The following excerpt is from Tibble v. Edison Int'l, 843 F.3d 1187 (9th Cir. 2016):
In Phillips v. Alaska Hotel and Restaurant Employees Pension Fund , 944 F.2d 509, 52021 (9th Cir. 1991), we held that the limitations period under a different subsection of the ERISA statute of limitations, 29 U.S.C. 1113(2), begins when a plaintiff has actual knowledge of a breach. When there is "a series of discrete but related breaches" because a fiduciary violated a continuing duty over time, the 1113(2) limitations period does not begin anew with each related breach. Id.
The above passage should not be considered legal advice. Reliable answers to complex legal questions require comprehensive research memos. To learn more visit www.alexi.com.