Barchock v. CVS Health Corp., No. 17-1515 (1st Cir. 2018)Annotate this Case
The First Circuit affirmed the district court’s denial of Plaintiffs’ complaint alleging violations of the fiduciary duty of prudence under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001-1461, by the fiduciaries of an employer-sponsored retirement plan for failure to state a claim.
Plaintiffs, three individuals who participated in an ERISA employee retirement plan that was sponsored by their employer, CVS Health Corporation (CVS), and administered by the Benefits Plan Committee of CVS (the Committee), alleged that CVS, the Committee, and Galliard Capital Management, Inc., which managed the fund, owed Plaintiffs a fiduciary duty of prudence under ERISA with respect to the plan’s investments in the fund and that each of the defendants breached that duty. The district court granted Defendants’ motion to dismiss the complaint for failure to state a claim under ERISA. The First Circuit affirmed, holding that Plaintiffs’ complaint failed to state a plausible claim against any of the defendants.