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Minnesota District Court Applies De Novo Review, Finds SPD Discretionary Language Ineffectual Where Plan Document Failed to Grant Discretion (PDF)
U.S. District Court for the District of Minnesota 
May 15, 2014
"If the Life Policy was ambiguous as to whether it conferred discretion to [the defendant Life Insurance Co. of North America (LINA)], this SPD language may have resolved the ambiguity in LINA's favor. Because the Life Policy is not ambiguous, however, the SPD cannot by itself confer discretion to LINA at beneficiaries' expense." [Bowers v. Life Ins. Co. of North America (LINA), No. 13-891 (D. Minn. May 14, 2014)]
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