The U.S. Supreme Court's Decision in CIGNA Corp. v. Amara - A Mixed Bag for Plan Sponsors


The recent U.S. Supreme Court decision in the class action case of CIGNA Corp. v. Amara contains both good news and bad news for ERISA plan sponsors.

The U.S. Supreme Court held that a summary plan description ("SPD") does not constitute the terms of a plan. Therefore, a civil action under ERISA to enforce the terms of a plan cannot be used to enforce provisions of an SPD that conflict with the plan document. The Supreme Court also held that a presumption of likely harm is insufficient to determine the members of the class action. Actual harm is required.

While the above rulings are favorable to plan sponsors, the U.S. Supreme Court, in dicta, also stated that reformation of a plan and monetary damages may be acceptable equitable remedies for the failure to provide sufficient notice of benefit reductions and deficiencies in required plan communications.

Please see full article below for more information.

LOADING PDF: If there are any problems, click here to download the file.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Reed Smith | Attorney Advertising

Written by:


Reed Smith on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:

Sign up to create your digest using LinkedIn*

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.

Already signed up? Log in here

*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.