Ninth Circuit applied the Supreme Court’s ruling in CIGNA Corp. v. Amara, 131 S. Ct. 1866 (2011) wherein the high court ruled that ERISA "summary documents, important as they are, provide communication with beneficiaries about the plan, but that their statements do not themselves constitute the terms of the plan for purposes of § 502(a)(1)(B)." The Ninth Circuit adopted the Supreme Court’s logic and ruling, but left open the possibility that language contained only in the Summary Plan Description (“SPD”) could be enforced if the claimant relied on the language
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