Anderson v. Intel Corporation Investment Policy Committee
Overview
Overview
A case in which the Court will decide whether a complaint alleging a fiduciary breach in ERISA underperformance cases must include allegations of a "meaningful benchmark" to survive the pleading stage.
The Issue
Issue
Whether a complaint alleging ERISA fiduciary breach based on investment underperformance must include specific allegations of a 'meaningful benchmark' to survive a motion to dismiss under Rule 12(b)(6).
The Rules
Rule
Under ERISA, fiduciaries owe a duty of prudence in managing plan assets. Complaints challenging fiduciary decisions must allege facts that, if true, establish a plausible breach, meeting the pleading standards of Twombly and Iqbal.
The Application
Analysis
Anderson alleges that Intel's Investment Policy Committee breached its fiduciary duty by selecting underperforming investments. The central question is whether the complaint adequately alleges imprudence without explicitly identifying the benchmark used to measure that underperformance.
The Conclusion
Conclusion
The case is active and pending. The Court will determine whether meaningful-benchmark allegations are a pleading requirement for ERISA underperformance claims to survive dismissal.
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