Metropolitan Life Ins. Co. v. Glenn

Glenn, a former employee of Sears, sued the Metropolitan Life Insurance Company (MetLife), the plan administrator for Sears, under ERISA. Despite a determination by the Social Security Administration that Glenn was totally disabled due to a severe heart condition, MetLife terminated Glenn's long-term disability benefits on the ground that her condition had improved to the point that she was no longer totally disabled. The district court upheld MetLife’s determination, finding that the decision was not arbitrary and capricious.

The Sixth Circuit Court of Appeals reversed, concluding that MetLife's denial of Glenn’s claim was not the result of a deliberative process nor based on substantial evidence. While reviewing the denial, the Sixth Circuit took into account the existence of a conflict of interest that results when MetLife both decides whether an employee is eligible for benefits and is also obligated to pay those benefits, and also factored in MetLife's failure to give consideration to the Social Security Administration’s determination that Glenn was totally disabled.

Question 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)?

2. Whether the Sixth Circuit erred in holding, in conflict with six other Circuits, that an ERISA claim administrator must consider and refute in its written disability determination a decision, without the underlying record, of a Social Security Administration administrative law judge?

Decision under Review

Supreme Court Opinion