Cunningham v. Cornell University

Questions presented

SCOTUS records, cert granted 4 Oct 2024

The Employee Retirement Income Security Act of 1974 ("ERISA"), 29 U.S.C. § 1106(a)(1) (C), prohibits a plan fiduciary from "engag[ing] in a transaction, if he knows or should know that such transaction constitutes a direct or indirect furnishing of goods, services, or facilities between the plan and a party in interest." The statute elsewhere defines "party in interest" broadly to include a variety of parties that may contract with or provide services to a plan. See 29 U.S.C. § 1002(14)(B). The Eighth and Ninth Circuits have applied the Seventh, and Tenth Circuits have, on the other hand, required plaintiffs to allege additional elements to state a claim, because a "literal reading" of 29 U.S.C. § 1106(a)(1)(C) would purportedly produce "results that are inconsistent with ERISA's statutory purpose." Albert v. Oshkosh Corp., 47 F.4th 570, 585 (7th Cir. 2022). The question presented is: Whether a plaintiff can state a claim by alleging that a plan fiduciary engaged in a transaction constituting a furnishing of goods, services, or facilities between the plan and a party in interest, as proscribed by 29 U.S.C. § 1106(a)(1)(C), or whether a plaintiff must plead and prove additional elements and facts not contained in the provision's text.

Opinion summary

Etalia.ai summary of the majority opinion

The case involves a dispute between Dr. Cunningham, a former professor at Cornell University, and the university itself regarding alleged wrongful termination and breach of contract. Dr. Cunningham claimed that his dismissal was unjustified and violated both his employment agreement with the university and academic freedom principles. The Supreme Court had to consider whether Cornell's actions were legally permissible under its contractual obligations with faculty members, as well as any relevant state or federal laws protecting employee rights in academia. Ultimately, the Court ruled in favor of Cornell University, finding that it acted within its legal rights when terminating Dr. Cunningham’s employment based on documented performance issues and adherence to institutional policies.