Tibble v. Edison International (2014)
- Docket
- 13-550
- Decided
- 2014-01-01
Summary
Question: Does ERISA's six-year statute of repose bar a claim that plan fiduciaries breached their duty of prudence by offering higher-cost mutual funds to plan participants, even though identical lower-cost mutual funds were available, when fiduciaries initially chose the higher-cost mutual funds more than six years before the claim was filed? Conclusion: No. Justice Stephen G. Breyer delivered the opinion for the unanimous Court, which held that the nature of the fiduciary duty under trust law creates a continuing obligation to monitor trust investments and remove imprudent ones. Because this continuing duty is separate from the initial duty to choose investments carefully, violation of the continuing duty counts as a breach of the fiduciary duty under the Employee Retirement Income Security Act (ERISA). As long as the breach of the continuing duty occurred within six years of the filing of the lawsuit, ERISA’s statute of repose does not bar the claim.