The Supreme Court Holds that Reformation of ERISA Plan Terms Due to False or Misleading Plan Summaries Does Not Strictly Require a Showing of Detrimental Reliance
On Monday, the Supreme Court decided in CIGNA Corp. v. Amara, No. 09-804, that courts may reform the terms of retirement plans subject to the Employee Retirement Income Security Act of 1974 under traditional equitable principles where Summary Plan Descriptions or Summary of Material Modifications are false or misleading. In so doing, the Court also held that the showing of harm required of plaintiffs will depend on the type of equitable remedy invoked to reform the plan terms.