On May 16, the U.S. Supreme Court issued its much anticipated opinion in Cigna Corp. v. Amara, 2011 DJDAR 6962 (May 16, 2011), which, according to the grant of certiorari, was supposed to address the standard of proof necessary for a beneficiary of an Employee Retirement Income Security Act of 1974 (ERISA) plan to recover benefits where there is a discrepancy between the plan document and the plan summary, known as the summary plan de...
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