Awdziewicz v. City of Meriden

Summary

The Connecticut Supreme Court affirmed a judgment for the City of Meriden in a dispute concerning retired police officers’ and firefighters’ health insurance pension benefits. The court held that the applicable city charter provision and stipulated judgment permitted the city to impose on retirees a health insurance cost-share requirement corresponding to that imposed on active employees. The court also rejected or declined to reach the plaintiffs’ constitutional, evidentiary, implied-covenant, and statutory claims.

Holdings

1. Section 85D and the 1982 stipulated judgment, read together, plainly and unambiguously permitted the City to impose on retirees a health-insurance cost-sharing requirement proportionate to the requirement imposed on active Meriden police officers and firefighters.
2. The plaintiffs could not prevail on their federal due process and equal protection claims because the City’s imposition of the cost share did not violate § 85D or the stipulated judgment.
3. The trial court did not abuse its discretion by excluding evidence concerning additional benefits provided under the 2002 collective bargaining agreements because those benefits were immaterial to whether the cost share itself was authorized by § 85D and the stipulated judgment.
4. The trial court properly declined to address the plaintiffs’ § 7-450c claim because the plaintiffs did not plead that statutory claim or otherwise give the City timely notice of it; judicial notice could not cure the pleading defect.

Questions Presented

1. Whether § 85D of the prior Meriden City Charter and the 1982 stipulated judgment permitted the City to impose on retired police officers and firefighters the health-insurance cost-sharing requirement adopted for active employees.
2. Whether the City’s imposition of the cost-sharing requirement violated the plaintiffs’ federal due process and equal protection rights.
3. Whether the trial court properly excluded evidence concerning additional pension benefits in the collective bargaining agreements.
4. Whether the trial court properly declined to address the plaintiffs’ claim under General Statutes § 7-450c because that statutory claim was not pleaded or otherwise brought to the City’s notice.
5. Whether the plaintiffs’ implied-covenant, state constitutional, and attorney-fee claims required further consideration.

Disposition

affirmed