Bronner, et al. v. Barlow et al.Annotate this Case
David Bronner, secretary-treasurer of the Public Education Employees' Health Insurance Plan ("PEEHIP"), and individual members of the Board of Control of PEEHIP ("the PEEHIP Board"), the remaining defendants in this action (collectively, "defendants"), appealed the grant of summary judgment entered in favor of the plaintiffs and members of a purported class, who were all active public-education employees and PEEHIP participants married to other active public-education employees and PEEHIP participants and who had dependent children. Before October 1, 2010, all public-education employees participating in PEEHIP earned a monthly "allocation" or benefit, which could be used to obtain certain coverage alternatives under PEEHIP. In May 2010, the PEEHIP Board voted to eliminate "the combining allocation program" and to phase in a new premium rate structure ("the 2010 policy"), which required a public-education employee married to another public-education employee to gradually begin paying the same monthly premiums for family hospital-medical coverage that other PEEHIP participants were required to pay. In May 2014, the original named plaintiffs, individually and on behalf of a class of similarly situated individuals, filed a purported class action against the defendants, among others, pursuant to 42 U.S.C. 1983. In their complaint, the original named plaintiffs sought a judgment declaring that the 2010 policy was unconstitutional under the Due Process Clause and the Equal Protection Clause of the Fourteenth Amendment to the United States Constitution because, they claimed, the 2010 policy denied them and the members of the purported class a benefit for the payment of insurance accorded every other PEEHIP participant. The original named plaintiffs sought an order enjoining the defendants from denying them and the members of the purported class the use of that benefit, which, they claimed, would permit them and the members of the purported class to obtain family coverage at no cost. The defendants thereafter moved for a summary judgment, which the trial court denied. The Alabama Supreme Court reversed, finding nothing to indicate that the defendants intended to single out the public-education plaintiffs for disparate treatment under the 2010 policy. Accordingly, the Court concluded the 2010 policy was neither arbitrary nor discriminatory and that it did not violate either the Equal Protection Clause or the Due Process Clause of the Fourteenth Amendment to the United States Constitution.