Anderson v. Intel Corporation Investment Policy Committee

Background

The only remaining claim was Winston R. Anderson’s allegation that the Intel Corporation Investment Policy Committee violated the Employee Retirement Income Security Act (ERISA) by failing to timely provide plan documents. The opinion states that the court had previously dismissed Counts I through VI. Under ERISA, a plan administrator must provide certain documents after a participant or beneficiary makes a written request. If the administrator fails or refuses to comply within 30 days, the court may impose personal liability of up to $100 per day and may order other relief.

Anderson first requested plan documents from the Committee in April 2017. He received two documents about six weeks later but considered the response incomplete. He sent another letter in December 2017, and he alleges that the Committee failed to provide the requested documents in a February 2018 response. He sued 18 months later. The parties agreed that this was more than one year after the alleged failure.

Issue and arguments

The Committee moved for judgment on the pleadings, arguing that Anderson’s claim was barred by a one-year statute of limitations. Anderson argued that a three-year statute of limitations applied, so his claim was timely.

ERISA does not specify a limitations period for this type of claim. When a federal statute does not provide one, courts generally use the most closely similar state-law limitations period. The opinion identified two potentially relevant California periods: one year for an action seeking a statutory penalty, and three years for an action based on a liability created by statute other than a penalty.

The Committee argued that a later Department of Labor regulation described the ERISA provision as a penalty and that this characterization undermined the Ninth Circuit’s earlier decision in Stone v. Travelers Corp. In Stone, the Ninth Circuit held that the ERISA remedy was not a penalty for purposes of California’s limitations law and that California’s three-year period applied.

Ruling

Judge Vince Chhabria denied the motion for judgment on the pleadings. He held that Stone remains controlling on how California law treats this ERISA provision. The Department of Labor’s characterization of the provision as a penalty for another federal-law purpose did not determine whether California law treats it as a penalty. Under Stone’s public-wrong/private-wrong test, the provision addresses a wrong that is substantially private rather than public, so California’s three-year limitations period applies.

The court also rejected the Committee’s argument that decisions from other federal circuit courts created a conflict requiring a different result. Those decisions applied the laws of other states, while Stone addressed California law. The court stated that changing Stone would be for an en banc Ninth Circuit panel or the California Supreme Court, and concluded that the three-year limitations period continues to apply.