Studier v. Michigan Public School Employees' Retirement Board

Summary

The Michigan Supreme Court considered whether public school retirees’ health care benefits were protected as “accrued financial benefits” under Const. 1963, art. 9, § 24, and whether MCL 38.1391(1) created a contractual right to those benefits. The Court held that health care benefits were neither accrued nor financial benefits within the meaning of the constitutional provision and that the statute did not create a contractual right. The Court affirmed the judgment for the defendants.

Holdings

1. Health-care benefits are not accrued financial benefits protected by Const. 1963, art. 9, § 24 because they neither accrue in the relevant sense nor constitute financial benefits as those terms were commonly understood when the Constitution was ratified.
2. MCL 38.1391(1) does not create a contractual right to public-school-retiree health-care benefits subject to protection under Const. 1963, art. 1, § 10, or U.S. Const. art. I, § 10.

Questions Presented

1. Whether public-school-retiree health-care benefits are accrued financial benefits protected from diminishment or impairment by Const. 1963, art. 9, § 24.
2. Whether MCL 38.1391(1) creates a contractual right to public-school-retiree health-care benefits that later legislation or plan amendments cannot constitutionally impair.

Disposition

affirmed