NEW YORK - Lehman Brothers Holding Inc.'s former directors and benefit committee members did not breach fiduciary duties under the Employee Retirement Income Security Act by continuing to offer company stock as an investment option for Lehman's employee stock ownership plan (ESOP) before the company's declaring bankruptcy, the Second Circuit U.S. Court of Appeals affirmed July 15 (In re Lehman Bros. ERISA Litig. $(Alex E. Rinehart, et al. v. John F. Akers, et al.$), No. 11-4233-cv, 2nd Cir.; 2013 U.S. App. LEXIS 14194).