Mull v. Motion Picture Industry Health Plan, No. 15-56246 (9th Cir. 2017)
Annotate this CaseThe Ninth Circuit vacated the district court's grant of summary judgment in favor of plaintiffs in an Employee Retirement Income Security Act (ERISA) action. The panel held that the plan comprised of two documents: the Trust Agreement and the Summary Plan Description (SPD). The Supreme Court's decision in CIGNA Corp. v. Amara, 563 U.S. 421 (2011), was not to the contrary. An SPD may constitute a formal plan document, consistent with Amara, so long as the SPD neither adds to nor contradicts the terms of existing plan documents. In this case, the SPD was a part of the plan itself, and there was no conflict between the SPD and the Trust Agreement. Therefore, Amara did not prohibit this type of arrangement, and the district court erred in concluding that the SPD was not part of the plan. The panel remanded for further proceedings.
Court Description: Employee Retirement Income Security Act The panel vacated the district court’s grant of summary judgment in favor of the plaintiffs in an ERISA action. The district court enjoined an ERISA plan and its board of directors from enforcing Summary Plan Description provisions regarding reimbursement of benefits previously paid upon a plan participant’s receipt of a third-party recovery. The district court ruled that these reimbursement/recoupment provisions were not enforceable under ERISA because they were found only in the Summary Plan Description and not in any document that constituted the ERISA plan.
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