A recent court case out of the Sixth Circuit Court (Pearce v. Chrysler Group LLC Pension Plan
) reminds plan sponsors to carefully monitor the terms and provisions used in the retirement plan document versus those used in the summary plan description (SPD). The court held that a material conflict between an SPD and the plan permits a participant to file a claim. Chrysler offered Pearce a buyout package that would pay him a certain dollar amount on top of his normal pension benefits. At the time, Pearce was eligible for a supplemental pension benefit which paid an employee with 30 years of service an additional stipend until he became eligible for Social Security benefits. Chrysler did not pay supplemental benefits to Pearce, because the Plan said that a terminated employee was not eligible. Pearce argued that his rights were controlled by the SPD, which did not contain the exclusion for terminated employees, and therefore he met all the requirements. The SPD did go on to say, however, that if it conflicted with the Plan, the Plan controlled. The district court held that consistent with Cigna Corp. v. Amara (see our article
), Pearce was not eligible for the so-called “30-and-Out” benefits because the Plan document language did not allow the benefit. The Sixth Circuit held that since the SPD was directly inconsistent with the pension plan regarding the requirements, the SPD in effect misled or failed to state additional requirements for the benefits. It also found that Pearce satisfied the SPD requirements to be eligible to receive the supplemental benefits. The results of this case are a reminder to plan sponsors the importance of periodically reviewing your plan document’s provisions, as well as its subsequent amendments. The documents provisions should be accurately mirrored in the SPD or summary of material modifications participants receive for consistency in order to effectively communicate to participants the provisions of the Plan. Interested in more information about your plan documents being in line with your SPD? Please contact your Nyhart consultant.