Robert D. Rossignol v. Maine Public Employees Retirement System, 144 A.3d 1175

Robert D. Rossignol was a special education teacher at RSU 14 (SEA) from Aug 2009 to Apr 15, 2010; SEA did not renew his probationary contract after reports of classroom management problems.
In Jan 2011 Rossignol applied to MPERS for disability retirement, alleging major depressive disorder, generalized anxiety disorder, and panic attacks; he later sought to add PTSD but does not appeal that denial.
The Executive Director’s designee denied benefits; Rossignol appealed to the MPERS Board, which held hearings over months and adopted a hearing officer’s recommended denial in Apr 2015.
The Board found Rossignol had major depressive disorder but concluded he had not shown the disorder (or proven anxiety/panic) made it impossible to perform his job as of his last date in service or that the incapacity was expected to be permanent.
The Superior Court affirmed the Board’s decision; Rossignol appealed to the Maine Supreme Judicial Court, which reviews the Board’s factual findings and will overturn only if the record compels a contrary conclusion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rossignol proved a mental or physical incapacity that is expected to be permanent and makes performance of his job impossible	Rossignol argued his major depressive disorder (and alleged anxiety/panic) were debilitating and rendered him unable to perform essential duties as of his last date in service	MPERS argued the record showed disputed facts, expert opinions undermining causal linkage to work impairment as of last date in service, and evidence of ongoing functional abilities and alternative causes (inexperience) for teaching problems	Court held the record did not compel finding of permanent incapacity making performance impossible; Board’s contrary factual weight determinations stand
Whether the proceedings were tainted by bias sufficient to overturn the administrative decision	Rossignol claimed hearing officer was biased to "serve" MPERS and that analysis lacked rationality	MPERS asserted presumption of good faith and that the Board’s supported factual findings do not show bias	Court rejected bias claim, finding allegations insufficient to overcome presumption of good faith

Anderson v. Me. Pub. Emps. Ret. Sys., 985 A.2d 501 (Me. 2009) (standard of review: appellate court reviews agency fact-finding and will vacate only if record compels contrary conclusion)
Friends of Maine’s Mountains v. Bd. of Envtl. Prot., 61 A.3d 689 (Me. 2013) (presumption of good faith for hearing officers and agencies)