Case: Hudson v. Montgomery County

2:20-cv-01487 | U.S. District Court for the Eastern District of Pennsylvania

Filed Date: March 17, 2020

Closed Date: Feb. 2, 2021

Clearinghouse coding complete

Case Summary

This is a case about alleged wrongful retaliation and wrongful discharge of a public defender as a result of an amicus brief that was critical of Montgomery County’s money bail system. A former Montgomery County chief public defender filed this suit against Montgomery Country on March 17th, 2020 in the U.S. District Court for the Eastern District of Pennsylvania. She sued the County for First Amendment retaliation under 42 U.S.C. § 1983 and for wrongful discharge under the common law of Pennsyl…

This is a case about alleged wrongful retaliation and wrongful discharge of a public defender as a result of an amicus brief that was critical of Montgomery County’s money bail system. A former Montgomery County chief public defender filed this suit against Montgomery Country on March 17th, 2020 in the U.S. District Court for the Eastern District of Pennsylvania. She sued the County for First Amendment retaliation under 42 U.S.C. § 1983 and for wrongful discharge under the common law of Pennsylvania. Represented by the Civil Rights Corps and Kairys, Rudovsky, Messing, Feinberg & Lin, she sought injunctive relief, reinstatement, and compensatory damages.

Before she was fired, the plaintiff became aware of a class-action mandamus petition filed by the ACLU of Pennsylvania in March 2019: Philadelphia Community Bail Fund v. Arraignment Court Magistrates. In the petition, the Bail Fund alleged that the bail system in Philadelphia County violated both the federal and state constitutions in three ways: 1) lack of consideration of the ability of defendants to pay, 2) purposeful imposition of higher monetary conditions to ensure pretrial incarceration, and 3) lack of due process in its preliminary arraignments. To highlight the existence of similar violations in Montgomery County and throughout Pennsylvania, the plaintiff “directed the filing of” an amicus brief in support of the Bail Fund in early February 2020. She was fired on February 26, 2020, she alleged, as a result.

On May 18th, 2020, Montgomery County moved to dismiss the case. Montgomery County asserted that the speech at issue was not in fact the plaintiff’s own speech because she did not draft, file, or sign the amicus brief in question, and therefore she lacked standing to seek protections under the First Amendment. Moreover, the County argued that the speech in question was not citizen speech since it was prepared as part of the professional duties and with the specialized knowledge of the Montgomery County Office of Public Defender. Finally, the County argued that the wrongful discharge claim should be dismissed because the County had immunity for a claim of wrongful discharge.

The plaintiff filed a response to the motion on June 8th, 2020, and on June 16th, 2020 the defendants filed their reply. On September 30, 2025, the court denied the defendants' motion to dismiss, holding that the defendant had standing to pursue her claim, and that, construing the disputed facts in the light most favorable to the plaintiff, it was plausible that the drafting and filing of the amicus brief was outside of her ordinary job responsibilities and therefore constituted protected citizen speech. 

On October 8, 2020, the district court consolidated this case with Beer v. Montgomery County. On October 28, 2020, the court referred the consolidated matter to Magistrate Judge Elizabeth T. Hey for settlement proceedings. On February 2, 2021, following a settlement conference and notice that the parties had settled, the court dismissed the action with prejudice, with each party bearing its own costs and attorneys’ fees.

 

Summary Authors

Madeline Buday (9/24/2020)

Related Cases

Beer v. Montgomery County, Eastern District of Pennsylvania (2020)

People

For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/16995933/parties/hudson-v-montgomery-county/


Judge(s)
Attorney for Plaintiff

AHMAD, BINA (Pennsylvania)

Boykin, Olevia (District of Columbia)

Gerstein, Charles L. (District of Columbia)

Attorney for Defendant

Brown, Mary Kay (Pennsylvania)

McGarry, Raymond (Pennsylvania)

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Documents in the Clearinghouse

Document

2:20-cv-01487

Docket [PACER]

Sept. 9, 2020

Sept. 9, 2020

Docket
1

2:20-cv-01487

Complaint

March 17, 2020

March 17, 2020

Complaint
10-1

2:20-cv-01487

Defendant's Memorandum of Law in Support of its Motion to Dismiss Plaintiff's Complaint Pursuant to Rules 12(b)(6) and 12 (b)(1)

May 18, 2020

May 18, 2020

Pleading / Motion / Brief
18

2:20-cv-01487

Order

Sept. 30, 2020

Sept. 30, 2020

Order/Opinion

Docket

See docket on RECAP: https://www.courtlistener.com/docket/16995933/hudson-v-montgomery-county/

Last updated Jan. 15, 2026, 2:54 p.m.

ECF Number Description Date Link Date / Link

One Summons Issued as to MONTGOMERY COUNTY. Forwarded To: COUNSEL on 3/20/2020. (tjd) (Entered: 03/20/2020)

March 17, 2020

March 17, 2020

1

COMPLAINT against MONTGOMERY COUNTY ( Filing fee $ 400 receipt number PPE213130.), filed by KEISHA HUDSON. (Attachments: # 1 Cover Sheets)(tjd) (Entered: 03/20/2020)

1 Cover Sheets

View on PACER

March 17, 2020

March 17, 2020

Clearinghouse

DEMAND for Trial by Jury by KEISHA HUDSON. (tjd)

March 17, 2020

March 17, 2020

One Summons Issued as to MONTGOMERY COUNTY. Forwarded To: COUNSEL on 3/20/2020. (tjd)

March 17, 2020

March 17, 2020

Summons Issued

March 20, 2020

March 20, 2020

Jury Demand

March 20, 2020

March 20, 2020

2

WAIVER OF SERVICE Returned Executed by KEISHA HUDSON. KEISHA HUDSON waiver sent on 3/19/2020, answer due 5/18/2020. (RUDOVSKY, DAVID) (Entered: 03/25/2020)

March 25, 2020

March 25, 2020

3

MOTION for Pro Hac Vice filed by KEISHA HUDSON.application pro hac vice.(RUDOVSKY, DAVID) (Entered: 05/06/2020)

May 6, 2020

May 6, 2020

4

MOTION for Pro Hac Vice filed by KEISHA HUDSON.application pro hac vice.(RUDOVSKY, DAVID) (Entered: 05/06/2020)

May 6, 2020

May 6, 2020

Filing Fee for PRO HAC VICE by KEISHA HUDSON. (Filing Fee $40, receipt number 0313-14290581). (RUDOVSKY, DAVID) (Entered: 05/13/2020)

May 13, 2020

May 13, 2020

Filing Fee for PRO HAC VICE by KEISHA HUDSON. (Filing Fee $40, receipt number 0313-14290651). (RUDOVSKY, DAVID) (Entered: 05/13/2020)

May 13, 2020

May 13, 2020

Filing Fee (Pro Hac Vice)

May 13, 2020

May 13, 2020

Filing Fee for PRO HAC VICE by KEISHA HUDSON. (Filing Fee $40, receipt number 0313-14290581). (RUDOVSKY, DAVID)

May 13, 2020

May 13, 2020

Filing Fee for PRO HAC VICE by KEISHA HUDSON. (Filing Fee $40, receipt number 0313-14290651). (RUDOVSKY, DAVID)

May 13, 2020

May 13, 2020

5

ORDER THAT THE APPLICATION OF OLEVI BOYKIN TO APPEAR PRO HAC VICE IS GRANTED; ETC.. SIGNED BY HONORABLE JOSHUA D. WOLSON ON 5/14/20. 5/14/20 ENTERED AND E-MAILED, NOT MAILED TO COUNSEL ALONG WITH ECF FORMS.(JL) (Entered: 05/14/2020)

May 14, 2020

May 14, 2020

6

ORDER THAT THE APPLICATION OF CHARLES GERSTEIN TO APPEAR PRO HAC VICE IS GRANTED; ETC.. SIGNED BY HONORABLE JOSHUA D. WOLSON ON 5/14/20. 5/14/20 ENTERED AND E-MAILED, NOT MAILED TO COUNSEL ALONG WITH ECF FORMS.(JL) (Entered: 05/14/2020)

May 14, 2020

May 14, 2020

7

NOTICE of Appearance by RAYMOND MCGARRY on behalf of MONTGOMERY COUNTY with Certificate of Service(MCGARRY, RAYMOND) (Entered: 05/15/2020)

May 15, 2020

May 15, 2020

8

NOTICE of Appearance by MARY KAY BROWN on behalf of MONTGOMERY COUNTY with Certificate of Service(BROWN, MARY) (Entered: 05/15/2020)

May 15, 2020

May 15, 2020

9

NOTICE of Appearance by JAMI B. NIMEROFF on behalf of MONTGOMERY COUNTY with Certificate of Service(NIMEROFF, JAMI) (Entered: 05/15/2020)

May 15, 2020

May 15, 2020

10

MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM Defendant's Motion to Dismiss Plaintiff's Complaint Pursuant to Rules 12(b)(6) and 12(b)(1) filed by MONTGOMERY COUNTY.Memorandum of Law, Certification, Certificate of Service. (Attachments: # 1 Memorandum of Law, # 2 Exhibit A - Amicus Curiae Brief of MontCo PD in Support of Petitioners, # 3 Exhibit B - Docket Entries of Prior Amicus Briefs filed by OPD, # 4 Exhibit C - Certification of Raymond McGarry, Esquire, # 5 Text of Proposed Order)(MCGARRY, RAYMOND) (Entered: 05/18/2020)

1 Memorandum of Law

View on RECAP

2 Exhibit A - Amicus Curiae Brief of MontCo PD in Support of Petitioners

View on PACER

3 Exhibit B - Docket Entries of Prior Amicus Briefs filed by OPD

View on PACER

4 Exhibit C - Certification of Raymond McGarry, Esquire

View on PACER

5 Text of Proposed Order

View on PACER

May 18, 2020

May 18, 2020

11

ORDER THAT PLAINTIFF KEISHA HUDSON REQUEST FOR A ONE-WEEK EXTENSION OF TIME TO RESPOND TO DEFENDANT MONTGOMERY COUNTY'S MOTION TO DISMISS IS GRANTED. HUDSON RESPONSE IS DUE 6/8/20; ETC.. SIGNED BY HONORABLE JOSHUA D. WOLSON ON 5/26/20. 5/26/20 ENTERED AND E-MAILED.(JL ) (Entered: 05/26/2020)

May 26, 2020

May 26, 2020

12

RESPONSE in Opposition re 10 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM Defendant's Motion to Dismiss Plaintiff's Complaint Pursuant to Rules 12(b)(6) and 12(b)(1) filed by KEISHA HUDSON. (GERSTEIN, CHARLES) (Entered: 06/08/2020)

June 8, 2020

June 8, 2020

13

MOTION for Leave to File Reply in Further Support of Motion to Dismiss Plaintiff's Complaint Pursuant to Rules 12(b)(6) and 12(b)(1) filed by MONTGOMERY COUNTY.Certificate of Service. (Attachments: # 1 Exhibit 1 - Reply Brief, # 2 Text of Proposed Order)(MCGARRY, RAYMOND) (Entered: 06/15/2020)

June 15, 2020

June 15, 2020

14

ORDER THAT DEFENDANT'S MOTION FOR LEAVE TO FILE A REPLY IN FURTHER SUPPORT OF MOTION TO DISMISS PLAINTIFF'S COMPLAINT IS GRANTED; ETC.. SIGNED BY HONORABLE JOSHUA D. WOLSON ON 6/16/20.6/16/20 ENTERED AND E-MAILED.(JL ) (Entered: 06/16/2020)

June 16, 2020

June 16, 2020

15

DEFENDANTS REPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF ITSMOTION TO DISMISS PLAINTIFFS COMPLAINT PURSUANT TORULES 12(b)(6) and 12(b)(1) (JL) (Entered: 06/16/2020)

June 16, 2020

June 16, 2020

16

MOTION to Withdraw as Attorney filed by KEISHA HUDSON.Certificate of Service.(BOYKIN, OLEVIA) (Entered: 09/06/2020)

Sept. 6, 2020

Sept. 6, 2020

17

ORDER THAT THE 16 MOTION TO WITHDRAW AS ATTORNEY IS GRANTED AND OLEVIA BOYKIN IS GRANTED LEAVE TO WITHDRAW AS COUNSEL FOR PLAINTIFF IN THIS MATTER. SIGNED BY HONORABLE JOSHUA D. WOLSON ON 9/9/20.9/9/20 ENTERED & E-MAILED.(fdc) (Entered: 09/09/2020)

Sept. 9, 2020

Sept. 9, 2020

18

ORDER DENYING 10 DEFENDANT'S MOTION TO DISMISS, AS OUTLINED HEREIN. IT IS FURTHER ORDERED THAT, ON OR BEFORE OCTOBER 6, 2020, EACH PARTY SHALL EXPLAIN, IN A MEMORANDUM NOT TO EXCEED 10 PAGES, ITS POSITION ON WHETHER THE COURT SHOULD CONSOLIDATE THIS CASE WITH BEER v. MONTGOMERY COUNTY, ET AL., CASE NO. 2:20-CV-1486-JDW.SIGNED BY HONORABLE JOSHUA D. WOLSON ON 09/30/2020. 09/30/2020 ENTERED AND E-MAILED.(ja,) (Entered: 09/30/2020)

Sept. 30, 2020

Sept. 30, 2020

Clearinghouse
19

Statement - Position Regarding Consolidation by MONTGOMERY COUNTY. (MCGARRY, RAYMOND) (Entered: 10/06/2020)

Oct. 6, 2020

Oct. 6, 2020

REGENERATED #5,#6 (JL )

Oct. 7, 2020

Oct. 7, 2020

Remark

Oct. 7, 2020

Oct. 7, 2020

20

ORDER THAT 20-1487 AND 20-1486 ARE CONSOLIDATED UNDER THE LEAD CASE BEER VS MONTGOMERY CTY., ET AL CASE NO 20-CV-1486-JDW. THIS ORDER IS WITHOUT PREJUDICE TO ANY PARTY'S RIGHT TO SEEK SEPARATE TRIALS PURSUANT TO FED.R.CIV.P. 42 (b); ETC.. SIGNED BY HONORABLE JOSHUA D. WOLSON ON 10/8/20. 10/8/20 ENTERED AND E-MAILED.(JL ) (Entered: 10/08/2020)

Oct. 8, 2020

Oct. 8, 2020

21

ANSWER to 1 Complaint together with Affirmative Defenses by MONTGOMERY COUNTY.(MCGARRY, RAYMOND) (Entered: 10/14/2020)

Oct. 14, 2020

Oct. 14, 2020

22

ORDER THAT A TELEPHONIC PRETRIAL CONFERENCE IS SCHEDULED FOR 11/17/2020 AT 11:00 AM WITH LEAD COUNSEL FOR THE PARTIES, BEFORE HONORABLE JOSHUA D. WOLSON. FURTHER INFORMATION AND DEADLINES AS OUTLINED HEREIN. SIGNED BY HONORABLE JOSHUA D. WOLSON ON 10/27/2020. 10/27/2020 ENTERED AND E-MAILED.(ja,) (Entered: 10/27/2020)

Oct. 27, 2020

Oct. 27, 2020

23

ORDER THAT THIS CASE IS REFERRED TO MAGISTRATE JUDGE ELIZABETH T. HEY FOR PURPOSES OF CONDUCTING SETTLEMENT PROCEEDINGS, AS JUDGE HEY DEEMS APPROPRIATE. SIGNED BY HONORABLE JOSHUA D. WOLSON ON 10/28/2020. 10/28/2020 ENTERED AND E-MAILED.(ja,) (Entered: 10/28/2020)

Oct. 28, 2020

Oct. 28, 2020

24

NOTICE OF SETTLEMENT REFERRAL TO COUNSEL - MAGISTRATE JUDGE ELIZABETH T. HEY. 10/28/2020 ENTERED AND COPIES EMAILED. (miah,) (Entered: 10/28/2020)

Oct. 28, 2020

Oct. 28, 2020

25

ORDER THAT A SETTLEMENT CONFERENCE WILL BE HELD ON 12/10/20 AT 9:30 A.M. IN ROOM 3038; ETC.. SIGNED BY MAGISTRATE JUDGE ELIZABETH T. HEY ON 10/29/20. 10/29/20 ENTERED AND E-MAILED.(JL ) (Entered: 10/29/2020)

Oct. 29, 2020

Oct. 29, 2020

26

MOTION for Pro Hac Vice filed by KEISHA HUDSON..(RUDOVSKY, DAVID) (Entered: 10/30/2020)

Oct. 30, 2020

Oct. 30, 2020

27

ORDER THAT THE MOTION FOR PRO HAC VICE ADMISSION OF BINA AHMAD, ESQUORE (DOC. NO. 26 ) IS GRANTED. SIGNED BY HONORABLE JOSHUA D. WOLSON ON 11/3/20.11/3/20 ENTERED AND COPIES E-MAILED.(amas, ) (Entered: 11/03/2020)

Nov. 3, 2020

Nov. 3, 2020

28

STATUS REPORT Joint Rule 26(f) Report by MONTGOMERY COUNTY. (MCGARRY, RAYMOND) (Entered: 11/10/2020)

Nov. 10, 2020

Nov. 10, 2020

RECAP
29

ORDER THAT ALL FUTURE PLEADINGS SHALL BE FILED IN THE LEAD CASE BEER v. MONTGOMERY CO., ET AL., CASE NO. 2:20-CV-1486 AND THE CLERK OF THE COURT IS DIRECTED TO CLOSE THIS MATTER. SIGNED BY HONORABLE JOSHUA D. WOLSON ON 11/17/2020. 11/17/2020 ENTERED AND E-MAILED.(ja,) (Entered: 11/17/2020)

Nov. 17, 2020

Nov. 17, 2020

RECAP

Case Details

State / Territory:

Pennsylvania

Case Type(s):

Speech and Religious Freedom

Special Collection(s):

Multi-LexSum (in sample)

Key Dates

Filing Date: March 17, 2020

Closing Date: Feb. 2, 2021

Case Ongoing: No

Plaintiffs

Plaintiff Description:

A former Montgomery County chief public defender

Plaintiff Type(s):

Private Plaintiff

Attorney Organizations:

Civil Rights Corps

Public Interest Lawyer: Yes

Filed Pro Se: No

Class Action Sought: No

Class Action Outcome: Not sought

Defendants

Montgomery County (Montgomery), County

Case Details

Causes of Action:

42 U.S.C. § 1983

State law

Constitutional Clause(s):

Freedom of speech/association

Other Dockets:

Eastern District of Pennsylvania 2:20-cv-01487

Available Documents:

Complaint (any)

Trial Court Docket

Outcome

Prevailing Party: Plaintiff OR Mixed

Relief Granted:

Unknown

Source of Relief:

Settlement

Form of Settlement:

Voluntary Dismissal

Issues

General/Misc.:

Public benefits (includes, e.g., in-state tuition, govt. jobs)