Salcedo v. Retirement Board of the Policemen’s Annuity and Benefit Fund of the City of Chicago

Plaintiff, the widow of a Chicago police officer, appealed from the Retirement Board of the Policemen’s Annuity and Benefit Fund of the City of Chicago’s decision denying her claim for a widow’s supplemental annuity benefit. The Board found her ineligible to receive the benefit because her husband had retired prior to his death. The appellate court affirmed, finding that the decedent’s retirement was an “unavoidable and intervening reason” that plaintiff did not qualify for a widow’s supplemental annuity, even if the decedent was permanently disabled due to an on-duty injury at the time of his death. (HOWSE and ELLIS, concurring)