"With inevitable fluctuations in the stock market, ERISA's simultaneous demands to comply with plan documents and to exercise prudence in choosing investment options for plan participants can place fiduciaries on a razor's edge.... If ESOPs are to fulfill their purposes, fiduciaries ... need substantial protection from liability ... Without this shield, the duty of prudence would leave fiduciaries exposed to liability based on 20-20 hindsight for ... circumstances in which reasonable fiduciaries and other investors could easily disagree about the better course of action." [White v. Marshall & Ilsley Corp., No. 11-2660 (7th Cir. Apr. 19, 2013)]  MORE >>