General Motors Corp. v. Romein
Supreme Court of the United States
December 10, 1991, Argued ; March 9, 1992, Decided
[*183] [***335] [**1108] JUSTICE O'CONNOR delivered the opinion of the Court.
In 1987, the Michigan Legislature enacted a statute that had the effect of requiring petitioners General Motors Corporation (GM) and Ford Motor Company (Ford) to repay workers' compensation benefits GM and Ford had withheld in reliance on a 1981 workers' compensation statute. Petitioners challenge the provision of the statute mandating these retroactive payments on the ground that it violates the Contract Clause and the Due Process Clause of the Federal Constitution.
Since at least 1974, workers' compensation law in Michigan has been the subject of legislative study and bitter debate. VanderLaan & Studley, Workers' Compensation Reform: A Case Study of the Legislative Process in Michigan, 14 U. Mich. J. L. Ref. 451, 452-454 (1981). "Literally dozens of conflicting legislative proposals" were offered each year, and all were [****6] fought to a standstill by competing interest groups. Id., at 453. The legislative logjam was finally broken in 1980, when the Governor and four legislative leaders began a series of negotiations leading to an agreement on reforms. [*184] "Neither side was able to obtain everything it wanted -- possibly a good indication of the degree of balance this compromise represents." Id., at 458.
Among other things, the 1980 ] legislation raised maximum weekly benefits to 90% of the state average weekly wage, and provided workers injured before 1980 an annual supplemental adjustment of their benefits of up to five percent. Mich. Comp. Laws Ann. §§ 418.355(2), 418.352(1) (West 1982). In 1981, the legislature enacted a statute allowing employers to decrease workers' compensation benefits to those disabled employees eligible to receive wage-loss compensation from other employer-funded sources. § 418.354. This provision, allowing what is called "benefit coordination," is at the heart of the controversy in this case.
The benefit coordination provision did not specify whether it was to be applied to workers injured before its effective date, March 31, 1982. Petitioners took the [****7] position that the 1981 law allowed them to reduce workers' compensation benefits to workers injured before March 31, 1982, who were receiving benefits from other sources. For example, GM cut respondent Romein's weekly payment by $ 132 per week, and Ford cut respondent Gonzalez' payment by $ 176 per week. The lower state courts disagreed with petitioners' interpretation, holding that coordination was allowed only for employees injured after 1982. See, e. g., Franks v. White Pine Copper Div., Copper Range Co., 122 Mich. App. 177, 185, 332 N.W.2d 447, 449 (1982). Both Houses of the Michigan Legislature passed a concurrent resolution declaring that the coordination provisions were "not designed to disrupt benefits which were already being received by an employee prior to the effective date of this act or benefits resulting from injuries incurred prior to the act's effective date." See Senate Con. Res. 575, adopted by the Senate on April 1, 1982, and by the House on May 18, 1982; 1982 Senate J. 626, 706-707; [***336] 1982 House J. 1262. The same year, a bill was introduced in the Michigan Senate to amend the statute in this [**1109] respect, [*185] but it was not passed. Senate Bill 834, [****8] introduced on May 26, 1982.Read The Full CaseNot a Lexis Advance subscriber? Try it out for free.
Full case includes Shepard's, Headnotes, Legal Analytics from Lex Machina, and more.
503 U.S. 181 *; 112 S. Ct. 1105 **; 117 L. Ed. 2d 328 ***; 1992 U.S. LEXIS 1535 ****; 60 U.S.L.W. 4203; 92 Cal. Daily Op. Service 1977; 92 Daily Journal DAR 3082; 6 Fla. L. Weekly Fed. S 68
GENERAL MOTORS CORPORATION, ET AL., PETITIONERS v. EVERT ROMEIN ET AL.
Prior History: [****1] ON WRIT OF CERTIORARI TO THE SUPREME COURT OF MICHIGAN.
Disposition: 436 Mich. 515, 462 N. W. 2d 555, affirmed.
contracts, coordination, benefits, employees, impaired, parties, contractual, retroactive, workers' compensation, reimbursement, petitioners', disability, provisions, terms, workers' compensation benefits, employment contract, effective date, regulations
Labor & Employment Law, Disability Benefits, Evidence, General Overview, Workers' Compensation & SSDI, Administrative Proceedings, Awards, Credits, Enforcement, Benefit Determinations, Earning Capacity, Coverage, Employment Status, Governments, Legislation, Effect & Operation, Retrospective Operation, Employment Contracts, Conditions & Terms, Constitutional Law, Congressional Duties & Powers, Contracts Clause, Substantive Due Process, Scope, Contracts Law, Contract Conditions & Provisions, Express Conditions, Business & Corporate Compliance, Contracts Law, Contract Conditions & Provisions