Thomas v. State Retirement & Pension System
21 A.3d 1042
| Md. | 2011Background
- Thomas, a retired Maryland State Police officer, seeks special disability retirement benefits under Md. Code Ann., State Pers. & Pens. (SPP) §29-111(b)(1).
- MSP relied on Special Order 23-0001 (2000) instituting uniform auditing procedures; Thomas acknowledged receipt but did not comply.
- Disciplinary proceedings were initiated in 2001 for neglect and falsification of audit reports; he entered therapy for depression, anxiety, and agitation related to the proceedings.
- Thomas retired in 2003 amid ongoing disciplinary and legal action; medical opinions evolved from Adjustment Disorder to Major Depressive Disorder.
- SRPS Medical Board recommended ordinary disability benefits but denied special disability benefits, concluding the disability did not arise from duty and, alternatively, that it resulted from willful negligence.
- An Administrative Law Judge and later the SRPS Board found Thomas’s depression arose from his willful negligence in failing to follow new procedures; the Board denied special disability benefits and the circuit courts affirmed the denial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether willful negligence bars special disability benefits | Thomas argues willful negligence does not apply to a disease triggered by disciplinary stress | The Board and ALJ held that willful neglect of duties and noncompliance with procedures trigger the bar | Yes; willful negligence bars eligibility for special disability benefits |
Key Cases Cited
- Grasslands Plantation, Inc. v. Frizz-King Enters., LLC, 410 Md. 191 (2009) (agency deference; review standard for agency decisions)
- Bd. of Physician Quality Assurance v. Banks, 354 Md. 59 (1999) (deference to agency interpretations of statutes)
- Marzullo v. Kahl, 366 Md. 158 (2001) (agency deference; review of agency interpretations)
- Ins. Comm’r v. Engelman, 345 Md. 402 (1997) (agency decision review; limits of legal error acceptance)
- Thomas v. State Ret. & Pension Sys. of Md., 184 Md.App. 240 (2009) (cited for conflict/complication in disability eligibility)