Selethia Pruitt v. Suntrust Banks, Inc.
791 F.3d 1309
11th Cir.2015Background
- Plaintiffs allege ERISA fiduciary breaches based on failure to monitor and remove imprudent investments.
- The appellate panel previously treated Fuller’s claims; this is the first presentation of Pruitt’s case to the court.
- Tibble v. Edison International held that fiduciaries have a continuing duty to monitor investments and that a timely breach can be raised if within six years of suit, altering the six-year limitations analysis.
- The parties agree remand is appropriate in light of Tibble, and the court vacates and remands for proceedings consistent with Tibble.
- The court vacates Fuller’s Rule 60(b) denial and remands for further proceedings, and remands Pruitt’s case to the district court.
- The court declines to reassign the cases to a different district judge, finding reassignment unwarranted after applying several factors.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Tibble abrogates the six-year limitations defense. | Pruitt/Fuller argue Tibble makes the claim timely. | Defendants contend the prior dismissal remains appropriate. | Tibble abrogates the prior limitations ruling; remand for eligibility analysis. |
| Whether the cases should be remanded for further proceedings. | Remand is appropriate to address Tibble-based duties. | Defendants agree remand is proper but dispute other remedies. | Remand to the district court is required for Tibble-consistent proceedings. |
| Whether reassignment to another district judge is warranted on remand. | Plaintiffs request reassignment due to perceived bias. | Defendants oppose reassignment. | Reassignment denied; insufficient benefit to justify the waste and duplication. |
Key Cases Cited
- Tibble v. Edison Int'l, 135 S. Ct. 1823 (Supreme Court, 2015) (continuing duty to monitor investments; timely breach within six years)
- Fuller v. SunTrust Banks, Inc., 744 F.3d 685 (11th Cir. 2014) (prior panel decision on Fuller; context for ERISA fiduciary duties)
- Chudasama v. Mazda Motor Corp., 123 F.3d 1353 (11th Cir. 1997) (factors informing reassignment as a severe remedy)
- United States v. Remillong, 55 F.3d 572 (11th Cir. 1995) (per curiam analysis for reassignment considerations)