A nonprofit advocating for law clerks has filed a misconduct complaint against Judge Sarah Merriam of the 2nd U.S. Circuit Court of Appeals, alleging she bullies and mistreats her staff. The complaint, based on accounts from former clerks, highlights a pattern of abusive behavior in her chambers. This marks the second such public complaint against her in four years.
The Legal Accountability Project submitted the complaint earlier this month, drawing from interviews with multiple former law clerks who expressed fears of retaliation if they spoke out directly. Aliza Shatzman, the group's president and founder, described the judge's conduct sharply: "She is a bully, in all the ways one might bully their employees: yelling, berating clerks, sending all-caps unhinged emails."
This is not the first allegation against Merriam. In December 2023, the 2nd Circuit's judicial council investigated an unnamed judge for an "overly harsh" management style, concluding with the judge agreeing to view workplace conduct videos and undergo counseling on staff management. A 2024 report by legal commentator David Lat identified Merriam as the subject. To address the issue, the court's workplace relations coordinator was tasked with periodic check-ins with her clerks to ensure respectful treatment and absence of abuse.
Recent reports to the nonprofit include a clerk who resigned after just one month in 2025, and four others who withdrew job offers upon learning of the environment. Shatzman noted these accounts from 2024 and 2025 underscore ongoing problems.
Merriam, a former federal public defender and magistrate judge in Connecticut, was nominated by President Joe Biden. She received Senate confirmation for a district court position in October 2021 and for the appeals court in September 2022, earning a lifetime appointment.
The case spotlights broader tensions in the federal judiciary, where young clerks often lack typical workplace protections amid a power imbalance with judges. Officials from the 2nd Circuit, Merriam herself, and the Administrative Office of the U.S. Courts have not commented, as is standard for pending complaints. The filing may lead to interviews with current and former staff.
