Tibble v. Edison International

Summarized by:

  • Court: U.S. Supreme Court Certiorari Granted
  • Area(s) of Law: Administrative Law
  • Date Filed: October 2, 2014
  • Case #: 13-550
  • Judge(s)/Court Below: Court Below: 711 F.3d 1061 (9th Cir. 2013)
  • Full Text Opinion

Whether the statute of limitations immunizes ERISA plan fiduciaries from retaining imprudent investments when the investments were first included in the plan more than six years ago, and whether Firestone deference applies in fiduciary breach actions when a fiduciary violates the terms of a governing plan document.

Petitioners, pension beneficiaries, brought a class action under the Employee Retirement Income Security Act (ERISA) against Respondent, their employer. Petitioners alleged that their pension plan was imprudently managed, and violated the pension plan’s governing document.

The district court granted Respondent’s motion for summary judgement on claims barred by ERISA’s statute of limitations, and rejected Petitioner’s continuing violation theory. On the remaining claims, the district court held that Respondent had acted imprudently when it selected investments with greater fees and risk than alternatives available to Respondent as an institutional investor, and that Respondent did not provide evidence of their investment consultant’s prudence in decision making.

Petitioner appealed, and the United States Court of Appeals for the Ninth Circuit affirmed the decision of the district court.

In their petition for certiorari, Petitioner argues that the Ninth Circuit should have applied Firestone deference in determining Respondent’s fiduciary duty under ERISA, following decisions in the Second and Seventh circuits. Petitioners contend that by applying Firestone deference, their barred claims would have been characterized as a continuing breach of duty and therefore not barred by the statute of limitations.

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