arbitrary and capricious

Conkright v. Frommert

Issues

Whether a district court must defer to an ERISA plan administrator’s proposed remedy for an ERISA violation, where the violation resulted from a prior interpretation by the plan administrator.

 

Courts generally give deference to discretionary decisions made by ERISA pension plan administrators. This case will test the limits of that deference and will decide if a court is obligated to defer to a plan administrator’s proposed remedy for an ERISA violation, when the cause of the violation itself was the administrator’s prior interpretation. Petitioners and their amici argue that allowing judges to involve themselves in ERISA pension plan determinations without deferring to decisions made by the plan administrator will increase the costs and uncertainty of maintaining pension plans. Respondents and their amici, on the other hand, argue that deferring repeatedly to a plan administrator will increase costs through more and prolonged litigation, and will be unfair to plan participants who justifiably rely on promised benefits to plan for retirement.

​

Questions as Framed for the Court by the Parties

1. Whether the Second Circuit erred in holding, in conflict with decisions of thisCourt and other Circuits, that a district court has no obligation to defer to an ERISA plan administrator's reasonable interpretation of the terms of the plan if the planadministrator arrived at its interpretation outside the context of an administrativeclaim for benefits.

2. Whether the Second Circuit erred in holding, in conflict with decisions of other Circuits, that a district court has "allowable discretion" to adopt any "reasonable"interpretation of the terms of an ERISA plan when the plan interpretation issue arises in the course of calculating additional benefits due under the plan as a result of an ERISA violation.

 

The Employee Retirement Income Security Act (“ERISA”), 29 U.S.C.

Edited by

Additional Resources

•       FindLaw: Pension Plans and ERISA

•       United States Department of Labor: ERISA

Submit for publication
0

MetLife v. Glenn

Issues

Given that an administrator of an ERISA plan has a conflict of interest because it both pays claims and determines whether claims are eligible for payment, how much weight should a court give that conflict of interest in deciding whether the administrator abused its discretion regarding a claim?

 

The Employee Retirement Income Security Act of 1974 ("ERISA"), 29 U.S.C. § 1001 et seq., provides a private cause of action for employees challenging wrongful denials of benefits under an employee benefits plan. Under ERISA, Wanda Glenn challenged MetLife's discontinuation of her disability benefits on the ground that the company faced a conflict of interest by both determining eligibilities for benefits payments and making these same payments. The U.S. District Court for the Southern District of Ohio affirmed MetLife's discontinuation of benefits. The U.S. Court of Appeals for the Sixth Circuit, siding with five other Circuits, ruled that a court reviewing a claims-denial must consider whether and to what extent a plan administrator's conflict of interest may have affected its determination of benefits. In this case, the U.S. Supreme Court will determine whether and to what extent a plan administrator that both authorizes the payment of benefits and is responsible for the payment of those benefits has a conflict of interest that must be considered on judicial review.

Questions as Framed for the Court by the Parties

If an administrator that both determines and pays claims under an ERISA plan is deemed to be operating under a conflict of interest, how should that conflict be taken into account on judicial review of a discretionary benefit determination?

In 1989, Wanda Glenn's heart suddenly stopped. Glenn v. MetLife, 461 F.3d 660, 663 (6th Cir.

Submit for publication
0

Ohio v. Environmental Protection Agency

Issues

Should the Supreme Court stay implementation of the EPA’s “Good Neighbor Plan,” a federal default implementation plan for emissions reduction, after that organization disapproved of the emissions reductions plans of twenty-three different states and attempted to implement their own federal plan?

This challenge to administrative action by numerous states, including Ohio (“Ohio et al.”) asks the Court to determine whether a stay of enforcement of the Environmental Protection Agency (“EPA”) default emissions regulations, named the “Good Neighbor Provision,” is appropriate, pending review of the legality of the EPA’s action under the Clean Air Act (CAA). Ohio et al. maintain that they are requesting a stay, which should be approved when considering the irreparable harm to state parties as a result of the implementation of the federal-default rule. Meanwhile, the EPA claims Ohio et al. are actually requesting an injunction, which should only be granted in exceptional circumstances. Ohio et al. further argue that the agency’s disapproval of their state-level implementation plans was an “arbitrary and capricious” action because the EPA failed to consider that state courts would limit the applicability of the federal-implementation plan, leading to a less effective rule. The EPA counters that its consideration of the “reasonableness” of the plan was adequate at the time of its initial promulgation and that it was not required to consider subsequent legal action. The outcome of this case has significant implications regarding the transition to greener energy, specifically related to economic costs, and the success of environmental goals.

Questions as Framed for the Court by the Parties

(1) Whether the court should stay the Environmental Protection Agency’s federal emission reductions rule, the Good Neighbor Plan; and (2) whether the emissions controls imposed by the rule are reasonable regardless of the number of states subject to the rule.

Under the Clean Air Act (“CAA”), states are required to submit a plan that provides for the “implementation, maintenance, and enforcement” of ambient air quality standards consistent with those promulgated by the Environmental Protection Agency (“EPA”).

Submit for publication
0
Subscribe to arbitrary and capricious