Ventura Cty Emp Ret Assn v. Crim J Atty Ret Assn Ventura Cty

Summary

The California Supreme Court held that under PEPRA's amendment to Government Code section 31461(b)(2), a legacy member's retirement benefit calculation may not include cashed-out leave time exceeding the annual cashout limit set by the terms of employment, even when the employee designates a final compensation period straddling two calendar years. The court first confirmed that its earlier description of the provision in Alameda County was not a definitive holding because that case concerned PEPRA's constitutionality, then conducted a de novo statutory analysis: finding the text ambiguous, it resolved the ambiguity through PEPRA's anti-pension-spiking purpose and administrability concerns about predictable county funding. It affirmed the Court of Appeal's judgment upholding VCERA's exclusion of the 40 hours retired county counsel Leroy Smith cashed out beyond his 200-hour annual allowance. Chief Justice Guerrero concurred in the holding and judgment but argued the result rests on a latent ambiguity resolved by legislative purpose, not on the face of the statutory text.