Lurie on Amara By Way of BenefitsLink By Way of the Workplace Prof
Well, this piece by Alvin Lurie on Amara is about as good as you are going to find, running as it does from the technical aspects of the case to the philosophy of its jurisprudence. I can commend it to you for a few reasons, not the least of which is that it does a wonderful job of actually explaining the case itself, in terms of its genesis, the underlying proceedings, the plan at issue, and the decision of the Supreme Court. It also, though, goes straight to the most important aspect of Amara from the point of view of a practicing lawyer litigating benefit claims, which is the majority opinion’s exposition on how to obtain redress when the problem concerns inaccurate summary plan descriptions. As I discussed in this post here, the majority opinion instructs that a plan participant cannot recover increased benefits beyond what would be available under the plan terms themselves by basing a claim for benefits on the summary; rather, the proper approach is to seek reformation of the plan to provide the amount of benefits indicated by the summary, if different from that provided under the plan terms themselves. To my way of thinking, this is the key practical significance of Amara: it explains how to properly plead a claim seeking to recover the greater benefit amounts set forth in a summary, as compared to that set forth in the plan itself.
My thanks to Paul Secunda and the always vigilant Workplace Prof for highlighting the article.