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Indiana Supreme Court Upholds County's Right to Exclude Part-Time Officials

The Indiana Supreme Court ruled that Perry County lawfully excluded elected councilman Keith Huck from group health insurance coverage by classifying him as a part-time employee. The 4-1 decision reversed a lower court's preliminary injunction and clarified local governments' authority over employee benefit eligibility.

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4 min readcourtlistener
Seal of the Indiana Supreme Court

Case Information

Case No.:
24S-PL-297

Key Takeaways

  • Indiana Supreme Court ruled 4-1 that Perry County properly excluded councilman Keith Huck from health insurance
  • Court held local governments can exclude part-time employees from group health coverage under state law
  • Decision reversed trial court ruling and vacated preliminary injunction requiring coverage
  • Huck earned $4,783 annually as county councilman before being excluded from benefits

The Indiana Supreme Court ruled July 22 that Perry County properly excluded an elected county councilman from group health insurance coverage by classifying him as a part-time employee under state law. The court's 4-1 decision in *Perry County, Indiana v. Keith D. Huck* reversed a trial court ruling that had favored the councilman and vacated a preliminary injunction requiring the county to provide coverage.

Justice Christopher Massa wrote for the majority that Indiana law permits public employers to provide health insurance to employees while also allowing local governmental units to exclude part-time employees from group coverage. The court held that Perry County's Board of Commissioners acted within their statutory authority when they voted to exclude Keith Huck from the county's group health plan.

"As we read the statutes, Perry County was permitted to do so," Massa wrote in the opinion. "We therefore reverse the trial court's ruling to the contrary, vacate the preliminary injunction, and remand for further proceedings consistent with this opinion."

The case centers on Huck's status as an elected member of the Perry County Common Council. Prior to January 1, 2024, Perry County provided group health insurance to its employees, retired employees, and dependent family members. Huck, who receives a salary forhis council service, was covered under the group plan until the Board of Commissioners voted to exclude him.

According to court records, Huck earned an annual salary of $4,783 in 2023 for his council duties, which amounts to approximately $186.96 per pay period. The commissioners determined this compensation level and the part-time nature of his elected position qualified him for exclusion under the relevant statutes governing public employee health benefits.

The dispute began when Perry County changed its health insurance policy effective January 1, 2024. Huck challenged the exclusion in Perry Circuit Court under case number 62C01-2401-PL-31, arguing that the county lacked authority to remove him from coverage. Special Judge Justin B. Mills initially ruled in Huck's favor and issued a preliminary injunction requiring the county to maintain his coverage.

The case then proceeded through the Indiana Court of Appeals before reaching the state's highest court. The Indiana Supreme Court heard oral arguments on October 31, 2024, and issued its decision eight months later.

Justices Steven David and Derek Molter joined Massa's majority opinion, while Chief Justice Loretta Rush concurred in the judgment but wrote a separate opinion explaining her reasoning. Justice Mark Massa dissented with a separate opinion, creating the 4-1 split.

The majority's interpretation of Indiana's public employee health insurance statutes gives local governmental units discretion to define which employees qualify for coverage based on their employment status. The court found that elected officials serving in part-time capacities can be classified as part-time employees for benefits purposes, even though they hold elected positions.

The decision has implications for how local governments across Indiana structure their employee benefit programs. Counties, municipalities, and other local governmental units now have clearer guidance on their authority to exclude certain categories of employees from group health insurance coverage based on their work status and compensation levels.

For Perry County, the ruling validates the Board of Commissioners' policy decision and eliminates their obligation to provide health insurance coverage to Huck. The county had argued throughout the litigation that they possessed statutory authority to make benefits eligibility determinations for their workforce, including elected officials who serve in part-time capacities.

Huck's legal challenge highlighted tensions that can arise when elected officials also serve as county employees for benefits purposes. While elected positions carry certain statutory protections and duties, the court's ruling suggests those protections do not automatically extend to employee benefit eligibility when the position is deemed part-time under relevant statutes.

The case returns to Perry Circuit Court for further proceedings following the Supreme Court's remand order. The trial court will need to address any remaining issues in the litigation consistent with the high court's interpretation of the governing statutes.

The ruling provides local governments with greater certainty about their authority to structure employee benefit programs according to their interpretation of state law regarding part-time versus full-time employment classifications. However, it also underscores the importance of careful policy development and clear communication when making changes to employee benefits that affect elected officials.

Topics

health insurancepublic employmentpart-time employee benefitselected officialslocal governmentstatutory interpretation

Original Source: courtlistener

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