After a career as a deputy sheriff, Charles Aldean worked as a police officer with the City of Woodbury, Minnesota from 2017 until 2020. During his tenure, Aldean enrolled in the City’s health insurance plan with his wife and two children listed as dependents. Aldean experienced health problems at work and applied for duty-disability benefits prior to his retirement. In April 2020, the relevant state agency determined that Aldean was eligible for duty-disability benefits and ordered the City to continue his health insurance coverage until the age of 65. The City did not petition for review of this decision, and Aldean retired several weeks later, still enrolled in the City’s health insurance plan.
Within months, Aldean found new employment with the Minnesota Department of Employment and Economic Development. He ceased paying his insurance premiums for the City plan and was unenrolled. About one year later, Aldean requested to be placed back on the City’s health insurance plan and was denied. Aldean sued under a state statute which requires municipalities to “continue to provide health coverage” for duty-disabled police officers and their dependents. The trial court granted summary judgment to Aldean, and the City appealed.
The appellate court affirmed. The Court’s analysis focused mainly on statutory language, and how to best interpret it in line with general legal principles. Most relevant here is the principle that statutory language should be interpreted such that no word or provision is rendered meaningless. Aldean’s argument was simple – the statute required the City to provide duty-disabled officers and their dependents medical insurance until the officer reached age 65. As a duty-disabled officer under the age of 65, Aldean was improperly denied the opportunity to reenroll in the City’s health insurance plan. The City argued that the statute was ambiguous, and that it was not intended to require reenrollment after a duty-disabled officer voluntarily withdrew from the employer’s health insurance plan. In other words, the City argued that since it provided health insurance coverage to Aldean when he retired, it discharged its obligations under the statute.
The Court disagreed. First, it agreed with Aldean that the statute was clear in requiring that the City “continue to provide health coverage” to him upon his retirement for duty-related disability, without any explicit limitations based on voluntarily unenrolling in the plan. It also noted that the City’s argument would require it to ignore, or render meaningless, another provision of the statute, which requires municipalities to provide health coverage to duty-disabled officers and their dependents until the officer reaches age 65. This was the only limitation explicitly placed on the City’s obligation, and the City’s position would require the Court to ignore it, and instead read another limitation into the statute based on the officer’s voluntary withdrawal from the health insurance coverage. The Court affirmed the trial court’s decision, and ordered the City to enroll Aldean and his dependents.
Aldean v. City of Woodbury, A23-0359, 2024 WL 413472 (Ct. App. Minn., 2024).