Court Rules City Can Provide Lesser Health Care Benefit to Disabled Firefighters

A lawsuit filed by a disabled Florida firefighter challenging a limitation on her eligibility for a city-paid health plan in retirement has been dismissed. Karyn D. Stanley claimed that the City of Sanford violated a state law governing health insurance benefits for retirees and violated the Equal Protection clause of the US Constitution by discontinuing the payment of health care premiums for disabled firefighters twenty-four months after their date of retirement.

Stanley had been a Sanford firefighter from February, 1999 to November 18, 2018. She was forced to retire due to Parkinson’s disease. Over the years the city changed the health care benefits that retirees were eligible for. Quoting from the ruling:

  • The City’s policy for providing health insurance to its employees and retirees is included in its Human Resources Manual.
  • Prior to September 20, 2003, Paragraph 2.45 of the Manual provided that “[a]n employee if hired before October 1,2002 will have met the criteria for eligibility for continuation of city-paid health insurance at the time of retirement upon completion of twenty-five (25) years’ service to the City of Sanford. Employees hired after October 1, 2002 who retire with twenty-five (25) years of service to the City shall not be eligible for any city paid health insurance in accordance with the foregoing retirement eligibility criteria in this paragraph.”
  • Paragraph 2.45 further provided that “[e]mployees retiring for disability reasons and who meet the criteria for disability retirement as prescribed by the Florida Retirement System or who meet the criteria for disability retirement as prescribed by the Police or Fire Pension Plan are eligible for continued City-paid health insurance.”
  • This benefit was not conditioned on the employee’s date of hire and ended when the employee reached sixty-five years of age.
  • Pursuant to Ordinance No. 3806, the City amended this portion of its policy on October 1, 2003 “for the purpose of Continuing the City’s Health Care Cost Containment Initiatives.”
  • The change allows disability retirees to remain on the City’s health insurance until they are Medicare age, but after twenty-four months of disability retirement they are required to pay the premiums themselves.
  • “Normal” retirees, however, who were hired prior to October 1, 2002, and who have twenty-five years of service with the City continue to receive paid health care until they reach the age of sixty-five.
  • The policy provides that the “retiring employee approved for disability reasons will be entitled to the same health insurance coverage as is afforded regular employees and the total premium will not exceed the total premium charged to the active group.”
  • In accordance with the policy, twenty-four months after Plaintiff began her disability retirement, she was notified that she was no longer eligible to receive the City’s paid contributions toward the cost of participating in the City’s health insurance coverage.
  • Instead, in order to remain on the City’s health insurance coverage, Plaintiff was required to pay $1,359.00 per month for Employee and Spouse coverage.

Stanley’s suit pointed to the inequities of the city paying full medical premiums for those hired before October 1, 2002 who take a regular retirement after 25 years, but limiting the payment of medical premiums for disabled employees to just twenty-four months, understanding that both groups would be required to go on Medicare at age 65. She argued that city’s policy violated Florida Statutes § 112.0801 and violated Equal Protection because it was arbitrary, irrational, and penalized disabled firefighters.

The US District Court for the Middle District of Florida disagreed with Stanley on both counts. As to the state law claim:

  • Section 112.0801 is not ambiguous and in no way requires the municipality to pay the cost of continued participation [in a health care plan after retirement].
  • Here, the City offered Plaintiff health insurance coverage at the same cost as active employees, it just required her to pay the premiums.
  • Moreover, there is nothing in the statute that prohibits the City from paying the premiums for a normal retiree but refusing to pay the premiums for a disabled retiree.
  • Accordingly, Paragraph 2.45 of the Manual does not violate the statute and the City’s Motion [for summary judgment] will to be granted.

As to the equal protection claim (embedded quotations removed for ease of reading):

  • The Equal Protection Clause requires the government to treat similarly situated persons in a similar manner.
  • When legislation classifies persons in such a way that they receive different treatment under the law, the degree of scrutiny the court applies depends upon the basis for the classification.
  • Classifications that neither implicate fundamental rights nor proceed along suspect lines are subject to rational basis review.
  • Accordingly, the Court must determine if the ordinance requiring disabled retirees to pay their own health insurance premiums is rationally related to a legitimate government interest.
  • The Constitution does not require the City to draw the perfect line nor even to draw a line superior to some other line it might have drawn.
  • It requires only that the line actually drawn be a rational line.
  • Furthermore, as long as the classificatory scheme chosen by the municipality rationally advances a reasonable and identifiable governmental objective, the court must disregard the existence of other methods of allocation that it perhaps would have preferred.
  • Yet, the municipality may not rely on a classification whose relationship to an asserted goal is so attenuated as to render the distinction arbitrary or irrational.
  • The Supreme Court has consistently refused to invalidate on equal protection grounds legislation which it simply deemed unwise or unartfully drawn in cases involving social and economic benefits.
  • Here, the City has placed retirees into several classifications.
  • There are retirees who were hired before October 1, 2002, who have twenty-five years of service.
  • Those are the only retirees who receive City-paid health insurance until they reach sixty-five years of age under the Ordinance.
  • Disabled retirees receive City-paid health insurance for up to twenty-four months.
  • All other retirees are required to pay their health insurance premiums.
  • The Ordinance provides on its face that City-paid health insurance premiums for disabled retirees were limited to twenty-four months in order to contain costs.
  • Indeed, once the retirees with twenty-five years of service who were hired before October 1, 2002, are phased out, the ordinance will eliminate all City-paid premiums for retirees save for disabled retirees.
  • Although Plaintiff presents several equations of how the present scheme does not reduce the City’s costs, the Court’s role is not to provide a more effective scheme.
  • And while the Court sympathizes with the fact that Plaintiff was forced to retire just short of her twenty-five years due to Parkinson’s disease, the City has demonstrated that it demarcated neutral lines that are rationally related to meet its legitimate goal-i.e., to contain future costs.

Here is a copy of the decision:

About Curt Varone

Curt Varone has over 40 years of fire service experience and 30 as a practicing attorney licensed in both Rhode Island and Maine. His background includes 29 years as a career firefighter in Providence (retiring as a Deputy Assistant Chief), as well as volunteer and paid on call experience. He is the author of two books: Legal Considerations for Fire and Emergency Services, (2006, 2nd ed. 2011, 3rd ed. 2014) and Fire Officer's Legal Handbook (2007), and is a contributing editor for Firehouse Magazine writing the Fire Law column.

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