Retired Employees Assn. of Orange County, Inc. v. County of Orange

In Retired Employees Assn. of Orange County, Inc. v. County of Orange (2011) 52 Cal.4th 1171, the California Supreme Court addressed the following question certified by the Ninth Circuit Court of Appeals: "'Whether, as a matter of California law, a California county and its employees can form an implied contract that confers vested rights to health benefits on retired county employees.'" The Court concluded, "a county may be bound by an implied contract under California law if there is no legislative prohibition against such arrangements, such as a statute or ordinance." (Retired Employees, supra, at p. 1176.) The basis and reasoning of the court's decision were that "under California law, contractual rights may be implied from legislative enactments under limited circumstances." (Id. at p. 1185.) The court explained the plaintiff did not seek to recover "'under a contract made in violation of the particularly prescribed statutory mode,'" but instead claimed to have "contractual rights that are implied in resolutions duly approved by County." (Id. at p. 1187.)