Douglas v. Broadlands Dept of Social Security
What is challenged
Retirement Age Policy
The law today
Retirement at 65
The appeal asks for
Retirement at 70
- Appellant
- Pax Americana
- Filed
- Sept. 27, 2022
- Decided
- Dec. 16, 2022
The case
The appellant's argument, then every party's submission, oldest first. Submissions are advisory: the justices read them, they do not count as votes.
Pax Americana Appellant · Sept. 27, 2022
PETITION FOR WRIT OF MANDAMUS / CERTIFICATION OF RETIREMENT AGE
I. STATEMENT OF JURISDICTION & AUTHORITY
Under Article XVI of the Constitution, the retirement age formula is self-executing and binding upon certification. In the absence of an independent statistical agency, Petitioner petitions this Court to take judicial notice of official national demographic records and certify the statutory retirement age.
II. FACTS & DEMOGRAPHIC EVIDENCE
Petitioner directs the Court to the official national Demographics record:
Average Age: 44.0 years.
Adult Cohort Breakdown: Seniors constitute 17% of the adult population, leaving the working-age population at 83%.
III. STATUTORY CALCULATION
Article XVI provides:
Retirement age = ((Average age * 1.85) + (18 * Dependency Ratio)) / (1 + Dependency Ratio)
Dependency Ratio:
Seniors / Working age population = 17 / 83 = 0.2048
(This does not exceed the constitutional limit of 1:3 / 0.3333, so 0.2048 applies.)
Numerator:
(44.0 * 1.85) + (18 * 0.2048)
= 81.4 + 3.6864
= 85.0864
Denominator:
1 + 0.2048 = 1.2048
Final Result:
85.0864 / 1.2048 = 70.62 years
IV. ARGUMENT
Because Article XVI is strictly self-executing, Respondent possesses no administrative discretion to stall implementation or maintain the obsolete age of 65. The demographic data establishes a verified formula result of ~70.6 years.
V. PRAYER FOR RELIEF
Petitioner respectfully requests that this Court:
Review and take judicial notice of the national demographics page;
Certify the constitutional retirement age at 70 years; and
Order the Department of Social Security to update its schedules immediately.
No party has pleaded yet.
The bench
Each justice's vote and reasoning, published under their seat number. The court never reveals who sits on it.
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Justice #1 Did not vote
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Justice #2 Did not vote
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Justice #3 Did not vote
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Justice #4 Uphold
The Appellant has raised the claim that the current retirement age is unconstitutional according to Article XVI of the Broadlander Constitution, which explicitly codifies a calculation to find the retirement age for Broadland. Upon reviewing the calculation, I can concur that the current age of 65 does not align with this calculation, and that the calculation does conclude that the retirement age should be ~70.6 years. As such I uphold the Appellant's appeal to fix retirement to 70, though I also stress that parties attempt to change legislation through the Legislature first, rather than immediately call the Court to change it.
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Justice #6 Did not vote