Justia Summary
Plaintiffs are retired participants a defined-benefit retirement plan, which guarantees them a fixed payment each month regardless of the plan’s value or its fiduciaries’ investment decisions. Both have been paid all of their monthly pension benefits so far and are legally entitled to those payments for the rest of their lives. They filed a putative class-action suit under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001, alleging violations of ERISA’s duties of loyalty and prudence by poorly investing the plan’s assets. They sought the repayment of approximately $750 million to the plan in losses suffered due to mismanagement; injunctive relief, including replacement of the plan’s fiduciaries; and attorney’s fees.
The Eighth Circuit and the Supreme Court affirmed the dismissal of the case. Because the plaintiffs have no concrete stake in the lawsuit, they lack Article III standing. Win or lose, they will still receive the exact same monthly benefits they are entitled to receive. Participants in a defined-benefit plan are not similarly situated to the beneficiaries of a private trust or to participants in a defined-contribution plan; they possess no equitable or property interest in the plan. The plaintiffs cannot assert representative standing based on injuries to the plan where they themselves have not “suffered an injury in fact,” or been legally or contractually appointed to represent the plan. The fact that ERISA affords all participants—including defined-benefit plan participants—a cause of action to sue does not satisfy the injury-in-fact requirement. Article III standing requires a concrete injury even in the context of a statutory violation. The Court rejected an argument that meaningful regulation of plan fiduciaries is possible only if they may sue to target perceived fiduciary misconduct; defined-benefit plans are regulated and monitored in multiple ways.