Summary
Justice Dougherty explains that Pennsylvania Bar Admission Rule 311(g) requires applicants seeking extensions of limited licenses to show why they were unable to obtain Pennsylvania bar admission within the initial 30-month period. Although concluding that Rieko Shepherd and Meagan Hart did not establish good cause under the clarified standard, the concurrence joins the orders granting relief because the applicants lacked fair notice of the Court’s stricter enforcement approach. The statement cautions that future applicants must specifically demonstrate good cause.
Topics
Practice areas
Questions Presented
- Whether an applicant seeking an extension of a limited license under Pennsylvania Bar Admission Rule 311(g) must specifically explain why the applicant was unable to obtain admission to the Pennsylvania bar within the thirty-month period.
- Whether an applicant who failed to make that showing should nevertheless receive an extension because the Court's more rigorous enforcement of Rule 311(g) had not yet been officially published when the application was filed.
Key quotations
“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.”” ([24 WM 2025] - 2)
“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 by Rule 311.” ([24 WM 2025] - 2)
Factual background
Shepherd sought an extension of a limited Pennsylvania law license governed by Pennsylvania Bar Admission Rule 311(g), which generally expires after thirty months unless the Court finds good cause for an extension. According to the concurring statement, Shepherd failed to specify why she was unable to obtain admission to the Pennsylvania bar within that period. She filed her application nine days after reconsideration was granted in In the Matter of: Taylor de Laveaga, but that decision apparently had not yet been officially published, and Shepherd did not share the same employer as the applicants in that matter.
Procedural history
Shepherd moved for an extension of her limited license. The Supreme Court of Pennsylvania granted the requested extension, and Justice Dougherty joined the Court's order while explaining that Shepherd had not shown the good cause required by Rule 311(g). Justice Dougherty concluded that relief was appropriate because the Court's course correction concerning enforcement of the rule had not yet been officially published when Shepherd filed her application.