News & Analysis as of

Breach of Duty Appeals Summary Judgment

McDermott Will & Emery

Sour Grapes: Attorney’s Oral Agreement Might Be Okay if Fair, Just, and Fully Advised

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The US Court of Appeals for the Ninth Circuit found that a district court erred in declaring on summary judgment that an attorney had no ownership interest in a winery because the alleged agreement was made orally. The Ninth...more

Farrell Fritz, P.C.

Help Comes From an Unexpected Place in LLC Deadlock Dissolution: The Third Department

Farrell Fritz, P.C. on

Join me if you know this refrain: In New York, deadlock is not an independent ground for LLC dissolution. But… Almost exactly two years ago from today, Peter Mahler published a post titled: “Has the Time Come for...more

McGlinchey Stafford

Court Clarifies HOA Responsibilities in Tenant vs. Tenant Conflicts

McGlinchey Stafford on

Often, in litigation between an owner and their homeowners association (HOA), there is a question regarding the nature and the extent of the duty owed by the HOA to an owner (or even to a tenant of an owner). The answer to...more

Proskauer - Employee Benefits & Executive...

Eleventh Circuit Reiterates that Burden of Proving Loss Causation Stays with Plaintiffs

The Eleventh Circuit Court of Appeals recently affirmed a district court’s grant of summary judgment in favor of the fiduciaries of the Home Depot 401(k) plan, who defended against claims that they breached their fiduciary...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Oil Contamination/Remediation: New York Court Considers Potential Liability of Insurance Company/Environmental Consultant

The New York Supreme Court – Appellate Division (Second Department) (“Court”) addressed in an October 20th Decision & Order (“Decision”) alleged damages associated with the remediation of oil contamination. See Bennett v....more

Goodwin

ERISA Litigation Update - October 2021

Goodwin on

Welcome to Goodwin’s ERISA Litigation Update. Litigation involving ERISA-governed benefits plans has exploded in recent years. Lawyers in our award-winning ERISA Litigation practice have extensive experience litigating these...more

Goodwin

Litigation Insights - July 2021

Goodwin on

FOREWORD - On behalf of the new and expanding Goodwin London litigation team I am delighted to welcome you to our first ever ‘Litigation Insights’: a series of quarterly updates on important and interesting developments...more

Winstead PC

Court Found That There Was A Fact Question On Whether Officers Violated Fiduciary Duties By Obtaining A Side Bonus From A...

Winstead PC on

A business divorce may mean that the owners need to sell the business or the business’s assets. In the following case, some of the owners/officers took advantage of a sale transaction to benefit from that transaction at the...more

Winstead PC

Court Holds That A Trustee Had The Power To Sell Trust Property To An Affiliate, Though Such An Act May Be In Breach Of A Duty

Winstead PC on

In Pense v. Bennett, the ward in a guardianship proceeding sued to invalidate the sale of real property from a trust created for his benefit to an affiliate of the trustee. No. 06-20-00030-CV, 2020 Tex. App. LEXIS 8002 (Tex....more

Winstead PC

Court Addresses Claims Against A Trustee Arising From The Management Of A Limited Partnership Interest

Winstead PC on

In Benge v. Thomas, a settlor created a trust and appointed her daughter, Missi, as the trustee. No. 13-18-00619-CV, 2020 Tex. App. LEXIS 6888 (Tex. App.—Corpus Christi August 27, 2020, no pet.)....more

Pullman & Comley - Labor, Employment and...

Supreme Court’s Sulyma Decision Creates Proof of Actual Knowledge Issue for Plan Fiduciaries

Since its adoption the Employee Retirement Income Securities Act of 1974, as amended (“ERISA”), has required employee benefit plan sponsors to make disclosures regarding plan terms and plan expenses.  The most well-known of...more

Hinshaw & Culbertson LLP

The LHD/ERISA Advisor - October 2020: Second Circuit Allows Breach of Fiduciary Duty Claim to Proceed Based on Misrepresentation...

Hinshaw & Culbertson LLP on

In Sullivan-Mestecky v. Verizon Communs. Inc., 961 F.3d 91 (2d Cir. 2020), the Second Circuit held that a claim under Section 502(a)(3) of ERISA could proceed, where the beneficiary pled that the plan and its agents...more

Hinshaw & Culbertson LLP

The LHD/ERISA Advisor: U.S. Supreme Court Issues Ruling on 'Actual Knowledge' Required to Trigger ERISA's Limitations Period

On February 26, 2020, the Supreme Court issued its decision in Intel Corp. Inv. Policy Comm. v. Sulyma, __. U.S. __, 140 S. Ct. 768 (2020). The Court unanimously held that Christopher Sulyma ("Sulyma") did not necessarily...more

Dechert LLP

Sixth Circuit Issues Section 36(b) Ruling Affirming Grant of Summary Judgment To Mutual Fund Investment Adviser

Dechert LLP on

Key Takeaways - Sixth Circuit Court of Appeals reaffirms that comparison of advisory fees to subadvisory fees is “inapt” under Jones v. Harris Assocs., relying on undisputed evidence of differences in services and risks. ...more

Rivkin Radler LLP

Employee Benefit Plan Review – From the Courts

Rivkin Radler LLP on

Ninth Circuit Affirms Decision Rejecting Suit Seeking Early Retirement Benefits - The U.S. Court of Appeals for the Ninth Circuit has affirmed a district court’s decision rejecting a plaintiff’s lawsuit seeking to overturn...more

Dechert LLP

"Actual" Actually Means Actual - U.S. Supreme Court Rules in Sulyma on ERISA's Statute of Limitations 

Dechert LLP on

Under Section 413(2) of the Employee Retirement Income Security Act of 1974 (“ERISA”), ERISA’s three-year statute of limitations for fiduciary breaches and certain other violations starts to run when “the plaintiff had actual...more

Robinson+Cole ERISA Claim Defense Blog

Supreme Court’s Sulyma Decision May Complicate Plan Administrators’ Consideration of the DOL’s New Proposed Electronic Safe Harbor...

As discussed in an earlier post on this blog, in Intel Corporation Investment Policy Committee et al. v. Sulyma, No. 18-1116 (Feb. 26, 2020), the U.S. Supreme Court addressed the statute of limitations for breach of fiduciary...more

Faegre Drinker Biddle & Reath LLP

Actual Knowledge Means Actual Knowledge: U.S. Supreme Court Resolves Circuit Split Over ERISA’s Statute of Limitations for...

In its February 26, 2020, unanimous decision in Intel Corporation Investment Policy Committee v. Sulyma, the United States Supreme Court resolved a circuit split regarding what constitutes “actual knowledge” for purposes of...more

Morgan Lewis - ML Benefits

Supreme Court’s Sulyma Decision Lays Out Roadmap for Employers and Fiduciaries

The US Supreme Court recently decided a closely watched ERISA case against employers and fiduciaries. Under Section 413 of ERISA, the statute of limitations for a fiduciary breach claim is shortened from six years to three...more

Faegre Drinker Biddle & Reath LLP

Actual Knowledge Means Actual Knowledge: The U.S. Supreme Court Resolves Circuit Split over ERISA’s Statute of Limitations for...

In its February 26, 2020, unanimous decision in Intel Corporation Investment Policy Committee v. Sulyma, the United States Supreme Court resolved a circuit split regarding what constitutes “actual knowledge” for purposes of...more

Kramer Levin Naftalis & Frankel LLP

Supreme Court Rejects Shorter Statute of Limitations in ERISA Case

The Supreme Court in Intel Corporation Investment Policy Committee et al. v. Sulyma, case No. 18–1116, significantly narrowed the circumstances in which a three-year statute of limitations would apply to a claim for breach of...more

Eversheds Sutherland (US) LLP

Supreme Court holds that longer ERISA statute of limitations applies in Intel case

The U.S. Supreme Court ruled on February 26, 2020 that ERISA plaintiffs do not gain “actual knowledge” of fiduciary misconduct merely by receiving financial disclosures from the plan. The unanimous opinion in Intel Corp....more

Seyfarth Shaw LLP

Supreme Court’s Sulyma Ruling Toughens ERISA’s “Actual Knowledge” Standard & Makes Dismissal of Fiduciary Breach Actions More...

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Seyfarth Synopsis: On February 26, 2020, the Supreme Court unanimously affirmed the Ninth Circuit’s ruling in Intel Corp. Investment Policy Committee, et al. v. Sulyma. 589 U.S. ___ (2020), holding that plan participants must...more

A&O Shearman

U.S. Supreme Court Holds Plaintiffs Need Actual Knowledge Of Breach Of Fiduciary Duty To Be Held To Three-Year Statute Of...

A&O Shearman on

On February 26, 2020, the United States Supreme Court, in a unanimous decision by Justice Samuel Alito, held that for purposes of assessing the appropriate statute of limitations for a breach of fiduciary duty claim under the...more

Brownstein Hyatt Farber Schreck

“Actual Knowledge” Required to Apply ERISA’S Three-Year Statute of Limitations to Fiduciary Breach Claims

Yesterday, the U.S. Supreme Court issued its decision in Intel Corp. Investment Policy Committee et al. v. Sulyma (case number 18-1116). The decision requires a participant to have “actual knowledge” in order to apply ERISA’s...more

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