"The retirees argued that the six-year limitations period set forth in ERISA Section 413 should apply because the fiduciaries' alleged misrepresentation amounted to fraud and thus fell within the fraud-or-concealment exception to the normal three-year limitations period. The appellate court rejected this argument because the retirees failed to adequately plead that any fraud had taken place.... The court dismissed all other claims, ruling that (1) the union did not act as a ERISA fiduciary; (2) the retirees failed to state a claim for equitable estoppel; (3) the retirees failed to show the fund did not provide requested plan documents; and (4) ERISA preempted the retirees' state law claims." [Cataldo v. United States Steel Corporation (CA-6)]  MORE >>