Sonnenblick

MEMORANDUM *

CB Richard Ellis Investors, L.L.C. (“CB Ellis”), as investment manager of Southern California, Arizona, Colorado, and Southern Nevada Glaziers, Architectural Metal and Glassworkers Pension Trust (“the Trust”), appeals the district court’s order dismissing its first amended complaint as barred by the three-year statute of limitations of the Employee Retirement Income Security Act of 1974 (“ERISA”). The complaint alleged that Robert Sonnenblick violated ERISA’s “prohibited transaction rules,” 29 U.S.C. §§ 1106 and 1108, through an improper real estate brokerage *681 service contract he entered into with the Trust. We reverse the district court’s dismissal because it improperly imputed to CB Ellis the Trust’s knowledge of the alleged ERISA violation.

The ERISA statute of limitations invites a “two-step analysis of accrual of an ERISA action .... ” Ziegler v. Conn. Gen. Life Ins. Co., 916 F.2d 548, 550 (9th Cir.1990). We “first isolate and define the underlying violation upon which ... [plaintiffs] claim is founded,” and determine when it occurred. Id. at 550-51 (citing Meagher v. Int’l Ass’n of Machinists & Aerospace Workers Pension Plan, 856 F.2d 1418, 1422 (9th…