U.S. Supreme Court Rejects Class-Wide Relief For Summary Plan Description Miscommunication

In Amara v. Cigna, No. 09-804 (U.S. May 16, 2011), the Supreme Court reversed and remanded a lower court ruling that had posed a substantial threat to employer plan sponsors by subjecting them to class-wide relief for a miscommunication without requiring any showing of harm.

The Court rejected outright the lower court's rationale, and the rationale advocated by the plaintiff and the Department of Labor, that a claim for a faulty summary plan description (SPD) can be pursued as a contractual claim for benefits, such that the court can enforce the terms of the SPD, as understood by the participants, instead of the terms of the plan itself. The Court correctly concluded that the SPD is merely meant to be a summary of the plan, and thus the mistaken terms of the SPD should not be enforced as a contractual matter.