Justia ERISA Opinion Summaries

A group of plaintiffs, including several states and corporations, challenged a Department of Labor rule that allowed ERISA fiduciaries to consider environmental, social, and governance (ESG) factors when making investment decisions if those factors equally serve the financial interests of the plan. This rule was issued following an executive order by President Biden, which counteracted a previous Trump-era rule that prohibited considering non-pecuniary factors in investment decisions.The United States District Court for the Northern District of Texas upheld the Department of Labor's rule, relying on the Chevron deference doctrine, which allows courts to defer to a federal agency's interpretation of ambiguous statutory language. The district court concluded that the rule was not "manifestly contrary to the statute" after affording the Department the deference due under Chevron.The United States Court of Appeals for the Fifth Circuit reviewed the case. During the appeal, the Supreme Court decided Loper Bright Enterprises v. Raimondo, which overruled Chevron, thus eliminating the deference previously given to agency interpretations. Given this significant change in the legal landscape, the Fifth Circuit vacated the district court's judgment and remanded the case for reconsideration in light of the new Supreme Court decision. The appellate court emphasized the importance of allowing the district court to reassess the merits without the Chevron framework, ensuring that the lower court's independent judgment is applied to the statutory interpretation of ERISA. View "State of Utah v. Su" on Justia Law