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. ยง 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.
Additional Resources
- LII Law about... Administrative Law, Employment, Pension
- Dep't of Labor: Health Plans & Benefits