Arneson v. State
Montana Supreme Court
864 P.2d 1245 (1993)

- Written by Deanna Curl, JD
Facts
In 1989, the state legislature adopted a statutory scheme that provided an adjustment in pension benefits for beneficiaries of the state Teachers’ Retirement System. Chapter 115 Session Laws of 1989 provided that retirees or their beneficiaries who were 55 or older could receive an adjustment in their benefits. Beneficiaries who received disability or survivorship benefits, however, could receive the adjustment at any age. Arneson (plaintiff) was the beneficiary of her mother, who died shortly after retiring. Under Chapter 115, Arneson was not eligible for the benefits adjustment because she was only 31 years old. If Arneson’s mother had died while still working, however, Arneson would have received the adjustment through survivorship benefits. Arneson filed a lawsuit alleging that Chapter 115 violated the equal-protection clause of the Montana Constitution. The district court applied rational-basis judicial review and found that the age classification was unconstitutional under the state constitution. The state (defendant) then appealed the district court’s ruling.
Rule of Law
Issue
Holding and Reasoning (McDonough, J.)
Concurrence (Trieweiler, J.)
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