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Stanley v. George Wash. Univ.

United States District Court for the District of Columbia

July 15, 2019, Decided; July 15, 2019, Filed

Civil Action No. 18-878 (JDB)

Opinion

 [*101]  MEMORANDUM OPINION

Melissa Stanley brings this putative class action against her former employer, The George Washington University, [**2] 1 alleging breaches of fiduciary duty in violation of the Employee Retirement Income Security Act of 1974 ("ERISA") §§ 502(a)(2), (a)(3) (codified at 29 U.S.C. §§ 1132(a)(2), (a)(3)). Pending before the Court is [21] GW's motion to dismiss. GW argues that Stanley lacks standing to sue because she signed a general release of claims against the University. Stanley responds that her claims fall into an express exclusion in the general release preserving claims for vested benefits under her retirement plan. For the reasons stated below, the Court finds that Stanley has released her fiduciary breach claims against GW under the terms of the release. Because this Court lacks jurisdiction over released claims, the Court  [*102]  will grant GW's motion and dismiss the complaint.

BACKGROUND

I. Statutory Background

ERISA is a "comprehensive and reticulated" statute aimed at protecting participants in private employee retirement plans. Nachman Corp. v. Pension Benefit Guar. Corp., 446 U.S. 359, 361, 100 S. Ct. 1723, 64 L. Ed. 2d 354 (1980); see 29 U.S.C. § 1001(a)-(b). Today, most private retirement plans are "'defined contribution plan[s]' or 'individual account plan[s].'" See LaRue v. DeWolff, Boberg & Assocs., Inc., 552 U.S. 248, 250 n.1, 128 S. Ct. 1020, 169 L. Ed. 2d 847 (2008) (citation omitted). Such plans "promise[] the participant the value of an individual account at retirement, which is largely a function of the amounts contributed to that account and the investment performance [**3]  of those contributions." Id.

ERISA authorizes participants to bring various "types of civil actions" to protect their interests. Mass. Mut. Life Ins. Co. v. Russell, 473 U.S. 134, 139, 105 S. Ct. 3085, 87 L. Ed. 2d 96 (1985); see ERISA § 502(a), 29 U.S.C. § 1132(a). Some of those actions "focus upon specific areas," or particular types of ERISA violations, while others are "'catchalls,' providing 'appropriate equitable relief' for . . . injuries caused by violations that § 502 does not elsewhere adequately remedy." Varity Corp. v. Howe, 516 U.S. 489, 512, 116 S. Ct. 1065, 134 L. Ed. 2d 130 (1996). Two "specific" and one "catchall" action are relevant to Stanley's claims.

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394 F. Supp. 3d 97 *; 2019 U.S. Dist. LEXIS 116788 **; 2019 WL 3083340

MELISSA STANLEY, individually and as representative of a class of participants and beneficiaries on behalf of The George Washington University Retirement Plan for Faculty and Staff and The George Washington University Supplemental Retirement Plan, Plaintiff, v. THE GEORGE WASHINGTON UNIVERSITY, et al., Defendants.

Subsequent History: Affirmed by Stanley v. George Wash. Univ., 2020 U.S. App. LEXIS 9175 (D.C. Cir., Mar. 24, 2020)

Prior History: Stanley v. George Wash. Univ., 2019 U.S. Dist. LEXIS 102945 (D.D.C., Mar. 29, 2019)

CORE TERMS

benefits, employee benefit plan, general release, fiduciary, terms, violations, Plans, vested, releasing, rights, fiduciary breach, alleges, settlement, suits, claim for benefits, motion to dismiss, contractual, preserving, breached, parties, retirement plan, contract claim, provisions, carve-out, equitable, injuries, exhaust