To arrive at a safe conclusion as to the validity of legislation. providing for teachers' pensions requires some consideration of all pension legislation. A pension is defined by BOUVIER as "A stated and certain allowance granted by the government to an individual, or those who represent him, for valuable services performed by him for the country;"1 "a periodical allowance of money granted by the government for services rendered;"2 "a stated payment to a person in consideration of the past services of himself or of some kinsman or ancestor;"3 "an annuity from the government for services rendered in the past;"4 "a bounty for past services rendered to the public;"5 "a mere bounty or gratuity given in consideration or recognition of meritorious past services rendered by the pensioner or by some kinsman or ancestor;"6 it "is in the nature of a gift for the personal benefit" of the beneficiary;"7 pensions, "are not granted in consequence of a deficiency of pay while in service, but they are gratuities for honorable service when the party in most cases is unable to render further services;" yet they are usually considered as being granted partly because the service rendered was of much greater value than the sum paid at the time, and also as a gratuity, because not founded on any enforceable contract.8 They include "any half pay, compensation, allowance, superannuation or retirement allowance, or other payment of the like nature, made on the retirement of any officer;9 a pension differs from a salary in that the pensioner is not under any obligation to render any service for his pension; but both pensions and salaries are property.10 In the foregoing, "pensions", are defined as grants of governments; however the term has also often been applied to gratuitous annuities granted by corporations.11
Wilgus, Horace LaFayette. "Constitutionality of Teachers' Pensions Legislation." Mich. L. Rev. 11 (1913): 451-77.