Two hundred twenty-five current and former employees of the steel mills located in Lorain, Ohio, claimed United States Steel Corporation, United States Steel and Carnegie Pension Fund and United Steel Workers of America (USW) intentionally misled them regarding the calculation of their pension benefits, inducing some to retire early.
The plaintiffs originally filed an action on June 1, 2099, asserting the following claims: breach of ERISA fiduciary duty, ERISA equitable accounting restitution and other equitable relief, equitable estoppel, failure to furnish requested plan documents, common-law fraud, common-law negligence, common-law breach of fiduciary duty and common-law promissory estoppel. The defendants moved to dismiss the claims for failure to state a claim, and the district court dismissed all the claims.
The court of appeals found that in regards to breach of ERISA fiduciary duty, the plaintiffs had no claim. ERISA contains a statue of limitations that requires a claim to be brought within three years of the date the plaintiff first receives knowledge of the breach or violation. Because the plaintiffs filed in 2009, three years after the expiry of the limitations period, the district court and court of appeals found the claims time-barred and dismissed them for failure to state a claim for relief.
The court also found that the complaint fails to plausibly allege that USW is an ERISA fiduciary.
According to the court opinion, “the complaint contains only the most conclusory of allegations that USW exercises discretionary control or authority over plan administration, management or assets, so it cannot be considered a de facto fiduciary under ERISA.”