Underwood v. City of Chicago, Ill.

Defendant-City’s action in informing plaintiffs-retirees who received pension benefits that they would have to pay more for medical coverage (after 2003 ordinance providing free or subsidized health care benefits had expired in 2013) did not violate Contracts Clause of U.S. Constitution. Plaintiffs failed to identify any action by defendant that prevented any implementation of contracts concerning health benefits, and plaintiffs could not show that expiration of subject ordinance constituted breach of any contract. Ct. also vacated Dist. Ct.’s dismissal of plaintiffs’ state-court claim alleging that defendant’s reduction of health care benefits violated Pension Clause of Illinois Constitution, where said decision came prior to Ill. Supreme Ct. decision in Kanerva, 2014 IL 115811, that found that Pension Clause applied to health benefits, and further remanded said action back to Dist. Ct. with directions to remand matter back to state court for resolution in that forum.