Vigeant v. Meek, No. 18-3616 (8th Cir. 2020)Annotate this Case
Plaintiffs filed a putative class action against former trustees of the Lifetouch Plan, the Board, and Lifetouch, alleging claims under the Employee Retirement Income Security Act (ERISA). The Eighth Circuit affirmed the district court's dismissal of the amended complaint for failure to state a claim. The court held that, because plaintiffs failed to plead a plausible breach of the duty of prudence by the trustee defendants, the district court properly dismissed their duty to monitor claims against the Board and Lifetouch because those claims cannot survive without a sufficiently pled theory of an underlying breach.