The FBI memo that initiated the Biden-era Arctic Frost investigation into President Donald Trump and hundreds of his allies over their activities related to January 6 lacked substantial evidence and clear legal justification, according to several former prosecutors and FBI agents who reviewed the newly released document and identified multiple deficiencies.

The investigation, code-named Arctic Frost, was initially led by an FBI supervisor who had expressed anti-Trump sentiments and was later taken over by Special Counsel Jack Smith.

The probe treated the effort by Trump’s allies to submit alternate electors to Congress during the 2020 election certification as a potential criminal conspiracy — despite similar actions in two prior instances of U.S. Continues…