Employee Benefits & Executive Compensation Blog

District Court Reinforces Role of Article III Standing Limits in Post-Cunningham ERISA Litigation

A federal district court in North Carolina dismissed a 401(k) plan participants’ prohibited‑transaction and fiduciary‑breach claims against Bayada Home Health Care, finding they lacked Article III standing and presented only speculative allegations. The plaintiffs failed to show that advisory or record‑keeping fees caused a concrete injury or that fee levels were excessive compared to comparable plans. The court emphasized the necessity of concrete, non‑speculative evidence linking fees to participant losses. The ruling reinforces the procedural hurdle of standing in post‑Cunningham ERISA litigation.