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"Special Procedureal or Evidentiary Rules" in Light of MetLife v. Glenn by Kenton J. Coppage
Smith Moore Leatherwood LLP - Atlanta Office
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March 19, 2009
Previously published by Life, Health and Disability News (DRI) on Fall 2008
In clarifying the effect of an ERISA
fiduciary's conflict of interest on the
level of judicial review accorded benefits
decisions, the Supreme Court in Metropolitan
Life v. Glenn, 128 S.Ct. 2343
(2008), wrote: "Neither do we believe it
necessary or desirable for courts to create
special burden of proof rules, or other
special procedural or evidentiary rules,
focused narrowly on the evaluator/payor
conflict."
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