On June 19, 2008 the Supreme Court decided MetLife v. Glenn, a case asking whether an ERISA plan administrator that both evaluates and pays employee benefit claims operates under a conflict of interest and, if so, how such a conflict ought be weighed on judicial review of benefit determinations. The Court held that this dual role creates a conflict of interest; that a reviewing court should consider that conflict as a factor in determining whether the plan administrator has abused its discretion in denying benefits; and that the significance of the factor will depend upon the circumstances of the particular case. Samuel Bray, an Associate in Law at Columbia Law School, discusses the case.
Oral Argument - April 23, 2008:
http://www.supremecourtus.gov/oral_arguments/argument_transcripts/06-923.pdf
Decision - June 19, 2008:
http://www.supremecourtus.gov/opinions/07pdf/06-923.pdf
