Inagawa v. Fayette County
291 Ga. 715
| Ga. | 2012Background
- Inagawa, Fayette County Solicitor-General, filed mandamus alleging underpayment of compensation since July 1, 2007.
- The 1994 Act set SG compensation at 75% of the State Court judge’s salary, with the judge’s salary tied to 85% of a superior court judge’s base salary.
- From 2007, the County raised the State Court judge’s supplement substantially while SG’s $5,000 supplement remained unchanged.
- The 2008 Act amended SG compensation to 68% of the judge’s base salary and adjusted the judge’s compensation to 90% of base plus 90% Griffin Circuit supplement, effective upon Governor’s approval.
- Inagawa argued the 2008 Act would unlawfully reduce his compensation during his term, making the Act void at inception and restoring the pre-2008 framework; the trial court found backpay owed from July 1, 2007 to January 1, 2009.
- The Higher Court held the 2008 Act’s effective date fixed by its plain text, invalidated the local amendment that reduced SG pay, and remanded to calculate backpay consistent with the 1994 Act.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| How to calculate SG compensation under the 1994 Act | Inagawa: use 75% of judge’s total compensation (salary + supplement) | County: use 75% of judge’s base salary only (excluding supplement) | SG compensation includes supplements; use total compensation as the basis |
| Validity and effective date of the 2008 Act conflicting with state law | Inagawa: 2008 Act would reduce pay during term; invalid at inception | County: 2008 Act valid as enacted | Section 2 of the 2008 Act invalid; 1994 Act remains controlling; 2008 Act cannot reduce pay during a term |
| Remedy and backpay calculation | Backpay owed from July 1, 2007; based on 1994 Act | Remand to calculate backpay with interest under the 1994 Act |
Key Cases Cited
- Savage v. City of Atlanta, 242 Ga. 671 (1978) (invalid local law conflicting with general statute calling for future-term effective increases)
- City of Atlanta v. Hudgins, 193 Ga. 618 (1942) (general laws prevail over conflicting local laws)
- Bible v. Bible, 259 Ga. 418 (1989) (plain language requires no judicial construction when language is unequivocal)
- Evans v. Employees’ Retirement System of Ga., 264 Ga. 729 (1994) (clarifies plain-language interpretation in statutory context)
- Thompson v. Talmadge, 201 Ga. 867 (1947) (presumes distinct meanings for similar terms when not explicitly defined)