Smith v. Recreational Equipment Inc

CourtDistrict Court, W.D. Washington
DecidedJuly 16, 2025
Docket3:24-cv-06032
StatusUnknown

This text of Smith v. Recreational Equipment Inc (Smith v. Recreational Equipment Inc) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Smith v. Recreational Equipment Inc, (W.D. Wash. 2025).

Opinion

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4 5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT TACOMA 7 MACY SMITH AND SALLY JOHNSON, Case No. 3:24-cv-06032-TMC 8 individually and on behalf others similarly ORDER GRANTING MOTION TO 9 DISMISS situated, 10 Plaintiff, 11 v. 12 RECREATIONAL EQUIPMENT INC.; 13 BOARD OF DIRECTORS OF 14 RECREATIONAL EQUIPMENT INC.; 15 RETIREMENT PLAN COMMITTEE OF 16 RECREATIONAL EQUIPMENT INC , 17 Defendant. 18

19 I. INTRODUCTION 20 This case arises from Defendant Recreational Equipment Inc.’s (“REI”) policy of 21 charging record-keeping and administrative fees only to participant accounts in its defined 22 contribution retirement program with balances of at least $5,000. Plaintiffs Macy Smith and 23 Sally Johnson bring this suit on behalf of themselves and as representatives of a putative class of 24 1 participants and beneficiaries of REI’s retirement plan against Defendants REI, Board of 2 Directors of REI (“Board”), and Retirement Plan Committee of REI (“Plan Committee”). 3 Dkt. 26. Plaintiffs allege that Defendants breached their fiduciary duties under the Employee

4 Retirement Income Security Act of 1974 (“ERISA”), 29 U.S.C. § 1001 et seq. by imposing fees 5 only on participant accounts containing $5,000 or more. Id. 6 Defendants moved to dismiss, arguing that the “settlor doctrine” bars Plaintiffs’ claims 7 because REI wrote the $5,000 threshold into the terms of the retirement plan. And even if the 8 claims are not barred, Defendants contend that the complaint does not plausibly allege a breach 9 of fiduciary duty. Dkt. 30. Because REI’s retirement plan provides the Plan Committee some 10 discretion to alter the $5,000 threshold for allocating fees to participant accounts, the Court 11 concludes that the settlor doctrine does not preclude Plaintiffs’ claims. But because Plaintiffs do 12 not allege a cognizable legal theory that a fiduciary duty was breached, the Court GRANTS the

13 motion to dismiss (Dkt. 30). And because the defect in Plaintiffs’ legal theory could not be cured 14 by the allegation of other facts, Plaintiffs’ claims are DISMISSED with prejudice. 15 II. BACKGROUND REI is an “American retail and outdoor recreational services corporation” that “sells 16 camping gear, hiking, climbing, cycling, water, running, fitness, snow, travel equipment, and 17 men, women, and kids clothing.” Dkt. 26 ¶ 19. REI provides it employees with a defined 18 contribution retirement plan (“REI Plan”) which permits participants to contribute to their 19 account over time. Id. ¶¶ 20, 31. At retirement, participants take the amount that is available in 20 their accounts, which is determined by the amount contributed, the market performance of the 21 contributions, and any expenses deducted from the account. Id. ¶¶ 31, 33. The REI Plan “is one 22 of the largest retirement plans in the country . . . [w]ith 24,455 active participants and 23 $1,020,194,239 billion in assets under management as of December 31, 2023.” Id. ¶ 14. 24 1 Retirement plans such as the REI Plan require administrative services to operate day to 2 day and incur recordkeeping and administrative (“RKA”) fees. Id. ¶ 37; Dkt. 31-2 at 5.1 3 Plaintiffs allege that “[t]here are at least three types of RKA services provided by all 4 recordkeepers and other service providers to massive plans like the REI Plan. . . . [and these] 5 Bundled RKA services are fungible and commoditized, and are standard services provided by all 6 major record keepers for massive ERISA 401(k) plans, like the REI Plan.” Dkt. 26 ¶¶ 41–43. 7 Guidance from the United States Department of Labor (“DOL”), the agency that oversees 8 ERISA, states that Plan sponsors may choose to pay for these expenses or deduct the fees from 9 participant account balances. Dkt. 31-2 at 3, 5. There are two common ways of allocating the 10 fees—the pro rata method and per capita method. Id. at 5. The pro rata method allocates 11 expenses in proportion to the amount in the individual account and the per capita method charges 12 expenses equally to each account, regardless of the value of its assets. Id.

13 The REI Plan retained Schwab Retirement Plan Services Inc. (“Schwab”) as a 14 recordkeeper and pays Schwab RKA fees to administer the plan. Id. ¶¶ 10, 39. Plaintiffs assert 15 that the Bundled RKA services provided by Schwab are standard and comparable to other RKA 16 1Defendants request that the Court take judicial notice of the REI Plan, ERISA participant fee 17 disclosures, publications by the DOL, and a report published by Vanguard. See Dkt. 31. Defendants assert that the REI Plan, fee disclosures, and Vanguard report may be considered 18 because they are incorporated into Plaintiffs’ complaint. Dkt. 30 at 10 n.2, 5, 21. They add that the Court may consider filings from the DOL because they are documents publicly available on 19 the DOL’s website, the authenticity is undisputed, and they are incorporated into the complaint. Id. at 10 n.2, 4. The Court may consider a document not physically attached to the complaint if 20 the parties do not contest its authenticity and the plaintiff necessarily relies on it. Branch v. Tunnell, 14 F.3d 449, 454 (9th Cir. 1994), overruled on other grounds by Galbraith v. Cnty. of 21 Santa Clara, 307 F.3d 1119 (9th Cir. 2002). The Court may also consider documents made publicly available by governmental entities where there is no dispute of authenticity or accuracy. 22 Daniels-Hall v. Nat’l Educ. Ass’n, 629 F.3d 992, 998 (9th Cir. 2010). Thus, while the Court takes the facts alleged in the amended complaint as true and construes them in the light most 23 favorable to Plaintiffs, it also takes judicial notice of the documents requested by Defendants. See Retail Prop. Tr. v. United Bhd. of Carpenters & Joiners of Am., 768 F.3d 938, 945 (9th Cir. 24 2014). 1 services provided by competitor recordkeepers in quality or type. Id. ¶¶ 45, 48. Plaintiffs allege, 2 however, that “Defendants failed to take advantage of REI’s massive size to timely negotiate 3 lower fees from Schwab or any other service providers[.]” Id. ¶ 113. They also assert that

4 “Defendants did not conduct effective or competitive bidding for Bundled RKA services . . . and 5 failed to use the Plan’s enormous size to negotiate rebates from Schwab.” Id. ¶ 114. 6 With respect to RKA fees, the REI Plan provides: 7 10.4 Expenses 8 All reasonable expenses that are necessary to operate and administer the Plan may be deducted from the Trust Fund or, at the election of the Company, paid directly 9 by the Employers. . . .

10 (b) On or after October 1, 2015, the following shall apply to expenses not paid directly by the Employers: 11 (i) Expenses related to a particular Participant Account, subaccount, or 12 investment fund may be charged directly to that Account, subaccount, or fund. The Retirement Plan Committee shall 13 determine which of such expenses shall be charged to a particular Participant Account and the amount to be charged. 14 (ii) Subject to (b)(v), record-keeping expense not paid under (b)(i) shall 15 be charged on a per capita basis (i.e. the same amount charged to each Participant) to the Accounts of Participants whose combined 16 account balances equal or exceed $5,000 in value. If a Participant has more than one Account, the per capita expense shall be divided 17 among the Participant’s Accounts pro rata. . . . .

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Smith v. Recreational Equipment Inc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/smith-v-recreational-equipment-inc-wawd-2025.