How a federal judge in the Eleventh Circuit received discipline for an affair in chambers, a partisan political event, and false statements to the chief judges — and why the public may never learn the judge’s name
UPDATE — JUNE 12, 2026
When this file was first published in May 2026, the subject judge was anonymous in the federal record, and the only source identifying her was a single law-blog post drawing inferences from the redacted C.C.D. memorandum. We declined to follow that identification, citing our standing editorial rule against publishing names based on third-party speculation.
The situation has materially changed. On June 9, 2026, U.S. Representatives Andrew Clyde and Clay Fuller, both of Georgia, filed separate articles of impeachment in the United States House of Representatives seeking the removal from office of U.S. District Judge Eleanor L. Ross of the United States District Court for the Northern District of Georgia. The articles describe the same conduct that is the subject of the Eleventh Circuit Judicial Council order discussed in this file. Mainstream press outlets (including NPR, the Associated Press, and the Washington Times) have reported the filing by name. Judge Ross’s identity as the subject judge of the C.C.D. order is no longer a matter of speculation.
The body of this file, below, is preserved essentially as originally published. The analysis of how the federal judicial-discipline system works does not change with the identification, and the editorial reasoning that led the firm to decline to name the judge in May is worth preserving as part of the record. Readers should understand the body of this file as a description of how the matter looked through the lens of the Eleventh Circuit’s anonymous order and the C.C.D.’s anonymous affirmance. The Postscript at the end of this file addresses the impeachment posture as of the date of this update.
| THE QUICK ANSWER
On May 22, 2026, the Committee on Judicial Conduct and Disability of the Judicial Conference of the United States affirmed a Judicial Council of the Eleventh Circuit order finding that an unnamed federal district judge engaged in judicial misconduct in three ways: a two-year extramarital affair with a high-ranking law enforcement officer, including sex in chambers within earshot of staff; attending a partisan political event; and making false statements to the Chief Circuit Judge and Chief District Judge when first questioned. The sanction is a private reprimand. The facts are public. The judge is not named. |
Case File at a Glance
| Judge | Anonymous in the federal record — federal district judge within the Eleventh Circuit (see UPDATE above) |
| Court | U.S. District Court (district not identified in the original record) |
| Circuit | Eleventh Circuit (covering Alabama, Florida, Georgia) |
| Case Numbers | C.C.D. No. 26-01 • J.C. No. 11-25-90212 |
| Reviewing Bodies | Eleventh Circuit Judicial Council; U.S. Judicial Conference Committee on Judicial Conduct & Disability |
| Sanction | Private Reprimand (plus three voluntary undertakings) |
| Underlying Order | February 11, 2026 |
| Affirmance | May 22, 2026 |
| WHY THIS CASE FILE READS DIFFERENTLY
The Gavel of Shame is built around named judges and the public record of their misconduct. This file is different on exactly that point: the subject judge is, by design of the federal system, anonymous in the official documents. National news outlets covering this case (from Reuters and Bloomberg Law to Law360 and Above the Law) have all treated the judge as unnamed, because the underlying orders identify the judge only as “the subject judge.” However, Reason claims to have uncovered the judge’s identity. We are running this file anyway because the conduct is significant, the findings are adjudicated and affirmed, and the federal system’s choice to keep this judge anonymous is itself part of the story. Throughout this post, we refer to the judge simply as “the judge” or “the subject judge,” as the federal record does. We do the same for the police officer involved. We are not in a position to identify either person, and we will not speculate. What this file can do is show the substance of the misconduct, walk through how the federal judicial discipline system works, and let readers weigh for themselves whether a private reprimand fits the conduct it sanctions. |
A Third System: How Federal Judges Are Disciplined
Texas readers of this series know the State Commission on Judicial Conduct, which both investigates and sanctions Texas judges. Our recent National Edition file on Jefferson County, Alabama walked through Alabama’s two-body system: a Judicial Inquiry Commission that investigates and charges, and a Court of the Judiciary that tries the case. This file introduces a third system entirely which is the one Congress set up for federal judges.
Federal judges have constitutional life tenure under Article III: with rare exceptions, only Congress can remove them, and only by impeachment. Short of that, the Judicial Conduct and Disability Act of 1980 (codified at 28 U.S.C. §§ 351–364, often called the “JC&D Act”) lays out a tiered process for handling misconduct complaints inside the judiciary itself. The structure has four levels:
| Body | Role |
| Chief Circuit Judge | Initial gatekeeper. Reviews complaints; can dismiss, conclude, or appoint a special investigative committee. Can also “identify” a complaint on the chief judge’s own motion when misconduct comes to light without a formal complainant. |
| Special Committee | Investigates the allegations. Interviews witnesses, gathers documents, may retain outside counsel. Reports findings and recommended action to the Judicial Council. |
| Judicial Council of the Circuit | The decision-maker for the circuit. Receives the special committee’s report and issues the formal order finding misconduct (or not) and imposing sanctions. The Eleventh Circuit Judicial Council issued that order here on February 11, 2026. |
| Committee on Judicial Conduct & Disability | The national review body, sitting at the Judicial Conference of the United States. Reviews circuit-council orders for errors of law, clear errors of fact, or abuse of discretion. The C.C.D. Committee issued the May 22, 2026 decision affirming the Eleventh Circuit’s order in this case. |
Available federal sanctions short of impeachment include private reprimand, public reprimand (called a public censure or reprimand in the rules), an order temporarily suspending case assignments, a request that the judge voluntarily retire, and (in the most serious cases) certification of misconduct to the Judicial Conference for transmission to Congress with a recommendation of impeachment. The Eleventh Circuit Judicial Council, with the C.C.D. Committee’s affirmance, chose the lowest of those options: a private reprimand.
What the Investigation Found
The case began with a law clerk. In the summer and early fall of 2025, the law clerk reported to the Chief District Judge of the subject judge’s court that the subject judge had, on multiple occasions, engaged in sexual activity with a uniformed law enforcement officer in chambers during work hours within earshot of the judge’s staff. The Chief District Judge passed the report to the Eleventh Circuit’s Chief Circuit Judge, William H. Pryor Jr., who on September 29, 2025, notified the subject judge of the allegations and requested a response.
The subject judge’s response was issued the same day. The judge denied every allegation, called the report “outrageous” and “baseless,” and (appearing to know which law clerk was the source) suggested the allegations were retaliation for prior performance criticism. In a separate email to the Chief District Judge that day, the subject judge also denied knowing who the alleged visitor to chambers was.
The next day, September 30, 2025, the Chief Circuit Judge formally identified a complaint under JC&D Rule 5(a) and appointed a special committee. The committee’s investigation was, by the C.C.D. Committee’s description, thorough. It interviewed six of the subject judge’s former law clerks; gathered emails, texts, and documents; reviewed courthouse security footage and visitor sign-in logs to corroborate the dates the original law clerk supplied; conducted acoustic testing in a similarly-laid-out chambers to determine whether sounds could be heard from outside; arranged forensic testing of a couch cushion in the subject judge’s chambers; examined court records for potential conflicts; and reviewed publicly available information about a campaign event hosted by a district attorney.
On December 10, 2025, the special committee issued its report. It made three findings of judicial misconduct, each of which the Eleventh Circuit Judicial Council adopted on February 11, 2026, and the C.C.D. Committee affirmed on May 22, 2026.
The Three Findings
First, the affair. The special committee found that the subject judge engaged in an extramarital affair with a high-ranking law enforcement officer for approximately two years, running from roughly October 2023 to October 2025. On multiple occasions, during business hours, the judge and the officer had sex in the judge’s chambers within earshot of the judge’s staff. The committee found that this “demonstrated a gross lack of judgment” and created a workplace environment that was, in its words, “extremely uncomfortable and troubling” for the clerks.
There is more to that finding than the simple impropriety. During the period the affair was ongoing, the officer’s police department was involved in numerous criminal and civil cases being litigated in the same federal district. The judge did not disclose the affair to any other judge, court staff member, or litigating party. As the special committee put it, the judge could have been assigned a case in which the officer or the police department had an interest, which would have created a conflict or the appearance of one. The committee did not find that this had actually occurred but it noted that this was because of “happenstance” rather than any screening by the judge. The committee also noted that the undisclosed affair left the judge “vulnerable to potential extortion or blackmail.”
Second, the political event. The committee found that the subject judge knowingly attended a partisan event hosted by a district attorney’s campaign. The judge “attended for the purpose of reuniting with former colleagues, did not speak publicly, did not make any donation, and did not otherwise engage in political activity.” But the event was, by its purpose, partisan. The Code of Conduct for United States Judges expressly forbids attending “a dinner or other event sponsored by a political organization or candidate.” Even a one-time appearance counts. The committee characterized this as “a one-time lapse in judgment and not part of a larger pattern” but made a finding of misconduct nonetheless.
Third, the false statements. The committee found that the judge’s September 29, 2025, denials (to the Chief Circuit Judge and the Chief District Judge) were “numerous, material false statements.” The judge denied having had sex in the courthouse and denied knowing who the allegations concerned. Both denials were false. Under JC&D Rule 4(a)(5), refusing without good cause to cooperate in an investigation is itself misconduct; under Rule 4(a)(6), a judge has an affirmative duty to report his or her own cognizable misconduct. The judge eventually recanted the denials, but the committee was direct that recantation “does not absolve the judge of liability,” particularly given that by the time the recantation came, the judge “knew that the first falsehood had been or would soon be exposed.”
| WHY THE CONFLICT-OF-INTEREST POINT MATTERS
The most striking finding in this case is not the affair itself. It is what the affair meant for the court’s neutrality: • Litigants in front of a federal judge are entitled to a neutral arbiter. A judge in an undisclosed sexual relationship with a high-ranking officer of a police department that is litigating numerous cases in the same district is, by definition, not neutral about that department. • Conflicts of interest do not require a smoking-gun ruling to matter. The standard the federal Code uses is whether the judge’s impartiality might reasonably be questioned. An undisclosed affair with a police-department leader plainly clears that bar. • The special committee found no instance where the judge actually presided over a case the officer or department was party to. But it called that result “happenstance” because the judge did not screen for it. The accident was the safeguard. This is the difference between misconduct and harm. The misconduct is the undisclosed conflict and the failure to disclose. The harm is what could have happened in any one of those numerous cases and what litigants in those cases had a right to know. |
What the Investigation Did Not Find
Fairness matters in this series, and it matters here. The original law clerk complaint included allegations beyond the affair: that the subject judge had failed to mentor the law clerks and edit their work, displayed visible anger toward them including yelling and cursing, and on one occasion attributed being off-duty the morning after a campaign event to having “too many martinis the night before.”
The special committee’s investigation (which included interviewing six former law clerks) did not substantiate the allegations regarding supervision or treatment of staff. The C.C.D. Committee’s decision is explicit on this point in a footnote. Those allegations were investigated, examined against testimony from the judge’s former clerks, and ultimately not adopted by the committee or the Judicial Council. They are part of the story of how the case began. They are not part of the findings.
We mention this for the same reason the federal record does: the judge deserves the benefit of the parts of the original complaint that did not hold up. The findings that stuck are serious enough on their own without borrowing from those that did not.
The Rules the Judge Broke
Federal judicial discipline does not run on the Texas Code of Judicial Conduct’s canons or the Alabama Canons of Judicial Ethics; it runs on the Code of Conduct for United States Judges, supplemented by the JC&D Rules. The order identified violations across several of those provisions:
| Rule | What It Requires |
| Code of Conduct, Canon 2 | A judge should avoid impropriety and the appearance of impropriety in all activities. |
| Code of Conduct, Canon 2(A) | A judge should respect and comply with the law and should act at all times in a manner that promotes public confidence in the integrity and impartiality of the judiciary. |
| Code of Conduct, Canon 5 | A judge should refrain from political activity. |
| Code of Conduct, Canon 5(A)(1)(c) | A judge shall not attend a dinner or other event sponsored by a political organization or candidate. |
| JC&D Rule 4(a)(5) | Cognizable misconduct includes refusing, without good cause shown, to cooperate in the investigation of a complaint. |
| JC&D Rule 4(a)(6) | A judge has a duty to report his or her own cognizable misconduct to the chief circuit or district judge. |
The Sanction and Why It’s Private
The Eleventh Circuit Judicial Council, adopting the special committee’s recommendation, imposed a private reprimand. The subject judge agreed not to oppose or challenge the sanction and, additionally, agreed to three voluntary undertakings: to issue letters of apology to the six former law clerks interviewed during the investigation; to forego service as chief judge if otherwise eligible; and to indefinitely refrain from serving on any Judicial Conference committee.
On May 22, 2026, the Committee on Judicial Conduct and Disability affirmed that result. Its review was deferential by design (errors of law, clear errors of fact, or abuse of discretion) and it found none.
The choice of private over public reprimand is the editorial question this case has put squarely on the table for the legal press. The special committee explained its rationale plainly. It “carefully considered whether to recommend a more severe sanction, including a public reprimand,” and decided against it for three reasons: the judge corrected the false statements and was subsequently candid; the committee did not consider the judge likely to repeat the conduct, in part because the affair had ended and the judge committed to avoid future partisan events; and the judge had “otherwise rendered exemplary service to the court.” The committee said it was “deeply troubled” by the conduct but found the judge “demonstrated a strong propensity for rehabilitation.”
That reasoning has drawn open criticism from legal commentators since the May 22 affirmance. The argument from the other side is straightforward: an affair conducted in chambers with a senior officer of a litigating police department, sustained over two years, layered with material false statements to the chief judges of one’s circuit and district, is exactly the kind of conduct a public sanction exists to address. Keeping it private, the criticism runs, lets a serious abuse of office pass without the public accountability that named state sanctions in our other case files have carried. We do not take a position on that debate. We do think it is important to acknowledge that the debate exists, and that reasonable people are having it.
How It Played in the Press
The C.C.D. Committee’s May 22, 2026 affirmance drew immediate national coverage. Reuters, Bloomberg Law, Law360, and Above the Law all ran accounts within days, focused on the affair, the false statements, and the choice of private over public reprimand. None named the judge.
The exception, at this writing, is a May 27, 2026 post on the Volokh Conspiracy, the long-running law blog hosted by Reason magazine. South Texas College of Law professor Josh Blackman, one of the blog’s regulars, attempted to deduce the judge’s identity from clues in the C.C.D. memorandum itself (i.e. the Eleventh Circuit jurisdiction; the order’s use of “District Attorney” terminology, which Florida does not use; the timing of a 2024 primary “victory party” that fit Georgia’s election calendar but not Alabama’s; references to martinis served at the event, which Blackman tied to public photographs of one high-profile Georgia DA primary celebration; and a chambers layout described in the order as “configured almost identically” to the chief district judge’s) which Blackman read as narrowing the building. Blackman proposed a specific district judge as the most likely subject and named a specific district attorney whose victory party the order describes. He also disclaimed certainty in his own bottom-line sentence and noted that he had emailed the proposed judge’s chambers for comment and received no response.
As of original publication, the Reason post stood alone in attempting to identify the judge. The major national outlets that covered the affirmance had continued to treat the judge as anonymous, and so did we. See the Update at the top of this file and the Postscript below for developments since.
Why You Won’t Find a Name Here
[Editor’s note, June 2026: This section reflects the firm’s editorial reasoning at the time File 13 was originally published. Since then, public identification has been confirmed in mainstream press, and articles of impeachment naming the judge have been filed in the U.S. House of Representatives. See the UPDATE at the top of this post and the POSTSCRIPT below for the current posture. The reasoning preserved in this section is part of the editorial record and is left intact.]
The federal system’s confidentiality rules are not an accident of this case. The JC&D Rules treat the identity of a judge who receives a private reprimand as protected information. Public documents (like the C.C.D. decision and the underlying Judicial Council order on which this post is based) are released with the judge’s name and identifying details removed. The factual findings are public. Who they apply to is not.
Could a name leak? In theory, yes. The investigation involved six former law clerks, two chief judges, a special committee, court staff, and the appellate review body. Identifying details circulating in legal circles often do find their way to reporters. But as of original publication, no major outlet that has covered this story (and there are many) had named the judge. We did not have independent information that would allow us to do so responsibly, and we did not believe speculation was appropriate.
Two things are worth saying about what this means. The first is for the subject judge: the conduct described in this case file has been formally found and twice affirmed, but the federal system has decided that the consequence stays private. Whether that is the right balance is a real question. The second is for the public: this is a structural feature of federal judicial discipline, not a one-time oversight. There are likely other federal judges in active service who have been privately reprimanded. The Gavel of Shame, by design, can only document the cases the public record lets us document.
The Takeaway
What sets this case apart is not the misconduct. We have seen affairs, abuse of office, and false statements in other case files in this series. It is the system’s response. A state-level reprimand in Texas or Alabama would have come with a name attached and a public record any voter, litigant, or future client could look up. The federal version of the same kind of sanction came, at the time of original publication, without a name. The conduct was on the record; the judge was not.
That difference is not lawlessness. It is a deliberate choice by Congress and the federal judiciary about how to balance accountability against the independence and reputation of judges who serve under Article III’s life tenure. It is a choice with a logic. It is also a choice that, in a case like this one, leaves a real gap between what the public knows about the conduct and what the public knows about the person responsible for it. The Gavel of Shame exists, in part, to keep that gap visible. We did what we could with this case at original publication. The rest, by federal design, was sealed.
That gap has now narrowed. See the Postscript below.
Postscript — The Subject Judge Has Been Publicly Identified, and Articles of Impeachment Have Been Filed
Since this file was first published in May 2026, the subject judge has been publicly identified in mainstream press, and the United States House of Representatives has begun to consider whether to act on her conduct by means of the only mechanism by which an Article III judge may be removed from office: impeachment.
The subject judge is U.S. District Judge Eleanor L. Ross of the United States District Court for the Northern District of Georgia. Judge Ross was nominated to that bench by President Barack Obama in January 2014 and confirmed by the Senate in November of that year. She previously served as a DeKalb County state court judge beginning in 2011 and, before that, worked as a state and federal prosecutor in the Atlanta area for more than a decade.
On Tuesday, June 9, 2026, U.S. Representative Andrew Clyde of Georgia filed articles of impeachment in the House of Representatives seeking Judge Ross’s removal. Representative Clay Fuller, also of Georgia, had filed a similar impeachment resolution the day before. Both reference the conduct described above including the affair, the political event, and the false statements to the chief judges. Both seek a vote of the House to impeach.
Impeachment of federal judges is a constitutionally specified process under Article II, Section 4 of the United States Constitution. The House of Representatives may impeach federal civil officers (including federal judges) by a simple majority vote for “treason, bribery, or other high crimes and misdemeanors.” The trial of an impeachment occurs in the Senate, which can convict and remove an officer by a two-thirds vote of members present. In the entire history of the United States, only fifteen federal judges have been impeached by the House; eight have been removed by the Senate.
The procedural posture matters. Most articles of impeachment introduced against federal judges never reach a committee vote. A House Judiciary Committee referral, an evidentiary hearing, and a markup of the resolution would have to precede any vote of the full House. The fact that two members of the Georgia delegation filed articles within twenty-four hours of one another is itself notable, but the next step is the Judiciary Committee’s. Whether that committee acts (and how it acts) will tell readers more about the trajectory of this case than the filings themselves.
There is a structural point worth drawing out. The Eleventh Circuit Judicial Council had a range of sanctions available, from private reprimand at one end up to certification of the matter to the Judicial Conference of the United States for transmission to Congress with a recommendation of impeachment at the other. The council chose the lowest of those options. The council’s reasoning is preserved in the body of this file: corrective behavior, low recurrence risk, exemplary prior service. Congress is now asking, through the impeachment process, whether the council’s choice was the right one. The judicial-council process and the impeachment process operate independently of one another, by constitutional design. Each can reach its own conclusion. The Constitution does not require that they agree.
That is, perhaps, the deepest lesson of this case. When a judicial-council’s private reprimand is followed by a congressional impeachment proceeding addressing the same conduct, the public is watching the federal system’s two accountability mechanisms work through the same record. They do not have to reach the same answer. They are not designed to.
| CONFLICTS OF INTEREST — EVEN HIDDEN ONES — MATTER
Every defendant is entitled to a courtroom where the judge’s loyalties are not in question. Watching for that, and pushing back when something is off, is part of the job of any defense lawyer worth hiring. At Deandra Grant Law, we know how to ask the questions other lawyers don’t think to ask. If you are facing a DWI or criminal charge in Dallas, Tarrant, Collin, Denton, Rockwall, or McLennan County, put our experience to work for you. Call (214) 225-7117 • texasdwisite.com |
The Gavel of Shame • National Edition • Case File No. 13
By Deandra Grant • Deandra Grant Law • Published May 2026 • Updated June 10, 2026
Sources
Primary source
Committee on Judicial Conduct and Disability of the Judicial Conference of the United States, In re Judicial Complaint, C.C.D. No. 26-01, Memorandum of Decision (filed May 22, 2026) (affirming Eleventh Circuit Judicial Council order, J.C. No. 11-25-90212, dated February 11, 2026). uscourts.gov
Code of Conduct for United States Judges (Judicial Conference of the United States). uscourts.gov
Rules for Judicial-Conduct and Judicial-Disability Proceedings (JC&D Rules). uscourts.gov
Judicial Conduct and Disability Act of 1980, 28 U.S.C. §§ 351–364. law.cornell.edu
News coverage
Reuters / CNBC, “Federal judge had sex in chambers with high-ranking police officer, panel says” (May 26, 2026). cnbc.com
Bloomberg Law, “Judge Had Sex in Chambers in Earshot of Clerks, Panel Says.” news.bloomberglaw.com
Law360, “Discipline Upheld For Fed. Judge Who Had Sex In Chambers” (May 22, 2026). law360.com
Above the Law, “Federal Judge Had Sex In Chambers — Bringing New Meaning To Gavel Bang.” abovethelaw.com
Josh Blackman, “Who Is The District Court Judge Who Was Privately Reprimanded For Having Loud Sex In Her Chambers With A Law Enforcement Officer From Her District?,” The Volokh Conspiracy / Reason (May 27, 2026). reason.com
Update coverage (June 2026)
Carrie Johnson, “Three judges, three scandals and new scrutiny of judicial accountability,” NPR / Houston Public Media (June 9, 2026). houstonpublicmedia.org
Washington Times, “Impeachment sought against federal judge over alleged sex in chambers, lying to investigators” (June 9, 2026). washingtontimes.com
This post summarizes a public order of the Judicial Council of the Eleventh Circuit, affirmed by the Committee on Judicial Conduct and Disability of the Judicial Conference of the United States, together with subsequent congressional filings. All findings and quotations from the judicial-conduct proceedings are drawn from those public documents and from published news reporting. The articles of impeachment described in the Update and Postscript are public legislative filings of the United States House of Representatives. This is general commentary on
