Piscotta v. Teledyne Industries, Inc., 91 F.3d 1326 (9^th Cir. 1996) - A class of retirees brought action when the employer sought to amend an employee welfare plan to put monetary caps on the amount of medical insurance for retired employees. The plaintiffs alleged that the amendments deprived them of vested rights in violation of ERISA and sought reimbursement for the amount of insurance premiums that they paid beyond the financial cap which defendant imposed. Plaintiff also sought an accounting from defendant. The district court granted summary judgment to the defendant because the insurance booklets issued in 1969 and 1972, which promised the lifetime health insurance benefits were not a summary plan description as defined by ERISA [29 U.S.C. § 1022(b)]. The Ninth Circuit agreed with this conclusion. Sec. 1022(b) lists twelve items that must be included in a document in order to constitute an SPD. Since there was no disputed issue that the insurance booklets did not contain all twelve of the statutory elements, the court found that "no plan documents exist which support" the plaintiff's allegation that defendant promised to pay lifetime medical benefits to retirees. In addition, the court found that even if the booklets could be construed as an SPD, the defendants reserved their right to modify or terminate the contract at any time, therefore the plaintiffs had no vested benefits. Finally, the court upheld the district court's decision to deny plaintiff's Motion to Amend Complaint to add a promissory estoppel claim. Under ERISA, estoppel principles apply only when there is a misrepresentation, reasonable and detrimental reliance, and upon extraordinary circumstances. The Ninth Circuit also requires that plaintiff must show that the plan is ambiguous and that representations must be made to the employee involving an oral interpretation of the plan. Since the plaintiff could not show an ambiguity, allowing the plaintiffs to amend their claims to include an estoppel cause of action was futile.