PEEHIP Board’s Action Did Not Violate Members’ Right to Equal Protection

Bronner, etc. v. Barlow, et al., [Ms. 1200570, Nov. 19, 2021] __ So. 3d __ (Ala. 2021). The Court (Sellers, J.; Bolin and Wise, JJ., concur; Parker, C.J., and Stewart, J., concur in the result) reverses the Montgomery Circuit Court’s summary judgment against individual members of the Public Education Employees’ Health Insurance Plan (“PEEHIP”) Board of Control and PEEHIP Secretary David Bronner in a 1983 action filed by public-education employees. The plaintiffs were PEEHIP participants married to other active PEEHIP participants and who have dependent children. The plaintiffs challenged a 2010 Board of Control action which eliminated “the combining allocation program.” Under that program, “a public-education employee married to another public-education employee could ‘combine’ their monthly benefits and receive family coverage, which would also cover their dependent children, without paying any additional monthly premium.” Ms. *4.

Applying rational basis scrutiny to the plaintiffs’ equal protection and due process 1983 claims, the Court holds “the evidence presented by the defendants supports the conclusion that the 2010 policy furthers one or more legitimate purposes and that the classifications in the 2010 policy are rationally related to those purposes. There is nothing before us to indicate that the defendants intended to single out the public-education plaintiffs for disparate treatment under the 2010 policy. Accordingly, we conclude that the 2010 policy is neither arbitrary nor discriminatory and that it does not violate either the Equal Protection Clause or the Due Process Clause of the Fourteenth Amendment to the United States Constitution.” Ms. *20.

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