Republican congressman Randy "Duke" Cunningham [3] recently resigned after pleading guilty to graft and tearfully admitting that he took $2.4 million in bribes from defense contractors, prompting an interesting question from Joshua Micah Marshall [4]: "How did Duke Cunningham manage to get so far entangled in an ethics mess that he had to plead guilty to federal charges of accepting bribes without anyone referring his case to the House ethics committee? Think about that for a second. With all that came out about Cunningham over the last six months and not one Democrat even filed a complaint against him, let alone any Republicans?" Melanie Sloan provides the answer [5]: "Since 1998, there has been an ethics 'truce' [6] in the House of Representatives, under the terms of which no member will file an ethics complaint against another member. Because outsiders are prohibited from filing complaints with the House ethics committee, this has effectively shut down the ethics process."