Casey Cunningham, et al., Petitioners v. Cornell University, et al.

The Supreme Court ruled that plaintiffs suing retirement plan fiduciaries under ERISA for engaging in prohibited transactions need only allege that the transaction occurred, not that it failed to qualify for statutory exemptions. The Court determined that exemptions for reasonable and necessary services are affirmative defenses that defendants must prove, rather than elements plaintiffs must disprove in their initial complaint.