Mealey's (April 29, 2021, 11:11 AM EDT) -- SAN FRANCISCO — Passively managed funds are not meaningful benchmarks for actively managed funds, a California federal judge ruled April 15, dismissing without further leave to amend for failure to state a claim 401(k) retirement plan participants’ allegations that the plan fiduciaries breached their duty of prudence under the Employee Retirement Income Security Act....