Slaughter v. Louisiana State Employees’ Retirement System

In 2009, plaintiff Dr. Ralph Slaughter retired as president of Southern University System (“Southern”) after thirty-five years of service. Upon retirement, the Louisiana State Employees’ Retirement System (“LASERS”) began paying plaintiff retirement benefits. Plaintiff filed suit against Southern for past due wages. The district court ruled that Southern had miscalculated plaintiff’s income base by including supplemental pay plaintiff had received from the Southern University Foundation, and determined plaintiff’s terminal pay (500 hours of unused leave) and retirement should have been calculated only on his annual base salary due from Southern. The court of appeal affirmed on appeal, noting plaintiff “manipulated the system and used his position for his own benefit.” Southern sent a letter to LASERS advising it had committed an error in including supplemental funds in plaintiff’s earnings. Because plaintiff's lawsuit was ongoing at the time, LASERS filed a concursus proceeding seeking to deposit the disputed amount of plaintiff’s benefit in the registry of court pending resolution of the litigation. Plaintiff filed an exception of no cause of action. The district court granted the exception and dismissed the second suit with prejudice. LASERS did not appeal this judgment. After the first suit became final, LASERS sent correspondence to plaintiff advising it intended to retroactively reduce his retirement benefit starting June 1, 2012 “due to an error made by Southern University in the reporting of your earnings.” Relying on La. R.S. 11:192, LASERS maintained it could adjust benefits and further reduce the corrected benefit to recover overpayment within a reasonable number of months. Plaintiff then filed the instant suit against LASERS, seeking a writ of mandamus, injunctive relief, and a declaratory judgment confirming LASERS had no authority or ability to reduce his retirement benefits. The petition alleged plaintiff’s retirement benefits should have been calculated based on the entirety of his earnings over thirty-five years of employment, including salary supplements. The Supreme Court was called on to determine whether the lower courts erred in finding the defendant retirement system failed to prove that it followed the proper procedure before initiating action to reduce and recoup plaintiff’s retirement benefits. The Court found the lower courts did not apply the proper statutory analysis and reached an erroneous result. The case was remanded for further proceedings. View "Slaughter v. Louisiana State Employees' Retirement System" on Justia Law