In re Tyco Litigation

2004 DNH 177
CourtDistrict Court, D. New Hampshire
DecidedDecember 2, 2004
DocketMDL-02-1335
StatusPublished
Cited by1 cases

This text of 2004 DNH 177 (In re Tyco Litigation) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Tyco Litigation, 2004 DNH 177 (D.N.H. 2004).

Opinion

In re Tyco Litigation MDL-02-1335 12/02/04

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

In re Tyco International. Ltd. Multidistrict Litigation (MDL 1335) MDL DOCKET NO. 02-1335-PB ERISA Action Case N o . 02-1357-PB Opinion No. 2004 DNH 177

MEMORANDOM AND ORDER

The named plaintiffs in this class action are participants

in retirement plans (“Plans”) sponsored by Tyco International

(US) Inc. (“Tyco U S ” ) . Plaintiffs invoke the Employee Retirement

Income Security Act (“ERISA”) in asserting breach of fiduciary

duty claims against Tyco U S , its parent corporation, Tyco

International Ltd. (“Tyco International”), the committee that

administered the Plans, and several former officers and directors

of Tyco US and its parent corporation. The claims concern the

Tyco Stock Fund, which holds Tyco International stock and is one

of the Plans’ investment options. Plaintiffs charge in Count I

that defendants made material misstatements and omissions to

participants concerning Tyco International’s financial condition

and the risk characteristics of the fund. They allege in Count II that defendants were negligent in allowing participants to

invest in the fund.

Defendants attack the complaint’s sufficiency on several

grounds. They first argue that only the committee that

administered the Plans was a fiduciary. Second, they assert that

plaintiffs’ claims are barred by Section 404(c) of ERISA, which

precludes certain breach of fiduciary claims for losses that were

caused by a participant’s own investment decisions. Next, they

contend that Count I fails because it does not allege any

actionable misstatements or omissions and Count II is deficient

because it does not sufficiently allege that defendants acted

imprudently. Finally, they contend that the complaint must be

dismissed because ERISA does not authorize Plan participants to

recover monetary relief for fiduciary breaches.

I. BACKGROUND

Tyco US sponsors the seven retirement plans that are at

issue in this case. All seven plans are “individual account

plans.” 29 U.S.C. § 1002(34). Accordingly, each participant is

assigned an individual account and the participant’s benefits are

-2- “based solely upon the amount contributed to the account, and any

income, expenses, gains or losses, and any forfeitures of

accounts of other participants which may be allocated to such

participant’s account.” Id. Participants are permitted to

contribute to their accounts and Tyco US is required to make

matching contributions in amounts equal to a specified percentage

of a participant’s regular compensation. Participants may choose

from among several different investment options and may transfer

funds from one investment to another at any time.

The Tyco Stock Fund is one of several investment options

that are available under the Plans. The fund holds shares in

Tyco International stock. Because it is a “unitized fund,” a

trustee designated by Tyco US holds title to the stock and

participants are assigned units in the fund. The trustee

acquires stock by purchasing it on the open market. Participants

are not permitted to invest more than 25% of their Plan assets in

the fund.

The Tyco US Retirement Committee (“Committee”) is both the

administrator and a “named fiduciary” for all seven Plans. The

Board of Directors of Tyco US is responsible for appointing and

-3- removing members of the Committee. The Plans describe the

respective powers and duties of the Board and the Committee by

stating that

[t]he Board of Directors of the Plan Sponsor and the Committee shall have only those specific powers, duties, responsibilities, and obligations as are specifically given them under this Plan and the Trust Agreement. In general, the Board of Directors of the Plan Sponsor shall have the sole responsibility for the appointment of the Retirement Committee. The Committee shall have the sole responsibility for the general administration of the Plan and for carrying out its provisions.

See, e.g., Plan II ¶ 8.1. Each Plan also states that

[t]he Board of Directors of the Plan Sponsor and the Committee and any other person who, by reason of his involvement in and under this Plan, shall be deemed to be a fiduciary within the meaning of Title I , Section 3(21) of ERISA, shall discharge their Plan-related duties and responsibilities solely in the interests of the participants and their beneficiaries and with the care, skill, prudence and diligence under the circumstances then prevailing that a prudent man acting in like capacity and familiar with such matters would use in the conduct of an enterprise of like character and with like aims.

See, e.g., Plan II Art. XIII.

Plaintiffs claim that the price of Tyco International’s

stock was grossly inflated during the class period as a result of

undisclosed looting and pervasive accounting fraud by its senior

-4- management. As a result, class members who held units in the

Tyco Stock Fund during the class period allegedly suffered

substantial losses when the company’s true financial condition

was exposed.

II. STANDARD OF REVIEW

“[A] complaint should be dismissed [pursuant to Fed. R. Civ.

P. 12(b)(a)]. . . ‘only if it is clear that no relief could be

granted under any set of facts that could be proved consistent

with the allegations.’” Gorski v . N.H. Dep’t of Corr., 290 F.3d

466, 473 (1st Cir. 2002) (quoting Hishon v . King & Spalding, 467

U.S. 6 9 , 73 (1984)). Accordingly, I must accept the complaint’s

factual allegations as true and draw all reasonable inferences

from those alleged facts in favor of the plaintiffs. Id.

Although the complaint is governed by the liberal pleading

standards of Fed. R. Civ. P. 8 ( a ) , it nevertheless “must set

forth factual allegations, either direct or inferential,

respecting each material element necessary to sustain recovery

under some actionable legal theory.” United States ex rel.

Karvelas v . Melrose-Wakefield Hosp., 360 F.3d 2 2 0 , 240 (1st Cir.

2004).

-5- III. ANALYSIS1

A. Fiduciary Status

Defendants first argue that only the Committee and its

members can be held liable for a breach of fiduciary duty because

the Committee is the only entity that was named as a fiduciary

under the Plans.

Retirement plans regulated under ERISA must have one or more

named fiduciaries. 29 U.S.C. § 1102(a). In addition, Section

3(21)(a) of ERISA provides that

a person is a fiduciary with respect to a plan to the extent (i) he exercises any discretionary authority or discretionary control respecting management of such plan or exercises any authority or control respecting management or disposition of assets, (ii) he renders investment advice for a fee or other compensation, direct or indirect, with respect to any moneys or other property of such plan, or has any authority or respon-

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Related

In re Tyco MDL (ERISA)
2006 DNH 091 (D. New Hampshire, 2006)

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2004 DNH 177, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-tyco-litigation-nhd-2004.