Pension benefits; Defined benefit plan; Vested deferred member; Normal retirement; Deferred retirement; Contract interpretation; Patel v FisherBroyles, LLP; Administrative decision review; Competent, material, & substantial evidence; Romulus v Michigan Dep’t of Envtl Quality

The court held that defendants were entitled to summary disposition because the applicable retirement documents unambiguously provided that plaintiff’s vested deferred pension benefits did not begin until age 65. Plaintiff was 57 years old when his at-will employment with defendant-Wayne County Airport Authority ended, and he had accrued slightly more than 20 years of service. The Retirement Commission determined that, as a vested deferred member, he could not receive pension benefits until age 65, but the trial court granted plaintiff summary disposition and awarded damages. On appeal, the court held that plaintiff did not satisfy normal-retirement requirements because he had not reached age 60 at his “selected date of retirement,” which was the date of termination. It further held that the Summary of Benefits controlled the timing of deferred retirement benefits under Plan #5A, which stated that payment of retirement benefits would begin “at age sixty-five (65).” The court rejected the trial court’s ambiguity ruling because the Plan and Summary of Benefits, read together, did not conflict, as the Plan itself did not contain a separate provision addressing the timing of deferred benefits. Because the unambiguous documents supported the Retirement Commission’s determination, the trial court erred by failing to “‘accord due deference to administrative expertise.’” Reversed and remanded.