Among the most prominent allegations are that Boebert conducted a four-year “romantic and sexual relationship” with a senior female staffer, named as Clarice Navarro Ratzlaff, then paid her $200,000 when Ratzlaff broke off the affair and threatened to file an ethics complaint of her own.

Additionally, Wheeler alleges, Boebert had a sexual relationships around the same time with Raven Finegan, a congressional employee and the congresswoman’s district chief of staff, and Jeffrey Small, who was her chief of staff from 2021 to 2025.

The complaint includes detailed financial records of Boebert’s congressional spending, and payments to staff that included more than $450,000 to Finegan to June 2026, and almost $780,000 to Small. Ratzlaff received more than $461,000.