Wagner v. Hess Corporation

CourtDistrict Court, N.D. Texas
DecidedMarch 21, 2025
Docket6:24-cv-00004
StatusUnknown

This text of Wagner v. Hess Corporation (Wagner v. Hess Corporation) is published on Counsel Stack Legal Research, covering District Court, N.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wagner v. Hess Corporation, (N.D. Tex. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS SAN ANGELO DIVISION

JOSHUA WAGNER, individually and on behalf of the Hess Corporation Employees’ Savings Plan, and all others similarly situated, Plaintiff, v. No. 6:24-CV-004-H HESS CORPORATION, et al., Defendants. MEMORANDUM OPINION AND ORDER In this ERISA putative class action, the plaintiff alleges that the defendants breached their fiduciary duties by selecting excessively expensive investment options for employees’ retirement plans. The plaintiff asserts that the defendants should have replaced certain investment options with similar investments that had lower fees. In addition, the plaintiff alleges that the Hess Corporation is liable for failing to monitor the performance of the Hess Corporation Investment Committee. Before the Court are two motions. First, the defendants moved to dismiss (Dkt. No. 28) the plaintiff’s second amended complaint for failure to state a claim and lack of standing to pursue injunctive relief. Second, the plaintiff seeks leave to file a third amended complaint (Dkt. No. 39), which the defendants argue is futile for the same reasons presented in the motion to dismiss (see Dkt. No. 42). The Court grants the motion to amend (Dkt. No. 39). In addition, the Court considers the merits of the defendants’ motion to dismiss as to the third amended complaint and grants in part and denies in part the motion to dismiss (Dkt. No. 28). 1. Factual and Procedural Background A. Factual Background The Court takes the pertinent factual allegations from the plaintiff’s proposed third amended complaint. See Villareal v. Wells Fargo Bank, N.A., 814 F.3d 763, 766 (5th Cir. 2016). The plaintiff, Joshua Wagner, is a former employee of the Hess Corporation, where

he worked between August 2018 and November 2021. Dkt. No. 39 at 66. The Hess Corporation is a large energy company that produces and sells crude oil and natural gas. Id. at 67. The Hess Corporation sponsors the Hess Corporation Employees’ Savings Plan (the Plan), which—with assets totaling over $1 billion in 2023—is one of the largest 401(k) retirement plans in the United States. Id. at 62, 65. The plaintiff was a participant in the Plan until 2022, when he took his last distribution from the Plan. Id. at 66. The Hess Corporation delegated to the Hess Corporation Investment Committee (Investment Committee) the responsibility of selecting and monitoring the Plan’s investments. Id. at 67. The CEO of the Hess Corporation appointed and has the power to

remove the members of the Investment Committee. Id. at 68. The Investment Committee selected a menu of investment options for the Plan. Id. at 73. Plan participants could then invest the assets in their individual accounts by selecting from those options. Id. One important feature of any investment is its expense ratio. Id. at 74. Any given investment provider charges a fee called an “expense ratio,” which is the percentage of the assets under management that the provider takes as a fee. Id. Because the money charged as a fee would otherwise have been invested, a higher expense ratio leads to lower returns, all other things being equal. See id. Plan administrators are subject to fiduciary duties under ERISA. Id. at 69. The plaintiff alleges that the defendants breached their fiduciary duty of prudence by failing to replace certain investments selected for the Plan with indistinguishable or similar investments that had lower expense ratios. Id. at 76, 78. Because of those breaches,

excessive fees caused millions of dollars in losses to the Plan’s participants. Id. at 78–79. The plaintiff asserts that three particular categories of investments were overpriced and should have been replaced. First, the Plan offered a series of T. Rowe Price target-date funds. Id. at 79. Target-date funds are “a class of funds that periodically rebalance asset class weights” to “gradually shift to a more conservative profile over time so as to minimize risk when the target date approaches.” Id. For example, if an employee plans to retire in 2060, she could choose to invest her 401(k) in a 2060 target-date fund. The target-date funds chosen by the Plan were structured as mutual funds. Id. at 79, 83. T. Rowe Price also offered target-date funds in a collective-investment trust vehicle

(also called a collective trust). Id. at 81–82. Collective trusts differ in structure, as well as in regulatory and disclosure requirements, from mutual funds. Id. at 80. These trusts are not available to the general public and may have lower fees than mutual funds. Id. T. Rowe Price described the target-date collective-trusts as having “the same portfolio management team, glidepath, subasset-class exposure, tactical allocation overlay and underlying investments” as their mutual-fund alternatives. Id. at 82. In other words, the collective trusts have the same underlying investment makeup, risk, strategy, and objectives as their mutual-fund counterparts. Id. The plaintiff asserts that the defendants should have switched from mutual funds to

collective trusts, as the Investment Committee did beginning in 2018 in two other retirement plans sponsored by the Hess Corporation. Id. at 81–82, 89. Between 2020 and 2023, the T. Rowe Price target-date collective trusts had expense ratios ranging from 0.01% to 0.09% lower than the challenged target-date mutual funds. See id. at 83–87. Second, the Plan offered certain “single asset class investment options” (the other

mutual funds) that the plaintiff asserts the Investment Committee should have switched for other comparable, lower-cost funds. Id. at 90. The plaintiff identified the comparator funds with an unidentified “industry[-]recognized software program that uses quantitative methods . . . to find funds that are highly similar to the fund being analyzed.” Id. at 95. In addition, the plaintiff’s comparators share the same Morningstar category—a classification assigned by a financial-services provider that groups funds together based on similar holdings or investment styles. Id. at 95–96. The plaintiff’s comparator funds have expense ratios ranging from 0.11% to 0.97% lower than these challenged funds. See id. at 90–94. Third, the Plan selected certain Vanguard index funds—funds that track a market

index such as the S&P 500. Id. at 99. The plaintiff asserts that other investment companies offer comparable funds tracking the same indexes but with lower expense ratios. Id. These comparator index funds have expense ratios ranging from 0.005% to 0.03% lower than the Plan’s challenged index funds. See id. at 99–101. B. Procedural Background The defendants moved to dismiss the second amended complaint under Federal Rule of Civil Procedure 12(b)(1) and (b)(6), asserting that the plaintiff lacks standing to pursue injunctive relief and that the complaint fails to state a claim. Dkt. No. 28. The plaintiff responded (Dkt. No. 33), and the defendants replied (Dkt. No. 34). After the briefing on the motion to dismiss was complete, the plaintiff moved for leave to file a third amended complaint. Dkt. No. 39. The plaintiff seeks leave to amend the complaint to add factual allegations that the defendants’ document productions revealed and that were not previously available to the plaintiff. See generally id. The defendants

responded to the motion to amend (Dkt. No. 42), and the plaintiff replied (Dkt. No. 47). The motion to dismiss and the motion for leave to amend are both ripe. 2. Standards of Review A. Motion to dismiss for lack of subject-matter jurisdiction under Rule 12(b)(1) A party may challenge a court’s subject-matter jurisdiction under

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Wagner v. Hess Corporation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wagner-v-hess-corporation-txnd-2025.