Legal Alert: Supreme Court's Anticlimactic Decision in Glenn does not Streamline ERISA Litigation

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Yesterday, the U.S. Supreme Court issued its decision in Metropolitan Life Ins. Co. v. Glenn (June 19, 2008), which many had hoped would provide more clarity with regard to a court?s role in reviewing a plan administrator?s decision denying benefits, where the plan administrator also pays benefits under the plan. However, the Court?s decision in Glenn merely ?elucidates? the standards announced by the Court in Firestone Tire & Rubber Co. v Bruch, 489 U.S. 101 (1989), which held that a conflict of interest is a factor to be considered in determining whether to affirm a plan administrator?s benefits determination. The Court did clarify that an entity administering an employee benefit plan, which both determines whether an employee is eligible for benefits and pays those benefits out of its own pocket, operates under an inherent conflict of interest, a question that was not specifically addressed by the Court?s earlier decision in Bruch.

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