Tibble v. Edison Int'l

**Question presented** When does the six‑year “statute of limitations” in the Employee Retirement Income Security Act (ERISA) begin to run for a claim that a plan fiduciary (the person who runs a retirement plan) failed to act prudently by keeping an investment in the plan that should have been replaced with a cheaper, equivalent option? Specifically, does the clock start when the investment is first added to the plan, or does it start when the fiduciary’s continuing duty to monitor and, if necessary, remove imprudent investments is breached? **Holding** The Supreme Court held that the Ninth Circuit was wrong to apply the six‑year limit to the original selection of the mutual funds. A fiduciary’s duty to monitor investments is a *continuing* obligation. If the fiduciary’s failure to review or replace an imprudent investment occurs within six years of the filing of the lawsuit, the claim is timely—even if the investment was originally added to the plan more than six years earlier. The case was sent back to the Ninth Circuit to decide whether the plaintiffs’ claims about the 1999 funds were filed within the six‑year period. **Core reasoning (majority)** - ERISA’s fiduciary duty is drawn from ordinary trust law, which says a trustee must not only choose investments prudently at the start but must also keep watching them and remove those that become imprudent. - Because that duty is ongoing, the “last action” that triggers the six‑year clock is not automatically the date the fund was first offered. Instead, the clock starts when the fiduciary’s *omission*—the failure to reassess and possibly replace the fund—could have been corrected. - Therefore, a plaintiff can sue within six years of the time the fiduciary should have acted to fix the problem, even if the fund had been in the plan for many years. **Dissent** No dissent was filed; the decision was unanimous (9‑0), with Justice Breyer writing the opinion for the Court. *(Definitions: “certiorari” is the Court’s agreement to hear a case; a “fiduciary” is a person who must act in the best financial interests of others; “statute of limitations” is the time limit for filing a lawsuit.)*