Moser v. The Virginia Retirement System

CourtDistrict Court, W.D. Virginia
DecidedOctober 3, 2024
Docket4:24-cv-00010
StatusUnknown

This text of Moser v. The Virginia Retirement System (Moser v. The Virginia Retirement System) is published on Counsel Stack Legal Research, covering District Court, W.D. Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Moser v. The Virginia Retirement System, (W.D. Va. 2024).

Opinion

AT DANVILLE, VA FILED OCT 3, 2024 IN THE UNITED STATES DISTRICT COURT LAURA A. AUSTIN, CLERK FOR THE WESTERN DISTRICT OF VIRGINIA Boop vrcabee DANVILLE DIVISION DEPUTY CLERK SAMMIE TODD MOSER, ) ) Plaintiff, ) Civil Action No. 4:24-cv-00010 ) v. ) MEMORANDUM OPINION ) THE HALIFAX COUNTY, VA, BOARD By: — Hon. Thomas T. Cullen OF SUPERVISORS and THE VIRGINIA _ ) United States District Judge RETIREMENT SYSTEM, ) ) Defendants. )

Plaintiff Sammie Todd Moser (“Moser”) brought this action against Defendants the Halifax County, VA, Board of Supervisors (“the Board”) and the Virginia Retirement System (“VRS”). (See generally Compl. [ECF No. 1].) Under Virginia law, state employees are entitled to participate in a retirement plan administered by the state. One element of that plan, though, dictates that, if an employee is convicted of a felony, he will forfeit the state’s contribution to his retirement account (although he is entitled to a refund of any personal contributions, plus interest). After Moser was convicted of embezzling state funds while he served as the Halifax County Animal Control Warden, the Board determined that he was no longer entitled to retirement benefits under the VRS. Moser contends that decision—and the statutory scheme that stripped him of the state’s contributions to his retirement—violate his constitutional rights.

This matter is before the court on the Board’s motion to dismiss for lack of jurisdiction and for failure to state a claim.1 (Mot. Dismiss [ECF No. 8].) The motion has been fully briefed by the parties, and the court heard argument on the motion on September 30, 2024. For the

reasons discussed below, the court finds that Moser’s claims against the Board are barred by the doctrine of res judicata and that Moser does not seek any relief from the Board. Accordingly, the Board’s motion to dismiss will be granted. I. STATEMENT OF FACTS The following facts are either undisputed or presented in the light most favorable to Moser, the nonmoving party. See Glynn v. EDO Corp., 710 F.3d 209, 213 (4th Cir. 2013).

Like most employers, Virginia has established a retirement system for state employees.2 Under that program, employees and the state jointly contribute to an interest-bearing retirement account that is payable to the employee, over time, at his retirement. But Virginia law provides that a person who has elected to participate in the retirement system is not entitled to receive retirement benefits under the VRS if “(i) he is convicted of a felony and (ii) the person’s employer determines that the felony arose from misconduct occurring . . . in any

position in which the person was a member covered for retirement purposes under any retirement system administered by the Board [of Trustees of the Virginia Retirement System].” Va. Code Ann. § 51.1-124.13(A); see id. § 51.1-125(A) (stating that eligible employees “shall be

1 VRS is not a party to the motion and has not moved to dismiss the claims asserted against it.

2 Moser’s complaint omits many salient, relevant, and necessary details. For example, outside of the caption of the case, he does not mention the Board at all. The court would be justified in dismissing the claims against the Board on that basis alone, as Moser does not allege any action or inaction by the Board that violated his constitutional rights. But the court takes judicial notice of the statutory scheme at issue, as well as the state- court proceedings that lay out the relevant facts, giving the court an adequate basis to understand Moser’s claims. members of the retirement system” unless they “elect[] not to participate”). If an employer determines that an employee’s misconduct falls within the provision, the employee can appeal that determination to the appropriate state circuit court, but “no further proceedings shall

follow the decision of the circuit court.” Id. Moser served in VRS-covered law enforcement jobs in Halifax County for 26 years. (Compl. ¶ 3.) In 2022, he was convicted of two felonies for embezzling funds from the Halifax County Animal Shelter while he served as the County’s Animal Control Warden. (Id. ¶ 4.) The Board—Moser’s employer—then followed the procedure set out in § 51.1-124.13, and determined that, because Moser had been convicted of felonies that arose from misconduct

during his state employment, he was no longer entitled to receive VRS benefits. (See Mem. Supp. Mot. Dismiss, Ex. A at 5–7 [ECF No. 9-1].)3 Moser appealed that determination to the Halifax County Circuit Court. (See id. at 7.) In the circuit court, he argued that § 51.1-124.13 deprived him of due process in violation of the Fourteenth Amendment, and that the forfeiture of his retirement benefits is an excessive fine in violation of the Eighth Amendment. (Id.; Compl. at 3–6.)

During a hearing on Moser’s appeal of the Board’s decision, the circuit court stated the following with respect to Moser’s due-process claim: [J]ust for this record, the due process argument, I think, clearly, that there was due process for Mr. Moser. He was given Notice, he appeared, he had his attorney there, he had a court reporter there and [was] given an opportunity to present any evidence or argument that they needed to be presented. And he did that, and

3 The exhibits to the Memorandum in Support of the Motion to Dismiss are records of the proceedings in Halifax County Circuit Court. This court can take judicial notice of related proceedings in other courts, see Corbitt v. Baltimore City Police Dep’t, 675 F. Supp. 3d 578, 586 (D. Md. 2023), and the court does so here to fill in the factual gaps in Moser’s pleading. then he was notified of the decision by the Board and felt that they had the Right to Appeal. They’ve done that, and that’s why we’re here today. But I think, clearly . . . if the . . . Due Process argument is to be heard in this proceeding, I think clearly that he had due process under the law as far as the Constitutional objections of due process. (Mem. Supp. Mot. Dismiss, Ex. A at 7.) Turning to the excessive-fines claim, the court stated: I’ve read [the United States Supreme Court’s decision in Timbs v. Indiana, 586 U.S. 146 (2019)]. And in dealing with these facts of this case, the Statute, you know, does require Forfeiture o[f] the VRS Benefits. But it also allows a return of the contributions made by the employee plus interest. So even though the Statute, you know, it is somewhat a penalty, it also offsets the effects of this Statute by being able to return his benefits. . . . So—you know, I think this is distinguishable from the Timbs case for two reasons. This is really not an excessive punishment case because he’s getting refunded some of these benefits plus interest. . . . [F]or the reasons the Court stated I’m going to overrule any objection on the Appeal. . . . [T]he Court finds the determination by the Board was correct, that there’s no due process violation and no excessive penalty violation. (Id. at 7–10.) After the Halifax County Circuit Court affirmed the Board’s determination, Moser appealed, first to the Virginia Supreme Court, then to the United States Supreme Court. The Virginia Supreme Court dismissed the appeal because the circuit court’s order is not appealable under § 51.1-124.13(b); by the statute’s terms, the circuit court’s decision is the final say. (See Mem. Supp. Mot. Dismiss, Ex. C [ECF No. 9-3].) Moser appealed that determination to the United States Supreme Court, but the Court denied his petition for writ of certiorari. See Moser v. Halifax Cnty. Bd. of Supervisors, 144 S. Ct. 1033 (March 4, 2024). On March 11, 2023, Moser filed the instant suit, again raising the Fourteenth Amendment due-process claim and Eighth Amendment excessive-fines claim. (See Compl. at 3–6.) On April 29, 2024, the Board moved to dismiss the suit for lack of subject-matter jurisdiction and for failure to state a claim. (Mot. Dismiss; Mem.

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Moser v. The Virginia Retirement System, Counsel Stack Legal Research, https://law.counselstack.com/opinion/moser-v-the-virginia-retirement-system-vawd-2024.