Lynn v. Peabody Energy Corp.

The federal district court for the Eastern District of Missouri dismissed a class action under the Employee Retirement Income Security Act of 1974 (ERISA) that had been brought against the coal company Peabody Energy Corporation (Peabody) and related entities and individuals. The court concluded that the plaintiffs, who were participants in Peabody employee stock option plans, had failed to state a claim that the defendants breached their duty of prudence under ERISA by retaining and continuing to purchase Peabody stock in light of public information that established that doing so was unreasonable. The court also found that the plaintiff’s “nonpublic information” claim—based on Peabody’s allegedly deceptive representations regarding the future of coal—failed because the plaintiffs had not established that a prudent fiduciary could not have concluded that alternatives to continued investment in Peabody stock would do more harm than good.

A representative participant in the employee pension plan of Peabody Energy Corporation (Peabody) filed a class action complaint against the company alleging breaches of fiduciary duty pursuant to the Employee Retirement Income Security Act (ERISA). The plaintiff asserted that the defendants retained Peabody stock as investment options in the plans when a reasonable fiduciary would have done otherwise. The complaint alleged that defendants should have known that the pension plan’s investments in Peabody stock were imprudent because of the “sea-change” in the coal industry. Causes of this “sea-change” cited in the complaint included the regulation of carbon dioxide emissions from power plants.