‘MetLife V. Glenn’: The Court Addresses A Conflict Over Conflicts In ERISA Benefit Administration

In its June 2008 decision in MetLife v. Glenn, the Supreme Court held that federal courts reviewing claim denials by Employee Retirement Income Security Act (ERISA) employee benefit plan administrators should take into account the fact that plan administrators (insurers or self-insured plans) face a conflict of interest because they pay claims out of their own pockets and arguably stand to profit by denying claims. This paper analyzes the history of the conflict in the courts over this issue; the Supreme Court's resolution of it in MetLife; and the implications of this decision for plans, beneficiaries, and health policy.