The U.S. Supreme Court quoted § 90 of Restatement of the Law Third, Trusts, in supporting its unanimous May 18 decision to reverse and remand a Ninth Circuit opinion that rejected certain ERISA breach-of-fiduciary-duty claims on grounds of untimeliness.
In Tibble et al. v. Edison International et al., Justice Stephen Breyer wrote for the Court that the Ninth Circuit had erred in applying a statutory bar to the claims “without considering the role of the fiduciary’s duty of prudence under trust law.”
The Court quoted § 90 and other treatises that addressed fiduciary duties under the common law of trusts, and remanded for the Ninth Circuit to consider the claims “recognizing the importance of analogous trust law.”