Intel Corp. Investment Policy Comm. v. Sulyma

Background

A former Intel employee sued in 2015 on behalf of a class, saying plan managers overinvested retirement money in expensive alternative assets. While he worked at Intel from 2010 to 2012 he received multiple notices and online disclosures—emails pointing him to a NetBenefits website, QDIA and annual notices, and fund fact sheets showing allocations. He said he did not remember reviewing those disclosures and declared he was unaware his money was in hedge funds or private equity. The district court granted the plan managers summary judgment under ERISA’s three-year rule, but the court of appeals reversed.

Reasoning

The Court addressed whether receiving but not reading or recalling disclosures counts as "actual knowledge." Relying on the statute’s plain language and dictionary meanings, the Court concluded "actual knowledge" means being actually aware of the facts, not merely having them sent or constructively knowing them. The opinion explains Congress used different language elsewhere when it wanted constructive knowledge, and it cites prior cases distinguishing actual awareness from what a reasonable person should know. The Court confirmed that evidence of reading, electronic records, actions taken in response, or strong circumstantial proof can still show actual knowledge, and that willful blindness may also be relevant.

Real world impact

The ruling means the three-year ERISA clock starts only when a person actually knows the disclosed facts; unread or forgotten notices do not automatically shorten the filing period. The six-year repose period still protects defendants for very old claims. The Supreme Court affirmed the appeals court’s decision and left open the usual ways plaintiffs or defendants can prove actual knowledge.