Deputy Sheriffs' Assn. v. County of San Diego

INTRODUCTION

In this appeal, we consider whether the state Constitution’s prohibition against the impairment of contracts precludes the application of the defined benefit formulas and employee contribution provisions of the California Public Employees’ Pension Reform Act of 2013 (Act) (Gov. Code, § 7522 et seq.) to County of San Diego (county) safety employees who were hired after the Act’s effective date, but who were covered by preexisting collective bargaining agreements containing conflicting terms. We conclude the application of the defined benefit formula provisions does not result in a constitutionally prohibited impairment of the agreements. We do not reach the constitutional question as to the application of the employee contribution provisions as we conclude their application resulted in a statutorily prohibited impairment of the agreements. We, therefore, affirm the judgment as to the application of the defined benefit formula provisions and remand the matter to the superior court for further proceedings as to the application of the employee contribution provisions.

DISCUSSION

I

Application of Act’s Defined Benefit Formula Provisions

A

Background

The…