Richmond State Hospital v. Brattain
2012 Ind. LEXIS 16
| Ind. | 2012Background
- Indiana maintained a split-pay system for over 25 years that paid some employees for 40 hours and others for 37.5 hours, creating an hourly wage disparity despite identical biweekly pay.
- The State ended the split-pay policy in 1993, and a class action was brought on behalf of the 40-hour employees seeking back pay and other relief.
- The Court of Appeals detailed the litigation history and adopted key findings; the Indiana Supreme Court granted transfer and split into opinions but sought resolution on laches.
- For merit employees, the Court of Appeals held back pay from ten days before complaint or grievance filing until the elimination of the split-pay system; for non-merit employees, back pay spanned roughly twenty years.
- Four Justices participated with a 2-2 division; the Supreme Court summarily affirmed in part and limited damages for non-merit claims under laches, directing recalculation.
- The Court concluded that laches limits non-merit back pay but not all merit claims, remanding for recalculation consistent with laches-based time limits.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does laches bar all claims? | Brattain argues laches should not bar all claims. | State argues laches should bar all claims. | Laches does not bar all claims; it limits non-merit back pay only. |
| Whether merit employees' back pay period is properly limited to ten days before filing/grievance or until elimination of split-pay. | Brattain seeks broader back pay exposure prior to filing/grievance. | State contends statutory/administrative timelines support extension. | Back pay for merit employees is limited to the ten-day pre-filing window and ends with elimination of the split-pay system. |
| Whether non-merit employees' back pay should be limited by laches to a similar time frame as merit employees. | Brattain argues full constitutional claims dating long ago are recoverable. | State asserts laches should bar late claims and cap damages. | Non-merit back pay is limited by laches to a timeframe comparable to merit claims; damages remanded for recalculation. |
Key Cases Cited
- Arden v. State Employees' Appeals Comm'n, 578 N.E.2d 769 (Ind.Ct.App.1991) (foundational for split-pay illegality guiding timeliness)
- Collins v. Day, 644 N.E.2d 72 (Ind.1994) (established test for Equal Privileges Clause claims)
- SMDfund, Inc. v. Fort Wayne-Allen Cty. Airport Auth., 831 N.E.2d 725 (Ind.2005) (laches as a remedy-restricting defense in claims)
- Bishop II, 741 N.E.2d 1229 (Ind.2001) (ten-day notice requirement to correct employment conditions)
- Cornetta v. United States, 851 F.2d 1372 (Fed.Cir.1988) (prejudice from back pay not required; military context framework discussed)
- Occidental Life Ins. Co. v. EEOC, 432 U.S. 355 (U.S. Supreme Court 1977) (back-pay damages may be restricted to avoid prejudice to government)