Overview
Four recent US Court of Appeals decisions address a variety of issues affecting employee benefit plans. The First Circuit held that equitable estoppel cannot be asserted to contradict the unambiguous terms of an ERISA-covered plan; as in the past, it refrained from deciding whether the estoppel remedy is available at all. The Sixth Circuit concurred with the Pension Benefit Guaranty Corporation's position that a pension plan amendment changing the actuarial factors for converting benefits into lump sums is ineffective if adopted after the plan termination date, even if it would otherwise be permitted. The Eleventh Circuit held that a summary plan description may, in some circumstances, be treated as the equivalent of a plan document. The Second Circuit summarily affirmed a district court decision that ERISA does not prevent a welfare plan from refusing to treat opposite-sex and same-sex spouses identically.
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