A state ethics panel quietly dismissed a complaint last summer against the New York judge presiding over the criminal trial of Donald J. Trump, issuing a warning over small donations the judge had made to groups supporting Democrats, including the campaign of Joseph R. Biden.
The judge, Juan M. Merchan, donated a total of $35 to the groups in 2020, including a $15 donation earmarked for the Biden campaign, and $10 to a group called “Stop Republicans.”
Political contributions of any kind are prohibited under state judicial ethics rules.
“Justice Merchan said the complaint, from more than a year ago, was dismissed in July with a caution,” the spokesman for the court system, Al Baker, said in a statement.
A caution does not include any penalty, but it can be considered in any future cases reviewed by the state’s Commission on Judicial Conduct. A letter outlining the caution was not released because of the commission’s rules, and Justice Merchan did not make the letter available.
“The Commission on Judicial Conduct is governed by a confidentiality statute and cannot comment on nonpublic dispositions,” said Robert Tembeckjian, the commission’s administrator.
The commission’s decision was first reported by Reuters.
In its 2024 annual report, the commission said it was made aware of dozens of New York judges who had violated the rules against political contributions in recent years. Most were modest amounts, the report said, and many appeared to stem from the misperception that the rules only apply to state campaigns. In fact, judges are prohibited from contributing to any campaigns, including for federal office.
“Like so much of the misconduct the Commission encounters, making a prohibited political contribution is a self-inflicted mistake,” the commission wrote in the report.
For Justice Merchan, the stakes of such a mistake are considerably higher than most: He is the first judge in American history to preside over the criminal trial of a former president.
The donations in part fueled Mr. Trump’s efforts to have Justice Merchan removed from the case before the trial began. Mr. Trump’s lawyers also focused on Justice Merchan’s adult daughter and her work at a Democratic consulting firm.
But Justice Merchan declined to recuse himself, appeals court judges declined to step in, and the trial is now nearing its conclusion.
The case centers on a hush-money payment to a porn star, Stormy Daniels, in the last days of the 2016 presidential campaign. Ms. Daniels says she had a sexual encounter with Mr. Trump, but a $130,000 payment from Mr. Trump’s fixer bought her silence. Mr. Trump is accused of falsifying business records to cover up his reimbursement of the fixer, Michael D. Cohen, casting them as routine legal expenses.
Mr. Trump has denied the accusations against him — and has lashed out at Justice Merchan and the Manhattan district attorney, Alvin L. Bragg, who brought the case, noting that both are Democrats.
