Initially decided in December 2024, the Nevada Supreme Court granted en banc reconsideration in 2025 in Public Employees’ Retirement System of Nevada v. Las Vegas Police Managers & Supervisors Association and Las Vegas Peace Officers Association. The case centered on whether the Public Employee’s Retirement Systems (“PERS”) was required to collect additional retirement benefits from increased wages earned on negotiated holidays.
The Las Vegas Police Managers & Supervisors Association and the Las Vegas Peace Officers Association (the “Associations”) entered into collective bargaining agreements with the Las Vegas Metropolitan Police Department and the City of Las Vegas. Under those agreements, Christmas Eve, New Year’s Eve, and Juneteenth were designated paid holidays. PERS is required to collect retirement contributions on all compensation earned, including increased holiday wages. PERS declined to collect higher retirement contributions on those negotiated holidays, stating they were not included in Nevada’s statutory list of holidays.
The Court engaged in an analysis of what exactly the Nevada legislature intended the definitionof “holiday” to be. Nevada Revised Statute (“NRS”) 236.015(1) contains the statutory definition of state holidays. The statute lists explicitly lists several holidays but then includes a provision that defines a legal holiday as “[a]ny day that may be appoint by the President of the United State for public fast, thanksgiving or as a legal holiday.” NRS 236.015(1). The Court also determined that this provision contemplated the President designating a corresponding holiday for federal employees
As applied to Juneteenth, the Court found that even though it was not formally codified as a state law until 2023, it was a state holiday once the President created it, signed it into law, and further expressed the intent was to designate the day as a national holiday. PERS therefore was required to collect the increased retirement amounts. As for Christmas Eve and New Year’s Eve, the Court determined that the Associations had the statutory power under NRS 288.150(2) to negotiate holiday pay for holidays beyond the statutory list.
While the ruling may focus on specific Associations and specific agreement, the case presents an interesting look at what is considered a holiday under Nevada law. Holidays do not need to be included in the statutory list and can be created without any formal recognition by the state or codification into state law.
