Charles D. Easley v. Public Employees' Retirement System
222 So. 3d 1096
| Miss. Ct. App. | 2017Background
- From 1986–2000 Charles D. Easley served as a court‑appointed attorney in Lowndes County Chancery Court representing indigent respondents in commitment proceedings while maintaining a private practice.
- The chancery‑court order stated Easley was “entitled to a monthly salary of $450” approved by the Board of Supervisors; this order was the only written appointment evidence.
- Lowndes County reported Easley on IRS Form 1099‑MISC from 1986–1998 and on W‑2s for 1999–2000; his earnings were never reported to PERS and he never contributed to the system.
- PERS concluded Easley was an independent contractor and denied membership/service credit; the Board’s Claims Committee upheld that decision after a hearing.
- Hinds County Circuit Court affirmed the Board’s denial; Easley appealed to the Court of Appeals arguing the decision was arbitrary, exceeded PERS’s authority, and violated due process.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether PERS’s denial was arbitrary or capricious | Easley argued he should receive PERS credit for his court‑appointed service | PERS argued substantial evidence showed an independent‑contractor, part‑time arrangement not qualifying for membership | Court held PERS decision was supported by substantial evidence and not arbitrary or capricious |
| Whether PERS exceeded authority by restricting chancery court appointments | Easley argued PERS’s ruling limited the chancery court’s statutory power to appoint counsel | PERS said its determination concerned employee status for retirement, not the chancery court’s appointment authority | Court held PERS did not exceed authority and did not impair the court’s appointment power |
| Whether attorney general’s role as hearing officer violated due process | Easley contended the AG’s office improperly investigated and adjudicated, creating bias | PERS/AG argued hearing officers are presumed impartial; dual investigative/adjudicative roles are permissible absent evidence of bias | Court held no evidence of bias; AG participation did not violate due process |
| Whether Easley was an employee under PERS statutes | Easley implied county payments and benefits indicated employee status | PERS relied on control factors, 1099 classification, intermittent assignment, and statutory discretion to exclude part‑time/intermittent workers | Court held factual record supported finding Easley was not a PERS employee |
Key Cases Cited
- Vaughn v. Pub. Emps’ Ret. Sys. of Miss., 182 So. 3d 433 (administrative‑decision review standards)
- Dishmon v. Pub. Emps’ Ret. Sys., 797 So. 2d 888 (presumption in favor of PERS rulings)
- Chisolm v. Miss. Dep’t of Transp., 942 So. 2d 136 (employee v. independent contractor: right to control test)
- Stamps v. Pub. Emps’ Ret. Sys., 898 So. 2d 664 (presumption of impartiality for hearing officers; due‑process standards)
- United Cement Co. v. Safe Air for the Env’t Inc., 558 So. 2d 840 (no inherent conflict in assistant attorney general serving as hearing officer)