Michael G. Sigur v. Municipal Employees' Retirement System of Louisiana

CourtLouisiana Court of Appeal
DecidedMarch 4, 2022
Docket2021CA0790
StatusUnknown

This text of Michael G. Sigur v. Municipal Employees' Retirement System of Louisiana (Michael G. Sigur v. Municipal Employees' Retirement System of Louisiana) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Michael G. Sigur v. Municipal Employees' Retirement System of Louisiana, (La. Ct. App. 2022).

Opinion

STATE OF LOUISIANA

COURT OF APPEAL

FIRST CIRCUIT

NO. 2021 CA 0790

MICHAEL G. SIGUR

VERSUS

THE MUNICIPAL EMPLOYEES' RETIREMENT SYSTEM OF LOUISIANA

Judgment Rendered: MAR 0 4 2022

On Appeal from the 19th Judicial District Court Parish of East Baton Rouge, State of Louisiana Trial Court No. 693, 357

The Honorable Michael E. Kirby, Judge Pro Tempore Presiding

Keith R. Credo Attorney for Plaintiff A - ppellant, Metairie, Louisiana Michael G. Sigur

Larry M. Roedel Attorneys for Defendant -Appellee, J. Kenton Parsons Municipal Employees' Retirement David B. Phelps System of Louisiana

Bradley C. Guin Baton Rouge, Louisiana

BEFORE: McDONALD, LANIER, AND WOLFE, JJ. WOLFE, I

Plaintiff, Michael G. Sigur, appeals a summary judgment rendered in favor of

defendant, the Municipal Employees' Retirement System of Louisiana (" MERS"),

and the denial of his cross- motion for summary judgment. For the following

reasons, we reverse and render judgment in favor of plaintiff.

BACKGROUND

The parties jointly stipulated to the relevant facts concerning this matter. Mr.

Sigur was a full-time municipal employee of the City of Kenner and a contributing

member of MERS. Upon his retirement in January 2014, MERS paid Mr. Sigur

normal monthly retirement benefits. In April 2014, Mr. Sigur was elected to the

Kenner City Council, serving as a part-time councilman beginning July 1, 2014. He

was re- elected in April 2018 and will be term -limited from any further re- election to

that particular public servant position at the end of his second term in June 2022. As

a part-time and term -limited elected official, Mr. Sigur is not eligible to be a member

of MERS while serving as a council member! Nevertheless, it is uncontested that

as a retiree during the time -period of July 2014 through September 2018, Mr. Sigur

received $ 44, 629. 45 in retirement benefits from MERS, which MERS now claims

was an overpayment. MERS began to recoup the alleged overpayment by offsetting

Mr. Sigur' s monthly retirement benefits. To date, a total of $14, 000. 00 has been

offset; however, MERS has suspended the offset pending the outcome of this

litigation.

1 Louisiana Revised Statutes 11: 164, which was effective on June 30, 2011, before Mr. Sigur' s election, prohibits part-time elected public servants from participating in or receiving credit for service in any public retirement system such as MERS. Accord La. Const. Art. 10, § 29. 1( A). Louisiana Revised Statutes 11: 1751. 1, which was effective July 1, 2003, also before Mr. Sigur' s election, prohibits a term -limited elected official from being eligible to be a member of any statewide public retirement system such as MERS, when such term limits prevent him from earning the minimum number of years of creditable service necessary to receive a benefit.

2 On January 29, 2020, Mr. Sigur filed a petition against MERS, seeking a

declaratory judgment that MERS had arbitrarily miscalculated an offset of his

retirement benefits contrary to law, such that he is entitled to the return of his

seized" retirement benefits. In its answer, MERS contended that as a public entity

in control of public funds, it has a duty to accurately calculate and adjust a retired

member' s retirement benefits when a retiree is re- employed with a municipal entity.

Mr. Sigur and MERS filed cross- motions for summary judgment regarding the

interpretation of the statutes governing the calculation of Mr. Sigur' s retirement

benefits during his public service as a city councilman. After conducting a hearing

and taking the matter under advisement, the trial court granted MERS' s motion for

summary judgment and denied Mr. Sigur' s motion for summary judgment, signing

a judgment with incorporated written reasons on January 19, 2021. Mr. Sigur

suspensively appealed, primarily arguing that the trial court erroneously interpreted

the statutes affecting his monthly retirement benefits, failed to rule on numerous

constitutional issues, and failed to award attorney fees to him.

STANDARD OF REVIEW

Appellate courts review summary judgments de novo. Vine v. Teachers

Retirement System of Louisiana, 2019- 0106 ( La. App. 1st Cir. 12/ 19/ 19), 292

So. 3d 116, 121. Mr. Sigur essentially argues that the trial court erred in interpreting

the relevant statutory provisions as they apply to his retirement benefits. The

interpretation of a statute is a question of law that may be decided by summary

judgment. Louisiana Workers' Compensation Corp. v. Landry, 2011- 1973 ( La.

App. 1st Cir. 5/ 2/ 12), 92 So. 3d 1018, 1021, writ denied, 2012- 1179 ( La. 9/ 14/ 12),

99 So. 3d 34. When addressing legal issues, an appellate court gives no special

weight to the findings of the trial court, but exercises its constitutional duty to review

questions of law de novo, after which it renders judgment on the record. Id.

Additionally, courts should avoid constitutional rulings when the case can be

3 disposed of on non -constitutional grounds, such as statutory interpretation. See

Burmaster v. Plaquemines Parish Government, 2007- 2432 ( La. 5/ 21/ 08), 982

So. 2d 7951 802. Therefore, if this case can be decided on the basis of a statutory

interpretation argument, this court should do so and pretermit any constitutional

ruling. Id. at 802- 803.

MOTION TO STRIKE

At the hearing before this court, counsel for MERS made an oral motion to

strike Mr. Sigur' s reply brief. MERS asserted that Mr. Sigur raised issues regarding

the correct version of the applicable statutes, as well as constitutional arguments,

that he had not previously raised and had not been considered at the trial court level.

We referred the motion to the merits and gave MERS and Mr. Sigur each a separate

deadline for filing additional briefs with this court. MERS asserts that because Mr.

Sigur did not raise the applicable dates and versions of the statutes in the court below,

this court is barred from considering statutes not cited to the trial court.

Louisiana Uniform Rules — Courts of Appeal, Rule 1- 3 provides that an

appellate court " will review only issues which were submitted to the trial court and

which are contained in specifications or assignments of error, unless the interest of

justice clearly requires otherwise." ( Emphasis added.) Furthermore, La. Code Civ.

P. art. 2164 gives an appellate court the authority to " render any judgment which is

just, legal, and proper upon the record on appeal." ( Emphasis added.) See Official

Revision Comments —1960, Comment (a) (" The purpose of this article is to give the

appellate court complete freedom to do justice on the record irrespective of whether

a particular legal point or theory was made, argued, or passed on by the court

below.")

Throughout this litigation, Mr. Sigur has consistently challenged the

appropriate version of the applicable statutes and has maintained all along that the

appropriate date to consider the applicable statute is the date of his retirement, not

El the date that MERS adjusted his retirement benefits. We find that these issues are

proper for our consideration even though Mr.

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