Articles Posted in US Court of Appeals for the First Circuit

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The First Circuit affirmed the district court’s denial of Plaintiffs’ complaint alleging violations of the fiduciary duty of prudence under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001-1461, by the fiduciaries of an employer-sponsored retirement plan for failure to state a claim. Plaintiffs, three individuals who participated in an ERISA employee retirement plan that was sponsored by their employer, CVS Health Corporation (CVS), and administered by the Benefits Plan Committee of CVS (the Committee), alleged that CVS, the Committee, and Galliard Capital Management, Inc., which managed the fund, owed Plaintiffs a fiduciary duty of prudence under ERISA with respect to the plan’s investments in the fund and that each of the defendants breached that duty. The district court granted Defendants’ motion to dismiss the complaint for failure to state a claim under ERISA. The First Circuit affirmed, holding that Plaintiffs’ complaint failed to state a plausible claim against any of the defendants. View "Barchock v. CVS Health Corp." on Justia Law

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In this certified class action brought under the Employee Retirement Income Security Act of 1974 (ERISA), the district court correctly concluded that Plaintiffs failed to adduce evidence necessary to proceed to trial. Plaintiffs sued Fidelity Management Trust Company, the fiduciary for a fund in which Plaintiffs had invested, arguing that Fidelity breached its duties of loyalty and prudence in managing the fund. The district court granted summary judgment for Fidelity, finding that Plaintiffs’ arguments lacked the evidentiary support needed to survive summary judgment. The First Circuit affirmed, holding (1) the district court employed the correct legal test in its evaluation of the evidence; and (2) the district court correctly held that Plaintiffs had presented insufficient evidence to proceed to trial on their claims of disloyalty and imprudence. View "Ellis v. Fidelity Management Trust Co." on Justia Law

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The district court erred in refusing to vacate its dismissal of a pension fund’s lawsuit against an employer’s alleged alter egos. In the lawsuit, the fund sought $1.2 million in unpaid withdrawal liability that was previously assessed against the employer in a default judgment. The district court dismissed the case, concluding that subject matter jurisdiction did not exist under the Employee Retirement Income Security Act (ERISA). The court subsequently denied Appellant’s motion for post-judgment relief. The First Circuit vacated the court’s post-judgment ruling and remanded the case for further proceedings, holding that the fund’s alter ego claims were anchored in ERISA, and thus the fund had established federal subject matter jurisdiction. View "Groden v. N&D Transportation Co., Inc." on Justia Law