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No. 18-1116October Term 2019Decided Feb 26, 2020

Docket 18-1116October Term 2019 (2019–2020)

Intel Corp. Investment Policy Comm. v. Sulyma

Making information available is not enough by itself to start ERISA's three-year clock; the plaintiff must actually know the key facts.

Case status

Current stage
Decided
Latest event
Decision released Feb 26, 2020
Case Accepted
Arguments
Decision ReleasedFeb 26, 2020
What it's about

This case asked when the three-year deadline for bringing an ERISA fiduciary-breach claim begins to run. The Court held that a plaintiff does not have the required "actual knowledge" just because plan disclosures were made available to him if he did not read them or cannot remember reading them.

Question presented

Whether the three-year limitations period in Section 413(2) of the Employee Retirement Income Security Act, 29 U.S.C. 1113(2), which runs from "the earliest date on which the plaintiff had actual knowledge of the breach or violation," bars suit where all of the relevant information was disclosed to the plaintiff by the defendants more than three years before the plaintiff filed the complaint, but the plaintiff chose not to read or could not recall having read the information.

Case path

United States Court of Appeals for the Ninth Circuit / Decision released Feb 26, 2020

Area

Decided Supreme Court case

Briefing

What it's about

This case was about when the three-year deadline starts for an ERISA fiduciary-breach claim. The Court said a plaintiff lacks the required "actual knowledge" just because plan disclosures were available if he did not read them or cannot remember reading them.

Vote

The Court decided the case on February 26, 2020, after argument on December 4, 2019, but the vote count and opinion lineup are not provided here.

Impact

The decision makes it harder for retirement-plan managers to end cases early just by showing they sent disclosures years before. It matters to workers who receive complex investment documents but may not actually read or recall them.

What's next

The Supreme Court has finished this case. The practical next step is for lower courts and ERISA litigants to apply this reading of "actual knowledge" in future disputes.

What was the main dispute in Intel Corp. Investment Policy Comm. v. Sulyma?

The fight was over ERISA's three-year deadline. The question was whether disclosure alone counts as a plaintiff's actual knowledge.

Who is most affected by this decision in the real world?

Workers in retirement plans and the companies managing those plans are most affected. Sending disclosures alone may not start the shorter deadline.

What happens after the Supreme Court's decision in this case?

The Supreme Court's work is done on this docket. Lower courts must use this interpretation when deciding similar ERISA timing disputes.

Decision

Decision record

What the Court decided

Making information available is not enough by itself to start ERISA's three-year clock; the plaintiff must actually know the key facts.

Impact

The decision makes it harder for retirement-plan managers to end cases early just by showing they sent disclosures years before. It matters to workers who receive complex investment documents but may not actually read or recall them.

Not official Court text.

Opinion documents