Article: Client Alert: Supreme Court Comes Down With "Combination-Of-Factors" Method Of Review.

Supreme Court Addresses Review Of Conflicted ERISA Claims Administrator's Decision

In Metropolitan Life Ins. Co. v. Glenn, __U.S.__(2008), 2008 U.S. LEXIS 5053 (June 19, 2008), the Supreme Court addressed two important and closely-related related issues involving the situation in which a plan administrator who also funds plan benefits decides claims appeals under an ERISA plan. The case involved a plan administrator - Metropolitan Life, which insured benefits under Sears Roebuck's long-term disability insurance plan - that was vested with discretionary authority to decide such appeals. The first issue is whether this dual role creates a conflict of interest. This ...

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