CYNTHIA MEEKINS VS. STATE HEALTH BENEFITS COMMISSION (STATE HEALTH BENEFITS COMMISSION)
A-3182-19
| N.J. Super. Ct. App. Div. | Dec 6, 2021Background
- Cynthia Meekins worked in New Jersey public employment from 1985, joined PERS, and was employed by Rutgers from 2004 until lay-offs in 2015, 2016 (returned), and 2017.
- After the February 2017 layoff she maintained SHBP briefly via COBRA (Mar–Jul 2017), then took a private-sector job at Barnard and cancelled SHBP; she did not return to NJ public employment.
- On May 31, 2019 Meekins applied for early PERS retirement (effective June 1, 2019) based on age and service; SHBP retiree coverage would have begun July 1, 2019.
- The State Health Benefits Commission denied retiree SHBP coverage because Meekins had a gap in SHBP coverage from July 1, 2017 to July 1, 2019, and regulations require active coverage immediately prior to retirement.
- Meekins appealed administratively (requested contested case hearing) and then to the Appellate Division arguing statutory entitlement (25+ service years) and equitable estoppel based on alleged misadvice; the Appellate Division affirmed the Commission.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Eligibility for SHBP retiree coverage given lapse in active coverage | Meekins: with 31 years PERS service and statutory scheme, she should receive retiree SHBP coverage | Commission/State: statutes/regulations require active SHBP coverage immediately prior to retirement; a lapse disqualifies | Held: Affirmed — plain statutory/regulatory text requires coverage at retirement; lapse disqualifies Meekins |
| Equitable estoppel based on Division counselor's alleged misadvice in 2015 and lack of notice in 2017 | Meekins: she relied on counselor’s statements and lacked notice that losing active SHBP would bar retiree coverage | Commission/State: no detrimental reliance; counselor had no duty; Fact Sheet #11 and employer materials informed her of requirement | Held: Rejected — no evidence of detrimental reliance or affirmative duty; estoppel fails |
| Denial of contested case hearing | Meekins: requested contested case because factual disputes and reliance claims warranted hearing | Commission/State: facts undisputed and decision based on law; no hearing necessary | Held: Affirmed — Commission could resolve matter on undisputed facts and legal issues |
Key Cases Cited
- Barron v. State Health Benefits Com'n, 343 N.J. Super. 583 (App. Div. 2001) (interpreting retiree SHBP coverage under the 25-year statutory framework)
- Merin v. Maglaki, 126 N.J. 430 (1992) (agency interpretations entitled to deference unless plainly unreasonable)
- Saccone v. Bd. of Trs. of Police & Firemen's Ret. Sys., 219 N.J. 369 (2014) (statutory interpretation of administrative determinations is a question of law subject to de novo review)
- Tasca v. Bd. of Trs., Police & Firemen's Ret. Sys., 458 N.J. Super. 47 (App. Div. 2019) (equitable estoppel requires conduct inducing reliance and detrimental change of position)