Kennebec County v. Maine Pub. Employees Retirement Sys.

CourtSuperior Court of Maine
DecidedApril 8, 2013
DocketKENap-12-11
StatusUnpublished

This text of Kennebec County v. Maine Pub. Employees Retirement Sys. (Kennebec County v. Maine Pub. Employees Retirement Sys.) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kennebec County v. Maine Pub. Employees Retirement Sys., (Me. Super. Ct. 2013).

Opinion

STATE OF MAINE BUSINESS AND CONSUMER COURT CUMBERLAND, ss Location: Portland Docket No.: BCD-AP-12-p / ll 11;] }I [/c--' /.r" / ' : n fbjtt -- r\: i ~·- t--j/'t· ;_ :)(7 I<

) KENNEBEC COUNTY, ) ) Petitioner, )

v. ) ) / ) MAINE PUBLIC EMPLOYEES ) RETIREMENT SYSTEM, ) ) Respondent ) )

DECISION AND ORDER

In this appeal of state agency action under Rule 80C of the Maine Rules of Civil

Procedure, Petitioner Kennebec County (the "County"), appeals from a decision of the Maine

Public Employees Retirement System (the "System") Board ofTrustees' (the "Board").

In its November 28, 2011, Decision and Order, the Board affirmed, in part, the January

20, 2011, final decision of the System's Executive Director's Designee ("EDD"). The Board

determined the County had a responsibility to offer System membership to its employees, and

that the County had failed to meet that responsibility with respect to three County employees. 1

The Board concluded the County was responsible for payment of past employer contributions

and interest on both employee and employer contributions for each of the employees should

they elect to enroll in the System.

1 The EDD ultimately concluded the County was responsible for back contributions to the Maine Public

Employees Retirement System for four of its employees, but the Board affirmed as to only three of the four employees. The fourth employee is not part of this appeal.

1 STATUTORY BACKGROUND

The State of Maine provides retirement benefits to eligible public employees through a

pension plan administered by the System. The Legislature created the retirement program to

attract and retain qualified employees for public service. 5 M.R.S. § 17050 (2012). The System

offers eligible public employees retirement savings plans with favorable tax treatment. 5

M.R.S. § 17053 (2012). The Board is responsible for overseeing the administration and proper

operation ofthe System. 5 M.R.S. §17103(1) (2012).

Municipalities and counties may elect to have their employees participate in the System

by becoming a Participating Local District (PLD). See 5 M.R.S. §§ 17001(19), (27) (2012)

(defining local district and PLD); 5 M.R.S. §§ 18201 & 18804 (2012) (explaining how a local

district becomes a PLD). In 1990, the Legislature established the Consolidated Retirement

Plan for Participating Local Districts (the Plan), see P.L. 1989, Ch. 811, § 3 (effective April 10,

1990) (codified at 5 M.R.S. §§ 18801-06 (2012)), and the County joined the Plan in 1995

(R. 6.74). Employees of PLDs may also be covered by Social Security, and System and Plan

membership is optional for employees in PLDs that also offer Social Security coverage.

5 M.R.S. §§ 18251(3)(D), 18252 (2012).

Section 18252 governs PLDs that also offer Social Security coverage; section 18252-A

governs PLDS that do not offer Social Security coverage. 5 M.R.S. §§ 18252, 18252-A (2012).

The County, however, offers Social Security coverage to its employees and thus is governed by

section 18252. The statute provided, 2 at the relevant time period:

An employee who is or would be covered by the United States Social Security Act as a result of employment by a participating local district having a

2 There have been numerous amendments to the statutes governing the System in the relevant time period. The

parties agree, however, that section 18252, which is the key statutory provision, did not change substantively between 1985 and 2000. All further references to section 18252 are to the 2000 version as contained in the 2002 edition of the Maine Revised Statutes Annotated. Also relevant to this appeal is section 18252-A; references to section 18252-A are to the 2000 version as contained in the 2002 edition of the Maine Revised Statutes Annotated. The Court otherwise cites to the relevant statutes currently in effect.

2 so-called "Social Security Section 218 agreement" may elect to join, not to join or to withdraw from the retirement system under the following conditions.

I. New employees. A new employee may join the retirement system at the beginning of employment or at any time after beginning employment, so long as he is still an employee of the participating local district and the district continues to be a participating local district.

5 M.R.S.A. § 18252 (2002).

FACTUAL BACKGROUND

On July 1, 1951, the County became a local district within the System. (R. 14.198.)

County employees have Social Security under a "218 Agreement," (R. 18.1.), and since 1982,

their membership in the System has been optional pursuant to section 18252. The County has

offered a deferred compensation program administered by the Aetna insurance company as an

alternative to participation in the System. (R. 1.56.)

In February 2008, the System conducted a benefits presentation for County employees.

(R. 77 .11; 53.66). After the presentation, four County employees, hired between 1985 and 2000,

sent letters to the System stating the County had not informed them of their membership

eligibility and inquiring into the possibility of purchasing credit for previous service with the

County. (R. 77.11.) In a March 2008 letter, the System informed the County it had received

letters from four County employee claiming they had not been offered membership when hired

and asked the County to confirm whether the four employees had been offered membership

(R. 77.12.) The County responded that it had no specific documentation to demonstrate

whether the employees were told they could join the System when they were hired. (R. 77.12.)

Instead, the County asked the System to review additional, general evidence that all four

employees had been informed of their right to join the System. (R. 1.5.) The County offered

the following evidence:

3 • On August 25, 1995 and again on August 31, 2000, County Commissioners distributed a memorandum to all department heads describing the retirement options available to employees. (R. 77.7.)

• On September 9, 1994, during a presentation to County employees, an Aetna case manager informed County employees that those not enrolled in the System were eligible to enroll in the Aetna deferred compensation plan on a matching basis. (R. 77.7.)

• On September 12, 1994, the County Commissioners sent a memorandum to all department heads informing them of amendments made to union contracts. Because of those amendments, all County employees would have a choice of retirement options, which included System benefits. (R. 77.7.)

• The County Commissioner sent a letter to the System stating that conversations with former clerks who were responsible for enrolling employees for membership revealed that "all employees, including the [four] employees, were offered membership when they were hired."3 (R. 77.12.)

• Other employees who were hired around the same dates as the four employees at issue in this case had enrolled in the System, and three of the four employees chose other retirement plan options. (R. 1.63.)

• Finally, in 2002, the County implemented procedures to document whether an employee was offered membership. (R. 14.8-14.9).

The Retirement Services Supervisor reviewed the County's evidence and concluded that the

County failed to provide sufficient documentation to support its assertion that the four

employees had been offered System membership.4

In December 2008, the County asked the Executive Director's Designee (EDD) to

review the supervisor's findings. The County argued that neither section 18252 nor section

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