NEW YORK - A federal district court erred in deferring to a pension plan administrator's interpretation of an offset provision under the Employee Retirement Income Security Act because the interpretation violated the plan's provisions and was not disclosed in summary plan descriptions (SPDs) given to the plan participants, the Second Circuit U.S. Court of Appeals ruled Dec. 23 (Paul J. Frommert, et al. v. Sally L. Conkright, et al., No. 12-67-cv, 2nd Cir.; 2013 U.S. App. LEXIS 25500).