Does the Employer Trustees have to make a distinction between a valid plan amendment and a breach of fiduciary duty claim?

Our decision in Janese similarly makes no distinction between breach of fiduciary duty claims premised on invalid, as opposed to valid, amendments. In fact, Janese cited with approval a case from the Northern District of New York, Fuchs v. Allen, see Janese, 692 F.3d at 227, which dismissed a breach of fiduciary duty claim based on a plan amendment despite the plaintiffs' allegation that the plan amendment was invalid. 363 F.Supp.2d 407, 413 (N.D.N.Y. 2005). We therefore reject the Employer Trustees' argument that invalid plan amendments are somehow exempted from Janese's general rule.