Metropolitan Life Ins. Co. v. Glenn, 554 U.S. 105 (2008)
Primary Holding
A plan administrator's dual role as both the decision-maker and the payor of benefits creates a conflict of interest, which a reviewing court must consider as a factor in determining whether the administrator abused its discretion in denying benefits under ERISA.
In the case of Metropolitan Life Ins. Co. v. Glenn, the Supreme Court ruled that when an insurance company both decides whether to approve claims and pays those claims, it creates a conflict of interest. This matters because it means that if you are denied benefits, a court will consider whether this conflict influenced the decision, giving you a better chance of getting a fair review of your claim. This case is relevant if you are applying for benefits under an employee plan and feel that your claim was unfairly denied, as it helps ensure that the decision-maker is held accountable.
AI-generated plain-language summary to help you understand this case
In the case of Metropolitan Life Ins. Co. v. Glenn, Wanda Glenn, an employee of Sears, Roebuck & Company, was diagnosed with severe dilated cardiomyopathy, a serious heart condition. She applied for long-term disability benefits under an employee benefit plan administered by Metropolitan Life Insurance Company (MetLife) in June 2000. Initially, MetLife approved her claim for benefits for the first 24 months, determining that she could not perform the material duties of her own job. During this period, MetLife also referred Glenn to a law firm to assist her in applying for federal Social Security disability benefits. An Administrative Law Judge later found that her condition prevented her from performing any jobs available in significant numbers in the national economy, leading to the Social Security Administration granting her permanent disability payments retroactive to April 2000. However, to continue receiving benefits beyond the initial 24 months, Glenn needed to meet a more stringent standard, demonstrating that her condition rendered her incapable of performing any gainful occupation for which she was reasonably qualified. MetLife ultimately denied her claim for extended benefits, asserting that she was capable of performing full-time sedentary work. After exhausting her administrative remedies, Glenn filed a federal lawsuit seeking judicial review of MetLife's denial of her benefits. The case reached the Supreme Court after the District Court denied Glenn relief, and she subsequently appealed to the Court of Appeals for the Sixth Circuit, which ruled in her favor. The Supreme Court granted certiorari to address the issue of whether MetLife's dual role as both the plan administrator and insurer created a conflict of interest that should be considered in determining whether it abused its discretion in denying benefits. The Court's decision would clarify how such conflicts should be evaluated in ERISA cases.
Whether a court reviewing a denial of benefits under the Employee Retirement Income Security Act (ERISA) should consider the conflict of interest that arises when the plan administrator both determines eligibility for benefits and pays those benefits.
The judgment is affirmed.
- Court
- Supreme Court
- Decision Date
- April 23, 2008
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Breyer
- Damages Awarded
- N/A
- Data Quality
- high
LaRue v. DeWolff, Boberg & Associates, Inc., 552 U.S. 248 (2008)
Consumer WonA participant in a defined contribution pension plan may sue a fiduciary under §502(a)(2) of the Employee Retirement Income Security Act (ERISA) for breaches of fiduciary duty that impair the value of their individual account, allowing for recovery that benefits the individual rather than solely the plan as a whole.
Beck v. PACE Int’l Union, 551 U.S. 96 (2007)
Consumer LostAn employer that sponsors and administers a single-employer defined-benefit pension plan does not have a fiduciary obligation under the Employee Retirement Income Security Act (ERISA) to consider a merger with a multiemployer plan as a method of terminating the plan.
Sereboff v. Mid Atlantic Medical Services, Inc., 547 U.S. 356 (2006)
Consumer LostA fiduciary under the Employee Retirement Income Security Act (ERISA) may sue a beneficiary for reimbursement of medical expenses paid by the ERISA plan when the beneficiary has recovered damages from a third party, as long as the plan contains a valid reimbursement provision.
Kentucky Retirement Systems v. EEOC, 554 U.S. 135 (2008)
Consumer LostKentucky's retirement system does not discriminate against employees based on age under the Age Discrimination in Employment Act (ADEA) because the benefits provided to disabled employees are based on their years of service and not their age at the time of disability.