Kuna Rural Fire District v. Public Employee Retirement System of Idaho Board

Summary

The Idaho Supreme Court affirmed the district court’s decision requiring Kuna Rural Fire District to continue making additional contributions to the Firefighters’ Retirement Fund through PERSI. The court held that an entity qualifies as an “employer” under Idaho Code section 59-1391(e) if it employed a participating paid firefighter on October 1, 1980, and that status does not end when the firefighter later retires or becomes ineligible for benefits. The court awarded costs to PERSI.

Holdings

1. Idaho Code section 59-1391(e) defines an employer as a city or fire district that employed a paid firefighter participating in the Firefighters' Retirement Fund on October 1, 1980. Because Kuna employed Maus, who was participating in the fund on that date, Kuna remained an employer required to make additional contributions under section 59-1394, and Maus's later retirement and refund of contributions did not terminate that obligation.
2. The district court correctly affirmed the PERSI Board's final order requiring Kuna to continue making additional contributions.

Questions Presented

1. Whether Idaho Code section 59-1391(e) defines an employer based on the entity's employment of a paid firefighter participating in the Firefighters' Retirement Fund on October 1, 1980, such that the employer remains obligated to make additional contributions after that firefighter leaves employment and becomes ineligible for benefits.
2. Whether the district court properly affirmed the PERSI Board's interpretation and order under the Idaho Administrative Procedure Act.

Disposition

affirmed