Yuba City Unified Sch. Dist. v. Cal. State Teachers' Ret. Sys.

*651 The California State Teachers' Retirement System (CalSTRS) appeals from a decision granting the Yuba City Unified School District's (District) petition for writ of mandate and setting aside CalSTRS's decision to collect overpayments mistakenly made to some of the District's retirees. The superior court held that the three-year statute of limitations set forth in Education Code section 22008, subdivision (c) bars collection of the overpayments because a 2005 letter CalSTRS sent one of the retirees demonstrated actual notice of the payment issues. 1 We disagree. The letter does not reflect actual notice of the specific payment issues raised in this proceeding. We conclude, however, that inquiry notice would be sufficient to start the limitation period contained in section 22008, subdivision (c). Whether CalSTRS had inquiry notice in this case is a question of fact that was not addressed at the administrative level or by the superior court. We will reverse and remand for further proceedings in light of these conclusions.

I. BACKGROUND

"[Cal]STRS is the state agency responsible for managing contributions made by employees and member school districts to the State Teachers'…