Supreme Court Decision in CIGNA v. Amara Sends Mixed Message on Reliance on Summary Plan Descriptions

To read the headlines on the Supreme Court decision CIGNA v. Amara, No. 09-804 (U.S. May 16, 2011), it might seem that employers won a big victory. The court had ruled that a conflict between language in a summary plan description (SPD) and the plan document itself should be resolved in favor of the plan, at least under one part of ERISA. But the court's ruling was far more complex, finding that employees can still seek equitable and monetary relief if they can show damage resulting from the miscommunication under other sections of ERISA. A more detailed explanation worth reading appeared in the BNA Pension Reporter (available at this link).