Metropolitan Life Insurance Company, et al. v. Glenn

Case Updates

Disagreeing with NCLC, the Supreme Court held that a plan administrator that both evaluates and pays claims operates under a conflict of interest that is subject to a heightened judicial review of ERISA benefits decisions.

NCLC urged the Supreme Court to reverse a Sixth Circuit decision that ERISA benefits decisions made by a plan administrator that both evaluates and pays claims operates under a conflict of interest that is subject to a searching judicial review. Glenn sued MetLife, who both funded and paid the benefits plan, for making a determination that she was not eligible for long-term disability payments under the ERISA plan. In its brief, NCLC argued that market pressures and regulatory constraints on plan administrators operate to ensure that fiduciary claim determinations are not driven by improper considerations, but are made with an eye toward the best interests of the plan as a whole. Moreover, heightened judicial review of discretionary determinations would frustrate ERISA’s purpose of achieving uniformity and predictability in the oversight of benefit plans, and would increase the litigation costs by encouraging every individual whose claim is denied to seek a second opinion in court.