The Supreme Court Considers Conflicts of Interest in Benefit Claims Procedures

Where an insurance company both determines an appeal for ERISA benefits and also pays that claim, a conflict of interest is present. The U.S. Supreme Court in Metropolitan Life v. Glenn, holds that where the language of a plan grants the administrator discretionary review of claims, this conflict will be taken into account as a "factor" to be weighed in determining whether judicial deference should be given to the administrator's decision.