Cunningham v. Cornell Univ.
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Cunningham v. Cornell Univ. and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Cunningham v. Cornell Univ..
The Supreme Court addressed whether plaintiffs must plead that certain exemptions do not apply when alleging prohibited transactions under ERISA. The Court concluded that plaintiffs need only allege the elements of § 1106(a)(1)(C) without addressing § 1108 exemptions. The decision reversed the Second Circuit's requirement for plaintiffs to disprove exemptions in their initial pleadings.
Holding
The single most important “bottom line” of what the Court decided in Cunningham v. Cornell Univ..
The Court held that to state a claim under § 1106(a)(1)(C), plaintiffs need not address potential § 1108 exemptions.
Constitutional Concepts
These are the Constitution-related themes that appear in Cunningham v. Cornell Univ.. Click a concept to see other cases that involve the same idea.
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Why Judicial Review is relevant to Cunningham v. Cornell Univ.
The Court's decision involves interpreting statutory provisions and determining the appropriate pleading standards, which is an exercise of judicial review.
Syllabus excerpt (verbatim)Held: To state a claim under § 1106(a)(1)(C), a plaintiff need only plausibly allege the elements contained in that provision itself, without addressing potential § 1108 exemptions.
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Why Procedural Due Process is relevant to Cunningham v. Cornell Univ.
The case involves procedural aspects of how claims under ERISA should be pleaded, which relates to procedural due process considerations.
Syllabus excerpt (verbatim)The exemptions in § 1108 do not impose additional pleading requirements for § 1106(a)(1) claims.
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Why Standing is relevant to Cunningham v. Cornell Univ.
The Court discusses the requirements for plaintiffs to state a claim, which is related to the concept of standing and the right to bring a case.
Syllabus excerpt (verbatim)District courts have various tools at their disposal to screen out meritless claims, including requiring plaintiffs to file a reply addressing exemptions under Federal Rule of Civil Procedure 7(a).
Key Quotes
Short excerpts from the syllabus in Cunningham v. Cornell Univ. that support the summary and concepts above.
To state a claim under § 1106(a)(1)(C), a plaintiff need only plausibly allege the elements contained in that provision itself.
The exemptions in § 1108 do not impose additional pleading requirements for § 1106(a)(1) claims.
Requiring plaintiffs to plead and disprove all potentially relevant § 1108 exemptions would be impractical.