Chemung Canal Trust Co. ex rel. Fairway Spring Co. v. Sovran Bank/Maryland
The Chemung Canal Trust Company and beneficiaries sued Sovran Bank/Maryland under ERISA, alleging breach of fiduciary duties related to pension plan management. Sovran, a former trustee, was accused of failing to rectify prior trustee Glenn Dawson's wrongful acts and making two imprudent investments. Sovran then filed a third-party complaint against Fairway Spring Co., the employer, for indemnity/contribution, and a counterclaim against Chemung for failing to adequately pursue claims. The court dismissed Sovran's counterclaim against Chemung due to lack of standing as a former fiduciary. Furthermore, the court dismissed Sovran's claims for contribution and indemnity against Chemung and Fairway, ruling that ERISA does not explicitly or implicitly provide for such actions, nor can they be created under federal common law.