Goodrich v. Maine Public Employees Retirement System, 48 A.3d 212

Ellen Goodrich never received an application form for basic life insurance when she first became eligible in 1995, so no enrollment or premium deductions occurred and she became uninsured.
The System later notified Goodrich in 2006 that it could not determine initial eligibility and offered to reinstate coverage if she paid back premiums, filed evidence of insurability, or waited for open enrollment; she did not respond within 30 days.
Goodrich in 2007 applied for coverage but declined back payments; in 2008 the insurer deemed her uninsurable; in 2008 the System denied prospective coverage without back premiums or insurability proof.
The Board in 2010 denied coverage, ruling Goodrich had refused coverage by not timely responding and by failing to provide evidence of insurability.
The Superior Court held that the 2006 offer did not constitute a written refusal and invalidated Rule 601 and the back-premiums requirement, ordering prospective coverage without insurability or back payments.
The Court of Appeals vacated the Rule 601 invalidity portion, affirmed the rest, and remanded with instructions to provide Goodrich basic coverage while requiring back premiums to be paid to retroactively restore eligibility.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the statute creates unconditional automatic coverage.	Goodrich argues entitlement is unconditional upon eligibility.	System contends limitations and opt-out rules affect entitlement.	Unconditional coverage exists; opt-out required in writing to relinquish.
Whether failure to file within 31 days or opt-out constitutes a waiver.	No written waiver occurred; Goodrich did not opt out in writing.	Any nonresponse plus later actions constitutes a refusal/waiver.	Written waiver is required; failure to respond does not equal a written opt-out.
Whether Rule 601 and the 2006 offer are invalid due to statutory scheme.	Rule 601 and 2006 offer align with statutory entitlement.	The procedures conflict with automatic coverage rules.	Rule 601 can be reconciled; the invalidity portion is vacated, allowing retroactive restoration.
What remedy should apply for retroactive entitlement and back premiums.	Should be retroactive to initial eligibility without back premiums.	Back premiums must be paid; coverage can be restored prospectively.	Retroactive restoration is available upon payment of back premiums; prospective coverage can be provided.

FPL Energy Me. Hydro LLC v. Dep't of Envtl. Prot., 2007 ME 97 (Me. 2007) (statutory interpretation and agency-review standard)