E. Yale (Account of F. Yale) v. SERS, 178 C.D. 2016

Frank Yale (decedent) retired from Pennsylvania State Police on Jan. 5, 1991, electing Option 1 annuity and naming his wife, Eleanor Yale, as beneficiary.
Option 1 guarantees a present-value pool; if member dies before receiving the present value, remaining balance is paid to beneficiary; payments continue to member for life even after present value is exhausted.
Yale withdrew his member contributions as a lump sum at retirement; the Commonwealth portion funded the monthly lifetime annuity.
By the time of Yale’s death (June 4, 2013), he had received $372,625.48 more than the original present value; SERS paid only a prorated final monthly check to Eleanor.
Petitioner asserted claims that SERS’ failure to require spousal sign-off (1) constituted sex discrimination under federal and state constitutions, (2) violated ERISA, and (3) violated the Divorce Code/equitable lien principles.
The Board (adopting the hearing officer) denied relief; the Commonwealth Court affirmed, finding no statutory or constitutional entitlement to additional survivor benefits.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Petitioner is entitled to additional survivor benefits from Decedent's SERS account	Yale: SERS should have required spousal sign-off; she thus has an entitlement to benefits / equitable interest	SERS: Option 1 election was valid and irrevocable; account was exhausted so no death benefit existed	Held: No additional benefits — Option 1 exhausted; no statutory survivor entitlement
Whether failure to require spousal consent is sex discrimination under federal or PA Constitution	Yale: Lack of required sign-off disproportionately burdens wives and violates Equal Rights Amendment / federal equal protection	SERS: Benefit rules apply equally to all members regardless of gender; no gender-based classification exists	Held: No discrimination — statute and practice gender-neutral; claim fails
Whether ERISA protections/consent rules apply	Yale: ERISA requires spousal protections/consent that would have preserved her interest	SERS: ERISA does not apply to governmental plans like SERS	Held: ERISA inapplicable to SERS; claim fails
Whether Decedent's SERS pension was marital property under Divorce Code / created an equitable lien	Yale: Divorce Code provides spousal marital interest or equitable lien in pension	SERS: No such right when spouses remain married at death; Retirement Code governs rights	Held: Divorce Code argument rejected — no marital interest/enforceable lien given facts

Teti v. State Employees’ Retirement Board, 981 A.2d 399 (Pa. Cmwlth. 2009) (Retirement Code benefits are personal to member; spouse has no automatic consent/right)
Weaver v. Harpster, 975 A.2d 555 (Pa. 2009) (declined to invalidate gender-neutral statute under the Equal Rights Amendment)
Hoffman v. Pennsylvania State Employees Retirement Board, 743 A.2d 1014 (Pa. Cmwlth. 2000) (No spousal right to SERS death benefit created by statute)
Cosgrove v. State Employees’ Retirement Board, 665 A.2d 870 (Pa. Cmwlth. 1995) (statutory scheme governs member rights to SERS benefits)