Former FEMA CFO Mary Comans Implicates Kristi Noem and Corey Lewandowski in Defamatory Leaks
The legal and ethical battles over the leadership and financial operations of the Federal Emergency Management Agency (FEMA) have escalated with blockbuster court disclosures. Newly unsealed deposition transcripts from ongoing federal employee litigation have exposed a highly suspect shadow network operating within FEMA, connecting top political aides to a back-channel financial operation involving the Department of Government Efficiency (DOGE).
The Comans Due Process Lawsuit
The controversy began with a lawsuit filed by former FEMA Chief Financial Officer Mary Comans, who alleges she was unlawfully terminated and subjected to a coordinated smear campaign. Comans’ complaint directly implicates former Department of Homeland Security (DHS) Secretary Kristi Noem and senior White House adviser Corey Lewandowski in orchestrating defamatory leaks to the media to justify her removal and clear the way for political control over FEMA's multi-billion-dollar budget.
The "Shadow Administrator" Deposition
The structural context behind Comans' removal has now been laid bare in newly filed discovery documents from the related lawsuit AFGE v. Trump (No. 3:25-cv-03698-SI, N.D. Cal.).
In a deposition filed in late August 2026, Kara Voorhies—previously described by congressional investigators as FEMA's "shadow administrator"—detailed how she was installed at the agency without prior government experience. Voorhies testified that she was serving as CFO for Crest Investment Company when its founder introduced her to Corey Lewandowski, who was then serving as Noem's chief of staff at DHS.
Despite having no formal job description, Voorhies was given the authority to review and terminate FEMA grants and contracts exceeding $100,000.1
The DOGE Subcontracting Loophole
Because Special Government Employees (SGEs) are legally limited to working 130 days per year, Voorhies and her political sponsors devised an extraordinary back-channel arrangement once her SGE status expired in the fall of 2025:
- LV Consulting: In September 2025, Voorhies formed a single-employee consulting firm.
- AnchorCode Technologies: In October 2025, Voorhies' firm was hired as a subcontractor by AnchorCode Technologies, a firm owned by Kyle Schutt—a prominent DOGE software engineer and GSA employee who was given direct access to FEMA's payment software.
- IMGE: AnchorCode was itself a subcontractor to IMGE, a conservative marketing agency serving as the "prime" contractor for DHS.
This multi-layered subcontracting arrangement allowed Voorhies to continue directing FEMA's financial operations from the outside, shielding her and Schutt from direct federal procurement databases and ethics disclosure requirements.2
Potential Criminal Violations
Legal and ethics experts have raised severe alarms regarding the legality of this arrangement. Under federal law, government contractors are strictly prohibited from performing "inherently governmental functions," such as approving or terminating federal grants.
Margaret Dylus-Yukins, senior legal counsel for ethics at the Campaign Legal Center, noted that because of her outsize influence at FEMA, Voorhies should have been subject to a strict two-year communication ban after her SGE status expired. Without an official waiver:
"...this is illegal under 18 USC 207 of the criminal code."
What the Pattern Signals
The integration of DOGE operatives into FEMA’s financial apparatus, combined with the forced removal of career professionals like Mary Comans, signals a coordinated effort by the Trump administration to bypass traditional civil service and procurement guardrails. By utilizing private subcontracts and loyalist "shadow" administrators, the administration has consolidated executive control over federal disaster aid and counterterrorism grants, turning FEMA's budget into a tool of political leverage.
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An instance of Unitary executive controls convert merit-based federal grants into tools of partisan compliance. — Loyalist shadow figures were installed directly into federal agencies to bypass standard merit reviews and execute political grant terminations. ↩︎
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An instance of Unpublished directives and unwritten policies allow agencies to execute controversial overhauls without public scrutiny. — A shadow administrator used layered private subcontracts to run agency operations from the outside without public registry or ethics disclosure. ↩︎