Case: Beer v. Montgomery County

2:20-cv-01486 | 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 county chief public defender following the filing of an amicus curiae brief critical of Montgomery County’s cash bail system. In March 2020, Dean Beer, the former Chief Public Defender of Montgomery County, filed suit against Montgomery County and county officials in the U.S. District Court for the Eastern District of Pennsylvania. Beer alleged that he was terminated in retaliation for protected speech in violation of…

This is a case about alleged wrongful retaliation and wrongful discharge of a county chief public defender following the filing of an amicus curiae brief critical of Montgomery County’s cash bail system.

In March 2020, Dean Beer, the former Chief Public Defender of Montgomery County, filed suit against Montgomery County and county officials in the U.S. District Court for the Eastern District of Pennsylvania. Beer alleged that he was terminated in retaliation for protected speech in violation of the First Amendment under 42 U.S.C. § 1983, in violation of the Pennsylvania Whistleblower Law, and for wrongful discharge in violation of Pennsylvania public policy. He sought preliminary and permanent injunctive relief restoring him to his position as Chief Public Defender with just-cause employment protections, compensatory damages for economic, emotional, and reputational harm, punitive damages, and attorneys’ fees and costs.

As Chief Public Defender from 2016 to 2020, Beer had institutional responsibility for overseeing the Office of the Public Defender and ensuring compliance with constitutional and professional obligations. During his tenure, he raised concerns about the impact of cash bail on indigent defendants and Montgomery County’s failure to provide counsel at preliminary arraignments where bail was set.

The challenged speech arose in the context of statewide litigation concerning bail practices. In March 2019, the Philadelphia Community Bail Fund and other plaintiffs filed a class action mandamus petition in the Supreme Court of Pennsylvania alleging unconstitutional cash bail practices (Philadelphia Community Bail Fund v. First Judicial District Arraignment Magistrates). In July 2019, the Pennsylvania Supreme Court invoked its King’s Bench jurisdiction to review the operation of the cash bail system. In February 2020, Beer directed the filing of an amicus curiae brief on behalf of the Montgomery County Office of the Public Defender in that proceeding. The brief detailed systemic bail practices in Montgomery County, provided examples of indigent defendants harmed by those practices, and proposed safeguards to ensure constitutional compliance statewide.

Beer alleged that shortly after the amicus brief was filed, county officials and judicial officers expressed opposition to the filing and pressured him to withdraw it. On February 26, 2020, Beer was terminated from his position. He alleged that his termination was directly motivated by the filing of the amicus brief and constituted unlawful retaliation for speech and whistleblowing activity on matters of public concern.

On May 21, 2020, Montgomery County and the named county officials moved to dismiss the complaint. Defendants argued that the filing of the amicus curiae brief was not protected by the First Amendment because it was undertaken in Beer’s official capacity as Chief Public Defender, on behalf of the Montgomery County Office of the Public Defender, and therefore did not constitute citizen speech. Defendants further contended that the filing of an amicus brief did not qualify as protected activity under the Pennsylvania Whistleblower Law, as it was not a report of wrongdoing to an appropriate authority. Finally, Defendants asserted that they were immune from liability for the claim of wrongful discharge in violation of public policy and that the claim otherwise failed to state a viable cause of action under Pennsylvania law.

On September 30, 2020, the district court granted in part and denied in part the defendants’ motion to dismiss. The court dismissed the Pennsylvania Whistleblower Law claim, concluding that the characteristics of the case placed it outside the statute’s scope. The court allowed the First Amendment retaliation claim to proceed, holding that Beer had standing and that it was plausible at the pleading stage that the filing of the amicus curiae brief constituted citizen speech, rather than speech made pursuant to his ordinary job responsibilities. The court also allowed the wrongful discharge claim to proceed against the County, but dismissed the First Amendment and wrongful discharge claims against the individual defendants in their individual capacities, holding that the County Commissioners and the Chief Operating Officer were high public officials entitled to immunity. The court also directed the parties to address whether the case should be consolidated with Hudson v. Montgomery County.

On October 8, 2020, the district court consolidated this case with Hudson 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

Augusto Colín (1/11/2026)

Related Cases

Philadelphia Community Bail Fund v. First Judicial District Arraignment Magistrates, Pennsylvania state supreme court (2019)

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

People

For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/16995640/parties/beer-v-montgomery-county/


Judge(s)
Attorney for Plaintiff

AHMAD, BINA (Pennsylvania)

GERSTEIN, CHARLES L. (Pennsylvania)

Attorney for Defendant

BROWN, MARY KAY (Pennsylvania)

MCGARRY, RAYMOND (Pennsylvania)

NIMEROFF, JAMI B. (Pennsylvania)

show all people

Documents in the Clearinghouse

Document
1

2:20-cv-01486

Complaint

March 17, 2020

March 17, 2020

Complaint
16

2:20-cv-01486

Order

Sept. 30, 2020

Sept. 30, 2020

Order/Opinion
34

2:20-cv-01486

Order

Feb. 2, 2021

Feb. 2, 2021

Order/Opinion

Docket

See docket on RECAP: https://www.courtlistener.com/docket/16995640/beer-v-montgomery-county/

Last updated Jan. 11, 2026, 6:12 p.m.

ECF Number Description Date Link Date / Link
1

COMPLAINT against VALARIE ARKOOSH, JOSEPH C. GALE, KENNETH LAWRENCE, JR, MONTGOMERY COUNTY, LEE SOLTYSIAK ( Filing fee $ 400 receipt number PPE213129.)filed by DEAN BEER. (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 DEAN BEER. (tjd)

March 17, 2020

March 17, 2020

Summons Issued

March 20, 2020

March 20, 2020

Jury Demand

March 20, 2020

March 20, 2020

5 Summons Issued as to VALARIE ARKOOSH, JOSEPH C. GALE, KENNETH LAWRENCE, JR, MONTGOMERY COUNTY, LEE SOLTYSIAK. Forwarded To: COUNSEL on 3/20/2020. (tjd)

March 20, 2020

March 20, 2020

2

WAIVER OF SERVICE Returned Executed by DEAN BEER. All Defendants. (PIERCE, PATRICIA) (Entered: 03/24/2020)

March 24, 2020

March 24, 2020

3

ORDER THAT DEFENDANTS' REQUEST TO EXCEED PAGE LIMIT IS GRANTED. IT IS FURTHER ORDERED THAT PLAINTIFF MAY FILE A 30-PAGE OPPOSITION IN RESPONSE TO DEFENDANTS' MOTION TO DISMISS.. SIGNED BY HONORABLE JOSHUA D. WOLSON ON 5/14/20. 5/15/20 ENTERED AND COPIES NOT MAILED TO UNREPS AND E-MAILED.(mbh, ) (Entered: 05/15/2020)

May 15, 2020

May 15, 2020

4

NOTICE of Appearance by RAYMOND MCGARRY on behalf of VALARIE ARKOOSH, JOSEPH C. GALE, KENNETH LAWRENCE, JR, MONTGOMERY COUNTY, LEE SOLTYSIAK with Certificate of Service(MCGARRY, RAYMOND) (Entered: 05/15/2020)

May 15, 2020

May 15, 2020

5

NOTICE of Appearance by MARY KAY BROWN on behalf of VALARIE ARKOOSH, JOSEPH C. GALE, KENNETH LAWRENCE, JR, MONTGOMERY COUNTY, LEE SOLTYSIAK with Certificate of Service(BROWN, MARY) (Entered: 05/15/2020)

May 15, 2020

May 15, 2020

6

NOTICE of Appearance by JAMI B. NIMEROFF on behalf of VALARIE ARKOOSH, JOSEPH C. GALE, KENNETH LAWRENCE, JR, MONTGOMERY COUNTY, LEE SOLTYSIAK with Certificate of Service(NIMEROFF, JAMI) (Entered: 05/15/2020)

May 15, 2020

May 15, 2020

7

ORDER THAT DEFENDANTS SHALL. HAVE UNTIL 6/15/20 TO FILE AN ANSWER OR OTHERWISE RESPOND TO PLAINTIFF'S COMPLAINT. SIGNED BY HONORABLE JOSHUA D. WOLSON ON 5/21/20. 5/21/20 ENTERED AND COPIES E-MAILED.(mbh, )(VACATED PER ORDER # 8 ) Modified on 5/21/2020 (nd, ). (Entered: 05/21/2020)

May 21, 2020

May 21, 2020

8

ORDER THAT THE COURT'S ORDER DATED 05/21/2020 (ECF 7 ) IS VACATED. SIGNED BY HONORABLE JOSHUA D. WOLSON ON 05/21/2020. 05/21/2020 ENTERED AND COPIES E-MAILED.(nd, ) Modified on 5/21/2020 (ja, ). (Entered: 05/21/2020)

May 21, 2020

May 21, 2020

9

MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM Defendants' Motion to Dismiss Plaintiff's Complaint Pursuant to Rules 12(b)(6) and 12(b)(1) filed by VALARIE ARKOOSH, JOSEPH C. GALE, KENNETH LAWRENCE, JR, MONTGOMERY COUNTY, LEE SOLTYSIAK.Memorandum, Attorney 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 Certification of Raymond McGarry, Esquire, # 5 Text of Proposed Order)(MCGARRY, RAYMOND) (Entered: 05/21/2020)

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 Certification of Raymond McGarry, Esquire

View on PACER

5 Text of Proposed Order

View on PACER

May 21, 2020

May 21, 2020

RECAP
10

ORDER THAT PLAINTIFF SHALL HAVE UNTIL 6/15/2020 TO FILE A RESPONSE TO DEFENDANTS' MOTION TO DISMISS. SIGNED BY HONORABLE JOSHUA D. WOLSON ON 5/26/20. 5/26/20 ENTERED AND COPIES E-MAILED.(mbh, ) (Entered: 05/26/2020)

May 26, 2020

May 26, 2020

11

RESPONSE to Motion re 9 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM Defendants' Motion to Dismiss Plaintiff's Complaint Pursuant to Rules 12(b)(6) and 12(b)(1) filed by DEAN BEER. (Attachments: # 1 Certificate of Service Certificate of Service)(PIERCE, PATRICIA) (Entered: 06/15/2020)

June 15, 2020

June 15, 2020

12

EXHIBIT A & B to Plaintiff's Brief in Opposition to Defendants' Motion to Dismiss by DEAN BEER.. (Attachments: # 1 Exhibit)(PIERCE, PATRICIA) (Entered: 06/16/2020)

June 16, 2020

June 16, 2020

13

MOTION for Leave to File 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 VALARIE ARKOOSH, JOSEPH C. GALE, KENNETH LAWRENCE, JR, MONTGOMERY COUNTY, LEE SOLTYSIAK.Certificate of Service. (Attachments: # 1 Exhibit 1 - Proposed Reply Brief, # 2 Text of Proposed Order)(MCGARRY, RAYMOND) (Entered: 06/22/2020)

June 22, 2020

June 22, 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. IT IS FURTHER ORDERED THAT THE REPLY ATTACHED AS EXHIBIT 1 TO THE MOTION IS DEEMED FILED AS OF TODAY'S DATE. SIGNED BY HONORABLE JOSHUA D. WOLSON ON 6/23/20.6/24/20 ENTERED AND COPIES E-MAILED.(mbh, ) (Entered: 06/24/2020)

June 24, 2020

June 24, 2020

15

Defendant's Reply Memorandum of Law in Further Support of their Motion to Dismiss Plaintiff's Complaint Pursuant to Rules 12(b)(6) and 12(B)(1) (mbh, ). (Entered: 06/24/2020)

June 24, 2020

June 24, 2020

16

ORDER GRANTING IN PART AND DENYING IN PART 9 DEFENDANTS' MOTION TO DISISS FOR FAILURE TO STATE A CLAIM. COUNT II OF THE COMPLAINT IS DISMISSED. IN ADDITION, COUNTS I AND III ARE DISMISSED AGAINST DR. ARKOOSH, MR. LAWRENCE, MR. GALE, AND MR. SOLTYSIAK TO THE EXTENT THOSE CLAIMS ARE ASSERTED AGAINST THEM IN THEIR INDIVIDUAL CAPACITIES. THE MOTION IS OTHERWISE DENIED. IT IS FURTHER ORDERED THAT, ON OR BEFORE OCTOBER 7, 2020, EACH PARTY SHALL EXPLAIN, IN A MEMORANDUM NOT TO EXCEED 10 PAGES, ITS POSITION ON WHETHER THE COURT SHOULD CONSOLIDATE THIS CASE WITH HUDSON v. MONTGOMERY COUNTY, CASE NO. 2:20-CV-1487-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
17

Statement - Position Regarding Consolidation by VALARIE ARKOOSH, JOSEPH C. GALE, KENNETH LAWRENCE, JR, MONTGOMERY COUNTY, LEE SOLTYSIAK. (MCGARRY, RAYMOND) (Entered: 10/06/2020)

Oct. 6, 2020

Oct. 6, 2020

18

ORDER THAT C.A. NOS 20-1486 AND 20-1487 ARE CONSOLIDATED UNDER THE CASE 20-1486. THIS ORDER IS WITHOUT PREJUDICE TO ANY PARTY'S RIGHT TO SEEK SEPARATE TRIALS PURSUANT TO FRCP 42(b). SIGNED BY HONORABLE JOSHUA D. WOLSON ON 10/8/20. 10/8/20 ENTERED AND COPIES E-MAILED.(mbh, ) (Entered: 10/08/2020)

Oct. 8, 2020

Oct. 8, 2020

19

ANSWER to 1 Complaint together with Affirmative Defenses by VALARIE ARKOOSH, JOSEPH C. GALE, KENNETH LAWRENCE, JR, MONTGOMERY COUNTY, LEE SOLTYSIAK.(MCGARRY, RAYMOND) (Entered: 10/14/2020)

Oct. 14, 2020

Oct. 14, 2020

20

Response - Answer to Plaintiff Keisha Hudson's Complaint with Affirmative Defenses by MONTGOMERY COUNTY. (MCGARRY, RAYMOND) (Entered: 10/14/2020)

Oct. 14, 2020

Oct. 14, 2020

21

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

22

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

23

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

24

ORDER THAT A SETTLEMENT CONFERENCE WILL HELD ON 12/10/2020 AT 9:30 AM IN CHAMBERS BEFORE MAGISTRATE JUDGE ELIZABETH T. HEY. SIGNED BY MAGISTRATE JUDGE ELIZABETH T. HEY ON 10/29/20. 10/29/20 ENTERED AND COPIES E-MAILED.(mbh, ) (Entered: 10/29/2020)

Oct. 29, 2020

Oct. 29, 2020

25

STATUS REPORT Joint Rule 26(f) Report by VALARIE ARKOOSH, JOSEPH C. GALE, KENNETH LAWRENCE, JR, MONTGOMERY COUNTY, LEE SOLTYSIAK. (MCGARRY, RAYMOND) (Entered: 11/10/2020)

Nov. 10, 2020

Nov. 10, 2020

RECAP
26

Minute Entry for proceedings held before HONORABLE JOSHUA D. WOLSON Telephonic Pretrial Conference held on 11/17/20 (mbh, ) (Entered: 11/17/2020)

Nov. 17, 2020

Nov. 17, 2020

27

SCHEDULING ORDER: ALL MOTIONS TO AMEND THE COMPLAINT AND TO JOIN OR ADD ADDITIONAL PARTIES SHALL BE FILED BY 01/17/2021; THE PARTIES SHALL COMPLETE ALL DISCOVERY BY 5/17/2021; MOTIONS FOR SUMMARY JUDGMENT SHALL BE FILED BY 6/18/2021. FURTHER INFORMATION AND DEADLINES AS OUTLINED HEREIN. 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

28

Minute Entry for proceedings held before MAGISTRATE JUDGE ELIZABETH T. HEY Settlement Conference held on 12/10/20. (mbh, ) (Entered: 12/10/2020)

Dec. 10, 2020

Dec. 10, 2020

29

ORDER THAT A TELEPHONIC SETTLEMENT STATUS CONFERENCE SET FOR 1/28/2021 AT 4:00 PM BEFORE MAGISTRATE JUDGE ELIZABETH T. HEY. SIGNED BY MAGISTRATE JUDGE ELIZABETH T. HEY ON 12/14/20. 12/14/20 ENTERED AND COPIES E-MAILED.(mbh, ) (Entered: 12/14/2020)

Dec. 14, 2020

Dec. 14, 2020

30

STIPULATION of Dismissal with Prejudice of Hudson Action Only by MONTGOMERY COUNTY. (MCGARRY, RAYMOND) (Entered: 12/28/2020)

Dec. 28, 2020

Dec. 28, 2020

31

ORDER THAT THE TELEPHONIC SETTLEMENT STATUS CONFERENCE SCHEDULED FOR 1/28/21 AT 4:00 PM IS CANCELLED. SIGNED BY MAGISTRATE JUDGE ELIZABETH T. HEY ON 1/25/21. 1/26/21 ENTERED AND COPIES E-MAILED.(mbh, ) (Entered: 01/26/2021)

Jan. 26, 2021

Jan. 26, 2021

RECAP
32

ORDER THAT A SUPPLEMENTAL SETTLEMENT CONFERENCE WILL BE HELD ON 2/2/2021 AT 9:30 AM IN CHAMBERS BEFORE MAGISTRATE JUDGE ELIZABETH T. HEY. SIGNED BY MAGISTRATE JUDGE ELIZABETH T. HEY ON 1/26/21. 1/26/21 ENTERED AND COPIES E-MAILED.(mbh, ) (Entered: 01/26/2021)

Jan. 26, 2021

Jan. 26, 2021

RECAP
33

Settlement Conference

Feb. 2, 2021

Feb. 2, 2021

34

Order Dismissing Case - 41(b)

Feb. 2, 2021

Feb. 2, 2021

Clearinghouse

Case Details

State / Territory:

Pennsylvania

Case Type(s):

Speech and Religious Freedom

Key Dates

Filing Date: March 17, 2020

Closing Date: Feb. 2, 2021

Case Ongoing: No

Plaintiffs

Plaintiff Description:

former Chief Public Defender of Montgomery County

Plaintiff Type(s):

Private Plaintiff

Public Interest Lawyer: No

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-01486

Available Documents:

Any published opinion

Complaint (any)

Trial Court Docket

Outcome

Prevailing Party: Plaintiff OR Mixed

Relief Sought:

Attorneys fees

Damages

Injunction

Relief Granted:

Unknown

Source of Relief:

Settlement

Form of Settlement:

Court Approved Settlement or Consent Decree

Issues

General/Misc.:

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

Presidential/Gubernatorial Authority:

Appointment Authority