American Journal of Law & Medicine

Federal courts struggle with Supreme Court refusal to promulgate a bright-line rule for evaluating ERISA plan administrators' conflicts of interest.

Federal Courts Struggle with Supreme Court Refusal to Promulgate a Bright-Line Rule for Evaluating ERISA Plan Administrators' Conflicts of Interest--Metropolitan Life Insurance Company v. Glenn. (1)--The Employee Retirement Income Security Act of 1974 ("ERISA") regulates employer-provided pension and welfare benefit plans to ensure that participants receive their promised benefits. (2) Under an ERISA-governed employee benefit plan, a single entity may act in a "dual role" as both an insurer and the payer of benefit claims. (3) ERISA requires administrators to "provide a full and fair review of claim denials." (4) In the event of a benefit denial, beneficiaries may seek judicial review after exhausting their administrative remedies. (5) Where ERISA "grant[s] the administrator or fiduciary discretionary authority to determine eligibility for benefits," courts must review denials deferentially. (6)

In Metropolitan Life Insurance Company v. Glenn, after being diagnosed with a heart condition, Respondent Wanda Glenn ("Glenn") applied for disability benefits from Metropolitan Life Insurance Company ("MetLife"). (7) MetLife served as both the administrator and insurer of Glenn's insurance plan under ERISA. (8) In 2000, MetLife determined that Glenn qualified for 24 months of disability and in 2002 an Administrative Law Judge determined that she could not "perform[] anyjob[] for which she could qualify existing in significant numbers in the national economy." (9) Accordingly, the Social Security Administration ("SSA") awarded Glenn permanent disability payments. (10) MetLife, however, denied Glenn's claim for continued benefits under a similar standard requiring Glenn's condition prevent her from both performing her own job and "the material duties of any gainful occupation for which she was reasonably qualified[,]" finding her "capable of performing full time sedentary work. …

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