On June 19, 2008, the Supreme Court issued an opinion in Metropolitan Life Insurance Co. v. Glenn, holding that where an insurance company both determines an appeal for ERISA benefits and pays that claim, a conflict of interest as described in Firestone v. Bruch is presented. Where the language of a plan grants the administrator discretionary review of claims, this conflict must be taken into account as a "factor to be weighed in determining whether judicial deference should still be accorded to the administrator's decision.


Facts of the Case
Wanda Glenn was a participant in the Sears long-term disability plan that was insured and administered by MetLife. The plan's disability standard required the participant to be unable, due to the disability, to engage in any gainful occupation or employment - a standard similar to the "Social Security disability standard. Glenn suffered from a heart condition, and at MetLife's suggestion, applied for and obtained a ruling from the Social Security Administration that she was completely disabled. Later, MetLife concluded that she could engage in sedentary occupations, and the company denied her claim.  The district court upheld MetLife's denial of the claim, but the Sixth Circuit Court of Appeals reversed. The Supreme Court granted certiorari to determine whether the fact that MetLife both insured the plan and determined the claim was a conflict of interest as described in Firestone, and if so, what effect it would have in reducing the level of deference to be granted to MetLife's decision to deny benefits.




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