Brick Township Pba Local 230 and Michael Spallina Vs., 140 A.3d 577

Plaintiff Brick Township PBA Local 230 and member Michael Spallina sued for a declaratory judgment after the Township required Spallina to continue contributing to retiree health insurance premiums following his accidental disability retirement.
Spallina was a Township police officer (1994–2012) who sustained line-of-duty injuries in January 2011 and was granted accidental disability retirement effective October 1, 2012.
The Township relied on Chapter 78 of P.L. 2011, c. 78 (N.J.S.A. 40A:10-21.1), enacted June 28, 2011, to require contributions from retirees absent specified exemptions.
The collective negotiations agreement (CNA) between PBA Local 230 and the Township referenced Chapter 78 and stated retirees would not have premium-sharing responsibilities except as provided by Chapter 78.
The trial court granted summary judgment for the Township, concluding Chapter 78’s contribution requirement applied to Spallina because he had fewer than 20 years’ service on the statute’s effective date.
The Appellate Division reviewed statutory interpretation de novo and considered legislative history and agency guidance in addition to the statute’s plain language.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Chapter 78 requires disability retirees to contribute to retiree health insurance premiums	Chapter 78 does not apply to retirees who retired solely due to disability; disability retirees are excluded	Chapter 78 applies to retirees generally; only those with 20+ years of service on the effective date are exempt, so Spallina ( <20 yrs) must contribute	Reversed: Chapter 78 does not apply to ordinary or accidental disability retirees; they are excluded from the contribution requirement
Whether Spallina is entitled to reimbursement for prior premium contributions	Spallina sought reimbursement for premiums already paid while retirement was on disability grounds	Township did not prevail below; trial court did not decide reimbursement after reaching statutory-interpretation ruling	Remanded for the trial court to address the reimbursement claim (not decided on appeal)

Commerce Bancorp, Inc. v. InterArch, Inc., 417 N.J. Super. 329 (App. Div. 2010) (statutory interpretation reviewed de novo)
Manalapan Realty, L.P. v. Twp. Comm., 140 N.J. 366 (1995) (trial court legal conclusions get no special deference)
DiProspero v. Penn, 183 N.J. 477 (2005) (ascertaining legislative intent from statutory language)
Tumpson v. Farina, 218 N.J. 450 (2014) (use ordinary meaning when interpreting statutes)
State v. Shelley, 205 N.J. 320 (2011) (no need for extrinsic aids when statute is clear)
DePascale v. State, 211 N.J. 40 (2012) (context on Chapter 78 and pension funding concerns)
Paterson PBA Local 1 v. City of Paterson, 433 N.J. Super. 416 (App. Div. 2013) (courts may consider agency practical interpretations)
Berg v. Christie, 436 N.J. Super. 220 (App. Div. 2014) (overview of State retirement system funding sources)
Sternesky v. Salcie-Sternesky, 396 N.J. Super. 290 (App. Div. 2007) (distinguishing ordinary vs. accidental disability retirement benefits)