Plaintiffs Not Entitled to Jury Trial for ERISA Breach of Fiduciary Duty Claims
Massachusetts Institute of Technology persuaded a federal district court to toss a jury demand in a case alleging that the MIT 401(k) plan fiduciaries breached their duties by charging unreasonable administrative and management fees, engaging in prohibited transactions and failing to monitor those to whom the fiduciaries delegated their responsibilities. In so ruling, the court held that plaintiffs had no Seventh Amendment right to a jury trial because actions under ERISA to remedy alleged violations of fiduciary duties are equitable rather than legal in nature. The court explained that the “great weight of authority” has concluded that claims by plan participants against plan fiduciaries are analogous to claims against trustees typically heard only in a court of equity. The case is Tracey v. Massachusetts Institute of Technology, No. 1:16-cv-11620, 2019 WL 1005488 (D. Mass. Feb. 28, 2019).