Eleventh Circuit Vacates Prior Decision on ERISA Fiduciary

The Eleventh Circuit revisited its holding in Pruitt v. SunTrust Banks, Inc., No. 14-13207 (11th Cir. June 30, 2015), a putative ERISA class action brought against ERISA fiduciaries by plan participants, concerning certain investments in the plan.  The district court had dismissed the case based on ERISA’s borrowed six-year statute of limitations.  In related proceedings, another panel of the Court had affirmed that conclusion in Fuller v. SunTrust Banks, Inc., 744 F.3d 685 (11th Cir. 2014).  Recently, the Supreme Court decided Tibble v. Edison International, 135 S. Ct. 1823 (2015) which held under trust law, which controls the contours of an ERISA fiduciary’s duties, “a fiduciary normally has a continuing duty of some kind to monitor investments and remove imprudent ones.” 135 S. Ct. at 1828-29. Accordingly, the Supreme Court held that a plaintiff can effectively allege that a defendant breached its duty of prudence under ERISA “by failing to properly monitor investments and remove imprudent ones[,] . . . [and] so long as the alleged breach of the continuing duty occurred within six years of suit, the claim is timely.” Id. at 1829.  In light of this holding, the Eleventh Circuit panel vacated the district court’s summary judgment to defendant and remanded for reconsideration in light of Tibble v. Edison International.

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