Court Rules on Alleged Conflict Between SPD and Plan Documents

A district court in Illinois granted summary judgment in favor of Holden Industries, rejecting claims by a former ESOP participant, which were based on his reading of the summary plan description (SPD). The judge found that the SPD would not govern, even if it contradicted the plan document, and further found that the company had not violated the terms of the SPD. The judge also noted that the "decision to seek simplicity over exacting detail in the 2011 SPD does not amount to a breach of [the company's] fiduciary duty."