Nason v. State Employees' Retirement System
290 Mich. App. 416
| Mich. Ct. App. | 2010Background
- Petitioner Murphy, a corrections officer, suffered a non-duty-related injury (shattered right calcaneus) while on vacation in 2006 and sought non-duty disability retirement benefits under MCL 38.24.
- Initial application was denied by SERS; Murphy then requested a hearing under the APA, resulting in a hearing referee’s proposal for decision awarding benefits.
- SERS challenged the referee’s recommendation; the Board issued a separate ruling denying Murphy benefits, applying Knauss to allow consideration of employment beyond the state job.
- The circuit court reversed the Board, remanding for entry of an order granting Murphy’s non-duty disability retirement benefits, focusing on Murphy’s experience and training in prior jobs.
- The Michigan Court of Appeals vacated the circuit court’s order and remanded, holding that MCL 38.24(1)(l)(b) requires consideration of total incapacitation only with respect to the state job from which Murphy seeks retirement, not other positions.
- This opinion concludes that Knauss is disavowed and remands to the Board to determine whether Murphy is totally incapacitated relative to his state job.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does MCL 38.24(1)(b) limit 'total incapacitation' to the state job from which retirement is sought? | Murphy: only the state job matters; other jobs are irrelevant. | SERS: broader interpretation allowed by prior decisions. | Yes; duty refers to the state job only. |
| Is Knauss controlling, or should it be overruled in interpreting § 24? | Knauss supports broad view of total disability. | Knauss is not binding and conflicts with plain § 24 language; should be disavowed. | Knauss is disavowed. |
| Should the case be remanded to address whether Murphy is totally incapacitated relative to his state job? | Remand unnecessary if statutory interpretation is clear. | Remand is required to apply the correct statutory interpretation to Murphy’s state job. | Remand to Board for a direct determination on total incapacitation relative to the state job. |
Key Cases Cited
- Knauss v State Employees’ Retirement Sys, 143 Mich App 644; 372 NW2d 643 (1985) (Mich App 1985) (discussed total disability interpretation and duty-related vs non-duty)
- VanZandt v State Employees’ Retirement Sys, 266 Mich App 579; 701 NW2d 214 (2005) (Mich App 2005) (reliance on Knauss elements in a non-duty disability context)
- Chalmers v Metro Life Ins Co, 86 Mich App 25; 272 NW2d 188 (1978) (Mich App 1978) (three views of total disability in insurance context)
- Herring v Golden State Mut Life Ins Co, 114 Mich App 148; 318 NW2d 641 (1982) (Mich App 1982) (related to intermediate interpretation of total disability)
- Zwiers v Growney, 286 Mich App 38; 778 NW2d 81 (2009) (Mich App 2009) (statutory construction principles guiding interpretation)