The Supreme Court will decide whether a benefit plan administrator that both
determines and pays benefits operates under a conflict of interest that must be
considered by courts reviewing benefits cases.
The high court heard arguments Wednesday, April 23, in a case that raises the
question about plans governed by the Employee Retirement Income Security Act.
The case—Metropolitan Life Insurance Co. et al vs. Wanda Glenn—involves a former
Sears, Roebuck & Co. employee who suffers from a severe heart condition.
Glenn received benefits for “total disability” from MetLife, which
administers and insures the Sears-sponsored plan. After Glenn’s condition began
to improve, MetLife rescinded the benefits, holding that Glenn could perform
low-stress work.
Glenn sued, and a U.S. district court ruled for MetLife. Glenn appealed, and
a three-judge panel of the U.S. 6th Circuit Court of Appeals ruled on September
1, 2006, that MetLife’s dual role in both determining and paying benefits
represented a conflict of interest, and that its decision to stop the benefits
was “arbitrary and capricious.” MetLife appealed to the Supreme Court.
The federal government weighed in on Glenn’s side in a brief filed with the
high court before Wednesday’s arguments.
“An ERISA plan administrator that both makes benefits determinations and pays
benefits out of its own funds, such as MetLife, is operating under a conflict of
interest, because it benefits financially if it denies an employee’s claim,”
wrote the U.S. solicitor general in the brief. “A court reviewing a benefit
determination by a dual-role administrator should consider the administrator’s
conflict of interest, even in the absence of evidence indicating that the
administrator was motivated by its financial self-interest.”
Filed by Mark A. Hofmann of Business Insurance, a sister publication of
Workforce Management. To comment, e-mail editors@workforce.com.