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ERISA - Aftermath of Metlife v. Glenn for Standards of Review for Plan Administrators Who Both Evaluate and Pay Claims |
October 10, 2008
Previously published on September 29, 2008
On several occasions over the past year we have published updates about the Metlife v. Glenn case, in which the Supreme Court addressed so-called "structural" conflicts of interest and held that (1) an insurer who both administers and funds an Employee Retirement Income Security Act (ERISA) benefits plan operates under a conflict of interest; and (2) courts should consider that conflict of interest when reviewing a conflicted insurer's denial of benefits, but should give the conflict varying weight based on the circumstances of the case.
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The views expressed in this article are solely the views of the author and not Martindale-Hubbell. This article is intended for informational purposes only and is not legal advice or a substitute for consultation with a licensed legal professional in a particular case or circumstance. |
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