A federal appeals panel has clarified the standard of review of an administrator’s denial of benefits where there are competing benefit plan descriptions.

Addressing an issue of first impression under the Employee Retirement Income Security Act (ERISA), the 2nd U.S. Circuit Court of Appeals held that a company’s attempt to alter the terms of a summary plan description was ineffective as to a disabled employee in Gibbs v. CIGNA Corp., 05-3879-cv.

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