Custer v. Sweeney

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• concluding that a malpractice claim by a trustee was not preempted because “claims against third-party service providers to an ERISA plan do not implicate the essential functions of an employee benefit plan, such as funding, benefits, reporting and administration”
• noting that ERISA fiduciaries include both named fiduciaries and “any individual[s] who de facto perform[] specified discretionary functions with respect to the managements, assets, or administration of a plan”
• noting that ERISA fiduciaries include both named fiduciaries and “any individual[s] who de facto perform[] specified discretionary functions with respect to the management, assets, or administration of a plan”
• finding that when considering a Rule 12 motion to dismiss, a court need not accept “unwarranted deductions” or “sweeping legal conclusions cast in the form of factual allegations” (internal quotation marks omitted
• collecting extensive appellate authority and stating that professional malpractice law and its parameters are matters within “a traditional exercise of state authority.”
• affirming dismissal of ERISA complaint that “lacked any specific factual allegations” to support the assertion that the defendant was a de facto fiduciary of the plan

Source: CourtListener parenthetical corpus (CC0).