CIGNA Corp. v. Amara (09-804)
argument 09-804CIGNA Corp. v. Amara
Supreme Court of the United States
1h 1m
4 speakers
8 chapters
transcribed 4 days ago
official recording ↗
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What is the ERISA enforcement scheme that frames the case?
We'll hear argument first this morning in case zero nine eight oh four Cigna Corporation versus Amara. Mr. Olson?
Mr Chief Justice, and may have pleased the court. Congress crafted a carefully balanced ERISA enforcement scheme. that enables planned participants to recover planned benefits under Section five oh two A one B. and equitable remedies for ERISA violations under Section five hundred oh two A three. In this case, respondents are seeking a remedy for misleading planned summaries that violated ERISA. Their remedy, if they were harmed by defective plan summaries, is under five hundred two A three equitable remedies, not for planned benefits under five hundred oh two A one B. The section that governs the relief that is sought is a necessary antecedent to any of the other questions in this case. And ERISA carefully structures, and this court has repeatedly said the court is not interested and does not w is not willing to alter the structure that Ca Congress carefully crafted and carefully developed over the years to provide remedies with respect to ERISA programs.
And the scheme is such that if there is a participant of the plan who is seeking benefits under that plan, subsections A one B of Section 502 provides for relief under the plan. If there are other violations of ERISA, Section 502A3 provides for equitable relief. That is the scheme carefully developed by Congress. Now in this case, what happens is that Signa changed its pension programme, its ERISAP plan, from a defined benefit plan to a cash um benefit plan um uh cash value plan. And it put out, as required by IRISA, summaries of the new plan that The district court found and the Court of Appeals affirmed were misleading in that in the sense that they did not provide all of the information necessary for plan participants to evaluate what was happening.
Now the changes to the plan were lawful. ERISA permitted and does permit these kind of changes to an ERISA plan. There was nothing unlawful about the plan. Um and the plan changed. And the beneficiaries, the participants to the plan, did not have any choice. Cygna had the right to change the plan. It did change the plan. It did have an obligation under ERISA to provide accurate summaries. And the District Court and the Court of Appeals found that those summaries were not inaccurate. In other words, they were not accurate. Mr
Mr. Olsen, when you say The employees had no choice. But The district court found Sign it that the in the reason for this plan summary being misleading was that the employer signal feared that there might be A backlash on the part of the employees. If they found out if they were told the truth about this plan, that is, that it was less favourable that they would not have the same benefits that they had under the prior plan.
That is correct, Justice Ginsburg. They had no choice in the sense that Cigna could adopt a change in the plan as it did. That was permitted under ERISA, but it was required to give accurate summaries. The choice that you are suggesting and the District Court was concerned about is that an individual could have left the employee of Cigna if he or she was unhappy with the change in the plan, or the District Court said there could have been some sort of a protest. What we're saying is that the remedy what was a what was the violation is the summary itself. And we're not we're not challenging that here. That's a finding below. The summary was misleading, but that makes it a violation of Irisa, the summary is not the plan.
And well
Mr. Olson, we've several times referred to the plan. as having a range of documents associated with it, not as having just a single written instrument, but we've referred to documents and instruments governing the plan. We did that in Curtis Wright, which is the case that you pinned so much on. We did that in Kennedy. And the statute itself talks about that on numerous occasions, that there are um documents and instruments in the plural. And and one would think that the SPD is is one of those documents and instruments that govern the plan.
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Chapters
8 chapters
1
What is the ERISA enforcement scheme that frames the case?
0:01–8:06
2
How did Cigna’s conversion from a defined‑benefit to a cash‑balance plan raise ERISA issues?
8:06–16:16
3
Why do the parties argue that the Summary Plan Description (SPD) is or isn’t part of the plan?
16:16–24:20
4
What is the “likely harm” standard and how does the Second Circuit apply it here?
24:20–31:50
5
How do equity remedies under §502(a)(3) differ from benefit‑recovery claims under §502(a)(1)(B)?
31:50–39:40
6
Is the dispute a contract claim, a trust claim, or something else under ERISA?
39:40–47:56
7
What are the arguments for and against a class‑action remedy in this case?
47:56–56:08
8
What conclusion does the Court reach about the SPD’s role and the available relief?
56:08–1:01:53