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Sixth Circuit Grants Benefits Based on SPD Language, Despite Exclusionary Clause in the Plan, on the Grounds of Equitable Estoppel
ERISA Lawyer Blog July 23, 2018
"[T]he SPD omitted an exclusionary clause contained in the Plan document itself, which said that an employee who was terminated was ineligible for the early retirement supplement.... [T]he Sixth Circuit Court of Appeals reversed the district court's grant of summary judgment to the Plan on Pearce's request for reformation, [and] affirmed summary judgment on Pearce's request for equitable estoppel under which the provisions of the SPD would be applied." [Pearce v. Chrysler Group LLC Pension Plan, No. 17-1431 (6th Cir. June 20, 2018)]
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