Forum
U.S. Supreme Court
Case Status
Decided
Docket Number
06–923
Term
2007 Term
Oral Argument Date
April 23, 2008
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)?
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?
Case Updates
Supreme Court holds conflict of interest for ERISA plan administrators who both evaluate and pay claims
June 19, 2008
Disagreeing with NCLC, the Supreme Court held that a plan administrator that both evaluates and pays claims operates under a conflict of interest that is subject to a heightened judicial review of ERISA benefits decisions.
U.S. Chamber files amicus brief on the merits
March 03, 2008
NCLC urged the Supreme Court to reverse a Sixth Circuit decision that ERISA benefits decisions made by a plan administrator that both evaluates and pays claims operates under a conflict of interest that is subject to a searching judicial review. Glenn sued MetLife, who both funded and paid the benefits plan, for making a determination that she was not eligible for long-term disability payments under the ERISA plan. In its brief, NCLC argued that market pressures and regulatory constraints on plan administrators operate to ensure that fiduciary claim determinations are not driven by improper considerations, but are made with an eye toward the best interests of the plan as a whole. Moreover, heightened judicial review of discretionary determinations would frustrate ERISA’s purpose of achieving uniformity and predictability in the oversight of benefit plans, and would increase the litigation costs by encouraging every individual whose claim is denied to seek a second opinion in court.