James J. Thole, Petitioners v. U. S. Bank N.a .

Summary

The Supreme Court affirmed the Eighth Circuit's dismissal of retired U.S. Bank defined-benefit plan participants' ERISA fiduciary-mismanagement suit, holding that James Thole and Sherry Smith lack Article III standing because they have received all vested monthly benefits and will continue receiving identical payments whether the lawsuit wins or loses, leaving them no concrete stake. The Court rejected their four alternative standing arguments: a trust-law analogy (participants hold no equitable or property interest in a defined-benefit plan), representational standing for the plan (no assignment or appointment and no personal injury in fact), reliance on ERISA's Sec. 502(a)(2), (3) cause of action (a statutory grant does not supply a concrete injury), and the claim that no one else would police fiduciaries. Justice Thomas, joined by Justice Gorsuch, concurred in the result while urging a simpler, historically grounded standing framework; Justice Sotomayor, joined by Justice Ginsburg, Breyer, and Kagan, dissented, arguing that trust-law, breach-of-fiduciary-duty, and representational theories gave the plaintiffs standing.