On August 31, 2011, in Stillman v. Board of Retirement of the Fresno County Employees' Retirement Association, "FCERA" (California Courts of Appeal – 5th District, No. F059430) the court found that a "pickup" paid for by a retirement association resulting from a bargaining agreement is not compensation for purposes of calculating final compensation. Stillman was a member of FCERA and later San Luis Obispo County Pension Trust "SLOCPT." The SLOCPT paid for a $724.85 "pickup" and FCERA won't include that in her compensation to calculate Stillman's final compensation. The trial court found that FCERA properly defined compensation as not including "pickups"
The appeals court also found that FCERA properly defined compensation. The court reasoned that "pickups" were not a typical payment for employees like Stillman because it was the result of a bargaining agreement.