SPD V. Plan Document: Who Wins?

Conflicts between a benefit plan Summary Plan Description and a plan document are an ever-present concern for plan sponsors. An aggrieved participant who relies on SPD language will often pursue a claim for benefits even though he/she is not entitled to the benefit under the plain terms of the plan document. This problem is illustrated by a recent 6^th Circuit Court of Appeals decision, Pearce v. Chrysler Group LLC Pension Plan, No. 17-1431 (6^th Cir. June 20, 2018).

In 2008, Mr. Pearce was 60 years old and had 33 years of service with Chrysler. He declined a buyout offer and Chrysler terminated his employment. Based on Chrysler's pension plan SPD, Mr. Pearce believed that he was entitled to a "30-and-out" early retirement supplement under the pension plan. The SPD stated: “[y]ou do not need to be actively employed at retirement to be eligible for a supplement. However, you must retire and begin receiving pension benefits within five years of your last day of work for