A Potential Turning of the Tide: Eleventh Circuit Affirms Enforcement of Summary Plan Description Terms

While the debate over Amara and its implications continues, the Eleventh Circuit gave welcome ammunition to ERISA plan administrators and fiduciaries in a recent opinion. In Board of Trustees of the National Elevator Industry Health Benefit Plan v. Montanile, No. 14-11678 (Nov. 25, 2014), the court held that a summary plan description constituted a written instrument that sets out enforceable terms of an ERISA employee welfare benefit plan. The court affirmed the District Court of Southern District Florida’s grant of summary judgment for the Plaintiff-Appellee Board of Trustees.

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