Lovely-Belyea v. Maine State Retirement Sys.

CourtSuperior Court of Maine
DecidedDecember 19, 2001
DocketCUMap-01-10
StatusUnpublished

This text of Lovely-Belyea v. Maine State Retirement Sys. (Lovely-Belyea v. Maine State 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
Lovely-Belyea v. Maine State Retirement Sys., (Me. Super. Ct. 2001).

Opinion

STATE OF MAINE SAF eOe SUPERIOR COURT

CUMBERLAND, ss. cant CIVIL ACTION lee [2 te 32 ANU DOCKET NO. AP-01-10 \ Pec. « CU oe f |

CAROLE LOVELY-BELYEA, Petitioner, Vv. ORDER ON PETITIONER’S 80C APPEAL MAINE STATE RETIREMENT SYSTEM,

Respondent.

The petitioner, Carole Lovely-Belyea, has appealed the final administrative action by the Maine State Retirement System (“MSRS”), pursuant to MLR. Civ. P. 80C. The petitioner asserts that MSRS did not comply with the applicable state and federal regulations governing the conversion of a retirement system from one that includes an age-discriminatory disability policy to one that does not, and consequently argues that she should be permitted to enroll in the non- discriminatory plan. After reviewing the petitioner’s brief, MSRS’s response, and the relevant law, the petitioner’s requested relief is denied.

STATUTORY BACKGROUND

The federal Older Workers Benefit Protection Act (“OWBPA”), 104 Stat. 978, 981-82, Public Law 101-433, contains a provision prohibiting age-dependent disability benefits in retirement systems, but includes a provision by which employees could continue to be covered by the “age-discriminatory” plan if the employees are given the opportunity to elect participation in the new plan. The employer could offer

employees, hired prior to October 16, 1992, the option to elect participation in the new, non-discriminatory plan in lieu of the existing age-discriminatory plan if : (1) the offer was made and reasonable notice provided no later than the date that was two years after the enactment of the OWBPA,; and (2) the employee was given up to 180 days after the offer in which to make the election. OWBPA, § 105(c)(2)(A)(ii). The date of enactment was October 16, 1990. If the employee did not elect to be covered by the new disability benefits, the employer could continue to cover the employee under the age-discriminatory plan. OWBPA, § 105(c)(2)(B).

In Maine, legislation governing the election of the new, non-discriminatory benefits plan by public employees was enacted as required by the OWBPA. 5 M.RS.A. § 17941 (1992) repealed by P.L. 1995, ch. 643, § 16 (eff. April 10, 1996). Under § 17941, MSRS was responsible for providing information to state agencies and school administrative units that described the amended disability plan, the disability plan without the amendment, and “a form for individual member election to be

covered under the plan as amended.” 5 M.RS.A. § 17941(1)(A). The statute provided that the state agency or school administrative unit was responsible for distributing information and election forms to the eligible members, and collecting the completed election forms and returning the forms to MSRS. 5 M.RS.A. § 17941(1)(A). The statute specified that the information and election form were to be given to the eligible members not later than October 16, 1992, and that the election to participate in the new plans was to be effective 180 days later (April 14, 1993) only if

the election was signed and dated on or before a date “established by the executive director that may not be later than 180 days after October 16, 1992 [April 14, 1993].”! § 17941(1)(C),(D)(E). Unless a member elected to be covered by the new plan, she would be covered by the existing plan. § 17941(2). The election was irrevocable. § 17941(1)(E).

FACTUAL BACKGROUND

The petitioner was employed as a teacher by the Lewiston School Department when, on March 31, 1993, she signed an MSRS 1993 Disability Election Form, electing not to move to the non-discriminatory benefits plan. The petitioner remained covered under the age-discriminatory plan. When the petitioner applied for disability benefits in 1998, her claim was denied by the Executive Director of MSRS, because she was beyond the “normal retirement age.” She appealed the denial to the Maine State Retirement Board (Board), on the ground that her election was not valid because she was not given the proper notice of election under the governing statute, and the Board affirmed the Executive Director.

The Board found that the election form was not distributed by MSRS until February of 1993, and was not distributed to the school employees until March 3, 1993, in contravention of § 17941(1)(C), which provides that the “school administrative unit shall give the information and election form to each member entitled to the election not later than October 16, 1992.” R. 34.6- R. 34.7 (emphasis

added). The Board found that the preponderance of the evidence demonstrated that

1 Based on legislative history of the federal statute, OWBPA, the Board accepted the assertion that the employees were to be given, 180 days, as a minimum, in which to make their election. the initial employee information sheet, which was sent by MSRS to the Lewiston School Department (and all employers of members of the retirement system) in October 1992, had been distributed to all employees. R. 34.7. The Board found that although the petitioner testified that she regularly did not receive materials that had been left in her school mailbox, the record did not demonstrate that this was due to the school’s lack of delivery, but rather could have been attributable to the fact that a third person, with the petitioner’s permission, would remove the contents of the box and place them on the petitioner’s desk. R. 34.7. The Board found that, even if the petitioner had not received the information sheet by October 16, 1992, she had received both the information sheet and election form by March 3, 1993.2 R. 34.7. The Board concluded that the petitioner’s election was valid because she had received an information sheet and election form by March 3, 1993, and the petitioner has not provided any facts that demonstrate she was actually prejudiced

by the delay in receiving this information. R. 34.

The petitioner argues that there was no specific finding that she received the information sheet by October 16, 1992, and that the finding that the petitioner received the information sheet in October 1992 was not supported by substantial evidence. The petitioner asserts that because she did not receive the information by

October 16, 1992, her election was invalid. The petitioner asserts that because there

was no compliance with the statute which required the timely distribution of

2 The Board’s opinion erroneously states that the petitioner had received an election form and information sheet by March 3, 1992., however this is clearly a typographical error. information and election forms, the employer was not permitted to continue the age-discriminatory benefits plan. The petitioner argues that MSRS was wrong to hold that the petitioner was required to establish prejudice resulting from the lack of compliance with the statutory notice requirements. DISCUSSION

I. Substantial Evidence

When reviewing administrative agency decisions, the Superior Court must uphold the agency’s findings of fact if supported by substantial evidence on the

record as a whole. MacDougall v. Department of Human Services, 2001 ME 64, { 6,

769 A.2d 829, 831. The finding of fact must be supported by substantial evidence and the reasonable inferences to be drawn therefrom. Wadleigh v. Higgins, 358 A.2d 531, 531-32 (Me. 1976). Even if there is evidence that would support a contrary

result, the findings should be upheld if not clearly erroneous. Harold D. Smith &

The petitioner first asserts that the Board did not make a finding that the information sheet had been distributed by October 16, 1992. The Board first writes, in the context of whether the provisions requiring that the information sheet and election form be provided by October 16, 1992, that “the preponderance of the

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