Weitzenkamp v. Unum Life Ins. Co. of America

Dist. Ct. erred in granting defendant-employee benefit plan's motion for summary judgment in ERISA action challenging defendant's denial of plaintiff's application for continued long-term disability benefits, where defendant based denial on plan's self-reported symptoms limitation. Defendant could not rely on said limitation where defendant had failed to include said limitation in summary plan description. However, Ct. rejected plaintiff's contention that Social Security Act prevented defendant from recouping prior overpayment of plan benefits resulting from plaintiff's receipt of social security benefits.