LaRue v. DeWolff, Boberg & Associates, Inc., 552 U.S. 248 (2008)
The case of LaRue v. DeWolff, Boberg & Associates, Inc., decided by the United States Supreme Court in 2008, is a cornerstone case in the landscape of employee retirement plan litigation under the Employee Retirement Income Security Act of 1974 (ERISA).
Can an individual participant in a 401(k) retirement plan sue plan fiduciaries for losses to his individual account under ERISA § 502(a)(2)?
ERISA § 502(a)(2) allows participants, beneficiaries, and fiduciaries to bring a civil action for violations of the fiduciary duties outlined in the statute, including breaches that result in losses to individual accounts in a defined contribution plan.
The United States Supreme Court held that ERISA § 502(a)(2) does allow an individual participant in a defined contribution pension plan, like a 401(k), to pursue losses to their individual account due to fiduciary breaches.
LaRue v. DeWolff is fundamental for law students studying ERISA as it clarifies the application of fiduciary duty and liability within the framework of defined contribution plans versus defined benefit plans. This precedent extended ERISA's civil enforcement provision to include individual account claims, reinforcing ERISA's role in providing robust protections to participants seeking remedies for fiduciary breaches at the individual level. This decision marks a significant shift towards recognizing the individual interests and rights of plan participants within defined contribution schemes, making it crucial for future fiduciary litigation.