Intel Corp. Investment Policy Committee v. Sulyma

In Intel Corp. Investment Policy Committee v. Sulyma (2020), the U.S. Supreme Court addressed the interpretation of "actual knowledge" under ERISA. Retiree Christopher Sulyma sued Intel's retirement plan fiduciaries, alleging mismanagement of investments from 2010 to 2012. Although Sulyma received mandatory disclosures regarding the investments, he claimed he did not read them or recall seeing the relevant information. The central issue was whether the 3-year statute of limitations began when the disclosures were provided or only when Sulyma actually became aware of the alleged breach. The Court held that "actual knowledge" requires the plaintiff to be subjectively aware of the breach, meaning mere disclosure without proof of the plaintiff's awareness does not start the clock. This decision protected employees' rights to sue by requiring more than just the distribution of complex financial documents.

The U.S. Supreme Court ruled unanimously in favor of Sulyma, holding that "actual knowledge" requires proof that the plaintiff was genuinely aware of the breach. The Court rejected the argument that constructive knowledge via disclosure was sufficient.

The precise meaning of "actual knowledge" under ERISA's statute of limitations: whether the 3-year clock starts upon the fiduciary's legal disclosure of information, or only when the plaintiff actually reads and becomes subjectively aware of the alleged breach of fiduciary duty.

The ruling clarified the evidentiary burden on retirement plan fiduciaries, strengthening protections for employees. It prevented the statute of limitations from being triggered merely by sending complex disclosures, thereby preserving participants' rights to sue for fiduciary mismanagement and encouraging fiduciaries to ensure that critical information is effectively communicated.