Cal Fire Local 2881 v. Cal. Pub. Employees' Ret. Sys.

Summary

The California Supreme Court considered whether public employees acquired an implied vested contractual right to purchase additional retirement service credits under Government Code section 20909. The court concluded that the opportunity was accepted through election and payment of the statutory purchase price, not merely through entering or continuing public employment, and therefore was not protected from later alteration or revocation by the California Constitution's contract clause. The document includes a concurring opinion explaining the contract-law basis for that conclusion.

Holdings

1. The statutory opportunity to purchase additional retirement service credit was not a vested contractual right protected by the Contract Clause.
2. Because no constitutionally protected contractual right to continued access to ARS credit existed, its elimination did not implicate or violate the Contract Clause.

Questions Presented

1. Whether the statutory opportunity for public employees to purchase additional retirement service credit constituted a vested contractual right protected by the Contract Clause of the California Constitution.
2. Whether the elimination of the ARS-credit opportunity constituted an unconstitutional impairment of public employees' contractual rights.

Disposition

affirmed