A Texas billionaire donor, Harlan Crow, paid for two years of private-school tuition for Justice Clarence Thomas's great-nephew, an undisclosed gift that adds to Crow's largesse to the Justice, ProPublica has revealed. The previous report documented luxury travel gifts to Thomas from Crow and the sale of Thomas’s mother’s home to him. There has been a lot of speculation about potential ethical violations by Thomas and increased scrutiny of his practices. Despite Mark Paoletta, a former Trump official and friend of Thomas, arguing that the Supreme Court justice was not legally required to report the tuition payment since the great-nephew did not meet the dependent criteria under a 1978 law, experts such as Kathleen Clark, an ethics law expert at Washington University in St. Louis, rejected Paoletta's argument, stating that Crow's gift was certainly reportable since it was to Thomas himself, not the great-nephew.

Richard Painter, a professor at the University of Minnesota who served as the top ethics lawyer in the Bush administration, agreed, stating that "I believe Justice Thomas had legal custody, and they have not disputed that." This gift of tuition points to Crow's investments in Thomas, adding to earlier examples of Crow's generosity to Thomas, including millions of dollars investment in a museum celebrating Thomas's hometown, financing a library project dedicated to Thomas at a cost of $175,000, and the financial support of Thomas’s wife, Ginni.