Kentucky Retirement Systems, Now Kentucky Public Pensions Authority v. Department of Public Advocacy

CourtCourt of Appeals of Kentucky
DecidedMay 11, 2023
Docket2022 CA 000518
StatusUnknown

This text of Kentucky Retirement Systems, Now Kentucky Public Pensions Authority v. Department of Public Advocacy (Kentucky Retirement Systems, Now Kentucky Public Pensions Authority v. Department of Public Advocacy) is published on Counsel Stack Legal Research, covering Court of Appeals of Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Kentucky Retirement Systems, Now Kentucky Public Pensions Authority v. Department of Public Advocacy, (Ky. Ct. App. 2023).

Opinion

RENDERED: MAY 12, 2023; 10:00 A.M. TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals

NO. 2022-CA-0518-MR

KENTUCKY RETIREMENT SYSTEMS, NOW KENTUCKY PUBLIC PENSIONS AUTHORITY APPELLANT

APPEAL FROM FRANKLIN CIRCUIT COURT v. HONORABLE THOMAS D. WINGATE, JUDGE ACTION NO. 18-CI-00860

DEPARTMENT OF PUBLIC ADVOCACY APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: CETRULO, DIXON, AND EASTON, JUDGES.

EASTON, JUDGE: The Appellant, Kentucky Retirement Systems, now Kentucky

Public Pensions Authority (“KPPA”),1 seeks relief from the Order of the Franklin

Circuit Court, which reversed the Final Order issued by the Board of Trustees of

1 We will refer to the new name of KPPA even though actions reviewed were taken when the name was Kentucky Retirement Systems. KPPA (the “Board”). The circuit court concluded the Board erred when it

determined the Department of Public Advocacy (“DPA”) must pay the actuarial

costs associated with a greater than ten percent increase in the salary of one of

DPA’s former employees for one of the last five years of her employment.

Recognizing the substantial financial impact on state agencies should the precedent

of this KPPA decision be upheld, the Justice and Public Safety Cabinet and the

Cabinet for Health and Family Services collectively filed an amicus brief, for

which we granted leave. Upon review, we conclude the Franklin Circuit Court

correctly applied the law to undisputed facts, and we affirm.

FACTUAL AND PROCEDURAL HISTORY

DPA is a participating agency in KPPA. Mary Rafizadeh

(“Rafizadeh”) was a former, full-time employee of DPA, and was a participant in

the pension administered by KPPA. Measuring the last five fiscal years of

Rafizadeh’s employment requires us to list the preceding year to see the increase

complained of by the KPPA, which was for Fiscal Year 2002. Between Fiscal

Year 2001 and Fiscal Year 2006 (“FY01-FY06”), Rafizadeh’s last years of

employment with DPA, Rafizadeh received the following compensation:

FY01 $54,117.38 FY02 $59,529.12 FY03 $65,990.10 FY04 $67,236.72 FY05 $68,863.80 FY06 $55,736.19

-2- DPA was Rafizadeh’s last participating employer with KPPA prior to her

retirement in 2016.

On September 23, 2016, KPPA sent a letter and Notice of Pension

Spiking Details to DPA, advising that Rafizadeh received an annual increase in her

creditable compensation greater than ten percent for one of the last five years of

her employment. Specifically, KPPA stated increases in compensation from FY01

to FY02 totaled a greater than ten percent increase. The total increase was 18.1%.

KPPA considered this increase to be “pension spiking” as defined by KRS2 61.598.

KPPA decided DPA, as Rafizadeh’s last participating employer, was responsible

for paying the additional actuarial costs resulting from this increase, unless DPA

could show that such increase was the direct result of a bona fide promotion or

career advancement. KPPA determined the actuarial costs to be in the amount of

$1,805.67.

In response, DPA submitted an Employer Request for Post-

Determination of Bona Fide Promotion or Career Advancement. Attached was a

document indicating Rafizadeh received a reallocation, a legislative salary change,

and increment increases during FY01 and FY02. On August 30, 2017, KPPA sent

DPA its decision. KPPA determined the greater than ten percent increase in

2 Kentucky Revised Statutes.

-3- creditable compensation for Rafizadeh was not the direct result of a bona fide

promotion or career advancement.

DPA then formally requested an administrative hearing to contest the

decision that Rafizadeh’s pay increase constituted pension spiking. An

administrative hearing before a Hearing Officer was held on February 21, 2018.

Erwin “Ernie” Lewis (“Lewis”) and Sherri Payne (“Payne”) testified on behalf of

DPA. Other than supporting exhibits for DPA, no other evidence was introduced.

Lewis was the Public Advocate of Kentucky from 1996 to 2008.

Early in his tenure, Lewis organized the “Blue Ribbon Group” to fulfill his goal of

increasing salaries for DPA employees, whom he described as historically

underpaid and subject to “horrific” caseloads. The Blue Ribbon Group was

comprised of twenty members from the legislative, executive, and judicial

branches of our state government as well as attorneys and other community

members. The Blue Ribbon Group compared the salaries of public defenders in

Kentucky to the salaries of public defenders in twenty other states.

The Blue Ribbon Group found DPA was the lowest funded group out

of all twenty comparable state systems studied, and specifically DPA’s employees

were the lowest paid employees out of all twenty states. Lewis testified the Blue

Ribbon Group determined DPA’s employees were deserving of an increase in

-4- compensation considering the comparable education and experience of the

employees of the other states.

The Blue Ribbon Group brought its recommendations to Governor

Paul Patton for consideration in the Commonwealth’s budget. The General

Assembly approved a budget increase (basically half of what was sought) for DPA

to fund these salary increases. As a result, all attorneys (including Rafizadeh)

employed by DPA received an increase in compensation for FY02.

Lewis explained DPA worked with the Personnel Cabinet to properly

allocate the salary increases. The salary structure of every attorney with DPA was

permanently changed. The resulting salary increases were mostly determined by

experience. Rafizadeh was the supervising attorney for DPA’s Covington office

during FY02, and her salary increase was like other supervising attorneys.

Lewis admitted Rafizadeh was not promoted. Lewis said Rafizadeh

also received a five percent pay increase in October of 2001, which was then

routine for state employees. Even without this standard five percent increment, the

increase resulting from the General Assembly’s specific budget provision would

have been greater than a ten percent increase.

Payne also testified on behalf of DPA. Payne is the Human Resources

Branch Manager for DPA. Payne explained that the term “reallocation” means a

certain job position is better classified as another position. A reallocated employee

-5- receives a pay increase if the new classification is at a higher grade. Reallocations

do not require additional training and are not considered promotions. Rafizadeh

was reallocated to a higher classification and pay grade. The Personnel Cabinet

directs reallocations, and DPA has no control over them. Once a position is

reallocated, all the employees in that position are reallocated, not specific

employees.

Following the hearing, both sides filed briefs. The Hearing Officer

issued a Recommended Order on June 12, 2018. The Recommended Order

advised the Board to affirm KPPA’s decision “that the increase in Ms. Rafizadeh’s

creditable compensation greater than 10 percent was not due to a bona fide

promotion or career advancement.” As a result, the Hearing Officer determined

DPA owed KPPA $1,805.67 in actuarial costs pursuant to KRS 61.598.

The Board met on July 26, 2018, and issued its Final Order. The

Final Order overruled DPA’s request for oral arguments and adopted the Hearing

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