Tibble v. Edison International

Glenn Tibble and other individuals (plaintiffs) were enrolled in the 401(k) savings plan of Edison International (Edison) (defendant). The plan was a defined-contribution plan, meaning that participants’ retirement benefits were limited to the value of each individual’s investment accounts. The value of the accounts was determined by the market performance of contributions, minus expenses. Expenses for these accounts included management and administrative fees. In 1999, three mutual funds were added to the savings plan’s investment options for participants, and three more were added in 2002. The six added funds were high-priced retail-class funds and were selected by Edison over materially identical lower-priced institutional-class funds that were available. In 2007, Tibble and other beneficiaries filed suit in federal district court against Edison for alleged breaches of fiduciary duties under the Employee Retirement Income Security Act (ERISA). Tibble claimed that Edison acted imprudently as a plan fiduciary by adding the six high-priced mutual funds instead of six lower-priced mutual funds that were available to institutional investors like the savings plan. The district court ruled in favor of Edison. The court found that although Edison did not exercise the prudence required of it as a fiduciary by acquiring the higher-priced funds, Tibble’s claims were untimely because more than six years had passed since the 1999 funds were added. Tibble appealed to the United States Court of Appeals for the Ninth Circuit, which affirmed the district court’s ruling. The court of appeals found that the claims regarding the 1999 funds were not timely because Tibble did not establish a change in circumstances that could have triggered Edison to review and change its investments within the six-year statutory period. Tibble appealed to the United States Supreme Court.