Revisiting Conflicts Between Plan Documents & SPDs
I commented on the recent Fifth Circuit case, Washington v. Murphy Oil, a couple of weeks ago. Catching up on a few newer cases I've been meaning to read, I came across the decision from the U.S. Court of Appeals for the Sixth Circuit, Haus v. Bechtel Jacobs Co., 491 F.3d 557 (6th Cir. 2007). Haus adds an interesting twist to the post about Washington v. Murphy Oil. In Haus the Sixth Circuit ruled that, notwithstanding a deferential standard of review, it could not sustain a plan administrator's reading of the language of the plan documents that resulted in a conflict with the unambiguous language of the Summary Plan Description (SPD). The case is interesting because the opinion makes clear that while, on its face, the language in the plan documents did not necessarily conflict with the SPD, the way in which the plan administrator interpreted that language resulted in a conflict. This conflict with the SPD that resulted by the plan administrator's application of the language in the plan documents triggered the same reasons for reversing the Plan's denial of benefits as identified by the Sixth Circuit in earlier cases and the Fifth Circuit in Washington. The result is sound but it is nevertheless an explicit extension of the rule in Washington and many other Circuits that when the SPD is more generous than the plan documents, the SPD governs.