United States Fourth Circuit

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Tatum v. RJR Pension Investment Committee, 13-1360

In a class action brought on behalf of plaintiff and other participants in defendant-employer's 401(k) retirement savings plan alleging that defendant-employer breached its fiduciary duties under the Employee Retirement Income Security Act (ERISA) when it liquidated two funds held by the plan on an arbitrary timeline without conducting a thorough investigation, thereby causing a substantial loss to the plan, judgment for defendant is: 1) affirmed in part, where the district court properly concluded that defendant-employer breached its duty of procedural prudence and therefore bore the burden of proof as to causation; but 2) reversed in part and remanded, where the district court then failed to apply the correct legal standard in assessing defendant-employer's liability.

Appellate Information

  • Decided 08/04/2014
  • Published 08/04/2014

Judges

  • MOTZ

Court

  • United States Fourth Circuit

Counsel


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