Meiners v. Wells Fargo & Co., No. 17-2397 (8th Cir. 2018)
Annotate this CaseThe Eighth Circuit affirmed the district court's dismissal of plaintiff's complaint for failure to state a claim. Plaintiff alleged that his former employer, Wells Fargo, breached their fiduciary duty under the Employment Retirement Income Security Act (ERISA). The court held that the district court correctly determined that plaintiff's omission of any meaningful benchmark in his complaint meant that he failed to allege any facts showing the Wells Fargo Target Date Funds were an imprudent choice. In this case, plaintiff did not plead that the Funds were underperforming and his conclusory allegations of bad conduct did not save the complaint from its deficient pleading. Therefore, plaintiff failed to state a claim for relief under ERISA.
Court Description: Grasz, Author, with Gruender and Erickson, Circuit Judges] Civil case - ERISA. The district court did not err in concluding plaintiff's complaint failed to state a plausible claim for breach of fiduciary duty because it lacked sufficient factual matter, accepted as true, to demonstrate that Wells Fargo's decision to use Wells Fargo Dow Jones Target Date Funds as plan investment options was an imprudent choice; specifically, plaintiff did not plead the Funds were underperforming funds; plaintiff's conclusory allegations of bad conduct do not save the complaint from its deficient pleading; there was no basis for plaintiff's allegation that the district court failed to read the complaint as a whole.
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