With no explanation, chose the best option from "A", "B", "C" or "D". 114 Hawaii 302, 347, 162 P.3d 696, 741 (2007), Alaska’s constitution contains a provision that is “nearly identical in wording and substance” to article XVI, section 2 of the Hawaii Constitution. Accordingly, the court in Kaho'ohanohano cited Alaska’s case law as “instructive in interpreting our own clause.” Id. Although the issue of when an employee’s constitutionally protected benefits accrue was not squarely before the court in Kaho'ohanohano, the court twice referenced that the Supreme Court of Alaska has determined that such benefits vest or accrue upon the employee’s employment and enrollment in an ERS, rather than when the employee becomes eligible to receive the benefits. Id. at 347-48, 162 P.3d at 741-42 (citing, e.g., Hammond v. Hoffbeck, 627 P.2d 1052, 1057 (Alaska 1981) (<HOLDING>); Municipality of Anchorage v. Gallion, 944

A: holding that unemployment compensation benefits received by plaintiff are collateral source and that defendant could not reduce personal injury damages because of such benefits
B: holding that disability benefits are not retirementtype benefits
C: holding that military retirement benefits are to be considered deferred pay for past services
D: holding that benefits under alaskas ers are in the nature of deferred compensation and that the right to such benefits vests immediately upon an employees enrollment in that system
D.