“Independent” Investigations Into Sexual Abuse Are Big Business. Can Survivors Really Trust Them?

Tania Culver Humphrey has spent most of her life grappling with her father’s secrets.

In public, her father, Ellsworth Culver, cultivated a reputation as a globetrotting Christian do-gooder. He taught schoolchildren in Cuba, ran missionary programs in the Philippines, and, in the early 1980s, co-founded the humanitarian nonprofit Mercy Corps with friends from the international aid world. At Mercy Corps, including the nine years he spent as its president, he built programs across three continents, conducted informal diplomacy in conflict zones, and received a medal from North Korea for organizing food and medical aid.

In private, he was sexually abusing ­Humphrey, his youngest daughter—at times raping her, choking her, and taking explicit photos of her, according to a lawsuit she eventually filed. The abuse, she says, began as far back as she can remember and lasted through her late teens.

Her father would sometimes take her on business trips to developing countries, where his violence continued. He told her that if she reported him, she’d be hurting his humanitarian work and the people who relied on it, she remembers. “I was told as a kid that I was helping to save refugees,” Humphrey says. “Like, ‘Don’t I want to be a good girl? I’m part of the team.’”

Mercy Corps workers from the late 1980s and early ’90s remember her as a thin, sad young woman who often visited the company’s small Portland, Oregon, headquarters, then occupied by about 20 people. (Today, the organization has some 6,000 employees globally.) Her horrific ordeal first became known to other Mercy Corps leadership in 1992, when she sought comfort from members of her prayer group. Word made it back to a board member, who launched an internal investigation with two colleagues, including one of her father’s close friends. They appear to have swiftly accepted Culver’s claim that his daughter was experiencing a false memory. They confronted her in a hostile interview, and only after another employee learned of the allegations did they demote him to vice president, without reducing his pay. (They told Humphrey the title change was due to her father’s poor management.) Culver would remain a Mercy Corps executive until his death in 2005.

At the height of the MeToo movement, in 2018, Humphrey contacted a Mercy Corps “integrity hotline” set up to receive employee reports of misconduct. She asked that the organization review her case from a contemporary perspective. But a lawyer brushed her off, informing her that the 1990s probe had found “insufficient evidence.”

The response echoed her father’s message: Mercy Corps’ reputation was more important than the truth. She decided to go to the media, and in October 2019, the Oregonian published a bombshell investigation that uncovered multiple witnesses to her childhood abuse and revealed how Mercy Corps had buried her allegations.

Mercy Corps leaders resigned one after another. “We failed her with our response. We failed her with our tone,” the then-CEO told the Oregonian before stepping down. “We were too legalistic instead of engaging in good faith, and I fear through that we added to her suffering.” Employees chalked Humphrey’s name on the sidewalk outside headquarters. “We believe you,” they wrote. “We stand with you.” After decades living estranged from much of her family, suffering PTSD and panic attacks, she went to see the messages herself. “I had to touch it,” she says. “There were no slots in my brain, from my life experience, to know that that could be real.”

Mercy Corps’ actions in the wake of the Oregonian article suggested to Humphrey that the organization was finally ready to reckon with the past. So she wrote to the board of directors, making a new, disturbing allegation: There were more Mercy Corps–linked child abusers, and more victims. Other men working with her father had abused not only her, but other children in the United States and abroad—allegations that amount to sex trafficking.

Humphrey has since said in court documents that the perpetrators included former Mercy Corps leaders, powerful Christian affiliates, and international contacts. In Honduras, for example, she says her father allowed a military officer to rape her after he signed some papers; on the same trip, she remembers witnessing her father sexually abuse local children between the ages of 3 and 14. When she was 9, her father took her to Thailand, where she says he and another international aid leader drugged, raped, and choked her and a young local girl who died beside her on the hotel bed after being strangled.

Following her letter, Mercy Corps offered her a private settlement if she agreed not to sue. Believing the legal window had run out for a lawsuit anyway, she accepted—on the condition that the nonprofit, which has an annual operating budget of more than $550 million, prove its commitment to change by fully investigating both her new ­allegations and also how it had handled the case in the 1990s. As part of the settlement, the charity agreed to release the results publicly “to the extent reasonably possible and appropriate.”

“I wanted the truth to be out,” she says, and to protect others who might be in danger from still-living perpetrators. To do that, she needed help filling in the missing puzzle pieces of the story: Time and trauma had blurred some names and details, but thoughts of other victims from the past haunted her. Memories of the violence sometimes emerged in flashbacks she recorded in her journals. She needed answers about why and how the abuse occurred, and what justice was still possible. “Who else knew? I want to understand how he got away with it,” she tells me. “I know it was transactional. I want to know how much I was used.”

But the solution she was seeking—an independent investigation—would become yet another nightmare. After the ink was dry on the settlement, Mercy Corps hired Freeh Group International Solutions, a risk management firm run by former FBI Director Louis Freeh, to conduct a probe. Over the summer of 2020, the firm’s investigators grilled Humphrey, sometimes in full-day interviews, for about 100 hours, leaving her distraught and suicidal. Yet when the report was released the following year, it concentrated on the mishandling of her claims in the 1990s—something the ­organization had already acknowledged and apologized for. If the hired sleuths had uncovered any new information about the circumstances under which the abuse took place, Humphrey says she was never informed of it.

In September 2022, Humphrey, then a 51-year-old art teacher and mother of two, sued Mercy Corps. The lawsuit calls the probe a “whitewash” and alleges the ­organization used the process to gather information about potential threats to itself—of which she was one. Mercy Corps had “manipulated and deceived [her] to gain exclusive access to her explosive information,” and had used “systematic intimidation and bullying” and “the guise of an independent investigation” to control reputational damage, her lawsuit says. “Had plaintiff known Mercy Corps’ true intentions, she never would have participated in this harmful process.” CEO Tjada D’Oyen McKenna told reporters that Humphrey’s characterization of the investigation was “distorted and untrue,” adding that Mercy Corps’ “highest priority” was to provide her “with the utmost care and respect.” In court filings, the organization has denied any inappropriate conduct in connection with the Freeh Group’s investigation. (Investigators on the Freeh Group team, as well as AlixPartners, a consulting firm that later acquired Freeh’s company, did not respond to requests for comment.)

Yet Humphrey is hardly the only survivor of abuse or harassment to feel betrayed by a privately commissioned investigation. These secretive, pricey probes, akin to those that companies use to root out financial fraud or corruption, have become an increasingly common way for institutions to deal with sexual misconduct claims. For survivors, an independent investigation can appear to offer a path forward for accountability, even justice. But it is difficult to distinguish bona fide efforts from cynical exercises in liability management. Mother Jones’ interviews with investigators, plaintiff’s attorneys, and academic experts, as well as survivors and their advocates, reveal a field characterized by inconsistency, a lack of transparency, and inherent conflicts of interest that undermine claims of independence. As a growing number of organizations turn to third-party firms to examine sexual misconduct, survivors face a difficult question: Can they really trust a process arranged and bankrolled by the very institutions that failed them?

“This whole notion of independent investigations, it sounds wonderful,” says Boz Tchividjian, a former sex crimes prosecutor and the founder of an investigations firm. “Until you dig below the surface.”

At first, Humphrey was apprehensive but hopeful about a new inquiry. Mercy Corps had assigned Mary Wheat, a former police detective who worked at the organization helping oversee its child protection work, to coordinate the investigation. When Humphrey visited the Mercy Corps headquarters to see the chalk, Wheat had ushered out a crowd of workers to embrace her.

Now, Wheat informed her that Mercy Corps had chosen a company run by the former FBI director to conduct the probe. The organization says it picked the Freeh Group for its “reputation and track record for handling investigations involving sexual abuse and misconduct.” It helped that the firm also had connections to law enforcement “that could potentially facilitate appropriate legal action based on information uncovered during the investigation,” Mercy Corps says.

Freeh helped define this line of work in 2011, when a task force of Pennsylvania State University trustees had hired him as a “special investigative counsel” amid the explosive revelations that former assistant football coach Jerry Sandusky had sexually abused young children for more than a decade. Many of the victims were participants in a charity for troubled youth that Sandusky had personally founded. Sandusky was charged with dozens of felonies, and two administrators were indicted for failing to report him.

Freeh’s mandate was to determine who at Penn State had been aware of Sandusky’s abuse, and when. The probe took eight months, included 430 interviews, and cost more than $8 million. When it was done, the task force waived attorney-­client privilege, allowing Freeh’s team to publish its “essential findings.” Their report concluded that legendary head football coach Joe Paterno, university President Graham Spanier, and the two indicted administrators had concealed Sandusky’s child abuse, acting with “total disregard” for the victims amid a “culture of reverence for the football program.”

The report was widely seen as vindicating the board’s decision to fire Paterno. But it also generated endless debate about whether Freeh’s investigation was truly independent. In 2013, Spanier sued the Freeh Group and its founder for defamation, arguing the report had served the trustees’ interest by making him a scapegoat. Freeh had “developed a lucrative business model—predicated on Freeh’s name recognition and FBI credentials—that depends on conducting so-called ‘independent investigations’ and producing ‘investigative reports’ custom tailored with preconceived storylines to meet his clients’ objectives,” Spanier’s lawsuit claimed. The suit was ultimately dismissed, but the controversy continued: In 2018, a group of dissenting trustees contested Freeh’s findings, arguing he was compromised by his collaborations with prosecutors and the NCAA, and his lawyerly obligations to his clients, the broader board of trustees. (Freeh did not respond to requests for comment on the investigation.)

In the years since, a cottage industry that sells investigations of harassment and abuse has flourished, with investigators saying many more lawyers have recently entered their field. “The one-two punch of the MeToo movement and the racial justice movement has made a big difference,” says Amy Oppenheimer, founding partner of a California firm that specializes in workplace investigations. “People realize, ‘Okay, we can make money on this,’” Tchividjian says.

The industry involves big names and big fees, ranging from thousands of dollars for a brief workplace inquiry to millions for a monthslong case. In 2021, Oregon Health and Science University paid $6.5 million to Covington & Burling for former Attorney General Eric Holder to examine harassment and discrimination claims. At Debevoise & Plimpton, former SEC Chair Mary Jo White has conducted several investigations of gender-based violence in football—recently looking at then–Washington Commanders owner Dan Snyder. And BlackRock, the world’s top asset manager, hired former Attorney General Loretta Lynch to look into sexual harassment and discrimination claims among employees. (Her conclusions have remained private.)

Even as the field grows, there are few rules governing how independent investigators carry out their work. The Association of Workplace Investigators, a professional group founded by Oppenheimer, has issued “guiding principles” on how employee complaints should be handled. Legal ethics codes provide some basic guardrails, and there are federal regulations for sexual harassment investigations in schools. In California, courts have spelled out specific expectations about what it takes for workplace probes to be prompt, fair, and thorough, says Eli Makus, senior partner at investigations law firm Van Dermyden Makus. Beyond that, the field is a Wild West. “Across the country, there’s a lot of inconsistency in how investigations are conducted,” Makus says. And there are virtually no resources available to help survivors understand what they’re signing up for when they agree to participate in a probe, making it hard for them to spot potential pitfalls—especially if they don’t have an attorney. Kat Thomas, a New York lawyer, says many survivors come to her after going through a corporate-­commissioned investigation without legal representation. “They think they’re doing the right thing,” Thomas says. “And then it ends up hurting them.”

“Nobody understands this,” says Eve Ahrens, a Utah counselor who supported both a friend and a relative as they reported sexual assault and abuse in the Anglican Church of North America. When church officials proposed firms to conduct an independent investigation in 2021, Ahrens and her friend pored over their websites, trying to figure out which might be trustworthy.

One red flag Ahrens noticed: a firm that advertised objective sexual misconduct investigations on the same page it touted eight cases in which it had gotten employers, schools, and churches off the hook for liability. “The conflict of interest involved in them being ‘independent’ investigators and also defense attorneys couldn’t be more stark,” Ahrens’ friend wrote to a church official. “They are signaling to you, ‘the client,’ that they will do an investigation in such a way that should you run into legal problems in the course of it, they can help you defend yourself on that front, against the victims.”

This type of arrangement is common. “‘Independent’ is somewhat of a misnomer,” says feminist legal theorist Martha Chamallas, a professor at Ohio State University. “Yes, it’s an outside law firm. But the company is their client.”

After signing the settlement in April 2020, Humphrey began regularly texting with Wheat and Mercy Corps board chair Gisel Kordestani, a former Google director married to tech billionaire Omid Kordestani. The two women sent soup and cookies when Humphrey came down with a severe case of Covid. She and Kordestani exchanged messages with heart emojis.

Then, in early summer 2020, the Freeh Group began interviewing Humphrey in earnest. For days at a time, she went to a downtown Portland Hampton Inn conference room to recount the worst moments of her life to a team of lawyers. Recovering from Covid, she sat curled up in an armchair, a blanket on her lap and a face shield over her forehead, while female investigators asked her hundreds of questions. She was not allowed to have her ­lawyers, ­therapist, or any other support person present, according to her lawsuit.

She spoke of assaults at Mercy Corps corporate events, of a man undressing her in a Mercy Corps office while her father took photos, and of a pregnancy and miscarriage when she was 12. Sometimes, she says, Freeh Group investigators used sensory prompts, a technique police use to prod traumatized witnesses, like when they asked about the death of the girl in Thailand. “‘What did she feel like? What color is her skin? What sounds do you hear?’” Humphrey remembers them asking. “Everything was very detailed.”

“These questions were wildly out of line and tortured plaintiff again by making her revisit incidents in detail that understandably traumatized her as a child,” her lawsuit states. They brought on flashbacks so intense she felt like a child again. She could see hotel rooms, smell laundered sheets and the stench of body odor. Hear false kindness in the voice of one of her father’s colleagues after he raped her.

She often lost control of her breathing, slipping into panic attacks. She’d pull the blanket over her head and continue answering questions. When she couldn’t bear to answer questions aloud, she responded with handwritten notes.

The World Health Organization recommends that people interviewing trafficking survivors avoid questions designed to provoke a strong reaction “or force a woman to reveal traumatic details unnecessary to understanding her experience.” Louise Godbold, executive director of the trauma education nonprofit Echo, says the kind of questioning Humphrey describes can trigger extreme physical reactions. “Your brain doesn’t know the difference between it actually happening to you and the act of reliving it,” Godbold explains. “It’s not something that you would want to do outside of a therapeutic situation.” (Godbold, who once worked in film development and was one of the first women to have reported being abused by Harvey Weinstein, connected with Humphrey after the Oregonian report and became her friend and advocate, supporting her throughout the Freeh Group investigation. She also accompanied her in some interviews with Mother Jones.)

“Your objectives of understanding who knew what, and why they failed to protect you are within reach,” Karen Fischer-Anderson, one of the Freeh Group investigators, wrote to Humphrey in July. “I know it is scary but I encourage you to share what you know so that you never regret having the opportunity this investigation provides and not taking advantage of it.” Mercy Corps, too, reassured her: “We are a little army here supporting you,” Kordestani texted.

Over time, Humphrey would identify by name or photograph at least eight people she says sexually abused her, in addition to her father. Wheat helped her scan and send to investigators boxes of journals, papers saved since childhood, medical records, and old photos—a treasure trove of potential evidence and leads rarely seen in sexual violence investigations. Some pictures showed other survivors, she says; some, locations where she was abused. “I have several photos of unmade beds in hotel rooms that I just snapped when nobody was looking,” she tells me.

In mid-August, Humphrey returned to the Hampton Inn to answer more questions. But this meeting was different. Rather than the usual interviewers, questioning was conducted by Wheat—the Mercy Corps employee—and Matthew Dolan, the leader of the Freeh team. That day, Humphrey identified a powerful former Mercy Corps official as one of the men who had abused her. When she returned to her room at the hotel that night, she was engulfed in a flashback. She remembered that man screaming at her, forcing her, then around age 11, to shower with him in a hotel near where she was now staying. The memories were too much to bear: “I’m going to jump off the building, or I’m going to carve his name and ­everybody else’s name into my body,” she remembers deciding.

She walked from the hotel where she was being questioned to the one where she’d been assaulted. She stared into the lobby. And then she turned around. The next day, the investigators ended her in-person interviews.

Independent investigators argue that helping companies uncover the raw truth is just good business sense. Under corporate logic, rooting out sexual misconduct is risk management. Abuse and harassment threaten the bottom line; eliminating them will prevent future lawsuits and financial losses. “We do our best to conduct investigations in an impartial and unbiased manner, as we believe that is in the best interests of everyone,” Ivy Kagan Bierman, an entertainment lawyer at Loeb & Loeb who has handled independent investigations in Hollywood for more than two decades, writes in an email.

Yet Timothy Lytton, a Georgia State University law professor who has authored books on sexual abuse in the Catholic Church and the dynamics of self-policing industries, is mindful of the ways that companies can exert influence on a seemingly independent investigation, for reasons other than getting to the facts. Not only do institutions set the scope of the probes, they control what evidence they disclose to investigators. Lacking any subpoena power, he adds, investigators are “dependent on the information that they’re provided, which they don’t have any particular legal or economic muscle to ferret out.” Lytton points to an early review of sexual abuse claims in the Catholic Church, when the US Conference of Catholic Bishops promised investigators access to case records, but dioceses turned over only older allegations. As a result, he says, the Conference was able to both portray itself as transparent and erroneously suggest abuse by priests had mostly ended in the 1980s.

In other cases, Lytton says, institutions use outside probes “to further a cover-up by providing a plausible story or trying to put the issue to bed.” In one recent case in Prosper, Texas, a school district claimed it was conducting an independent investigation into a bus driver charged with sexually abusing two young sisters hundreds of times. Only later did a trustee reveal that the investigator was the same lawyer defending the district in a lawsuit brought by the victims’ family. Though the district commissioned a second investigation, it declined to release information about its findings.

Similar problems arose in the multiple investigations into sexual abuse by USA Gymnastics doctor Larry Nassar. In 2016, Rachael Denhollander, a former competitive gymnast, became the first person to speak publicly about abuse at Nassar’s hands. As more survivors came forward and said they had reported him as early as the 1990s, questions arose about how Michigan State University, where Nassar worked, could have failed to act for decades. Soon, the public university announced it was hiring former federal prosecutor Patrick Fitzgerald to conduct a “factual review.” But when Michigan Attorney General Bill Schuette asked Fitzgerald for his findings, Fitzgerald explained that his job had been to defend the university and that he’d never produced a written report. So Schuette launched his own inquiry, saying it was “abundantly clear that a full and complete investigation…is required.” At first, MSU said it would cooperate. But after it cited attorney-client privilege to hold back more than 6,000 documents, Dana Nessel, Schuette’s successor, closed the probe. “We have used every legal mechanism available to us—including going to court,” Nessel said. “The University’s refusal to voluntarily provide them closes the last door.” MSU paid $500 million to a fund for Nassar’s victims in December 2018, but exactly what the university knew—and when—remains shrouded in mystery. That could soon change: This past December, trustees voted to release the withheld documents in response to a lawsuit by survivors.

Attorney-client privilege also shielded facts about the Nassar timeline at USA Gymnastics, which had hired its own independent investigator, Deborah Daniels, and made her report and recommendations public. But when Daniels, a lawyer, was asked in a deposition if she ever questioned USA Gymnastics officials about when they first learned of the abuse complaints, she responded that she was “not going to reveal communications with the client.”

Denhollander, who is now a lawyer and consultant advising churches and universities on establishing investigations that are transparent and fair, says MSU’s probe “is a blown-up picture of what we see happening all over the place.” While attorney-client privilege can have a role in protecting witness privacy, the Nassar case illustrates how it can be used to obscure findings from survivors, the courts, and the public. “Unless investigators have had full access to all the information—including privileged information—and have a right and authority and are charged with the duty to report whatever is relevant that they find, you are almost certainly missing a significant portion of the puzzle,” Denhollander explains. “As long as there’s no written report, or the report is privileged, they can protect the public from seeing what they’ve actually found.”

Nor do companies and institutions always act on any findings of the probes they commission. Carolyn Bys, a former Mercy Corps lawyer who left the company in 2018 to open her own investigations firm, says she’s repeatedly seen NGOs launch inquiries into high-ranking employees, only to ultimately look the other way. “I’ve had to walk away and say, ‘I’m not going to be involved in this,’” Bys says, “because they refused to take action against people who are in positions of power.”

Bys also says she’s seen Mercy Corps spin findings to paint itself in a more flattering light. Even before Humphrey contacted the integrity hotline, Bys was part of internal Mercy Corps conversations about Humphrey posting abuse allegations on social media. Bys says she quit largely because she believed the organization wasn’t taking how it bungled its 1990s investigation seriously enough.

After the Oregonian story ran in 2019, but before Humphrey’s letter to the board, Mercy Corps hired Vestry Laight—a firm whose all-female partners are lawyers, DEI consultants, and crisis communications specialists—to evaluate how it had handled Humphrey’s hotline report. Bys agreed to share what she knew with an investigator from the firm. They produced a detailed draft that included much of the information Bys provided, but, as the investigator later wrote to her apologetically, the Mercy Corps board “took a long time deliberating about what to do…Ultimately they decided they want the public report to be much shorter and not name names.” While the final document concluded that “several missteps occurred…which resulted in a response that was not survivor centered,” investigators wrote they found no evidence of “intentional” wrongdoing.

“Frankly, I knew this report would be highly scrubbed internally, as that is status quo for this organization,” Bys wrote back to the Vestry Laight investigator.

“It turns out you were right to have concerns,” the investigator responded.

It took a few months for the Freeh Group to deliver a written report to the Mercy Corps board. Wheat told Humphrey in an email that she couldn’t read it because it would jeopardize attorney-client privilege.

Instead, it was arranged for Humphrey and her then-lawyer, Jacqueline Swanson, to return to the Hampton Inn conference room in early November 2020 for a private meeting with Wheat and Dolan. To Humphrey’s shock, they told her their report almost entirely focused on the 1990s cover-up. When it came to the details of the abuse, nothing had been committed to writing for the board, according to notes Swanson took. Instead, most board members had been given broad verbal descriptions of two incidents and were told that her father allowed other men to abuse her. A subsection of the board members received slightly more detailed information.

Humphrey was bewildered. “Sometimes,” she says, “people need to know it was rape. Or that he came into the room and made everybody leave. That in the same room, my father molested myself and another girl. That we went from place to place.”

According to Swanson’s notes, Humphrey asked Wheat and Dolan why so much had been left out. They claimed they had omitted details out of respect for her. She told them she appreciated the sensitivity, but that she had expected a fuller version of her story, even if it didn’t include the names of alleged perpetrators. “Otherwise, why did I go through all that?” she asked them.

Humphrey says she knew from the beginning that Mercy Corps would not be publishing names. Instead, Wheat and Dolan reported that information directly to the FBI’s Portland field office, according to an email from the FBI that Mercy Corps filed in the suit. Yet, to date, Humphrey—who had not been permitted to go with them to make the report, despite her wishes—has heard nothing from the FBI. In response to multiple public records requests from Mother Jones, the FBI says it has no records related to Humphrey or her father.

For months after the November meeting, she joined conference calls with lawyers and Mercy Corps officials to plan for the public release of the findings. As communication grew more distant and formal, her sense of alienation intensified. “This idea that we can truly have a partnership…that’s just words,” she journaled. “It’s words that sound really good, and make people feel good too. But it’s not real.” (Mercy Corps emphasizes that, during this period, it provided her with PR representation, and—because of her worries about retaliation from alleged abusers—a defamation lawyer and a home security system.)

Finally, in May 2021, Mercy Corps posted on its website a 33-page public report, which closely matched the version she’d been briefed on that fall. Most of it focused on the company’s response in the ’90s—finding, for instance, an email from a board member involved in the initial probe stating that he had “saved [Culver’s] job and career when he was accused by his daughter.” Details of actual violence were scant. Investigators had condensed her 100 hours of interviews into a two-page summary. “The abuse, as described by the Survivor, included severe sexual and physical abuse,” they reported, with a brief description of two overseas incidents, including the death of the girl in Thailand. The team had corroborated her father’s travel dates but had not attempted to contact survivors in other countries, citing obstacles presented by Covid and “potential harm that could be inflicted with indirect or direct outreach.”

At the time, in interviews with reporters and a prepared statement published on the Mercy Corps website, Humphrey praised the investigation. Despite her dissatisfaction with the result, she says she didn’t want to speak out, because she feared that doing so would undermine the findings, however incomplete they were. And, she adds, “I had to still have some belief and hope that something good could still come from this.”

After the report’s publication, as Humphrey tried to work through her conflicted feelings about the retraumatizing experience, she got in touch with Denhollander.

When Humphrey explained what she’d just been through, Denhollander grew concerned. “It had a high number of red flags that this was an exercise in liability management,” she says, “and very few to none of the benchmarks” of a “safe process…truly oriented towards truth and transparency and institutional transformation.”

Denhollander was particularly disturbed that Humphrey did not have an advocate present in her interviews, and that Wheat was so heavily involved in the investigation—even stepping in for the final sessions “as an interrogator,” as Humphrey’s lawsuit puts it. “The way they handled Tania’s interviews and care for her was just absolutely abhorrent,” Denhollander says. While Humphrey’s years of abuse had left a lot of material to cover, the length of time she spent answering questions was extreme, Denhollander says. “You don’t ever let a survivor go for eight or nine hours…not when they’re literally crumbling in front of you.”

“A hundred hours?” Chamallas, the Ohio State professor, asks. “This is crazy. It’s very odd and troubling.” (In a statement to Mother Jones, Mercy Corps says it has “confidence that the investigation was conducted appropriately and that Ms. Humphrey was treated sensitively, and with dignity and respect throughout.”)

Denhollander, too, was alarmed by the mismatch between the topics covered in Humphrey’s interviews and the content of the final report: “If they are spending [about 100] hours with her, getting names and dates and facts and identifying potential perpetrators, and then almost none of that comes out in the report, it begs the question—what exactly was this report to be?”

Today, Mercy Corps insists that the Freeh Group had “full editorial control” over its final report and “reached its own conclusion on what should be included…to ensure that it was fair, accurate and properly supported.” Humphrey’s lawyer’s notes from the November briefing on the investigation’s findings state that while Mercy Corps’ board could tell the Freeh Group what it wanted to include in the final version of the report, investigators made no promises about what the result would be. Ultimately, however, Mercy Corps would decide what to release publicly.

Mercy Corps’ contract with the Freeh Group could provide more information about the scope of the investigation. But Humphrey was not permitted to see it, so she cannot confirm that the investigators were actually tasked with looking into the things she cared about—not just her father’s violence, but the abuse and complicity of other people affiliated with Mercy Corps—as she was promised. The organization still declines to make this document public, but according to a request for proposals it issued while selecting an investigator, Mercy Corps was only interested in a probe examining the extent of the abuse perpetrated by Ellsworth Culver and the organization’s response in the 1990s.

Releasing the contract at the outset of an abuse investigation is a key step for transparency and accountability, Denhollander says, as it typically addresses expectations of a written report, the board’s involvement, and confidentiality.

To Bys, the Freeh Group’s unpursued leads, including the lack of international interviews, are a major problem. “If they were really interested in supporting Tania, their investigation would have been adequately resourced in order to follow up leads in other countries around other survivors,” Bys says.

Beyond that, in her interviews with the Freeh team, Humphrey also identified three still-living former Mercy Corps employees whom she believed knew about the abuse in the 1980s. One, Marie Lanier Kermani, tells Mother Jones that investigators never contacted her. Another, one of Ellsworth Culver’s former secretaries, declined to verify whether she was contacted, adding that she wished Humphrey would “turn to God” and “forgive her father.”

Talking to Denhollander, Humphrey grew more confident in her sense that Mercy Corps had done her wrong. She became certain after meeting Kim Sordyl, a fiery, orange-haired Portland-area employment lawyer who’d worked on cases involving independent investigations before. “I don’t think I’ve ever seen an investigation done by either the organization internally or hiring an outside lawyer or outside firm where they didn’t get the exact results that they paid for,” Sordyl said the first time we spoke.

In September 2022, with Sordyl’s help, Humphrey filed her lawsuit over the investigation and its aftermath, accusing Mercy Corps of negligence and intentional infliction of emotional distress. “I don’t want organizations to be able to do this and get away with it, to skate through some kind of scandal,” Humphrey says. “You finally regain your voice, to then be used by that organization? To then be hurt again? We just need to say, ‘No. We are not going to stand for that.’”

There are examples of a better way. In 2021, amid an escalating crisis over sexual abuse in the Southern Baptist Convention, its executive committee announced that it would hire an external firm, Guidepost Solutions, to investigate. Survivors were dubious that the committee, which stood accused of mishandling decades of reports of sexual abuse, should oversee its own audit. So Denhollander worked with survivors to successfully push for a separate task force to supervise Guidepost’s work; SBC officials were also forced to grant investigators­ access to documents that could have been withheld under attorney-client privilege, and to make the final report public.

Its conclusions were blistering, finding that executive committee leaders, concerned with avoiding legal liability, had ignored and covered up years of sexual abuse. It also revealed the existence of an internal list of more than 700 credible victims, and sparked the Department of Justice to launch its own probe.

Tchividjian also knows how carefully independent investigations must be set up. The grandson of Billy Graham, Tchividjian founded GRACE—short for Godly Response to Abuse in the Christian Environment—in 2004 to provide training on sexual abuse to churches. GRACE developed a reputation for audits that don’t pull punches. “Transparency lends to credibility,” Tchividjian says.

He has since left day-to-day management of GRACE and now represents survivors in civil litigation. Often, he says, his clients have been approached to participate in investigations of dubious independence. He suggests questions they should ask before agreeing: Will survivors be permitted to see the investigation’s agreed-upon scope? Will they get a copy of the final report? Will their interviews be handed over in full to the institution, or will their personal information be protected?

But no matter what safeguards are in place, there’s no getting around the fact that the institution pays the investigator’s bills. GRACE has itself faced this issue: In 2014, Bob Jones University tried to end an investigation by stopping payment, only to reverse course under public pressure. And in 2022, GRACE was forced to shutter an assessment of sexual abuse after Covenant Fellowship Church abruptly pulled funding. “In reality, if they decide to shut it down by stopping payment, they do have that control,” Tchividjian says.

In 2020, after the Oregonian article, Mercy Corps issued a list of 23 commitments to action. It has posted regular updates on its progress, including conducting the Freeh investigation, restructuring its ethics team, and putting a third-party investigations firm on retainer. In a statement to Mother Jones, a Mercy Corps spokesperson defended the Freeh Group’s probe, saying it involved 66 interviews and an “extensive” review of records: “We made no attempt to downplay or discredit either the abuse she shared with investigators or the past failures of Mercy Corps leadership to ­properly respond to, investigate, or report her allegations—all of which was described in considerable detail in the report.” Meanwhile, the organization is preparing to fight Humphrey’s lawsuit, set for trial in June.

Survivors have rarely, if ever, sued over independent investigations, and Humphrey’s case could shed rare light on the secretive processes that follow a sexual abuse scandal. Denhollander notes, however, that such cases can be extremely difficult to prove. “While damage to survivors from poorly done investigations is common, restitution for that damage is much more rare,” she says.

With the suit, Humphrey wants to put other organizations on notice, and she wants compensation for the mental health services she needs after the years of abuse and multiple investigations that have reopened the wounds—for as long as she needs them. “I want to be able to heal myself and my family,” Humphrey says. “And that takes resources.” (Mercy Corps covered some of her mental health costs during the Freeh inquiry, and paid her a lump sum to cover about a year of follow-up counseling.)

Bys agrees that Humphrey’s lawsuit highlights important problems in the field. “Tania is not an unreasonable person. She’s extremely intelligent. She understands process, and she understands the real world,” Bys says. “There is a valid discussion in that lawsuit around how we treat survivors. What is the purpose and end of these investigations? And how do they match up to survivors’ expectations?”

Humphrey knows she could herself name her other abusers. “It’s not off the table,” she tells me. But she feels betrayed that this is the position that Mercy Corps has left her with. “If they actually, really, did an investigation into some of these people,” she says, “that would make me feel like the weight wasn’t all on me.”

A few years back, she crafted a vase out of clay. On its side, she sculpted the legs and feet of a young girl, the one she says died beside her in Thailand. The hand of another young girl holds fast to her ankle. The clay is still fragile; Humphrey never fired it. Instead, inside, she placed flowers that Mercy Corps leaders had delivered to her on the day Wheat and Dolan met with the FBI.

“I don’t know why I haven’t finished it,” she starts to say. Then she interrupts herself. Of course she knows. “I can’t finish, I can’t fire this thing, because it’s not done.”