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NOTICE OF CLASS ACTION SETTLEMENT AGREEMENT
The notice your received advises you of the Settlement of Hagins, et al. v. Knight-Swift Transportation Holdings, Inc., Case No. 2:22-cv-01835 (D. of Arizona) (the “Action”).
On October 26, 2022, Plaintiffs Robert Hagins and Tommie Woodward filed a Class Action Complaint on behalf of the Knight-Swift Retirement Plan (the “Plan”) asserting claims under the Employee Retirement Income Security Act of 1974 (“ERISA”), 29 U.S.C. §§ 1109, 1132, for breach of fiduciary duties against Knight-Swift Transportation Holdings, Inc. (“Defendant”).
The parties in the Action have reached a Settlement and, if approved by the Court, the Settlement will release Defendant and related parties from any claims filed against them in the Actions. The terms and conditions of the Settlement are set forth in a Settlement Agreement & Stipulation (the “Settlement Agreement”). Capitalized terms used in the Notice but not defined in the Notice have the meanings assigned to them in the Settlement Agreement. The Settlement Agreement and additional information with respect to the Action and the Settlement are available on this website.
The Parties have agreed to settle this case for $3,000,000.00 (the “Gross Settlement Amount”). The Court has scheduled a hearing concerning Final Approval of the Settlement and Class Counsel’s anticipated motion for attorney’s fees and costs. That hearing, before the Honorable Roslyn O. Silver is scheduled on April 1, 2026 at 10:00am. in Courtroom 624, at the United States District Court, Sandra Day O’Connor U.S. Courthouse, 401 West Washington Street, Phoenix, Arizona 85003-2158.
If Final Approval is granted, the Settlement will bind you as a member of the Settlement Class. You may appear at this hearing and/or object to the Settlement. Any objection to the Settlement and/or the motion for attorney’s fees and costs must be served in writing on the Court and the Parties’ counsel. More information about the hearing and how to object is explained in the notice and on this website.
YOUR LEGAL RIGHTS WILL BE AFFECTED WHETHER OR NOT YOU TAKE ANY ACTION. READ THE NOTICE CAREFULLY. PLEASE DO NOT CONTACT DEFENDANT OR THE COURT. THEY WILL NOT BE ABLE TO ANSWER YOUR QUESTIONS.
YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT
| You can do nothing. (No action is necessary to receive a payment.) |
If the Settlement is approved by the Court and you are a member of the Settlement Class entitled to a payment under the Plan of Allocation, you need not do anything to receive a payment. |
| You can submit an objection. (It must be postmarked by March 18, 2026) |
If you wish to object to any part of the Settlement, you may write to the Court and Counsel and explain why. For more information and where to send your objection, see Question 13 on the Frequently Asked Questions page of this website. |
| You can appear at the Final Fairness Hearing on April 1, 2026. | If you submit a written objection to the Settlement before the Court-Approved Deadline, you may (but do not have to) speak in Court about the fairness of the Settlement. |
SUMMARY OF ACTIONS
As described in more detail below, Plaintiffs’ Class Action Complaint in Hagins (ECF No. 1) alleges on behalf of the Plan that Defendant breached ERISA fiduciary duties of prudence owed to participants in and beneficiaries of the Plan during the Class Period. Defendant denies these allegations. Plaintiffs’ Class Action Complaint in Sievert also alleges on behalf of the Plan that Defendant breached its ERISA fiduciary duties of prudence owed to participants in and beneficiaries and along with additional ERISA violations. The Hagins and Sievert actions are both brought on behalf of the Plan and seek recovery on behalf of the Plan during the same time period.
Copies of the Class Action Complaints, Settlement Agreement, and related documents are available on the Important Court Documents page of this website.
SUMMARY OF THE SETTLEMENT AGREEMENT
The Settlement Agreement provides that Defendant will pay $3,000,000.00, which will be deposited into an account called the Qualified Settlement Fund. After payment of attorneys’ fees and litigation costs, and any expenses related to administration of the Settlement, the amount remaining in the Qualified Settlement Fund shall constitute the Net Settlement Amount and will be allocated among members of the Settlement Class according to a Plan of Allocation to be approved by the Court.
STATEMENT OF POTENTIAL OUTCOME OF THE ACTION
Class Counsel believe that the claims against Defendant are well-grounded in law and fact and that ERISA violations have occurred in the Actions. However, as with any litigated case, members of the Settlement Class would face an uncertain outcome if the Actions were to continue against Defendant. Continued litigation of the Actions could result in a range of possible recoveries, including a judgment or verdict greater or less than the recovery under the Settlement Agreement, or no recovery at all.
Class Counsel believe that this Settlement reflects a reasonable compromise in light of the range of possible outcomes. Class Counsel believe that the Settlement is preferable to continued litigation and is in the best interest of the members of the Settlement Class because the Settlement provides certainty with respect to the amount of recovery and results in a prompt recovery.
Throughout this litigation, Defendant has denied and continues to deny the claims and contentions alleged by Plaintiffs. Defendant has strong and well thought-out defenses. Nevertheless, Defendant has concluded that it is desirable for the Action to be fully and finally settled as to it and the other Releasees on the terms and conditions set forth in the Settlement Agreement.
The Court has not ruled in favor of either side. Both sides agreed to the Settlement to ensure a resolution and avoid the cost and risk of further litigation.