Plaintiffs, a group of infrastructure analysts employed by defendant, routinely worked over forty hours per week but were not paid overtime wages. Plaintiffs alleged that defendant’s decision to classify them as “exempt” from overtime wages violated the Fair Labor Standards Act (FLSA). Based on these allegations, plaintiffs asserted claims against their employer for violation of the FLSA and breach of fiduciary duty under the Employee Retirement Income Security Act (ERISA) for failure to credit their retirement benefits plans with overtime wages that allegedly should have paid. The court dismissed the ERISA claim after ruling that defendant’s decision to exempt plaintiffs from overtime was a business decision and therefore not within the scope of defendant’s fiduciary duties under ERISA.

The court found that the benefits plans at issue only required defendant to credit its employees with wages that were “actually paid” and not also wages that allegedly should have been paid. Accordingly, the court ruled that defendant had complied with its ERISA obligation to adhere to the provisions of its benefit plans. The court also found that defendant’s decision to classify plaintiffs as “exempt” from overtime wages was a business decision that defendant made in its capacity as an employer—and not also in its separate capacity as an ERISA fiduciary. The court rejected the plaintiffs’ argument that ERISA imposes a fiduciary obligation on a plan administrator to investigate business decisions to ensure that they do not deprive participants of pension benefits, ruling that Congress did not intend for an ERISA fiduciary to be required to regulate purely corporate behavior or second-guess an employer’s business judgment. To the contrary, the court held that Congress “only sought to impose fiduciary duties on decisions dealing with plan management and administration to ensure that the funds promised to employees would be invested wisely and managed honestly.” (Steavens v. Electronic Data Systs. Corp., 2008 WL 3540070 (E.D.Mich. August 12, 2008))