In the Matter of: Meagan Hart
Supreme Court of Pennsylvania
Dougherty, Kevin M.
In the Matter of: Meagan Hart
Opinion
IN THE SUPREME COURT OF PENNSYLVANIA
WESTERN DISTRICT
IN THE MATTER OF: MEAGAN HART, : No. 14 WM 2025
ESQUIRE MOTION FOR EXTENSION :
PURSUANT TO RULE 311(G) :
CONCURRING STATEMENT
JUSTICE DOUGHERTY
As I recently explained, “[f]or too long, this Court has been too lax in its treatment
of requests by out-of-state attorneys for extensions of limited licenses issued under
Pennsylvania Bar Admission Rule 311.1 The Rule’s mandate is clear: ‘Admission to
practice under this rule shall expire after 30 months, unless the Court for good cause
shown shall extend such period in an individual case.’ Pa.B.A.R. 311(g) (emphasis
added).” In the Matter of: Taylor de Laveaga, 5 WM 2025, at 1 (Pa. Mar. 17, 2025)
(Dougherty, J., concurring statement). The “good cause shown” language in Rule 311(g)
necessarily requires “an applicant [to] specify why the attorney was unable to obtain
admission to the Pennsylvania bar in the normal course within the thirty months afforded
by Rule 311.” Id. (internal quotations and citation omitted).
Having provided that long-overdue clarification, which was endorsed by a majority
of the Court,2 I cautioned future applicants that, “moving forward, [they] are now on fair
1 See Pa.B.A.R. 311(a) (authorizing limited license for admission to practice law for “an
attorney who is not a member of the bar of this Commonwealth but is qualified to practice
in the courts of another state and who is employed by or associated with an organized
legal services program in this Commonwealth providing legal assistance to indigents in
civil matters or a public defender’s office or defender association in this Commonwealth
providing legal assistance to indigents in criminal matters”).
2 Justices Mundy and Brobson joined my concurring statement, which adopted Justice
Wecht’s position that “[a] ‘good cause’ showing . . . must specify why the attorney was
(continued…)
notice that this Court has course-corrected and intends to enforce Rule 311(g)’s ‘good
cause shown’ requirement. Future failures to demonstrate ‘good cause’ will not be
excused based on this Court’s past practice.” Id. at 2.
Today the Court grants extensions of limited licenses to applicants Hart and
Shepherd, see In the Matter of: Rieko Shepherd, 24 WM 2025, even though both utterly
failed to show good cause. I join the Court’s orders for two idiosyncratic reasons. First,
applicant Hart filed her extension request nearly one month before I issued my concurring
statement in de Laveaga. Thus, although she is employed by the same organization as
applicant de Laveaga and presumably learned about it later, she was not “on fair notice”
of our course correction at the time she filed her application. Second, although applicant
Shepherd filed her application nine days after we granted reconsideration in de Laveaga,
it appears that decision has yet to be officially published. Moreover, she does not share
the same employer as applicants de Laveaga and Hart. Given these circumstances, “I
do not believe th[ese] individual applicant[s] should bear the consequences of this Court’s
abrupt shift to more rigorous enforcement of Rule 311.” Id.
To be perfectly clear, however, as I see it, once this matter is published, future
applicants will finally be “on fair notice that this Court has course-corrected and intends
to enforce Rule 311(g)’s ‘good cause shown’ requirement.” Id. This means that to obtain
relief, an applicant from that date forward must specify why he or she was unable to obtain
admission to the Pennsylvania bar in the normal course within the thirty months afforded
unable to obtain admission to the Pennsylvania bar in the normal course within the thirty
months afforded by Rule 311.” In the Matter of: Taylor de Laveaga, 5 WM 2025, at 1-2
(Pa. Mar. 17, 2025) (Wecht, J., dissenting statement); see id. at 1 (“a subsequent ‘good
cause’ showing for extension cannot merely repeat the previously-made averment that
this is the public interest work the attorney is doing”).
[14 WM 2025] - 2
by Rule 311.3 Failure to meet this standard “will not be excused based on this Court’s
past practice.” Id. (emphasis added).
Justices Donohue, Mundy, Brobson and McCaffery join this concurring statement.
3 I recognize there may be others whose temporary licenses are set to expire between
the period when this decision issues and the results of the next available Pennsylvania
Bar Exam (in February 2026) become available. In my view, any such applicants would
be similarly situated to the present applicants and thus entitled to similar relief.
[14 WM 2025] - 3
Reference
- Status
- Published