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Metcalfe v. State

EMPLOYMENT LAW

Clara Nieman

In Metcalfe v. State, 484 P.3d 93 (Alaska 2021), the supreme court held that repeal of the statutory reinstatement right for former members of the public employee retirement benefits system diminished those members’ accrued benefits, in violation of the Alaska Constitution. (Id. at 95). Metcalfe was a former state employee who left public employment in 1981, taking a refund of his retirement contributions and leaving membership in the state retirement system. (Id. at 95–96). At the time, a statute allowed former members of the state retirement system who re-entered state employment and repaid their refunded contributions plus interest to be reinstated in the retirement system. (Id. at 96). In 2005, the legislature revoked the reinstatement right, and Metcalfe filed a complaint alleging that the revocation of the reinstatement violated article XII section 7 of the Alaska Constitution, which requires that accrued retirement benefits of state employees not be diminished or impaired. (Id.). The superior court certified the case as a class action and granted the State’s motion for summary judgment. (Id. at 97). On appeal, the State argued that the relevant constitutional provision should only apply to retirement system members in their retirement, that Alaska should follow California case law on this matter, that the relevant constitutional provision applied to a contractual relationship which did not exist between the State and its former employees, and that former retirement system members should be distinguished from active members. (Id. at 99–100). The supreme court reasoned that Metcalfe and other former state employees reasonably relied upon the reinstatement statute when making employment decisions, and that the benefit was accrued as soon as Metcalfe enrolled in the retirement system. (Id. at 98–99). Therefore, the revocation of the reinstatement right was a diminishment of Metcalfe’s accrued benefits, in violation of the Alaska Constitution. (Id.). Reversing the lower court’s decision, the supreme court held that repeal of the statutory reinstatement right for former members of the public employee retirement benefits system diminished those members’ accrued benefits, in violation of the Alaska Constitution. (Id. at 102).

Metcalfe v. State

EMPLOYMENT LAW

Clara Nieman

In Metcalfe v. State, 484 P.3d 93 (Alaska 2021), the supreme court held that repeal of the statutory reinstatement right for former members of the public employee retirement benefits system diminished those members’ accrued benefits, in violation of the Alaska Constitution. (Id. at 95). Metcalfe was a former state employee who left public employment in 1981, taking a refund of his retirement contributions and leaving membership in the state retirement system. (Id. at 95–96). At the time, a statute allowed former members of the state retirement system who re-entered state employment and repaid their refunded contributions plus interest to be reinstated in the retirement system. (Id. at 96). In 2005, the legislature revoked the reinstatement right, and Metcalfe filed a complaint alleging that the revocation of the reinstatement violated article XII section 7 of the Alaska Constitution, which requires that accrued retirement benefits of state employees not be diminished or impaired. (Id.). The superior court certified the case as a class action and granted the State’s motion for summary judgment. (Id. at 97). On appeal, the State argued that the relevant constitutional provision should only apply to retirement system members in their retirement, that Alaska should follow California case law on this matter, that the relevant constitutional provision applied to a contractual relationship which did not exist between the State and its former employees, and that former retirement system members should be distinguished from active members. (Id. at 99–100). The supreme court reasoned that Metcalfe and other former state employees reasonably relied upon the reinstatement statute when making employment decisions, and that the benefit was accrued as soon as Metcalfe enrolled in the retirement system. (Id. at 98–99). Therefore, the revocation of the reinstatement right was a diminishment of Metcalfe’s accrued benefits, in violation of the Alaska Constitution. (Id.). Reversing the lower court’s decision, the supreme court held that repeal of the statutory reinstatement right for former members of the public employee retirement benefits system diminished those members’ accrued benefits, in violation of the Alaska Constitution. (Id. at 102).