Summary Plan Descriptions

The First Circuit issued an opinion in the case of Morales-Alejandro v. Medical Card System on Wednesday. The case, which involved a challenge to a denial of long term disability benefits, is noteworthy for two aspects. The first is that the case reaffirms this circuit’s reluctance to allow discovery beyond production of the administrative record

A few short notes of interest from a weekend of reading:

• Jerry Kalish has nice things to say about (and agrees with) my recent post concerning the Second Circuit’s decision – correct in my view – precluding summary plan descriptions from trumping the actual plan terms.

• I don’t know quite what to say

Here is an interesting post concerning a recent decision from the Second Circuit on the impact – there is apparently none in that circuit, given this post and the Second Circuit decision, Tocker v. Phillip Morris Companies, discussed in the post – of an administrator reserving discretion in determining claims for benefits only in the