Justia Public Benefits Opinion Summaries

Articles Posted in Contracts
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The Maryland State Retirement System (System) filed a claim against Milliman, an actuary, asserting that Milliman had understated the contributions required to fund three of the State's ten retirement and pension systems because of Milliman's misinterpretation of a particular data code. The Retirement System Procurement Officer determined that Milliman had failed to comply with its contractual duties and awarded damages to the System. On appeal, the State Board of Contract Appeals determined that the actuary had substantially breached its contracts with the System and affirmed the damages. The circuit court affirmed the Board's findings that Milliman breached its contracts with the System and affirmed the award of lost investment earnings but reversed the Board's award of amounts equaling lost contributions. The Supreme Court granted certiorari, holding (1) Milliman was liable to the System for repeatedly misinterpreting a data code; (2) the System was not negligent in the development or transmission of data provided to Milliman and, therefore, contributory negligence did not bar the System's recovery; and (3) the circuit court erroneously reduced the Board's damage award representing lost contributions. The Court, therefore, vacated the judgment of the circuit court and affirmed the Board's decision.

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Donovan Donald (Don) was incapacitated in an accident and received several treatment in Kalispell Regional Medical Center (KRMC). Later, a dispute arose between Don's estate and KRMC over KRMC's acceptance or rejection of Medicaid's payments for Don's care. KRMC filed liens against the Estate. The Estate, in turn, sued KRMC and MASH, a company that had provided Medicaid application forms to the Estate, under several theories of liability. The district court granted Defendants' motions for summary judgment. The Supreme Court affirmed, holding the district court (1) did not err in granting summary judgment to KRMC and MASH; (2) correctly interpreted and applied the Montana Medicaid Act; (3) correctly awarded KRMC prejudgment interest but incorrectly included interest KRMC received from its interest-bearing account; and (4) did not abuse its discretion by awarding KRMC attorney fees and costs. Remanded with instructions to offset the prejudgment interest award by the amount of interest KRMC received from the interest-bearing account.

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Appellant Essie Simmons and Respondent Rubin Simmons divorced in 1990. The parties entered into a settlement agreement that was approved by the family court. Central to the agreement was the requirement that Mr. Simmons give Ms. Simmons a half or third of his Social Security benefits, depending on his age when he retired. When he retired, Mr. Simmons did not pay his ex-wife. She sued, but the family court declined to hear the complaint, finding that it could not hear a case that primarily dealt with Social Security benefits. Mr. Simmons appealed the dismissal, and the appellate court reversed. The court voided the division of Mr. Simmons' benefits, holding that the Social Security Act specifically precluded parties from dividing benefits under the settlement agreement. Because the agreement was partly voided by the court, Ms. Simmons sought to reopen the matter entirely. The family court dismissed again, holding that it lacked jurisdiction to revisit the agreement. On appeal, the Supreme Court was presented with the question of whether the family court could revisit the now partially voided agreement. Upon careful review of the arguments and applicable legal authority, the Court held that "basic principles of equity suggest[ed] that all issues should be revisited by the family court." The Court recognized the practical difficulties confronting the family court, but the Court noted, "that challenge pales in comparison to [Mr. Simmons'] suggestion that we simply end this matter with the remnant of the agreement remaining valid." The Court reversed the decision of the lower court and remanded the case to the family court for further proceedings.