Hughes v. Northwestern Univ.
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A short, plain-English overview of Hughes v. Northwestern Univ..
In Hughes v. Northwestern University, the Supreme Court addressed whether plan fiduciaries violated ERISA's duty of prudence by failing to monitor and control investment options and fees. The Court vacated the Seventh Circuit's decision, emphasizing the need for a context-specific inquiry into fiduciaries' ongoing duty to evaluate and remove imprudent investments. The case was remanded for further consideration under the standards articulated in Tibble v. Edison International.
Holding
The single most important “bottom line” of what the Court decided in Hughes v. Northwestern Univ..
The Court held that the Seventh Circuit erred by focusing solely on participant choice and not applying the duty of prudence as articulated in Tibble v. Edison International.
Key Quotes
Short excerpts from the syllabus in Hughes v. Northwestern Univ. that support the summary and concepts above.
The Seventh Circuit erred in relying on the participants' ultimate choice over their investments to excuse allegedly imprudent decisions by respondents.
Tibble's discussion of the continuing duty to monitor plan investments applies here.
The Court vacates the judgment below so that the Seventh Circuit may reevaluate the allegations as a whole.
