Third Publicly-Reported Instance Of Judicial Misconduct in Just 6 Weeks Highlights Outrageous Lack of Accountability for Judges Who Abuse Their Power
Wednesday, February 11, 2026
For Immediate Release
Contact: Aliza Shatzman, 267-481-2095, aliza.shatzman@legalaccountabilityproject.org
Third Publicly-Reported Instance Of Judicial Misconduct in Just 6 Weeks Highlights Outrageous Lack of Accountability for Judges Who Abuse Their Power
Maryland federal judge and Biden appointee Lydia Kay Griggsby acknowledged that she created an abusive work environment in chambers, according to a disciplinary order posted yesterday by the Fourth Circuit. This order, which comes just days after reporting about former judge Mark Wolf’s misconduct, and just six weeks after The Legal Accountability Project (LAP) filed our first complaint against Judge Sarah Merriam alleging similar abusive conduct, is just the latest in a long line of examples of the outrageous lack of accountability for federal judges who abuse their power by mistreating clerks.
The complainant and his co-clerk were simultaneously reassigned by the Administrative Office of the U.S. Courts (AO) in 2022 soon after they reached out seeking assistance–when one co-clerk had been working for Judge Griggsby for just two months, and the complainant, for just over a year. Reassigning two co-clerks simultaneously is very rare. And yet, despite knowing Judge Griggsby mistreated these clerks, and recognizing this mistreatment was severe enough to warrant such reassignments, the Chief Judge failed to open a judicial misconduct investigation into Griggsby back in 2022. The Chief Judge could have disciplined and retrained Griggsby at that time. Instead, the judiciary allowed Griggsby to continue supervising and mistreating clerks for three more years–without taking any corrective action–before finally investigating her in 2025.
According to LAP’s President and Founder Aliza Shatzman, who is familiar with the situation involving Judge Griggsby, “the federal judiciary is perpetrating a fraud upon the public. The judicial branch lawlessness we are witnessing evidences a brazen disregard for proper standards of workplace conduct and basic human decency by those tasked with interpreting our laws. Laws which, disturbingly, these federal judges are not themselves subject to, since the federal judiciary is exempt from Title VII and all federal anti-discrimination laws.”
In 2025, Fourth Circuit Chief Judge Albert Diaz conducted a limited inquiry into Judge Griggsby that included interviews with clerks and meetings with the judge. However, Judge Diaz disposed of the complaint rather than elevating it to a special committee, delineating some toothless remedies that will be familiar to those who follow LAP’s work.
The laughable corrective remedies delineated in the order–Griggsby agreed to participate in workplace conduct discussions and annual training, and agreed that the Circuit Director of Workplace Relations (DWR) would check in with clerks periodically, and basically nothing else–are literally the same meaningless remedies that did not deter Second Circuit Judge Sarah Merriam from mistreating her clerks.
Shatzman added, “in our complaint against Judge Merriam late last year, we alleged that check-ins with the DWR were useless, because this law clerk point of contact was actually aware of ongoing misconduct, yet failed to run it up the chain to the Chief Judge.”
The judiciary has a systemic misconduct problem that it is either unwilling or unable to solve. The courts insist they can self-police: that is clearly untrue. Nothing short of widescale reform–including extending Title VII protections to more than 30,000 exempt employees of the federal judiciary–and outside oversight by Congress will correct this judicial branch lawlessness.
Said Shatzman, “Shame on every member of Congress who refuses to act when confronted with this third judicial misconduct story in just six weeks. Congress has four tools at its disposal–legislation, oversight, appropriations, and the bully pulpit–all of which it can and should use right now to hold some of the most powerful and unaccountable members of our government, accountable for misconduct. Sadly, those tasked with conducting oversight over and holding the federal judiciary accountable, have abdicated this responsibility. It should disturb all of us that federal judges so brazenly flout congressional authority, and that Congress allows them to do so.”
This disciplinary order will not deter Judge Griggsby from mistreating clerks; it will not deter other judges from committing similar misconduct; and, sadly, it probably will not deter all prospective clerks from working for Judge Griggsby, given the whitewashing of the complainant’s allegations. Without meaningful discipline for judges who abuse their power, abusive conduct will persist unabated in the federal courts.

