Sarah Merriam Federal Reprimanded

Sarah A. L. Merriam, a judge on the U.S. Court of Appeals for the Second Circuit, is facing a second formal judicial misconduct complaint in under four years alleging she bullies her law clerks and has created a "culture of fear" in her chambers. The Legal Accountability Project, a legal nonprofit, filed the complaint on December 18, 2025 under the Judicial Conduct and Disability Act, saying clerks reported Merriam "routinely bullied, belittled, isolated, and dehumanized them," yelling, berating them, and sending "all-caps unhinged emails." An earlier misconduct investigation into Merriam's management style had already concluded with a public reprimand — reportedly the first time a federal judge was publicly reprimanded for mistreating law clerks — after which Merriam agreed to watch workplace-conduct training videos and receive counseling. The new complaint alleges that despite that discipline, the same pattern of conduct continued.