Missouri Prosecuting Attorneys and Circuit Attorneys Retirement System v. Barton County

Summary

The Supreme Court of Missouri held that pension contributions required from counties under section 56.807 are included within the constitutional phrase "compensation of county officers" in article VI, section 11. Because that provision exempts such compensation increases from treatment as new or increased services under the Hancock Amendment, the statute did not violate the Missouri Constitution. The court reversed the trial court's judgment and remanded the case.

Holdings

1. Pension contributions made on behalf of county prosecutors and circuit attorneys are included within the phrase "compensation of county officers" in article VI, section 11.
2. Section 56.807 does not violate the Hancock Amendment to the extent it requires counties to make pension contributions for their prosecutors and circuit attorneys without state reimbursement.

Questions Presented

1. Whether article VI, section 11 of the Missouri Constitution excludes increases in the compensation of county officers from the Hancock Amendment's restrictions on unfunded state mandates.
2. Whether pension contributions made on behalf of county prosecutors and circuit attorneys constitute compensation of county officers under article VI, section 11.
3. Whether section 56.807 therefore violates the Hancock Amendment by requiring counties to make pension contributions without state reimbursement.

Disposition

reversed_and_remanded