Comey recalls that he was warned early on that he needed to be careful to make sure the spotlight was always on the boss. Comey writes that at an early news conference over the dismantling of a car-theft ring, a supervisor warned him to keep quiet and stay put.

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“The most dangerous place in New York is between Rudy and a microphone,” the unidentified supervisor declared, according to Comey.


Comey writes that with the passage of time and the wisdom of age, he came to realize that Giuliani’s attention-seeking approach was a recipe for trouble.

“It took me a while to realize that Giuliani’s confidence was not leavened with a whole lot of humility. The cost of that imbalance was that there was very little oxygen left for others,” Comey wrote. “Though Giuliani’s confidence was exciting, it fed an imperial style that severely narrowed the circle of people with whom he interacted, something I didn’t realize was dangerous until much later: a leader needs the truth, but an emperor does not consistently hear it from his underlings.”

“Rudy’s demeanor left a trail of resentment among the dozens of federal judges in Manhattan, many of whom had worked in that U.S. attorney’s office. They thought he made the office about one person, himself, and used publicity about his cases as a way to foster his political ambitions rather than doing justice. It was a resentment that was still palpable when I became the chief federal prosecutor in Manhattan — and sat in Giuliani’s chair — a dozen years later,” Comey added.


Though Comey never draws a direct analogy between Giuliani and the chief villain in the book, Trump, the former FBI director faults both men for an overly authoritarian style that tends to stifle criticism and dissent.

Giuliani, who supported Trump during the 2016 campaign, did not respond to requests to discuss his treatment in Comey’s book.

One reader with extensive experience in New York law enforcement said Comey’s persistent focus on Giuliani’s flaws was striking.

“It’s something that jumped out at me,” said former FBI Agent James Gagliano, who spent 20 years in the FBI’s New York office. “Every mention he made of Giuliani as the U.S. attorney for the Southern District, there were gratuitous shots.”

Gagliano said Comey’s observations about Giuliani’s penchant for publicity were not unfair, but it was curious to fault him for that while taking a more flattering tone toward people like Sen. Chuck Schumer (D-N.Y.). Many in New York often make the same joke about the danger of getting between Schumer and a microphone, Gagliano observed.

“It seems like [Comey] had an ax to grind with Rudy Giuliani,” the ex-FBI agent said.

Comey could well have been irked by two things Giuliani did repeatedly during the 2016 presidential campaign: second-guessing the FBI’s determination not to pursue charges against Hillary Clinton, the Democratic presidential nominee, and publicizing dissatisfaction within the FBI over what some alleged was lax handling of investigations into Clinton and the Clinton Foundation.

Speaking to POLITICO in February 2016, Giuliani said Clinton deserved to be prosecuted for discussing classified topics in emails sent through her private server.


“It’s a tough decision, politically, but legally, I think it’s not: If Hillary Clinton was not running for president, she’d have been indicted by now,” Giuliani said. “I’d love to try this case.”

Comey doesn’t go after Giuliani by name on that point in the book, but says that sort of view was either biased or uninformed.

“No fair-minded person with any experience in the counterespionage world … could think this was a case the career prosecutors at the Department of Justice might pursue. There was literally zero chance of that,” Comey wrote.

In his interview with ABC’s George Stephanopoulos, Comey did say he was aware that Giuliani was on TV in 2016 predicting surprise developments from the FBI just before the November election. Giuliani’s comments suggested he was privy to the discovery of more Clinton emails on a laptop belonging to former Rep. Anthony Weiner (D-N.Y.), which the FBI got while investigating him on charges of sexting with a minor.

“Yes, I saw that,” Comey said. “It’s part of what I ordered investigated.”

At a Senate hearing last year, days before Comey was fired, he was also asked specifically about leaks to Giuliani. Comey was careful not to accuse Giuliani of anything and said it wasn’t clear whether people at the FBI were leaking to him.

“I don’t know yet,” Comey told Sen. Patrick Leahy (D-Vt.). “But if I find out that people were leaking information about our investigations, whether it’s to reporters or to private parties, there will be severe consequences. … It’s a matter that I’m very, very interested in.”

In the book, Comey seems so focused on Giuliani that he raises him as a kind of cautionary tale even in situations where the former mayor played no role at all, including an embarrassing incident when Comey was working as a federal prosecutor in Richmond, Virginia, in the mid-1990s.


Due to a comical series of events, Comey ended up in a photo on the front page of a local weekly newspaper, identified as the U.S. attorney, which he was not. “A stunt like that back in Rudy Giuliani’s office would have ended very badly,” Comey quipped.

