BELDING v. RUSSO

CourtDistrict Court, W.D. Pennsylvania
DecidedApril 15, 2025
Docket2:23-cv-02148
StatusUnknown

This text of BELDING v. RUSSO (BELDING v. RUSSO) is published on Counsel Stack Legal Research, covering District Court, W.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
BELDING v. RUSSO, (W.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA PITTSBURGH

MICHAEL BELDING, ) )

) 2:23-CV-02148-MJH Plaintiff, )

) vs. )

) DAVID RUSSO, SUED IN HIS OFFICIAL ) AND INDIVIDUAL CAPACITIES; ) ZACHARY SAMS, SUED IN HIS INDIVIDUAL CAPACITY; AND GREEN COUNTY, PENNSYLVANIA,

Defendants,

MEMORANDUM OPINION On December 21, 2023, Plaintiff, Michael Belding, filed suit against Defendants, David Russo, former District Attorney for Greene County, Pennsylvania; Zachary Sams, former Chief Detective for Greene County; and Green County, itself. (ECF No. 1). On February 26, 2024, Defendant, Greene County, moved to dismiss Counts Eight and Nine of the Complaint. (ECF No. 12). On August 2, 2024, this Court granted Defendant Greene County’s Motion to Dismiss. (ECF No. 29). On August 16, 2024, Plaintiff filed a ten count Amended Complaint, alleging violations of his rights under the First and Fourteenth Amendment. (ECF No. 32). On August 30, 2024, Defendant Greene County filed its Motion to Dismiss all claims and counts against it, (ECF No. 33), and an accompanying brief. (ECF No. 34). On September 13, 2024, Plaintiff filed his Brief in Opposition to Defendant Greene County’s Motion to Dismiss. (ECF No. 38). Greene County did not file a Reply. All issues have been briefed and are ripe for decision. For the reasons below, Greene County’s Motion to Dismiss will be denied. I. Statement of Facts In 2019, Plaintiff, Michael Belding, was elected to the Greene County Board of

Commissioners (“the Board”). (ECF No. 32, at ¶ 25). On January 6, 2020, David Russo was sworn in as the District Attorney for Greene County. (Id. ¶ 28). Mr. Belding alleges that, from the beginning of his tenure, Mr. Russo conflicted with county elected officials and employees, refused to pursue Board-requested investigations, and maintained an unprofessional relationship with Greene County’s Victim Witness Coordinator (“VWC”). (Id. ¶¶ 30-43). In late October 2021, the VWC resigned her County position. (Id. ¶ 43). Following her

resignation, the Board transferred oversight and management of the VWC position from the District Attorney’s Office to the County Commissioners’ Office. (Id. ¶ 45). The Board voted to appoint a member of their staff, Sarah Smith, to oversee the VWC program. (Id. ¶ 51). When asked why control of the VWC was being transferred, Mr. Belding told the press that the “transition was necessary because the District Attorney’s Office had been unable to keep [the] important position adequately staffed.” (Id. ¶ 54). Mr. Russo opposed Ms. Smith’s appointment. Mr. Russo sent the Board various cease-and-desist letters, which were published by the media. Mr. Belding also alleges that, on January 26, 2022, Mr. Russo informed reporters that he was launching a criminal investigation into the alleged “illegal hiring” of Ms. Smith. (Id. ¶¶ 52-57). Mr. Belding alleges that Mr. Russo instructed Zachary Sams, his Chief Detective, to investigate

Mr. Belding and the Board for the hiring of Ms. Smith. (Id. ¶¶ 58-60). Mr. Belding alleges that this investigation was conducted in retaliation for the public statements Mr. Belding made about the VWC position. (Id. ¶ 60). In the Fall of 2022, Mr. Russo announced his intention to form a special weapons and tactics (“SWAT”) unit under the Greene County District Attorney’s Office. (Id. ¶ 72). On September 2, 2022, the Board requested that Mr. Russo explain the operation, organizational structure, and procedures of the new SWAT unit. (Id. ¶ 73). Mr. Russo did not respond to such requests. (Id. ¶ 74). The Board sent two more letters to Mr. Russo, attempting to obtain a response and more information from Mr. Russo about the SWAT unit. Mr. Russo allegedly did not answer any of the Board’s requests. (Id. ¶¶ 77-81). On January 3, 2023, an editorial opinion, criticizing Mr.

Russo’s implementation and creation of the SWAT unit, was authored by Mr. Belding and published in the Observer Reporter, a newspaper in Pittsburgh, Pennsylvania. (Id. ¶¶ 81-83). Mr. Belding claims that his editorial opinion statements were made as a citizen on a matter of public concern. (Id. ¶ 82). Mr. Belding alleges that, two days after the Observer Reporter publication, Mr. Russo made statements to the press that two individuals were being charged with forging court orders, and

that one of the accused individuals was a former employee of Mr. Belding. (Id. ¶¶ 85-86). Mr. Belding alleges that Mr. Russo continued commenting to the press, stating that six other individuals employed by Mr. Belding had been arrested for crimes. (Id. ¶ 87). Mr. Belding claims that none of the individuals identified by Mr. Russo ever worked for Mr. Belding. (Id. ¶ 89). In fact, under Greene County’s organizational structure, no one works for a specific Commissioner, only the County itself. (Id.). Mr. Belding further alleges that Mr. Russo made these media statements in retaliation for Mr. Belding’s published Observer Reporter editorial opinion. (Id. ¶ 90-91).

In 2022, Greene County’s Office of the Controller audited the Greene County District Attorney’s §§ 5801 and 5803(a) Forfeiture Accounts. (Id. ¶ 99). Mr. Belding alleges that the results of the audit revealed that Mr. Russo had improperly utilized funds to buy gear for his SWAT unit, and that, at least twice, Mr. Russo had violated the Asset Forfeiture Statute related to handling and accounting for asset forfeitures. (Id. ¶¶ 100-101). On September 30, 2022, the Office of the Controller reported their findings to the Pennsylvania Office of the Attorney General. (Id. ¶ 101). On January 17, 2023, the chairman of the Greene County Republican committee filed a right-to-know request for the audit, which resulted in the release of several pages from the audit. (Id. ¶ 103). On February 18, 2023, Mr. Belding posted portions of the audit

on his personal Facebook page. (Id. ¶ 104). On March 2, 2023, Detective Sams sent a “Preservation Request” to the Green County Information Technology Director, instructing them to preserve certain emails and other electronic communications. The request indicated that such preservation related to the release of confidential information. (Id. ¶ 105). Mr. Belding claims that Greene County officials considered the preservation demand to be an investigation into the release of the County’s audit of the Office of the District Attorney, and that

Mr. Russo directed Detective Sams to begin said investigation. (Id. ¶¶ 107-108). On March 7, 2023, County Solicitor, Eugene Grimm, filed an action for declaratory judgment related to the investigation against County officials, asserting the investigation was politically motivated and a conflict of interest. (Id. ¶ 110). Mr. Belding signed the Verification for the Declaratory Judgment Action. Id. ¶ 111. On March 11, 2023, Mr. Russo issued a written statement to the media stating: To say I am furious beyond measure with Mike Belding and his cronies’ fabricated allegations would be an understatement. . . . Belding has surreptitiously and libelously used sensitive government documents in order to attempt to slander my name. . . . Belding and his cronies can be sure that this will be answered aggressively and swiftly and lawsuits will be filed against Belding regarding his action and behavior.

(Id. ¶ 112). On March 15, 2023, Greene County’s Office of Registration and Elections conducted a casting-of-lots to determine the order for listing candidates on the election ballot for the county election. (Id. ¶ 113). This casting-of-lots was not properly advertised in two newspapers, as required by 25 Pa. Stat. § 2875, which resulted in a challenge to the original casting-of-lots. (Id. ¶ 114). A recasting of the lots was rescheduled for March 23, 2023. (Id. ¶ 116). Mr.

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