Some summonings get a con bonus with talent level (e.g. Summoning (utility):Turtle or all Thought-forms). These con bonuses do not provide any extra health on summoning the creature. This is extremly noticable with the Turtle/jelly which easily gets + 100 con trough talent level later on.
A (same level) turtle with 10 con or 100 con will always have the same amount of health (+/- ~10 hp variance on summon) so these talent points don't really provide much and e.g. a high level jelly will always die as fast as a level 1 jelly.
They scale with con after summoning though, which can be tested with the Summoning (augmentation):Rage. The extra con they get grants them more maximum hp.
Although stated as a bug in 1.2.3, it acutally has been like this since I first started playing the game which is more than 1 year ago.
I did test it with the Summoner summons talent that scale with con (the summonings AND the resilience talent) and with the Solipsist thought forms. I did not test it with the golem (since it can't just be boosted high and then be undone without mods). They all get the con on paper (inspecting), but they don't get any extra health on summoning. Only when getting con trough rage after summoning.
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Furthermore: When summoner summons crit, they do not seem to get extra stats based on their stats from talent level + mindpower, as they always get a different % bonus on their stats depending on their talent level.
[1.2.3] Summonings' health not scaling with constitution
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