The court rejected a disclaimer in the SPD stating ” In the case of any discrepancy between this SPD and the official plan documents, the official plan documents always govern.”
As a matter of law, the judge said that giving legal weight to the disclaimer would effectively defeat the Employee Retirement Income Security Act (ERISA) requirement that an SPD be provided. Also, if a participant has to read the plan as well as the summary, then the summary is of no use, the court said.
The court then examined the meaning of various disputed terms under the SPD and concluded that language in the SPD required a person of average intelligence and experience to compare various sections of the SPD in order to fully understand the benefits.
That rendered the SPD terms ambiguous, the court ruled, and so sent the case back to the insurer for further action.
The case is Collinsworth v. AIG Life Ins. Co.