Blaser v. State Teachers' Retirement SystemAnnotate this Case
California State Teachers’ Retirement System (CalSTRS) manages contributions made by employees and member school districts to the State Teachers’ Retirement Fund. (Ed. Code 22000.) In 2014, the Baxter petitioners, formerly employed by the Salinas Unified High School District sought to prevent CalSTRS from continuing to reduce their monthly retirement benefit payments and to restore prior monies they claimed CalSTRS had wrongfully withheld to recoup overpayments made as a result of a years-long miscalculation by the District. The trial court held that a three-year limitations period barred CalSTRS from recouping the prior overpayments. The court of appeal reversed, finding that the continuous accrual theory applied. A second suit challenged the reductions. Before the court of appeal addressed Baxter, the trial court granted relief in the second suit, finding CalSTRS’s claims time-barred. The court of appeal followed Baxter, holding that the continuous accrual theory applies. CalSTRS was time-barred from pursuing any claim against teachers as to pension benefit overpayments made more than three years before CalSTRS commenced an action but is not time-barred from pursuing any claim concerning periodic overpayments to teachers and adjustments to teachers’ future monthly benefits, where the payment accrued not more than three years prior to commencement of an action. The reduction in benefits made by CalSTRS did not constitute the commencement of an “action.” CalSTRS constructively commenced an “action” when these teachers filed their verified petition and complaint in the superior court on February 1, 2016.