pension plan and retirement system of the state and its political subdivisions shall be a contractual obligation thereof which shall not he diminished or impaired thereby. Financial benefits arising on account of service rendered in each fiscal year shall he funded during that year and such funding shall not be used for financing unfunded accrued liabilities. This argument was properly rejected by the Court of Appeals in AFT Mich II on the basis of this Court’s holding in Studier that Const 1963, art 9, § 24 protects only accrued, or earned, pension benefits. AFT Mich II, 303 Mich App at 666-667, 670, citing Studier, 472 Mich at 654-658. The form or availability of future pension benefits for state employees is not governed by Const 1963, art 9, § 24. 25 See Roxborough, 309 Mich at 511 (<HOLDING>). See also Martin v Secretary of State, 482
holding that the complaints of a public employee about a reorganization plan were on a matter of public concern even though the employee was primarily motivated by the adverse effect of the plan on himself holding that the public employee plaintiff was charged with knowledge of the statutory limitation on the governors authority to bind the state to pay the employee a fixed annual salary holding that employee may claim contract created based on employer promise of severance pay to employee holding that a plaintiff must comply with the notice of claim requirements in order to maintain an action against a government employee even if the plaintiff claims that the employee acted with fraud or malice holding that the employers failure to interact with the employee does not preclude the employee from losing on summary judgment because the employee must still prove that a reasonable accommodation could have been made