Tibbles v. Teachers Retirement System of Georgia
297 Ga. 557
| Ga. | 2015Background
- Carol Tibbles retired after 31 years as a public school teacher and is a member of the Teachers Retirement System of Georgia (System).
- OCGA § 47-3-120(a)(2) requires computing a retiree’s annual allowance using the average compensation over “the two consecutive years of membership service producing the highest such average.”
- The System calculated Tibbles’s benefit using 24 consecutive calendar months (Feb 1992–Jan 1994) per its longstanding administrative rules and practice.
- Tibbles sued, arguing: (1) “two consecutive years” means 730 (or 731) consecutive days (i.e., any day-to-day 2-year span), and (2) “average compensation” means compensation paid (paycheck dates), not compensation earned.
- The trial court granted summary judgment to the System; the Supreme Court of Georgia affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Meaning of “two consecutive years” in OCGA § 47-3-120(a)(2) | “Two consecutive years” = 730 (or 731) consecutive days; period can start any day. | Means 24 consecutive calendar months (per System rules and statutory context requiring month-based remittance/payments). | Court: Statute reasonably means 24 consecutive calendar months; if ambiguous, System’s month-based interpretation is reasonable and entitled to deference. |
| Whether “average compensation” refers to compensation paid (paycheck dates) vs. compensation earned | Average compensation refers to compensation paid; therefore use paychecks falling within the pay period (Dec 5, 1991–Dec 4, 1993). | Average compensation refers to compensation earned during the statutory period as measured in months. | Court: Did not reach this issue because plaintiff had to prevail on both contentions; because first contention fails, claim fails. |
Key Cases Cited
- Chevron U.S.A. v. Natural Resources Defense Council, 467 U.S. 837 (establishes deference framework for agency statutory interpretation)
- United States v. Mead Corp., 533 U.S. 218 (agency implementation can receive Chevron-like deference even without notice-and-comment rulemaking)
- Barnhart v. Walton, 535 U.S. 212 (factors supporting deference include agency expertise, importance to administration, and careful consideration)
- National Cable & Telecommunications Assn. v. Brand X Internet Servs., 545 U.S. 967 (agency interpretations can have binding effect when authorized by statute)
- Cook v. Glover, 295 Ga. 495 (Georgia recognizes deference to administrative interpretations when Legislature commits resolution to the agency)
- Suttles v. Northwestern Mut. Life Ins. Co., 193 Ga. 495 (longstanding administrative practice can be controlling when statute is ambiguous)