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Metropolitan Life Insurance Company v. Glenn (06-923) 
ERISA:  Effect on judicial review when administrator both determines and pays claims under an ERISA plan  

MetLife, an ERISA plan administrator, terminated Glenn's disability benefits on the ground that she had improved to the point of no longer being totally disabled. Glenn sued to recover her benefits. The 6th Circuit noted that MetLife operated under an apparent conflict  of interests because MetLife both decides the claims and pays the claims. Although the trial court upheld MetLife's denial of the claim, the 6th Circuit reviewed the evidence and directed the trial court to reinstate Glenn's benefits. 

Case below:  Glenn v. MetLife (6th Cir 09/01/2006) 
Official docket sheet 
Certiorari granted January 18, 2008  
Oral argument: April 23, 2008.   [Transcript]  [The Solicitor General participates in oral argument as amicus curiae on behalf of Respondent.] 

Questions presented:  

1. Whether the Sixth Circuit erred in holding, in conflict with two other Circuits, that the fact that a claim administrator of an ERISA plan also funds the plan benefits, without more, constitutes a “conflict of interest” which must be weighed in a judicial review of the administrator’s benefit determination under Firestone Tire & Rubber v. Bruch, 489 U.S. 101 (1989)?

[The Supreme Court did not grant certiorari as to the petitioner's second question, and it is omitted.] 

[The Supreme Court added the following question:] 

2. If an administrator that both determines and pays claims under an ERISA plan is deemed to be operating under a conflict of interest, how should that conflict be taken into account on judicial review of a discretionary benefit determination?" 

Certiorari Documents: 

Briefs on the merits: 


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