Keith Isaac

CourtSupreme Court of New Jersey
DecidedJuly 31, 2025
DocketA-22-24
StatusPublished

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Bluebook
Keith Isaac, (N.J. 2025).

Opinion

SYLLABUS

This syllabus is not part of the Court’s opinion. It has been prepared by the Office of the Clerk for the convenience of the reader. It has been neither reviewed nor approved by the Court and may not summarize all portions of the opinion.

Keith Isaac, deceased v. Board of Trustees (A-22-24) (089370)

Argued March 17, 2025 -- Decided July 31, 2025

HOFFMAN, J., writing for a unanimous Court.

In this case, the Court considers whether the Board of Trustees of the Police and Firemen’s Retirement System (PFRS) properly distributed the unpaid benefits of former Newark policeman Keith Isaac to his estranged spouse following his death.

On September 12, 2016, the Board approved Isaac’s 2013 application for special retirement, retroactive to the amended date of August 1, 2014. Between August 1, 2014, and September 12, 2016, Isaac had accumulated $208,950.03 in unpaid benefits.

In March 2017, the Division of Pensions and Benefits distributed Isaac’s unpaid benefits to Roxanne Isaac, Isaac’s estranged spouse. Isaac’s estate wrote to the Division, asking that it reconsider its decision. In a letter dated November 21, 2018, the Board informed the estate that “in filing for retirement and listing Roxanne as his spouse . . . Isaac nominated and designated her as his beneficiary,” pursuant to N.J.S.A. 43:16A-12.2. Thus, the Board concluded that the Division “correctly paid” Roxanne the unpaid benefits. The estate appealed the Board’s decision, and the Office of Administrative Law (OAL) affirmed. The estate then appealed to the Appellate Division, which remanded the matter to the OAL to conduct a supplemental hearing to uncover Isaac’s probable intent regarding the disposition of his unpaid benefits. The Court granted certification. 259 N.J. 362 (2024).

HELD: By its plain language, N.J.S.A. 43:16A-12.2 directs that “unpaid benefits” be distributed to the decedent’s estate unless the PFRS member has nominated a beneficiary by “written designation.” Because Isaac made no such designation here, the Board must distribute Isaac’s $208,950.03 in unpaid benefits to his estate in accordance with the statutory mandate.

1. Pension benefits are part of the member’s recompense for past service. In the event that members accrue any unpaid benefits but those funds are withheld and not disbursed prior to the retirant’s passing -- as was the case here -- N.J.S.A. 43:16A- 12.2 provides that “[u]pon the death of a retirant, any unpaid benefits due him shall 1 be paid in one lump sum to such person, if living, as he shall have nominated by written designation duly executed and filed with the board of trustees, otherwise to the executor or administrator of the retirant’s estate.” Notably, members can nominate anyone to receive their unpaid benefits. As section -12.2 makes clear, if such a nomination is not made, these funds are returned to “the retirant’s estate.” Separate from the distribution of a member’s pension benefits is the survivors’ pension under N.J.S.A. 43:16A-12.1(a). A survivors’ pension is automatic, and the Legislature eliminated a member’s ability to name beneficiaries. (pp. 10-11)

2. The language of N.J.S.A. 43:16A-12.2 makes clear that when a member fails to affirmatively nominate a beneficiary “by written designation,” any unpaid benefits must be paid to the member’s estate, whether that estate is governed by a will (via the executor) or intestacy statutes (via the administrator). The statute is thus a closed circle that provides its own unambiguous gap-filler: the member’s estate. Given the stark distinctions between Isaac’s unpaid benefits and his automatic survivors’ pension, the Court agrees with the Appellate Division’s conclusion that Isaac’s identification of Roxanne on the retirement application did not also constitute a written designation pursuant to N.J.S.A. 43:16A-12.2. Accordingly, the Board’s decision to distribute Isaac’s unpaid benefits to Roxanne on this basis was arbitrary, capricious, and unreasonable. Based on the statute’s plain-language mandate that the benefits be paid to the estate, the Court parts ways from the Appellate Division’s decision to remand for additional fact finding to uncover Isaac’s probable intent as to the disposition of his unpaid benefits. The Court notes that the Board represented at oral argument that the concerns raised here would be addressed through the creation of a new form or prompt. (pp. 11-14)

REVERSED.

CHIEF JUSTICE RABNER and JUSTICES PATTERSON, PIERRE-LOUIS, WAINER APTER, FASCIALE, and NORIEGA join in JUSTICE HOFFMAN’s opinion.

2 SUPREME COURT OF NEW JERSEY A-22 September Term 2024 089370

Keith Isaac, deceased,

Petitioner-Appellant,

v.

Board of Trustees, Police and Firemen’s Retirement System,

Respondent-Respondent.

Roxanne Isaac, Intervenor.

On certification to the Superior Court, Appellate Division.

Argued Decided March 17, 2025 July 31, 2025

Eric A. Carosia argued the cause for appellant (Berkowitz, Lichtstein, Kuritsky, Giasullo & Gross, attorneys; Eric A. Carosia, on the brief).

Juliana C. DeAngelis, Legal Counsel, argued the cause for respondent (Nels J. Lauritzen, Deputy Director, Legal Affairs, attorney; Juliana C. DeAngelis, on the brief).

JUSTICE HOFFMAN delivered the opinion of the Court.

1 In this case, we hold that it was arbitrary, capricious, and unreasonable

for the Board of Trustees (the Board) of the Police and Firemen’s Retirement

System (PFRS) to distribute withheld pension benefits of former Newark

policeman Keith Isaac to his estranged spouse following Isaac’s death. The

funds, which accrued during Isaac’s lifetime but were withheld pending

resolution of an unrelated lawsuit, amounted to $208,950.03. By its plain

language, N.J.S.A. 43:16A-12.2 directs that “unpaid benefits” be distributed to

the decedent’s estate unless the PFRS member has nominated a beneficiary by

“written designation.” Because Isaac made no such designation here, we hold

that the Board must distribute Isaac’s $208,950.03 in unpaid benefits to his

estate in accordance with the statutory mandate.

I.

Under N.J.S.A. 43:16A-11.1, PFRS members may apply for “special

retirement” after twenty-five years of creditable service and, if approved, are

entitled to a retirement allowance of sixty-five percent of their final

compensation at the time of retirement. 1

1 In contrast to “special retirement,” members with only twenty years of creditable service may qualify for “service retirement,” which includes a base retirement allowance of only fifty percent of the member’s final compensation. N.J.S.A 53:5A-8(b)(2).

2 In March 2013, Isaac applied for “special retirement” from the Newark

Police Department. On his retirement application form, under a section titled

“Marital/Survivor Information,” Isaac listed Roxanne Isaac as his wife. 2

Under a subsequent section, titled “Life Insurance Information,” Isaac listed

four of his eight children as his “Primary Beneficiaries.”

At the time of his application, Isaac was on leave from the Newark

Police Department and serving as the Municipal Emergency Management

Coordinator for the City of Newark, his appointed position since 2007.

Accordingly, the Board postponed its consideration of Isaac’s retirement

application while his employment with the city was ongoing.

In July 2014, the City of Newark removed Isaac from his position, and

Isaac subsequently brought suit for wrongful termination. Isaac’s March 2013

retirement application remained pending during these proceedings. In April

2016, Isaac and the City of Newark reached a settlement agreement, and the

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Related

Seire v. Police and Fire Pension Commission of Orange
80 A.2d 97 (Supreme Court of New Jersey, 1951)
Matter of Estate of Branigan
609 A.2d 431 (Supreme Court of New Jersey, 1992)

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Keith Isaac, Counsel Stack Legal Research, https://law.counselstack.com/opinion/keith-isaac-nj-2025.