Parella, et al. v. RI Retirement Brd.

CourtDistrict Court, D. New Hampshire
DecidedMarch 31, 1997
DocketCV-96-434-M
StatusPublished

This text of Parella, et al. v. RI Retirement Brd. (Parella, et al. v. RI Retirement Brd.) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Parella, et al. v. RI Retirement Brd., (D.N.H. 1997).

Opinion

Parella, et a l . v . RI Retirement Brd. CV-96-434-M 03/31/97 UNITED STATES DISTRICT COURT DISTRICT OF NEW HAMPSHIRE

Gaetano Parella, Mildred Tantimonaco, John Gilgun, Helena McDermott, and Delores Ferry, on behalf of themselves and others similarly situated

Plaintiffs

v. N.H. Civil N o . 96-434-M R.I. Civil N o . 95-358 Retirement Board of the Rhode Island Employees' Retirement System, et a l .

Defendants.

O R D E R

In 1994 the State of Rhode Island and the Internal Revenue Service entered into an agreement aimed at preserving the qualified trust status of the Employees' Retirement System of the State of Rhode Island ("ERS"). See 26 U.S.C. § 401(a). Pursuant to that agreement, the Rhode Island Legislature capped state legislators' (both present and past) annual pensions at $10,000 — the maximum amount tax qualified pension plans were then permitted to pay under 26 U.S.C. § 415(b). See R.I. Gen. Laws §§ 36-8-20(e) and 36-10-10.1(e) (the " A c t " ) . The Act became effective in July, 1995. Plaintiffs are members of a class consisting of retired Rhode Island legislators and surviving spouses of legislators who, prior to July 1995, were receiving annual retirement benefits in excess of $10,000. They contend that the Act unlawfully deprives them of vested retirement benefits in excess of $10,000 a year. Specifically, they claim that the Act unlawfully impairs their contract rights and deprives them of property without due process of law and just compensation, in violation of the United States Constitution.

Seeking to enjoin enforcement of the Act's $10,000 per year

limitation, plaintiffs brought this action in the United States

District Court for the District of Rhode Island in July of 1995,

naming as defendants the Retirement Board of the Rhode Island

Employees' Retirement System (the "Board") and Nancy Mayer and

Joann Flaminio, in their official capacities. See 42 U.S.C.

§ 1983. The district court denied plaintiffs' request for an

order temporarily restraining defendants from implementing or

enforcing the Act and, following an evidentiary hearing, the

court denied plaintiffs' request for a preliminary injunction,

concluding that plaintiffs had failed to demonstrate that they

would suffer irreparable injury in the absence of a preliminary

2 injunction.1 The court noted, however, that it believed

plaintiffs were likely to prevail on the merits. Shortly

thereafter, the case was transferred to this district upon

recusal of the judges in the District of Rhode Island.

In August of 1996 Congress enacted the Small Business Job

Protection Act of 1996 which, among other things, amended § 415

of the Internal Revenue Code retroactively to December 3 1 , 1994.

The parties agree that the amendments to § 415 permit ERS and the

Board to reinstate plaintiffs' full retirement benefits and

reimburse plaintiffs all amounts which were withheld pursuant to

the Act, without risk that such payments might jeopardize ERS's

federal tax status. Accordingly, on September 6, 1996,

plaintiffs filed a motion for interim relief, seeking an order

compelling defendants to resume paying each class member the full

vested monthly retirement benefit to which he or she is entitled

and to reimburse each class member for the retirement benefits

1 Because the court found that defendants had the financial ability to compensate plaintiffs if plaintiffs should ultimately prevail, it concluded that they were not likely to suffer "irreparable injury." Implicit in that finding is the notion that defendants could and would compensate plaintiffs fully for the harm they suffered, if plaintiffs prevailed. Presumably, such full and adequate compensation would include the payment of interest for the period of time during which defendants wrongfully withheld plaintiffs' vested pension benefits. As will be seen, it is that obligation to pay interest which is currently at issue.

3 which were withheld during the pendency of this litigation. Defendants did not oppose the requested relief. Approximately two months later, defendants resumed paying plaintiffs their full vested monthly retirement benefits, and paid all past benefits which had been withheld.

The parties' basic dispute has, therefore, been resolved and plaintiffs' request for prospective injunctive relief is moot. Plaintiffs now move for an order compelling defendants to pay them additional compensation, in the form of prejudgment interest. They claim that such an award is necessary to fully and adequately compensate them for the harm they suffered when, prior to October of 1996, defendants wrongfully withheld their annual pension benefits in excess of $10,000. Defendants object, asserting that the court may not award prejudgment interest against a state in a § 1983 action when the plaintiffs' claims for injunctive relief are moot and there is no continuing constitutional violation. The legally significant facts are undisputed and the parties agree that the issues presently before the court involve only questions of law.

4 Discussion As a preliminary matter, the court first notes the somewhat

unusual procedural posture of this case. Although the substance

of the parties' dispute has been fully resolved, the court still

must determine whether plaintiffs would have prevailed if

Congress had not amended § 415 of the Internal Revenue Code and

if ERS had not reinstated plaintiffs' vested benefits, in order

to resolve plaintiffs’ claim for prejudgment interest.

Secondly, as a practical matter, the court cannot help but

wonder why the Board is even contesting the plaintiffs' right to

prejudgment interest. As trustee of the retirement funds, the

Board of course owes a fiduciary duty to these beneficiaries and

surely must appreciate that, absent payment of compensatory

prejudgment interest, ERS would stand unjustly enriched at

plaintiffs' expense (ERS having invested and presumably earned

interest on the very benefits that were withheld — even from

defendants’ perspective the benefits were withheld only because

the trustees felt compelled to do so under federal tax law and

then-applicable provisions of the Act, or so they s a y ) . Putting

ERS's legal defenses to one side for the moment, surely

defendants must agree that plaintiffs (as beneficiaries of the

ERS trust) have a superior equitable right to the interest earned

5 on their money during the period that defendants withheld their pension payments. Besides, even if the law did provide ERS with legal immunity from a federal court order to pay interest to these pensioners, certainly no available legal defense would preclude the trustees from doing the right and equitable thing for ERS’s beneficiaries.

Nevertheless, whether the Board ought to voluntarily pay interest or whether it ought instead to try to interpose the state's immunity in an effort to sidestep the payment of interest earned at the expense of its pensioners, despite its fiduciary obligations, are not issues properly before the court.

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