Joanne Roskey, former Deputy Associate Solicitor at the U.S. Department of Labor (DOL) and former Chief of the Division of Health Investigations in DOL's Employee Benefits Security Administration (EBSA), was quoted on the U.S. Supreme Court’s unanimous decision in Cunningham v. Cornell University, clarifying that plaintiffs bringing prohibited transaction claims under ERISA do not have to satisfy additional pleading requirements. "This decision makes it easier for plaintiffs to plead prohibited transactions related to service provider contracts with plans, because all they need to plausibly allege is that plan fiduciaries caused the plan to enter into a transaction with a service provider for goods, services, or facilities," Roskey said, adding, "We may also hear more talk of having Congress enact a legislative fix to ERISA" to circumvent the decision.