On February 3rd, the Sixth Circuit, in an opinion written by retired Associate Supreme Court Justice Sandra Day O'Connor (sitting by designation), strictly construed the state-actions exception to the Securities Litigation Uniform Standards Act("SLUSA"). The plaintiff, on behalf of a deferred compensation plan for sheriff's department employees, brought state law claims against the administrators of a deferred compensation plan. Affirming dismissal, the Court held that the plaintiff did not meet the state-actions exception to SLUSA. The exception does not permit third-party suits on behalf of plans and the suit was not brought by plaintiff as a member of a class comprised of other states, political subdivisions, or state pension plans. Demings v. Nationwide Life Insurance Co.