Meyers v. State Health Benefits Commission
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The Supreme Court of New Jersey affirmed the judgment of the Appellate Division in a case concerning the New Jersey State Health Benefits Program Act. The case was brought by James Meyers, a retired state police officer, who challenged the State Health Benefits Commission's (SHBC) decision that he was not exempt from health benefits premium-sharing obligations imposed by the Act. The Act requires public employees to contribute towards the cost of their healthcare benefits upon retirement, with an exemption for employees who had 20 or more years of creditable service in a state or locally administered retirement system as of June 28, 2011. Meyers had 17 years and 9 months of creditable service at that time. Upon his retirement in 2015, he was erroneously offered retiree health benefits at no premium cost. This mistake was discovered in 2017, and the state began deducting premium-sharing contributions from his pension payments.
The Court held that Meyers was not eligible for the exemption under the Act, and correcting the erroneous exemption was proper. The court found that neither Meyers' subsequent service nor his purchase of four years of military service credit could change the fact that he did not meet the Act's requirement as of June 28, 2011. The court also agreed with the Appellate Division's determination that it was not necessary to reach the issue of equitable estoppel. The court noted that a governmental entity cannot be estopped from refusing to take an action that it was never authorized to take under the law, even if it had mistakenly agreed to that action. In this case, the SHBC was never authorized to offer Meyers free healthcare benefits, an act beyond the jurisdiction of the SHBC and therefore ultra vires in the primary sense. Thus, the doctrine of equitable estoppel did not apply.
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