Mandamus Action to Provide Health Benefits In Pennsylvania
In DeGeorge v. Young, 892 A.2d 48 (Pa. Cmwlth. 2006), appeal denied, 588 Pa. 785, 906 A.2d 544 (2006), various auditors of Columbia County appealed an interlocutory order of the Court of Common Pleas of the 26th Judicial District (Columbia County Branch) that denied their motion for peremptory judgment.
The auditors filed a mandamus action to compel the Columbia County commissioners to provide them with the same health benefits as the commissioners provided to themselves and every other county officer.
The auditors moved for peremptory judgment arguing that Section 1556 of the County Code required the county to provide these benefits to them.
The trial court applied the definition of "eligible" found in Black's Law Dictionary to Section 1556 of the County Code and determined that the statute means "that a County officer is "legally qualified" to be included in the privilege of receiving health insurance benefits...and that the Legislature did not use mandatory language and, therefore, Commissioners were not required to provide Auditors with full-time health insurance." DeGeorge, 892 A.2d at 51.
The trial court denied the auditors motion.
The auditors appealed to our court.
The Court determined that the trial court was correct in its determination that "eligible" meant "legally qualified", but ultimately reversed its decision finding that:
Because Section 1556 does not bestow unlimited discretion on Commissioners to determine to whom they wish to provide full-time health benefits and, because this type of statute must be strictly construed so as not to conflict with the public interest, the Court held that Commissioners cannot treat similarly situated County officers differently than they treat themselves and others. Id. 892 A.2d at 54.