referring to Amara, holding that terms of a summary plan description cannot be enforced through § 1132(a)(1)(B)
How later courts described this case
- referring to Amara, holding that terms of a summary plan description cannot be enforced through § 1132(a)(1)(B)
- determining whether plan summary was ambiguous pri- or to interpreting plan language
- “We note that there is no right to a jury trial in ERISA denial-of-benefits cases.”
- noting “most important factor” in the analysis is “whether the administrator’s interpretation is consistent with a fair reading of the plan”
Written by the judges who cited it.
The opinion
*192 HAYNES, Circuit Judge,
concurring in part:
I agree that the decision of the district court should be reversed. However, I have reviewed the provisions of the plan so carefully and thoroughly set forth in the majority opinion. Taken as a whole, I cannot read these provisions to require preauthorization for this particular circumstance as a condition precedent to any recovery regardless of any other circumstances. Thus, I conclude there is no ambiguity, and I would hold that the plan administrator abused its discretion in concluding to the contrary. However, other reasons were given for denial of benefits, so I concur in remanding for purposes of considering those issues.