The Best U.S. States for New Teacher Retirement Benefits

There are lots of factors that new, prospective K–12 teachers have to consider when entering the education workforce. People typically pay the most attention to things like salary, location, and health insurance benefits, but what U.S. States are the best for new teachers looking for secure retirement?

Retirement benefits are a unique form of compensation in that they are deferred compensation. It is straightforward to compare the salaries offered to teach in one county versus another, or even to look at the health insurance benefits (medical plus dental? plus vision?) offered by one school district versus another. But comparing retirement plans on a state-by-state basis is a more difficult because there is no intuitive way to understand the value of one pension plan versus another, or whether a hybrid plan or defined contribution (DC) plan might be more valuable.

This article provides a ranking of states based on the quality of retirement benefits that they offer to new teachers entering the workforce in 2022-23, first published in Special Report #3 of the Retirement Security Report Teacher Edition.


Jump to the Complete Rankings

The Top 10 / Bottom 10 States by Average Quality of Retirement Benefits for New Teachers

  1. South Carolina (94.2%)
  2. Tennessee (88.2%)
  3. South Dakota (78.7%)
  4. Oregon (78.6%)
  5. Michigan (75.3%)
  6. Washington (74.4%)
  7. Rhode Island (73.9%)
  8. Florida (73.7%)
  9. Hawaii (71.0%)
  10. Virginia (70.7%)

  1. Illinois (49.7%)
  2. Mississippi (49.6%)
  3. Alabama (49.1%)
  4. New Jersey (48.0%)
  5. Nevada (47.1%)
  6. Georgia (46.2%)
  7. Wisconsin (46.1%)
  8. Kentucky (46.1%)
  9. Texas (44.9%)
  10. Louisiana (33.8%)
The score shown for each state is the percentage of available Retirement Benefits Score points that the retirement system averages overall for all open retirement plans available to public school teachers for the 2022-23 school year.


How States are Ranked

Our approach to ranking states is to grade each retirement plan offered to public school teachers based on the quality of benefits offered to three groups of people: those who are only going to teach for 10-years or less (“short-term” teachers), those who are going to spend 10-20 years in the classroom (“medium-term” teachers), and those who will teach in K–12 education for their entire lives (“full career” teachers).

This ranking includes all types of retirement plans for teachers, including “pension” plans, “defined contribution” plans, “guaranteed return” (or “cash balance”) plans, and “hybrid” plans that blend together various elements from the first three plan types.

While most teachers do not make their job decisions based on the retirement benefits being offered, today’s workforce is highly mobile and very much in flux. It is easily conceivable that someone who is getting their teaching certificate or finishing up an education program or considering changing professions might have some flexibility in where they want to go to work.

Best U.S. States for New Teacher Retirement Benefits front page.


Read the Report for Full Details on How We Measured Each Teacher Retirement Plan


State Ranking



States Ranked by Best Retirement Plan Available to New Public School Teachers

wdt_ID Rank State Best Plan Available (Design Type) Overall Retirement Benefits Score "Short-Term" Teacher Score "Medium-Term" Teacher Score "Full Career" Teacher Score
1 1 South Carolina DC Plan (Pension Option Available) 94.20% 86.20% 96.40% 100.00%
2 2 Tennessee Hybrid 88.20% 77.90% 86.70% 100.00%
3 3 South Dakota Hybrid 78.70% 62.30% 75.50% 98.30%
4 4 Oregon Hybrid 78.60% 59.30% 76.60% 100.00%
7 5 Michigan DC Plan (Hybrid Option Available) 75.30% 58.30% 67.70% 100.00%
10 6 Washington Pension (Hybrid Option Available) 74.40% 52.20% 72.60% 100.00%
11 7 Rhode Island Hybrid 73.90% 60.00% 63.30% 98.30%
13 8 Florida DC Plan (Pension Option Available) 73.70% 66.50% 63.00% 91.80%
14 9 Hawaii Hybrid 71.00% 41.70% 71.50% 100.00%
15 10 Virginia Hybrid 70.70% 51.50% 62.30% 98.30%
(1) “Pension” means a defined benefit pension plan, “DC plan” means a defined contribution plan, “GR plan” means guaranteed return plan (or cash balance plan), and “Hybrid” means a hybrid plan that combines elements of pension, DC, and/or GR plans.
(2) Different retirement plan designs (pension, DC, guaranteed return, hybrid) have different available Retirement Benefits Score points, given the underlying variance in the kind of provisions offered by each plan design. The percentages shown are the percentage of available Retirement Benefit Score points.
(3) The following states offer multiple plans to teachers who must make a choice which they want to join: Florida, Indiana, Michigan, Ohio, Pennsylvania, South Carolina, Utah, Washington.
(4) The following states show average scores for a statewide teacher plan and separately managed municipal teacher plan: Illinois, Minnesota, Missouri, New York
(5) Colorado has separate pension plans for Denver Public Schools and all other state school districts, but both plans are managed by the same state administrative organization.
(6) Nevada has two pension plan designs with different contribution rate structures. In most school districts the employer decides which to offer, but in some places employees have a choice.
(7) Rhode Island has different hybrid plan tiers of benefits based primarily on whether or not an individual is enrolled in Social Security.
(8) Texas has two pension plan designs that new members can join that differ slightly in their provisions based on the previous state employment history of the individual.


What All of This Data Means for Teachers

Many of the lowest scoring retirement plans for teachers are those that were created in the years following the Great Recession.

While some states replaced their pension plans with lower-risk alternative plan designs that offered comparable benefits, others simply reduced the value of pension benefits offered to new teachers. The net result is that the value of pension benefits today are roughly $100,000 less than they were in 2005, a 13% decline over the past two decades.

Teachers who were already hired before states began creating new tiers of benefits with less value will still retire with the benefits they were promised. This means the benefit value reduction is going to be felt primarily by new generations of teachers.

All of the new pension plans and benefit tiers were put in place as part of a wave of legislation to reduce costs and the risks to taxpayers from future investment shortfalls. These goals are understandable in the context of economic recession and financial volatility. And in the years since as teacher pension plans have accumulated over $600 billion in pension debt — i.e., unfunded liabilities — the costs of paying this down have become an acute burden for states and school districts.

But the state legislatures who chose to continue offering pension benefits only through a lower valued tier of benefits have effectively shifted the costs of their legacy retirement plans on to educators. By cutting the benefit values for future teachers, states are forcing those individuals to find additional ways to use their salaries to save for retirement independent of the state retirement system. The best U.S. States for new teachers do not put teachers in this position.


Details & Methodology Notes

Our ranking approach starts by grading each teacher retirement plan using Retirement Security Report methodology. This assigns a Retirement Benefits Score to each plan based on how well they are serving short-term teachers, medium-term teachers, and full career teachers. We blend those scores together to get an average overall score for each retirement plan. And that is what is used to determine the score for each state.
If a state only has one retirement plan that is open to enrolling new teachers, then the score for that retirement plan is the score for that state. If a state has multiple retirement plans available for new teachers to join, then we calculate the average score of those plans, and that is the score for the state.
Using this approach, the best state in the country for new teacher retirement benefits is Tennessee. Their hybrid plan for teachers serves all members well, including earning 100% of available Retirement Benefits Score points for full career teachers and 77.9% of available points for short-term teachers.
For states like Tennessee, South Dakota, or Oregon, the score for the one hybrid plan that they have available for new teacher is how we’ve ranked the state itself. For states like Pennsylvania and Michigan, each of which offers the choice of a hybrid retirement plan or defined contribution plan, we’ve averaged the scores for those plans to come up with a ranking for the state itself.
An example of how this works is South Carolina. They offer teachers the choice of a pension plan or defined contribution plan. The defined contribution plan on its own is actually the highest scoring teacher retirement plan in the country, but the South Carolina pension plan does not get very good scores. The average of those two puts South Carolina in fourth among the states with 78% of available points scored — 10% percentage points below Tennessee.
In cases where a state has a plan for teachers that is intended to be supplemental to primary retirement benefits or is only offered to part-time teachers, we do not include that in the state’s average. We also do not include retirement plans that are only offered to non-certified public school employees or plans exclusively for higher education employees.

Introducing the Retirement Security Report Teacher Edition

On June 28th, Equable Institute issued the Retirement Security Report Teacher Edition (2022). The report builds on The Retirement Security Report (RSR) initiative launched last year that evaluated the quality of retirement benefits offered to public workers nationwide using Equable’s Retirement Benefits Score methodology for all 335 statewide retirement plans currently open to new hires at that time.

The Teacher Edition of the report is an in-depth look at the 316 retirement plans currently offered to teachers and non-instructional staff in the U.S., including those offered to new hires and legacy plans with active enrollees – adding more than 200 plans to both our benefits database and interactive retirement security scorecards. The resulting omnibus analysis is comprised of four papers – a summary report and 3 special reports – that illuminate the state of teacher retirement benefits today.


Summary Report: “The National Landscape of Teacher Retirement Benefit Security”

The National Landscape of Teacher Retirement Benefit Security provides an overvie of teacher retirement benefits in America. The paper highlights the trends in the value of pension benefits, evaluates how well teachers are being served by the retirement plans offered to them based on plan type, and other key trends and analysis that are further expanded upon in the three special reports.

Read and Download the Summary Report 


Special Report #1: “The Fading Value of Teacher Retirement Benefits in America”

Special Report #1 looks at historical trends in the value of teacher retirement benefits. Analyzing lifetime benefit values going back to 1965, the report shows teachers today enrolled in a pension will earn 13% less in retirement than a teacher hired before the Great Recession. The report also evaluates similar trends in value for other retirement plan types.


Read and Download Special Report #1


Special Report #2: “The Best U.S. States for New Teacher Retirement Benefits”

Special Report #2 ranks states by the quality of their retirement benefits offered to new teachers using Equable’s Retirement Benefits Score methodology. The report offers two rankings: The first based on the best-scoring plan offered to teachers in each state and the second based on the average score for all plans.


Read and Download Special Report #2


Special Report #3: “Important Elements of Quality Teacher Retirement Plans”

Special Report #3 analyzes the design elements of the top-scoring plans in the Retirement Security database. The paper illuminates the best practice in plan design that help to ensure retirement income security for teachers.



Read and Download Special Report #3



In the coming days and weeks, we will be highlighting key findings and more data from the Retirement Security Report Teacher Edition. Visit to read more RSR content and learn more about the initiative.

About the Retirement Security Report 
The RSR is a universe of in-depth research, interactive tools, policy scores and other resources to shed light on the quality and value of retirement benefits for all public workers. All RSR projects are based on data from our comprehensive benefit database of retirement plans offered to public workers and use an open-source scoring methodology that accounts for three primary criteria: Eligibility, Income Adequacy (based on a 70% pre-retirement income replacement rate), and Flexibility & Mobility.


Alaska House Bill 55: Retirement Security Policy Score

Alaska is considering changes to plan provisions for peace officers and firefighters who are members of the Public Employees’ Retirement System (PERS), as presented in House Bill 55 (HB55), introduced in February 2021. The stated intent of the legislation is to improve recruitment and retention of public safety officers by replacing the current defined contribution plan with a pension plan.[1] Equable Institute has analyzed the proposed changes using methodology from the Retirement Security Report to measure how changes to benefits would influence current and/or future retirement plan members.



  • Peace officers and firefighter members of Alaska PERS who are enrolled in the current defined contribution plan will have the option to switch into a defined benefit pension plan.
  • All future peace officers and firefighter members of PERS will be enrolled in a defined benefit pension plan.
    • The pension plan has an increased multiplier after 10 years of service, inflation adjustment, and normal retirement eligibility at age 60 with five years of service or age 55 with 20 years.
    • By contrast, the status quo is a defined contribution plan that requires members to contribute 8% of salary, with a 5% employer match into an individual retirement account.
  • Employers will have to pay at least 9% of payroll for the new defined benefit pension plan, plus continue to pay down the existing PERS unfunded liability.



PERS public safety members would be offered a pension plan with inflation adjusted benefits in exchange for slightly lower overall annual earnings compared to the status quo. Our scoring methodology measures retirement plans based on how the benefit value they provide compares to an income adequacy threshold (reaching or exceeding 70% of an individual’s final average salary).

The table below shows the proposed plan’s total Benefit Scores, e.g., the percentage of available points for a given category. We also show the Benefits Score of the current plan as a point of comparison. And we show what the material effect would be on an average employee’s annual retirement earnings, using salary assumptions used by PERS trustees.

For PERS Members: To understand what HB55 might mean for you based on your age of entry into the public workforce, see a detailed breakdown at the end of this article.
To see an interactive score card of the current retirement plan’s benefits, click here.




The proposed pension plan under HB55 provides slightly worse retirement benefit values for most Alaska peace officers and firefighters compared to the current defined contribution plan, though overall the benefit values are similar. 

  • Short-Term Workers are not served well by the current plan, but they would likely be worse off under the proposed retirement plan. 
  • Medium-Term Workers could be slightly better off under the proposed plan than the current plan depending on personal factors in their career; but even if they are the proposed plan’s value is below common standards for adequate retirement income. The proposed plan does not meaningfully improve retirement security prospects for Medium-Term Workers.
  • Those who work more than 20 years for PERS are likely to have a larger benefit under the current plan than the proposed plan.

As a practical matter, it might be reasonable to consider the benefit values of these plans as similar — the proposed pension plan would have inflation adjusted guaranteed benefits; the current defined contribution plan has larger potential upside and greater portability of benefits. 

The underlying benefit provisions of HB55 create a modest benefit, but in the absence of Social Security or other supplemental retirement income benefits HB55’s projected benefits are not strong enough to provide all PERS public safety members with a path to adequate retirement income.

Because the proposed pension plan does not provide meaningfully better benefits, it is unclear whether adopting HB55 would achieve the stated goal of its proponents to improve retention.

Most academic literature suggests that few individuals join public service because of the retirement benefits, and other factors like salary, health benefits, and working conditions are stronger factors for retention than retirement benefits (no matter the plan design).[6]

However, theoretically the underlying concerns about recruitment or retention of public safety employees theoretically could be addressed by:

(a) improving the benefit values designed in HB55, 

(b) adding the option of an adequate pension plan alongside the status quo plan, and/or 

(c) adjusting provisions of the status quo plan to provide a better path to retirement income adequacy.


Looking Further at HB55’s Benefit Score

Since any projection about future retirement income requires certain assumptions about investment returns, salary growth rates, and more, it would be reasonable to consider the scores for these two plans to be roughly equivalent across the board. There are some minor ways that either the status quo plan or proposed plan might be better or worse than the other, but they are all marginal improvements or regressions — with the exception of the pension plan’s built-in cost-of-living adjustment. 

The status quo retirement plan is projected to create larger initial retirement income for all three worker-types in our analysis, compared to the proposed pension plan. However, the status quo defined contribution plan does not have built-in inflation protection. And the proposed pension plan does offer this, which enhances its value for Medium-Term and Full Career Workers. 

Neither plan, though, would serve most workers well compared to a retirement income adequacy benchmarks. To be fair, the lack of Social Security coverage makes it hard for a state-administered retirement plan on its own to provide adequate retirement income. The provisions of any single retirement plan must be particularly strong to reach targeted income adequacy in the absence of Social Security or other supplemental benefit. And neither the status quo plan’s contribution rate provisions nor the proposed pension plan’s benefit provisions are enough to create a path to adequacy for most public workers. Still, if a retirement plan is going to be offered and used as a workforce management tool, it should be capable of actually providing adequate retirement income.


Sustainability Analysis for House Bill 55

The proposed HB55 could have a significant, negative effect the funded status for Alaska PERS. 

Re-opening a pension plan is not inherently a problem. However, a key challenge for the legacy PERS pension plan has been investments underperforming actuarial assumptions about rates of return. Allowing current members of the defined contribution plan to switch and enrolling future hires into the pension plan would add liabilities that are assumed to be funded by unrealistic investment returns. 

The Alaska Retirement Management Board (ARMB) is currently using a 7.38% assumed rate of return for PERS, which is above the 7% national average, well above industry estimates for returns in the coming years, and implicitly reflects considerable risk.[10] Any new pension fund set up using that kind of investment assumption is likely to develop unfunded liabilities quickly.[11] Any new pension fund that allows defined contribution plan members to switch over based on a 7.38% assumed rate of return will effectively be underfunded from the start.

HB55 does attempt to include some risk-sharing provisions for the proposed pension plan. ARMB would be given the authority to increase member contributions from 8% of salary to as high as 10%. ARMB would also be allowed to reduce the “Postretirement Pension Adjustment” (elsewhere considered a cost-of-living adjustment) if the funded ratio for the new pension plan falls below 90%. In general, these are not bad policies. However, they are very minimal risk-mitigation rules and do not mirror shared-risk and cost-stabilization tools used by the best funded retirement systems in the country.[12]

Actuaries for Alaska PERS have found that HB55 would cost more than the status quo plan, primarily because of higher employer contribution rates required under the proposed legislation. Increased costs are not inherently a bad thing, particularly when they mean increased compensation for public workers or if they mean ensuring a retirement plan is being adequately funded. However, it appears that the benefit values offered by HB55 are slightly worse than the status quo. For select peace officers or firefighters it might be that the proposed pension plan is better for them, depending on the number of years that they work and the timing of returns for defined contribution plans. However, our analysis suggests that this bill would have higher costs for lower benefits for most future PERS peace officers and firefighters.

Based on these elements, we do not find that HB55 would improve the Sustainability Score for Alaska PERS. 


Alaska PERS Funded Status Brief History

The Alaska PERS funded status has had a troubled history. The state closed its defined benefit plan to new members as of July 1, 2006 and in the years since has not always fully paid the actuarially required contribution. While the state legislature has improved this practice, the primary reason that PERS developed unfunded liabilities has been underperforming investments. As of the most recent actuarial valuation from 2020, the funded status of PERS was 61.6% with $5.9 billion in unfunded liabilities. Nearly $3 billion of that is directly from investment returns being less than assumed.   

Some good news is that Alaska PERS, like all other pension funds, had significantly strong investment returns last year. The ARMB is still developing its actuarial valuation report for the fiscal year ending June, 2021. However, a preliminary ARMB assessment estimates the funding shortfall for PERS has declined to $3.67 billion reflecting a 76.46% funded ratio(on a net pension liability basis using a 7.38% rate of return as the discount rate).[13] 

Still, using a more realistic 6.38% rate of return assumption, ARMB estimates PERS unfunded liabilities are closer to $5.43 billion, reflecting a funded ratio around 71%. 


The two tables below show complete, detailed Benefits Scores for the proposed plan under HB55 and for the current plan. These two tables are summarized and combined for easier points of comparison above. However, the detailed breakout makes it clearer to see where the proposed plan and current plan perform better or worse.


What House Bill 55 Would Mean for 25-Year-Old New Hires & 40-Year-Old New Hires

The tables below show the proposed plan’s total Benefit Scores, based on how old a member is when they are hired. We also show how proposed changes compare to the current plan for the same kind of public worker. And we show what the material effect would be on an average employee’s annual retirement earnings, using salary assumptions used by PERS trustees. Underneath each table is a figure that shows a comparative forecast for the value of benefits over time


[1] See Sponsor Statement for House Bill 55,” Rep. Andrew Josephson.
[2] This is the average score for the plan, averaging across 25-year-old entrants and 40-year-old entrants, averaging across all classes within the retirement system, averaging across all worker types (Short-Term, Medium-Term, and Full Career). We consider only the classes within this plan that would be influenced by the legislation.
[3] As described in CS for House Bill No. 55(FIN)” as adopted by the Alaska House of Representatives, and the FiscalNote” for HB55, including analysis provided by Buck Consulting.
[4] The RSR’s Benefit Scores consider a range of factors including eligibility, income adequacy, inflation protection, mobility, and more. Defined benefit pension plans are scored on 10 factors; defined contribution plans are scored on 6 factors. To ensure appropriate comparison between such plans we report the percentage of available points scored across these factors. For a complete list of factors that are used to measure different kinds of retirement plans visit RetirementSecurity.Report and read the methodology.
[5] The current Alaska PERS Defined Contribution plan does not have a built-in, prefunded cost-of-living adjustment. The proposed defined benefit pension plan for PERS would have a “Postretirement Pension Adjustment,” subject to reduction in the future if the retirement plan’s funding declines below 90% The proposed plan’s 80% of available points for COLAs exceeds the 0% of points score for the defined contribution plan.
[6] Most individuals who become peace officers, firefighters, teachers, or other public workers join because of a personal commitment to the profession, for salary, for health benefits, for secure employment, or because of a family/friend connection. Few individuals make any job choice solely because of retirement plan benefits, no matter the underlying design. There is some evidence to suggest that pension plans can encourage retention of individuals after 15 to 20 years of service, but those effects only have been found with ”very generous” benefit values and low member contribution rates, and some academic analysis has found no meaningful retention effects from retirement plan design. For more see, academic analysis from Stock and Wise 1990; Coile and Gruber 2007; Behagel and Blau 2012; Brown 2013; Clark, Hanson and Mitchell 2016; Ni and Podgursky 2016; Morrill and Westhall 2018; Quinby and Sanzenbacher 2020
[7] The RSR’s Sustainability scores are an abridged assessment of the financial condition of a retirement system based on investment performance relative to assumptions, the historic consistency of state legislatures ensuring actuarially determined contributions are paid, the existence of risk-sharing tools, and whether the amortization period is projecting full funding in a reasonable period. For complete background on why we use these select factors visit RetirementSecurity.Report and read the methodology.
[8] Employer contributions to the legacy defined benefit plan are primarily paid by employers who participate in PERS. The statutory rate for PERS employers is 22% of payroll. This is less than the actuarially determined contribution rate, so the state makes up the difference with a contribution of its own. Employer contributions to the accounts of defined contribution plan members are 5% of payroll.
[9] Member contributions to the legacy defined benefit plan (for members hired on/before June 30, 2006) are 7.5% of salary for those who are peace officers or firefighters. Other members of Alaska PERS pay 6.75%. Members of PERS who have elected to have their service calculated using Teachers’ Retirement System of Alaska rules pay 9.67%. Member contributions to the PERS defined contribution plan (for members hired on/after July 1, 2006) are 8% of salary.
[10] State of Pensions 2021
[11] It is notable that in 2017, the Michigan legislature established a new pension plan option for public school employee members as of February 2018, and when they did so they prescribed a maximum assumed rate of return for that pension plan. At the time the legacy pension plan for teachers used an 8% assumed rate of return, but the pension plan for new members has a maximum 6% assumed rate of return. In this way, the state was able to set up the new pension plan that was desired, while applying best practices for risk-mitigation and not simultaneously causing a cost increase by forcing a change to the legacy pension plan’s assumed rate of return. 
[12] Policymakers who are building pension plans to be financially resilient should consider the risk-sharing and risk-mitigation concepts published in frameworks from Equable Institute, Urban Institute, and Rockefeller College.
[13] The preliminary assessment is the GASB 67 analysis published in the PERS FY 2021 Annual Comprehensive Financial Report (page 42).

Infographic: State Funded Ratio Histories

Funded Ratio History for U.S. Statewide Pension Funds

Download this infographic here.

These graphics originally appeared in the December Update to State of Pensions 2020. Read the report at

Individual state graphics are available for download here

Which States Have Laws that Allow for Police Pension Forfeiture?

If a police officer commits a crime in the course of performing their duties, they may be at risk of losing their pension. But only in certain states.

Most states have some kind of “pension forfeiture” laws on the books. These laws usually are related to public employees that are either convicted of, or plead no contest to, a felony or unlawful killing.[1] Only 23 of the state laws cover law enforcement employees, such as police officers.[2] There are three states that might cover police, depending on how they’re interpreted, and 24 states without laws covering police.

The details about what kind of crimes will lead to pension being stripped from a police officer vary from state to state. Usually the forfeiture law is limited to on-duty offenses, other times it is not. A few states allow for pension benefit reductions rather than taking the whole pension away. And the process for determining whether a pension is to be forfeited isn’t always the same: some states automatically strip pensions from individuals under these circumstances, other states have judges order the pension taken away or require pension boards to hold  proceeding to consider taking the right to a pension away.

For complete details, please review the relevant statutes in your state.

If you are interested in learning more about the benefits offered to public safety officers in your state, check out the Retirement Security Report.

Disclaimer: This article and infographic is not intended as legal advice or formal legal analysis. 



[1] There are seven states with pension forfeiture laws that do not apply to police officers, including: Delaware and Minnesota (laws only applies to surviving beneficiaries who commit an unlawful killing, not active members); Indiana and South Carolina (laws allows for pension benefits to be used as restitution for theft or embezzlement of public property, but does not otherwise require forfeiture for committing a crime); New Mexico and North Carolina (laws allow for pension forfeiture of elected official benefits only); New York (a 2018 law only allows pension forfeiture for elected officials, judges, and gubernatorial appointees)

[2] There are three states with laws that could be interpreted as covering police officers in addition to the 24 listed on the map above. Texas has a pension forfeiture law that only applies to the state Employees’ Retirement System, which does include some state police officers, but does not cover the vast majority of police around the state. Arkansas and Montana have laws that strip the pension of a public employee if they commit an unlawful killing, but only if the person they kill is another public employee.