How have courts interpreted the express discretion provision in pension plans?

Where, as here, a pension plan contains an express discretion provision, courts review the plan administrator's interpretation of the plan for abuse of discretion. O Rourke v. N. Cal. Elec. Workers Pension Plan, 934 F.3d 993, 998 (9th Cir. 2019). We review de novo the district court's application of the abuse of discretion standard, id., as well as the grant of summary judgment, United States v. Phattey, 943 F.3d 1277, 1280 (9th Cir. 2019).