Teamsters Local 97 v. State of New Jersey, 434 N.J. Super. 393

Background

consolidated appeals involve public employees challenging 2010 chapters reforming pensions and health benefits (Chs. 1–3).
Chapter 1 changes retirement calculations for new Police and Firemen's Retirement System members to a three-year average.
Chapter 2 imposes a 1.5% minimum health-benefits contribution for active and retired employees and expands local-employee cost-sharing via a Section 8-style applicability structure, with local impact.
Chapter 3 limits unused sick leave payout and vacation carryover for certain local officials and employees.
The trial court dismissed the complaints for failure to state a claim; plaintiffs appeal seeking invalidation as unconstitutional.
Chapter 78 (2011) later superseded parts of Chapter 2’s provisions, including the design-committee authority over plans.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Chapter 2’s 1.5% contribution violates Article I, Paragraph 19.	FMBA/Teamsters claim it infringes public employees' right to organize and bargain.	State Defendants contend Legislature preempted bargaining and that contributions are constitutional.	Chapter 2 constitutional; mootness applies to Section 8; 1.5% upheld.
Whether Chapter 2’s 1.5% contribution and Section 8 Applicability Provision violate equal protection.	1.5% unfairly targets certain employees and coverage types.	Legislation rationally related to controlling health-care costs and ensuring program viability.	Rational basis; equal protection upheld.
Whether the 1.5% contribution violates the Federal and State Contracts Clauses.	CNAs are impaired by ongoing law changes.	Legislation reasonably and necessarily serves important public interests.	No substantial impairment; upheld.
Whether Chapter 1’s final-compensation change for new PFRS members is constitutional.	New-enrollee distinction creates arbitrary classifications.	Rational delineation to preserve plan viability and reduce costs.	Constitutionality sustained.
Whether Legislative immunity and the Speech or Debate Clause require dismissal of claims against Senate/Assembly members.	Constitutional challenges implicate legislative actions; officials should be named.	Claims against legislators are unnecessary; controversy resolved by State defendants.	Court declines to resolve; affirm existing ruling; unnecessary to reach issue.

Key Cases Cited

Printing Mart-Morristown v. Sharp Elecs. Corp., 116 N.J. 739 (1989) (standard for evaluating Rule 4:6-2(e) dismissals)
Banco Popular N. Am. v. Gandi, 184 N.J. 161 (2005) (consideration of public-record materials in motions to dismiss)
Edwards v. Prudential Prop. & Cas. Co., 357 N.J. Super. 196 (2003) (allegations, attached docs, and public records in evaluating complaints)
J.D. ex rel. Scipio-Derrick v. Davy, 415 N.J. Super. 375 (2010) (dismissing constitutional challenges when pleadings fail to state a claim)
N.J. Sports & Exposition Auth. v. McCrane, 61 N.J. 1 (1972) (deference to legislative decisions in constitutional challenges)
Trautmann ex rel. Trautmann v. Christie, 211 N.J. 300 (2012) (presumption of constitutionality; substantial deference to legislature)
Brown v. State, 356 N.J. Super. 71 (2002) (limitations on benefits to preserve state resources)
Romero v. Evans, Romer v. Evans not cited in exact form; included here for context (N/A) (not used as a primary citation in this opinion)