Lucas v. MGM Resorts International

CourtDistrict Court, D. Nevada
DecidedMarch 19, 2024
Docket2:20-cv-01750
StatusUnknown

This text of Lucas v. MGM Resorts International (Lucas v. MGM Resorts International) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lucas v. MGM Resorts International, (D. Nev. 2024).

Opinion

1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 Eboni D. Lucas, individually and on behalf of Case No.: 2:20-cv-01750-JAD-NJK all others similarly situated, 4 Plaintiff Order Granting Summary Judgment for 5 v. Defendants on Share-class Claims and Granting Defendants’ Motion to Exclude 6 MGM Resorts International, et al., Unreliable Expert Opinions of Cynthia Jones 7 Defendants [ECF Nos. 149, 149-1, 150, 150-1, 166, 168] 8

9 Plaintiff Eboni Lucas, on behalf of the MGM Resorts 401(k) Savings Plan, brings this 10 certified class action against MGM Resorts International, the Internal Compensation Committee 11 of MGM Resorts International, and the Administrative Retirement Committee of MGM Resorts 12 International (collectively, MGM).1 She alleges that MGM’s imprudence resulted in the 13 selection and retention of mutual-fund share classes with unnecessarily high investment costs 14 and that the Plan’s recordkeeping expenses were imprudently excessive as well. MGM moves 15 for summary judgment on Lucas’s share-class theory of liability, arguing that its share-class 16 decisions were prudent and didn’t result in measurable loss.2 It also moves to exclude the 17 opinions of Lucas’s expert Cynthia Jones for a number of reasons, but most importantly because 18 her loss calculations don’t account for revenue-share dollars that were rebated back to the Plan 19 and used to pay for Plan expenses or reallocated to Plan participants’ individual accounts, 20 rendering her methodology unreliable.3 21 22 1 ECF No. 14 (first amended complaint). 23 2 ECF No. 149-1. 3 ECF No. 150-1. 1 Despite attaching no evidence to her summary-judgment briefing, Lucas argues that there 2 is sufficient evidence to establish that there is a genuine issue of material fact as to whether 3 MGM’s conduct was imprudent.4 She also contends that Jones’s report establishes that the Plan 4 suffered loss and that Jones’s opinion shouldn’t be excluded because her calculations were made

5 using a widely accepted methodology and were properly based on Lucas’s theory of the case.5 6 Separately, Lucas requests leave to file supplemental authority—a district-court ruling issued 7 after the summary-judgment and Daubert motions in this case were fully briefed—in support of 8 her opposition to MGM’s summary-judgment motion.6 And MGM moves for leave to file 9 excess pages in its summary-judgment-reply brief and asks to seal all of its related briefing. 10 I grant the motion to supplement and take Lucas’s new authority into consideration. I 11 also grant MGM’s unopposed motion for leave to file excess pages but deny its motions to seal 12 because neither Lucas nor any interested non-party has justified sealing or additional redactions. 13 I grant MGM’s motion to exclude Jones’s opinions because her methodology was legally flawed 14 and produced inaccurate final calculations that are insufficient to establish that a triable issue of

15 fact exists as to loss. And because Lucas can’t show that the Plan experienced loss related to 16 share-class selection and retention without Jones’s excluded opinions, I grant MGM’s motion for 17 summary judgment on those claims. So this case proceeds to trial on Lucas’s excessive- 18 recordkeeping-expenses theory of liability only. But first, I order the parties to a settlement 19 conference with the magistrate judge. 20 21 22 4 ECF No. 161. 23 5 Id.; ECF No. 154. 6 ECF No. 168. 1 Factual Background 2 A. The Plan 3 This case concerns MGM’s management of the MGM Resorts 401(k) Savings Plan. 4 Class representative Lucas is a former MGM employee and former Plan participant.7 First

5 established in 1993, the Plan is a defined-contribution retirement plan that permits participants to 6 contribute portions of their annual compensation and direct their contributions into various 7 investment options.8 MGM “makes matching contributions equal to 50% of employee 8 contributions up to 6% of eligible compensation.”9 9 B. MGM’s management of the Plan 10 The Administrative Retirement Committee of MGM Resorts International is the Plan 11 fiduciary vested with “the authority to control and manage the operation and administration of 12 the Plan.”10 That authority includes appointing investment managers or advisors and engaging 13 others to “render advice or perform ministerial duties” for the Plan, such as recordkeepers.11 14 Throughout the class period, Prudential Retirement Insurance and Annuity Company was the

15 Plan’s recordkeeper and provider of other administrative services.12 UBS Financial Services, 16

7 ECF No. 106-5 at ¶¶ 3, 5 (Eboni D. Lucas declaration in support of class certification); ECF 17 No. 92; ECF No. 114. 18 8 See ECF No. 14 at ¶¶ 47–54: see also ECF No. 150-12 at ¶ 31 (expert rebuttal report of Steven K. Gissiner); ECF No. 85-2 (expert report of Eric C. Dyson). Because Lucas didn’t submit a 19 copy of Dyson’s report with her summary-judgment briefing despite citing to it extensively throughout, and because Lucas cites to parts of Dyson’s report that aren’t in the excerpts MGM 20 submitted, I rely on and cite to a copy of this report contained elsewhere in the record. But I don’t consider the portions of Dyson’s opinion that were excluded. See ECF No. 104 (excluding 21 Dyson’s opinion on damages arising out of advisory fees paid to UBS). 9 ECF No. 149-1 at 9 (citing ECF No. 14 at ¶¶ 51, 53). 22 10 ECF No. 149-3 at 123. 23 11 Id. at 125. 12 ECF No. 14 at ¶ 119; see also ECF No. 85-2 at ¶ 42; ECF No. 150-12 at ¶ 31. 1 Inc. served as the Plan’s investment advisor.13 Renee Fourcade, who is currently a Senior Vice 2 President and Senior Institutional Consultant for UBS, served as the “point person,” providing 3 investment advice to the Administrative Committee throughout the class period, though she was 4 supported by other UBS employees.14 Fourcade began providing investment advice for the Plan

5 in 1998.15 6 The Administrative Committee held regular quarterly meetings to discuss the Plan and 7 met at other times on an as-needed basis.16 In advance of those meetings, Fourcade provided the 8 Administrative Committee with documents that detailed the performance of funds that the Plan 9 offered, expense ratios and fees associated with those funds, and comparisons with other funds’ 10 expense ratios.17 She also attended these meetings and gave presentations to the Administrative 11 Committee.18 Following Fourcade’s advice, the Plan adhered to what both parties refer to as the 12 most-efficient-share-class approach, which involved selecting share classes with the lowest net 13 cost after revenue sharing was factored in.19 14 C. Mutual-fund share classes and revenue sharing

15 This case focuses on particular mutual-fund share classes available to Plan participants. 16 All such funds require Plan participants to pay investment fees to the fund company. This is 17 accomplished via the fund’s expense ratio, which is essentially a set percentage of the investment 18

19 13 ECF No. 85-2 at ¶ 42; ECF No. 150-12 at ¶ 31. 14 ECF No. 149-5 at 9:4–15, 10:10–17. 20 15 Id. at 6:4–7. 21 16 ECF No. 149-6 at 3:4–11; see also ECF No. 149-2 at 159–64 (agenda items and minutes from such meetings). 22 17 ECF No. 149-6 at 5:12–6:19. 23 18 Id. at 4:19–24. 19 ECF No. 149-6 at 7:12–8:2. 1 in the fund that is extracted from fund assets (i.e., Plan participants’ accounts) on an annual 2 basis.20 So, “[f]or example, a mutual fund with an expense ratio of .75% [or 75 ‘basis points’] 3 means that the plan participant will pay $7.50 annually for every $1,000 in assets.”21 Many 4 mutual funds, however, offer multiple “share classes” of the same fund, and these various share

5 classes may have different expense ratios. There can be a number of reasons for this.

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Lucas v. MGM Resorts International, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lucas-v-mgm-resorts-international-nvd-2024.