Flethez v. San Bernardino Co. Employees Retirement Assn.
Annotate this CaseFollowing his last day of work as an employee of San Bernardino County, Frank Flethez underwent surgery for a work-related spinal injury he suffered in 1998. In 2008, he filed an application with the San Bernardino County Employees Retirement Association (SBCERA) for work-related disability retirements benefits. SBCERA granted his request for disability benefits, beginning as of 2008, but did not grant him retroactive benefits for the period before the date of his application. Flethez filed a petition for writ of mandamus seeking retroactive disability retirement benefits. The trial court issued a judgment granting his petition and awarding him Civil Code section 3287, subdivision (a),1 (section 3287(a)) prejudgment interest on the retroactive benefits to which the judgment provided he was entitled. On appeal, SBCERA argued the trial court erred by awarding Flethez section 3287(a) prejudgment interest on his retroactive benefits because SBCERA could not have granted those benefits until he filed an application for disability retirement and submitted evidence showing his entitlement to those benefits in 2008. Based on its interpretation of section 3287(a) and consideration of relevant case law and the facts in this case, the Court of Appeal concluded the trial court erred by awarding Flethez prejudgment interest on his retroactive disability benefits before payments of those benefits were due and before his right to recover those payments became vested under section 3287(a).
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