Patricia Batista v. Office of Retirement Services, 29 N.W.3d 115

Plaintiffs were Michigan public school superintendents and administrators hired under personal employment contracts, not collective bargaining agreements (CBAs).
The Office of Retirement Services (ORS) calculated pension benefits using its own "normal salary increase" (NSI) schedules for such employees, excluding some annual pay increases from pension calculations.
Plaintiffs filed suit, alleging ORS lacked statutory authority to create and apply these NSI schedules and that this resulted in improper pension calculations.
The Court of Claims mostly sided with ORS, the Court of Appeals reversed (finding ORS lacked authority for NSI schedules), and the Michigan Supreme Court affirmed in part, reversed in part, and further clarified the law.
Central to the dispute is the meaning of "normal salary schedule" in MCL 38.1303a(3)(f), specifically whether it is exclusive to CBA-covered employees, and whether any employee outside a CBA may rely on such a schedule for crediting salary increases in pension calculations.
The Supreme Court clarified the definition of "normal salary schedule," found ORS lacked authority to create its own, and remanded to determine if plaintiffs’ contracts or job classifications met the new legal definition.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does "normal salary schedule" in MCL 38.1303a(3)(f) only refer to CBAs?	Yes; only CBA-covered employees can use such schedules for pension credit.	No; all employees may be covered, not just those under CBAs.	No; "normal salary schedule" is not limited to CBAs. Can be established by statute or governing body for any job classification.
Can ORS create its own "normal salary increase" schedules for use in pension calculation?	No; not statutorily authorized.	Yes; necessary to administer the retirement system.	No; ORS lacks statutory authority to create/implement its own NSI schedules.
May annual compensation increases under contracts outside a CBA be included in retirement calculations?	Should be included if consistent with a "normal salary schedule."	Not unless increases are provided by a "normal salary schedule" per statute.	Only if increases are provided for in a "normal salary schedule" as defined (written, approved, applies to job classification, not individual).
How are pension increases calculated when a job classification has fewer than three members?	Use a similar schedule from the same or comparable reporting unit.	Same; rely on the statute's language for "most nearly identical job classification."	Statute authorizes using the normal salary schedule for the closest job classification inside or outside the district.

Brackett v. Focus Hope, Inc., 482 Mich 269 (Mich. 2008) (guides use of contemporaneous dictionaries for undefinied statutory terms)
Johnson v. VanderKooi, 502 Mich 751 (Mich. 2018) (review of summary disposition is de novo)
Pinkney v. Michigan, 501 Mich 259 (Mich. 2018) (statutory interpretation principles)
Madugula v. Taub, 496 Mich 685 (Mich. 2014) (context is crucial in statutory construction)
Hegadorn v. Dep’t of Human Servs Dir, 503 Mich 231 (Mich. 2019) (de novo review for statutory interpretation)