Supreme Court of the United States
James J. Thole, Petitioners v. U. S. Bank N.a .
June 1, 2020590 U.S. 538
Summary
The Court, in an opinion by Justice Kavanaugh, affirmed on Article III grounds the dismissal of defined-benefit pension participants’ ERISA fiduciary-mismanagement suit. Because the participants had received their promised benefits and the litigation would not change their future payments, they lacked a concrete stake. Trust-law analogies, asserted representation of the plan, ERISA’s statutory causes of action, and concerns about inadequate enforcement did not establish standing. The Court left unresolved whether sufficiently increased risks of plan and employer failure could establish standing in another case. Justice Thomas, joined by Justice Gorsuch, concurred, reasoning that the allegedly violated rights belonged to the plan rather than the participants and urging reconsideration of reliance on trust-law analogies. Justice Sotomayor, joined by Justices Ginsburg, Breyer, and Kagan, dissented, arguing that participants had standing through their equitable interest in plan assets, their rights to loyal and prudent fiduciaries, and their statutory authority to represent the injured plan.
Holding
- Article III standing based on alleged mismanagement of a defined-benefit pension plan.. These participants lacked Article III standing because they had received all vested pension payments and winning or losing the suit would not change their monthly benefits.
- Standing based on an asserted equitable interest in plan assets.. The participants’ analogy to private-trust beneficiaries did not establish standing to challenge the management of this defined-benefit plan.
- Standing to represent the plan.. The participants could not establish standing merely by asserting the plan’s interests.
- Standing based on ERISA’s enforcement provisions and asserted enforcement gaps.. Neither ERISA’s authorization to sue nor the asserted need for participant enforcement dispensed with Article III’s concrete-injury requirement.
Docket 17-1712
Cited authorities
- 18 U.S.C. § 1954
- 29 U.S.C. § 1132(a)(2)
- 29 U.S.C. § 1109
- 88 Stat. 829
- 29 U.S.C. § 1001
- 29 U.S.C. §§ 1132
- 29 U.S.C. § 1132
- 29 U.S.C. §§ 1132
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