Johnson v. Merrill Lynch, Pierce, Fenner & Smith, Inc.

Dist. Ct. did not err in dismissing on grounds of lack of standing plaintiff-plan administrator’s lawsuit seeking order requiring defendant-custodian of funds in said retirement plan to release said funds pursuant to directions from plaintiff. Record showed that defendant supported plaintiff’s request, but could not release said funds because state court had entered prior order precluding defendant from doing so. As such, plaintiff lacked standing to bring instant lawsuit against defendant since plaintiff’s injury was not traceable to actions taken by defendant, but rather was result of independent action taken by third-party, who was not included in instant lawsuit. Ct. rejected plaintiff’s argument that defendant should have released funds in contravention to state court’s order.