Help us improve in just 2 minutes—share your thoughts in our reader survey.

Intel Corp. Investment Policy Committee v. Sulyma

From Ballotpedia
Jump to: navigation, search

Supreme Court of the United States
Intel Corp. Investment Policy Committee v. Sulyma
Term: 2019
Important Dates
Argument: December 4, 2019
Decided: February 26, 2020
Outcome
Affirmed
Vote
9-0
Majority
Chief Justice John G. Roberts • Clarence Thomas • Ruth Bader Ginsburg • Stephen Breyer • Samuel Alito • Sonia Sotomayor • Elena Kagan • Neil Gorsuch • Brett Kavanaugh


Intel Corp. Investment Policy Committee v. Sulyma is a case argued before the Supreme Court of the United States on December 4, 2019, during the court's October 2019-2020 term. The case concerned the interpretation of the Employee Retirement Income Security Act statute of limitations. It came on a writ of certiorari to the United States Court of Appeals for the 9th Circuit.

The court affirmed the 9th Circuit's decision in a unanimous ruling, holding that to meet the "actual knowledge" requirement of Section 1113(2) of the ERISA, a plaintiff must be aware of an alleged breach or violation. Justice Alito wrote, "The addition of 'actual' in §1113(2) signals that the plaintiff's knowledge must be more than 'potential, possible, virtual, conceivable, theoretical, hypothetical, or nominal.'"[1] Click here for more information.

HIGHLIGHTS
  • The case: Christopher Sulyma worked at Intel from 2010 to 2012, where he participated in retirement accounts an Intel investment committee managed. In 2015, Sulyma sued Intel, claiming the committee mismanaged his retirement accounts and violated the Employee Retirement Income Security Act. The Northern District of California granted summary judgment in favor of Intel, who argued Sulyma's claims were untimely. The 9th Circuit reversed the ruling and remanded the case.
  • The issue: Whether the three-year limitations period in Section 413(2) of the Employee Retirement Income Security Act, 29 U.S.C. 1113(2), which runs from "the earliest date on which the plaintiff had actual knowledge of the breach or violation," bars suit where all of the relevant information was disclosed to the plaintiff by the defendants more than three years before the plaintiff filed the complaint, but the plaintiff chose not to read or could not recall having read the information.[2]
  • The outcome: The court affirmed the 9th Circuit's decision in a unanimous ruling, holding that to meet the "actual knowledge" requirement of Section 1113(2) of the ERISA, a plaintiff must be aware of an alleged breach or violation. Justice Alito wrote, "The addition of 'actual' in §1113(2) signals that the plaintiff's knowledge must be more than 'potential, possible, virtual, conceivable, theoretical, hypothetical, or nominal.'"[1]


    • You can review the lower court's opinion here.

    Timeline

    The following timeline details key events in this case:

    • February 26, 2020: The U.S. Supreme Court affirmed the 9th Circuit's opinion.
    • December 4, 2019: Oral argument
    • June 10, 2019: The U.S. Supreme Court agreed to hear the case.
    • February 26, 2019: The Intel Corporation Investment Policy Committee filed a petition with the U.S. Supreme Court.
    • November 28, 2018: The 9th Circuit reversed and remanded the ruling of the Northern District of California.

    Background

    Christopher Sulyma worked at Intel from 2010 to 2012, where he participated in two of the company's retirement plans, both governed by the Employee Retirement Income Security Act (ERISA). An Intel investment committee managed Sulyma's accounts, which were invested in the Intel Global Diversified Fund and the Intel Target Date 2045 Fund.[3]

    The Funds invested in "alternative investments" such as hedge funds. As a result, they did not perform as well as comparable portfolios. Intel disclosed the investment decisions and Fund performance in documents hosted on two websites. Sulyma said he accessed some of this information but was not aware that his retirement accounts were involved.[3]

    On October 29, 2015, Sulyma filed charges against Intel, alleging the investment committee imprudently invested in alternative investments—violating 29 U.S.C. § 1104—and alleging the administrative committee failed to disclose information about the investments—violating 29 U.S.C. § 1104 and 29 C.F.R. § 2250.404a-5(a). He also alleged the finance committee failed to monitor the investment and administrative committees, violating 29 U.S.C. § 1104.[3]

    Intel moved to dismiss the complaint as untimely under 29 U.S.C. § 1113(2), which provides an action under § 1104 has a three-year statute of limitations beginning on "the earliest date on which the plaintiff had actual knowledge of the breach or violation." The United States District Court for the Northern District of California converted the motion to dismiss into a motion for summary judgment and then granted summary judgment in favor of Intel. On appeal, the United States Court of Appeals for the 9th Circuit reversed and remanded the district court's ruling.[3]

    Questions presented

    The petitioner presented the following questions to the court:

    Questions presented:
    • Whether the three-year limitations period in Section 413(2) of the Employee Retirement Income Security Act, 29 U.S.C. 1113(2), which runs from "the earliest date on which the plaintiff had actual knowledge of the breach or violation," bars suit where all of the relevant information was disclosed to the plaintiff by the defendants more than three years before the plaintiff filed the complaint, but the plaintiff chose not to read or could not recall having read the information.[2]

    Outcome

    In a unanimous opinion, the court affirmed the judgment of the 9th Circuit Court of Appeals, holding that to meet the "actual knowledge" requirement of Section 1113(2) of the ERISA, a plaintiff "must in fact have become aware of" an alleged breach or violation. The opinion summary stated, "A plaintiff does not necessarily have 'actual knowledge' under §1113(2) of the information contained in disclosures that he receives but does not read or cannot recall reading."[1]

    Justice Samuel Alito delivered the opinion of the court.

    Opinion

    In his opinion, Justice Alito wrote:[4]

    “ We granted certiorari to resolve whether the phrase 'actual knowledge' does in fact mean 'what it says,' and hold that it does.

    ...
    Although ERISA does not define the phrase 'actual knowledge,' its meaning is plain. ... To have 'actual knowledge' of a piece of information, one must in fact be aware of it.

    Legal dictionaries give 'actual knowledge' the same meaning: '[r]eal knowledge as distinguished from presumed knowledge or knowledge imputed to one.'
    ...
    The addition of 'actual' in §1113(2) signals that the plaintiff ’s knowledge must be more than 'potential, possible, virtual, conceivable, theoretical, hypothetical, or nominal.' [5]

    		”

    Text of the opinion

    Read the full opinion here.

    Audio

    Audio of oral argument:[6]



    Transcript

    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 Supreme Court of the United States, Intel Corp. Investment Policy Committee v. Sulyma, decided February 26, 2020
    2. ↑ 2.0 2.1 Supreme Court of the United States, "Questions presented: 18-1116 Intel Corp. Investment v. Sulyma," accessed June 11, 2019
    3. ↑ 3.0 3.1 3.2 3.3 United States Court of Appeals for the 9th Circuit, Sulyma v. Intel Corp. Investment Policy Committee, decided November 28, 2018
    4. ↑ Cite error: Invalid <ref> tag; no text was provided for refs named REF
    5. ↑ Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    6. ↑ Supreme Court of the United States, "Oral Argument - Audio," accessed December 9, 2019
    Retrieved from "https://ballotpedia.org/wiki/index.php?title=Intel_Corp._Investment_Policy_Committee_v._Sulyma&oldid=8891664"