Cory McGeathy v. Reinalt-Thomas Corporation, et al.

Summary

The United States District Court for the District of Arizona denied Defendants’ motion to dismiss Cory McGeathy’s first amended complaint alleging ERISA fiduciary-duty violations. The court held that Plaintiff plausibly alleged imprudence by identifying meaningful comparator target-date funds and alleged underperformance, and that the derivative failure-to-monitor claim therefore also survived. The order was issued on March 4, 2026.

Holdings

1. A plaintiff plausibly states an ERISA imprudence claim by alleging that fiduciaries selected or retained an investment and comparing its performance to meaningful benchmarks with similar aims, risks, and potential rewards; the complaint adequately alleged such benchmarks and underperformance.
2. The derivative failure-to-monitor claim survived the motion to dismiss because the complaint adequately stated the underlying imprudence claim.

Questions Presented

1. Whether the first amended complaint plausibly alleged that Defendants breached ERISA's duty of prudence by retaining an allegedly underperforming investment without a meaningful benchmark comparison.
2. Whether the complaint's failure-to-monitor claim survived because the underlying imprudence claim was adequately pleaded.

Disposition

other