J.A. Wright v. Lower Salford Twp. Municipal Police Pension Fund

136 A.3d 1085, 2016 WL 1301277, 2016 Pa. Commw. LEXIS 161
CourtCommonwealth Court of Pennsylvania
DecidedApril 1, 2016
Docket1343 C.D. 2015
StatusPublished
Cited by10 cases

This text of 136 A.3d 1085 (J.A. Wright v. Lower Salford Twp. Municipal Police Pension Fund) is published on Counsel Stack Legal Research, covering Commonwealth Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
J.A. Wright v. Lower Salford Twp. Municipal Police Pension Fund, 136 A.3d 1085, 2016 WL 1301277, 2016 Pa. Commw. LEXIS 161 (Pa. Ct. App. 2016).

Opinion

OPINION BY

Judge PATRICIA A. McCullough.

This case returns to us following our remand for further proceedings in Wright v. Lower Salford Township, (Pa.Cmwlth., No. 788 C.D. 2012, 2013 WL 3156614, filed June 19, 2013) (unreported) (“Wright I”). Jeffery A. Wright (Wright) appeals from the June 24, 2015 order of the Court of Common Pleas of Montgomery County (trial court) entering judgment in favor of the Lower Salford Township Municipal Police Pension Fund, the Lower Salford Township Board of Supervisors (Board), and the Lower Salford Township Municipal Police Pension Fund Trustees (together, Township Defendants) on his claim seeking a disability pension. 1

Facts/Procedural History

As recounted in Wright I, this Court set forth the factual and procedural history of this case as follows. On January 23, 1996, Sergeant Wright sustained a knee injury while working as a police officer for the Lower Salford Police Department. Following knee surgery, Wright returned to duty at various times, sometimes at full-duty capacity and sometimes at light-duty capacity. Despite his efforts to continue working as a patrol sergeant, Wright eventually became unable to perform his job duties. At a public meeting on May 16, 2002, the Board unanimously voted to honorably discharge Wright from the police department. Wright I, slip op. at 2.

On April 17, 2002, one month before Wright’s honorable discharge, the General Assembly amended the Municipal Police Pension Law, Act of May 29, 1956, P.L. (1955) 1804, as amended, 53 P.S. §§ 767-778, commonly known as Act 600. The 2002 amendment, commonly known as Act 30, 2 added a mandatory disability pension for permanent service-connected injuries, as follows:

In the case of the payment of pensions for permanent injuries incurred in service, the amount and commencement of the payments shall be fixed by regulations of the governing body of the borough, town, township or regional police department and shall be calculated at a rate no less than fifty per centum of the member’s salary at the time the disability was incurred, provided that any member who receives benefits for the same injuries under the Social Security Act ... shall have his disability benefits off *1087 set or reduced by the amount of such benefits.

Section 5(e)(1) of Act 600, 53 P.S. § 771(e)(1). “Before the enactment of Act 30, municipalities were not required to pay police officers a disability pension; Act 30 amended Act 600 to create such an obligation.” Wright I, slip op. at 2-3.

On January 6, 2003, eight months after Wright’s honorable discharge, the Board amended the Lower Salford Code by adopting Ordinance 2003-2 (Ordinance), which incorporated Act 30’s requirements. The Ordinance states:

In the case of the payment of pensions for permanent injuries incurred on or after April 17, 2002, the amount of the payments shall be calculated at the rate of 50% of the member’s salary at the time the disability was incurred, provided that any member who receives benefits for the same injuries under the Social Security Act ... shall have his or her disability benefits offset or reduced by the amount of such benefits. Determination of eligibility of disability benefits shall be based on the eligibility of benefits payable for permanent injuries incurred in service under the Township’s long-term disability policy and shall be payable commencing at the later of termination of benefits under the long-term disability policy as a result of attaining the maximum age under the disability policy or upon the officer’s attainment of his superannuation retirement date.

(Lower Salford Code § 29 — 3(B)) (emphasis added).

In May 2006, Wright filed suit against the Township Defendants, seeking a disability pension calculated at 50% of his former salary, retroactive to May 16, 2002. The Township Defendants timely filed an answer and new matter. After the close of the pleadings, the Township Defendants moved for judgment on the pleadings. Wright I, slip op. at 3-4.

On April 4, 2012, the trial court granted the Township Defendants’ motion. The trial court determined that Act 30 was not self-executing because its. plain language mandated further legislative action by the local governing body. The trial court further determined that the Board did not adopt Act 30’s provisions until January 2003, well after Wright’s honorable discharge. Therefore, the trial court concluded that the Township Defendants were not obligated to pay Wright a disability pension. Wright filed a timely appeal to this Court. Wright I, slip op. at 4.

On appeal, this Court in Wright I concluded that material issues of fact existed that precluded the entry of judgment on the pleadings. We held:

The trial court determined that Act 30 did not apply to the Township Defendants until the Board adopted the Ordinance incorporating Act 30’s requirements in January 2003, which post-dated Wright’s discharge. However, the Ordinance states that it applies to “payment of pensions for permanent injuries incurred on or after April 17, 2002.” (Lower Salford Code § 29 — 3(B)) (emphasis added.) Therefore, regardless of whether Act 30 was self-executing, the text of the Ordinance suggests that it applies retroactively to permanent injuries incurred “on or after” Act 30’s effective date. The trial court, however, did not address this issue.
There is also a disputed factual issue regarding the date of Wright’s “permanent” injury. Wright claims that although his initial knee injury occurred in 1996, his injury did not become permanent until May 16, 2002. According to Wright, the Board’s vote to honorably discharge him was the first official determination that he was permanently *1088 disabled and could no longer work. The Township Defendants claim that the date of Wright’s only service-connected injury was January 23, 1996, and his last day of work was March 12, 2002. Both of these events pre-dated Act 30 and the Ordinance. Again, the trial court did not address this issue.
We conclude that the foregoing factual issues are material to the determination of whether Wright is entitled to the disability pension he seeks. Therefore, the trial court erred in granting the Township Defendants’ motion.

Wright I, slip op. at 4-5 (footnotes and citation omitted).

On these grounds, this Court in Wright I reversed the trial court’s order, reinstated Wright’s complaint, and remanded the matter to the trial court for further proceedings.

On March 11, 2014, the trial court held a remand hearing on the limited issue set forth by this Court in Wright I, specifically whether Wright incurred a permanent injury on or after April 17, 2002. Based on the evidence presented, namely Wright’s testimony and documentary evidence, the trial court made the following findings of fact.

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Cite This Page — Counsel Stack

Bluebook (online)
136 A.3d 1085, 2016 WL 1301277, 2016 Pa. Commw. LEXIS 161, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ja-wright-v-lower-salford-twp-municipal-police-pension-fund-pacommwct-2016.