The Legal Accountability Project has filed a complaint against Judge Sarah A.L. Merriam of the U.S. Court of Appeals for the Second Circuit, alleging mistreatment of law clerks. The complaint is based on accounts from multiple former clerks who, fearing retaliation, have chosen to remain anonymous.
Aliza Shatzman, president and founder of the Legal Accountability Project, described the allegations, stating that Judge Merriam is accused of “yelling, berating clerks, sending all-caps unhinged emails.” ([kpbs.org](https://www.kpbs.org/news/politics/2025/12/30/federal-appeals-court-judge-is-accused-of-bullying-her-clerks?utm_source=openai))
This marks the second publicly known complaint against Judge Merriam in four years. In December 2023, an internal investigation by the Second Circuit’s judicial council found that an unnamed judge had an “overly harsh” management style. The investigation concluded after the judge agreed to watch workplace conduct videos and receive counseling on staff management. Although the judge was not named, legal commentator David Lat reported in 2024 that the judge in question was Merriam. ([kpbs.org](https://www.kpbs.org/news/politics/2025/12/30/federal-appeals-court-judge-is-accused-of-bullying-her-clerks?utm_source=openai))
Shatzman noted that in 2024 and 2025, clerks reported alleged abuses by Merriam, including an unnamed clerk who resigned after one month on the job. Additionally, four others withdrew from offers to work for the judge after learning about the work environment. ([kpbs.org](https://www.kpbs.org/news/politics/2025/12/30/federal-appeals-court-judge-is-accused-of-bullying-her-clerks?utm_source=openai))
Judge Merriam, a former federal public defender and magistrate judge in Connecticut, was nominated by President Joe Biden to a lifetime tenured district court judgeship, confirmed in October 2021, and promoted to the federal appeals court in September 2022. ([kpbs.org](https://www.kpbs.org/news/politics/2025/12/30/federal-appeals-court-judge-is-accused-of-bullying-her-clerks?utm_source=openai))
These allegations highlight ongoing concerns about the power imbalance between federal judges and their clerks, who often lack the job protections afforded to other American workers. ([kpbs.org](https://www.kpbs.org/news/politics/2025/12/30/federal-appeals-court-judge-is-accused-of-bullying-her-clerks?utm_source=openai))
The recent complaint may prompt Second Circuit officials to conduct interviews with individuals who have worked for Judge Merriam and to seek her response to the allegations. ([kpbs.org](https://www.kpbs.org/news/politics/2025/12/30/federal-appeals-court-judge-is-accused-of-bullying-her-clerks?utm_source=openai))