Can a controller clear you through an SFRA? A pilot I know (lets call him Joe) recently had a minor run in with the FAA after he skirted the edge of the Washington DC Special Flight Rules Area (SFRA) while returning to Leesburg (JYO).  Here are the details:


Joe was returning from KOMH.
Joe was trying to get on the ground quickly to avoid a wall of convective sigmet from the west, moving east quickly and threatening to engulf Leesburg and his landing in a small GA plane.
Joe was in contact with the Leesburg Tower Note: Leesburg is NOT usually a towered airport.  However Leesburg has been a test site for mobile air traffic control tower and that tower was operational when this occurred.
Joe was instructed by the tower to "Proceed directly to Leesburg".  He immediately turned directly towards Leesburg (right turn shown on chart), received permission to land and landed.
Joe was provided with a number to call by the tower.
Joe was interviewed by someone in the FAA, told he had skirted the SFRA, received a warning and the case was closed with no further action.




Though the case was closed it was still the FAA's position that a violation of the SFRA rules had occurred.  

What I find confusing about this case is that, if ATC instructed Joe to "proceed directly to Leesburg", doesn't that mean they cleared him through the portion of the SFRA he will need to fly through to comply with their instruction?

Research done for this question


I have taken the SFRA training required to fly VFR in the SFRA and have again reviewed this material after hearing of Joe's incident.  I've found nothing in that material that conclusively answers this question.
I have reviewed this question/answers about flying in the Washington DC SFRA.
I have reviewed this general question about flying in SFRAs.
I have reviewed the NOTAM associated with Ingress/Egress to/from Leesburg airport.
I have reviewed already asked questions and did not find this specific question having already been asked.
An AOPA article on this has a chart of the Leesburg Maneuvering Area (LMA) which, as you said, doesn't require a DC SFRA flight plan (you do need one for pattern work, though):



If you compare the area in the chart to the flight path in the image in your question, it looks to me like Joe entered the SFRA southwest of JYO and then entered the south edge of the LMA. I suspect the FAA is saying that he should have flown further north, then entered the LMA from the west. In other words, he cut through a corner of the SFRA. I've marked that in red here:



The LMA NOTAM says:


  PILOTS MUST ENTER THE LMA VIA THE MOST DIRECT ROUTE AND AVOID ENTERING
  REST OF THE DC SFRA


By cutting the corner, Joe entered a part of the SFRA that was outside the LMA, hence the call with the FAA. That's my interpretation, at least, although I'm surprised that the FAA didn't spell out to him very clearly what the issue was.

And to answer the question in the title, ATC cannot clear a pilot to do something he isn't authorized to do. ATC could clear a student pilot into class B airspace, but if the student doesn't have a logbook endorsement for that airspace then he still isn't allowed to enter (barring emergencies). "Proceed direct Leesburg" doesn't mean "fly in a straight line to Leesburg regardless of other considerations", the pilot still has to get there legally.