"Amara does not support the broad proposition urged by the Estate, i.e. that an SPD can never serve as an ERISA plan document. As recently as May, 2011, notably in a decision rendered just two days after Amara, the Sixth Circuit recognized that where there is no formal ERISA plan separate and apart from the SPD, the SPD is the relevant plan document ... Amara does nothing to change the analysis and conclusion in this case. At the heart of Amara is the requirement that there be a conflict between the language of the SPD and the controlling plan document before the terms of the SPD can be ignored or overriden." [L&W Associates Welfare Benefit Plan v. Estate of Terance R. Wines, No. 12-cv-13524 (E.D. Mich. Jan. 13, 2014)]

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