Since an article she published in the Iowa Law Review in 1995, Professor Dana Muir has worked in the field of fiduciary obligation, particularly as it relates to the investment of the almost $37 trillion in U.S. retirement assets, but also as it relates to a variety of other employee benefit plans. In her 1995 article, Muir explained that the courts' attempts to define fiduciary obligation using concepts from fourteenth-century trust law were misguided. Muir has subsequently addressed fiduciary concepts in the context of investment advice, the extent to which employers serve as fiduciaries of the plans the sponsor, and, most recently, in their application to the consideration of environmental, societal, and governance factors in the investment of retirement fund assets.