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In Conflict Between Plan Document and SPD, SPD Prevails to Participant's Detriment
The Pension Protection Act Blog 
[Guidance Overview] May 22, 2008
Excerpt: In Kolpacke v. CSX Pension Plan, No. 07-1959 (CA6, May 21, 2008), the 6th Circuit affirmed the district court's grant of summary judgment in CSX's favor, stating that Kolpacke had failed to show that CSX had arbitrarily and capriciously applied the terms of the pension plan in calculating Kolpacke's estimated benefits. Unlike most ERISA opinions from the 6th Circuit, the Court's entire opinion is two paragraphs long and does not provide any detail.
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