Carmichael v. Laborers' & Retirement Board Employees' Annuity & Benefit Fund of Chicago

**Carmichael v. Laborers' & Retirement Board Case Summary** This case involved a dispute over changes to pension benefits for union employees in Chicago. The Illinois legislature passed a law in 2012 that made two significant changes to how union workers' pensions were calculated: it eliminated credit for time spent on union leave, and it restricted using union salaries when calculating final pension amounts. Several union employees and pension funds challenged these changes in court, arguing they violated the Illinois Constitution's pension protection clause, which prevents the government from reducing pension benefits that workers have already earned. The Illinois Supreme Court issued a split decision. The court ruled that eliminating union service credit for leaves starting after January 2012 was unconstitutional because it improperly reduced workers' pension benefits. However, the court allowed the restriction on using union salaries in pension calculations to stand. This decision matters for workers because it reinforces that states cannot simply cut pension benefits that employees have already earned through their service. While employers may be able to change how future benefits are calculated, they generally cannot reduce benefits workers have already accrued. This provides important protection for public employees' retirement security.