Roger J. Bouchard v. State Employees Retirement Commission

Summary

The court held that a six-year limitations period applies by analogy to administrative claims seeking recalculation of retirement benefits when the governing statutes contain no express limitation. The claims accrued when each retiree's benefits were approved and finalized, not when a later judicial decision clarified the governing law, and neither a continuing-violation nor continuous-course-of-conduct theory tolled the limitations period. The court therefore ordered judgment for the commission on the individual administrative appeal and affirmed the dismissal of the class claim.