In re Tyco MDL

2009 DNH 046
CourtDistrict Court, D. New Hampshire
DecidedApril 3, 2009
DocketMD-02-1335-B
StatusPublished

This text of 2009 DNH 046 (In re Tyco MDL) 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 MDL, 2009 DNH 046 (D.N.H. 2009).

Opinion

In re Tyco MDL MD-02-1335-B 04/03/09

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. 2009 DNH 046

MEMORANDUM AND ORDER

Section 404(c) of ERISA provides certain fiduciaries with an

affirmative defense against ERISA claims brought by plan

participants or beneficiaries who exercise control over the

assets in their individual account pension plans. Plaintiffs

argue in a motion for summary judgment that this defense is

unavailable to fiduciaries who are sued because of a decision to

designate the investment options that are available to plan

participants. Because I agree with the plaintiffs on this point,

I grant their motion to the extent that it is directed at

defendants’ section 404(c) defense.

I. THE CASE

The named plaintiffs in this class action are participants

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

(US) Inc. (“Tyco U S ” ) . Plaintiffs invoke 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, several former officers

and directors of Tyco U S , 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

designating the Tyco Stock Fund as an investment option and

allowing participants to invest in the fund. Defendants have

responded by denying plaintiffs’ claims and asserting an

affirmative defense based on section 404(c).

II. 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

“based solely upon the amount contributed to the participant’s

account, and any income, expenses, gains and losses, and any

forfeitures of accounts of other participants which may be

-2- 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 twenty-five percent 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

removing members of the Committee.

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

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

Tyco Stock Fund during the class period allegedly suffered

-3- substantial losses when the company’s true financial condition

was exposed.

III. ANALYSIS1

Plaintiffs argue that section 404(c) does not apply to

claims such as theirs, which are based on a fiduciary’s

designation of the investment options that are available to plan

participants. Their argument involves the following steps:

First, they note that section 404(c) provides fiduciaries with an

affirmative defense only with respect to losses that “result[]

from such participant’s or beneficiary’s exercise of control . .

. ” over the assets in the participant’s account. 29 U.S.C. §

1104(c)(1)(A)(ii). Next, they rely on regulations adopted by the

Department of Labor (“DOL”) which state that losses do not result

from a participant’s exercise of control over his assets unless

the losses are “the direct and necessary result of that

participant’s or beneficiary’s exercise of control.” 29 C.F.R. §

2550.404c-1(d)(2)(i) (emphasis added). Finally, they point to

the DOL’s statement in the preamble to the regulations that “the

1 Plaintiffs base their summary judgment argument on a pure question of law. Because the underlying facts that bear on this question are not in dispute, I resolve the motion on the legal issue without engaging in an extended discussion of the summary judgment standard.

-4- act of limiting or designating investment options which are

intended to constitute all or part of the investment universe of

an ERISA 404(c) plan is a fiduciary function which, whether

achieved through fiduciary designation or express plain language,

is not a direct or necessary result of any participant direction

of such plan.” Final Regulations Regarding Particular Directed

Individual Account Plans (ERISA Section 404(c) Plans), 57 Fed.

Reg. 46906-01, 46924 n.27 (Oct. 1 3 , 1992) (General Preamble).

Relying on these provisions, plaintiffs argue that defendants

are not entitled to a section 404(c) defense because the claims

at issue challenge defendants’ designation of the Tyco Stock Fund

as an investment option and the DOL has determined that

fiduciaries are not shielded by section 404(c) from losses which

result from such designation decisions.

Defendants respond by noting that in Langbecker v . Elec.

Data Sys. Corp., 476 F.3d 299, 310-13 (5th Cir. 2007), a divided

Fifth Circuit panel declined to give effect to the DOL’s

interpretation of its own regulations.2 I am unpersuaded by the

Fifth Circuit’s reasoning, however, and instead agree with the

dissent in that case that the DOL’s interpretation of its own

2 Defendants also cite the Third Circuit’s decision in In re Unisys Sav. Plan Litig., 74 F.3d 420 (3d Cir. 1996). This case is not relevant because it did not consider the DOL regulations.

-5- regulations is reasonable and should not be ignored. See id. at

320-22 (Reavley, J., dissenting).

Several factors lead me to this conclusion. First, section

404(c) is unclear as to whether it can be used to bar a claim

based on a fiduciary’s designation of investment options.

Second, section 404(c) requires the DOL to adopt regulations

explaining when a participant or beneficiary has sufficient

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74 F.3d 420 (Third Circuit, 1996)
In Re Tyco International Ltd. Multidistrict Litigation
606 F. Supp. 2d 166 (D. New Hampshire, 2009)

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