The judge overseeing Donald Trump’s hush-money campaign finance trial in New York has been cautioned by a state ethics panel over two small donations made to Democrat-aligned groups in 2020.

The caution is likely to be seized on by Trump and his lawyers as evidence of his claims that the New York trial, now entering its fourth week, has been unfairly adjudicated by Judge Juan Merchan along partisan political lines.

But the New York state commission on judicial conduct has not revealed who lodged the complaint against Merchan that stems from a $35 donation to the Democratic group ActBlue that included $15 earmarked for Biden for President and $10 each to Progressive Turnout Project and Stop Republicans.

Related: Trump’s hush-money trial: Here’s what’s happened in the case so far

“Justice Merchan said the complaint, from more than a year ago, was dismissed in July with a caution,” spokesperson Al Baker of the state office of court administration said in response to an inquiry from Reuters.

The commission considers that contributions violate the rules on prohibited political activity. In its 2024 annual report, the body said several dozen judges had apparently made prohibited contributions in the last few years, mostly to candidates for federal office.

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.

The commission has also received a complaint against the Manhattan judge Arthur Engoron, who oversaw the former president’s civil business fraud trial that resulted in a $454m fine earlier this year. That complaint, brought by Trump lawyers, has yet to be adjudicated.

Under commission guidelines, proceedings are confidential unless there is a public censure or the judge makes them public.

Trump has been highly critical of the justices in both cases. In the earlier trial he was censured for describing Judge Engoron’s law clerk of being Senate majority leader Chuck Schumer’s girlfriend. In the current case, he has drawn attention to Judge Merchan’s daughter, who works as a Democratic political consultant.

In response to a motion for Merchan to step aside, which the judge denied, a separate advisory committee on judicial ethics said the contributions did not create an impression of bias or favoritism.

Reports of the contributions come a day after the New York Times revealed that the wife of conservative supreme court justice Samuel Alito had flown an inverted American flag outside the couple’s home in the aftermath of the 2020 election.

Alito has said that his wife took that action because a Democratic neighbor had used a highly pejorative insult to describe her to her face.