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Summary Plan Description Language Ruled Unenforceable

  • Precision
  • October 2nd, 2014

A decision handed down yesterday, September 30, 2014 by the United States District Court Central District of California in Mull v. Motion Picture Industry Health Plan, LA CV 12-06693-VBF.

The following analysis come to us from Professor Roger Baron:

Yesterday the U.S. District  Court for California, Central Division (Los Angeles) entered its ruling that the Motion Picture Industry ERISA plan's reimbursement provisions are enforceable because they are contained only in the plan's Summary Plan Description (SPD) and not in a Plan Document.  This situation which developed here was especially burdensome for the ERISA beneficiary and her family.  The ERISA plan had paid $148,000 of medical bills and then demanded the victim turn over her entire tort recovery of $100,000, plus interest.  When the victim refused, the ERISA plan quit providing health coverage for the victim and her entire family of four. 

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