Illinois First District Holds Civilian Firefighter/Paramedic Is Not Entitled To Public Benefits
In Mitchell v. Village of Barrington, 2016 IL App (1st) 153094, the Illinois First District Appellate Court held that an employee was not entitled to health insurance benefits under the Public Safety Employee Benefits Act (Act) (820 ILCS 320/1 (West 2012)), because her position as a civilian paramedic did not fall within the classification of eligible employees under the Act. Additionally, the court found there was rational basis for the Village of Barrington Village to treat civilian paramedics and full-time firefighter/paramedics differently for the purposes of providing health care benefits under the Act.
Facts of the Case
Plaintiff Mitchell was employed as a paramedic for the Village of Barrington. In January 2007, while responding to a dispatch call for service at a residential home in Barrington, Mitchell injured her back by slipping on a patch of ice as she exited the ambulance. Mitchell continued to work for several shifts following this accident, but eventually went on a medical leave of absence in April 2007. In January 2008, the Village terminated her employment. In a termination letter, the Village stated that the Board of Trustees acted on a motion authorizing and approving her termination because Mitchell had reached “maximum medical improvement, and it appears there will be no significant change in your medical condition in the foreseeable future.” Mitchell, 2016 IL App (1st) 153094, ¶ 4.
In 2009 as part of her workers’ compensation claim, Mitchell sought health insurance benefits from the Village of Barrington under the Public Safety Employee Benefits Act, which provides health benefits for “full-time law enforcement, correctional or correctional probation officer, or firefighter, who… suffers a catastrophic injury or is killed in the line of duty.” Id. ¶ 4. The Village of Barrington denied her request on the grounds that she was not a “firefighter” covered by the Act but invited Mitchell to submit evidence demonstrating her eligibility. Mitchell did not submit any evidence at that time.
Over a year later in March 2011, Mitchell made the same request to the Village. Again, the Village denied the request citing its previous response, but also provided Mitchell with a formal application for benefits under the Act and evidence showing Mitchell was covered by the Act and the renewed demand was timely. Mitchell submitted her completed application in September 2011. The Village denied this application on April 26, 2012.
On September 10, 2012, Mitchell filed a Complaint for Declaratory Judgment against the Village of Barrington seeking health insurance benefits under the Act. Mitchell amended the complaint in April 12, 2013, alleging that her duties were the same as the paramedic duties performed by the full-time firefighter/paramedics. In response, the Village of Barrington filed a motion for summary judgment. The trial court granted the Village summary judgment based on its finding that Mitchell’s claim was barred under the doctrine of laches and that Mitchell had failed to prove her constitutional equal protection claim that civilian paramedics were treated differently than full-time firefighters.
Eligibility Under the Act
On appeal, Mitchell argued she was entitled to benefits because she was a “firefighter” within the meaning of the Act. Despite her attempts to argue legislative intent in statutory construction of the Act, the court found that Mitchell did not present evidence showing her job classification was a full-time firefighter.
The court examined Mitchell’s employment history with the Village of Barrington to determine whether she was eligible for benefits under the Act. The court found that, at the time the Village hired as Mitchell as a “paramedic” in 1988, Mitchell had possessed a certification as a “Firefighter II” from a previous employer. However, the Village of Barrington did not require such certification at the time she was hired. In 1994, the Village converted the paramedic positions to full-time firefighters, and offered Mitchell and other paramedics the opportunity to transition to full-time “firefighter/paramedic” positions. Any paramedic declining the offer would continue to work classified as a “Civilian Paramedic under the Village’s Pay Plan with continuing participation in the Illinois Municipal Reitrement Fund.” Id. ¶ 8. Mitchell declined this offer and chose to remain a civilian paramedic.
In 1999, in accordance with federal government regulations that affected the Village’s staffing of paramedics and full-time fire-fighters, the Village proposed in a written offer to Mitchell, an arrangement allowing her to remain a “civilian paramedic” and perform her duties assisting the full-time “firefighter/paramedics.” These duties were less than those of a full-time firefighter and consequently were paid at a rate lower than the wages for full-time firefighter/paramedics. She signed this agreement in June 1999.
Mitchell merely presented claims that she performed duties from time to time that were similar to that of a full-time firefighter. The court rejected this argument, finding that the “firefighter” classification was already considered within the context of pension benefits in McLear v. Village of Barrington, 392 Ill. App. 3d 664, 670 (1st Dist. 2009). In this case, the court determined that the mere participation in firefighting activities did not permit classification as a “firefighter” under the Act because the Act referenced a sworn or appointed member of the fire department. In Mitchell, the court found there was a clear delineation in the record between the classifications of a full-time firefighter/paramedic and a civilian paramedic. Since Mitchell was never appointed as a sworn firefighter and had expressly declined assuming of the additional responsibilities of a full-time firefighter, she did not fall under the Act.
Additionally, Mitchell argued that the Village’s denial of her health benefits claim under the Act was an impermissible treatment of civil paramedics differently than full-time firefighters in violation of her equal protection rights. Here, the court employed the “rational basis test” in its equal protection analysis, which inquires whether “the means employed by the statute to achieve the stated purpose of the legislation are rationally related to that goal.” People v. Breedlove, 213 Ill. 2d 509, 518 (2004). As a threshold matter, the movant must show that her position is “similarly situated” to the comparison group. People v. Masterson, 2011 IL 110072, ¶ 25. The court rejected Mitchell’s equal protection claim because she failed to present evidence showing how full-time sworn firefighters are “similarly situated” to unsworn civilian paramedics like her. Even assuming that Mitchell had shown she was “similarly situated” to sworn firefighter/paramedics, the court found there was a rational basis for the Village to treat civilian paramedics like Mitchell differently than the full-time firefighter/paramedics for the purposes of providing health care benefits under the Act.
The court affirmed the trial court’s ruling granting summary judgment for the Village.