Background
MetLife administered and insured an employer’s disability plan. It steered the claimant toward Social Security disability benefits, took most of the retroactive award as an offset, and then found she could do sedentary work, ignoring the agency’s contrary finding. The appeals court set aside the denial.
What the Court held
Building on Firestone v. Bruch, the Court held that the dual role of deciding claims and paying them from its own pocket creates a conflict of interest, whether the decision-maker is the employer or an insurance company. Courts still apply deferential review, but they weigh the conflict along with everything else. It may act as a tiebreaker. It counts for more where circumstances suggest it affected the decision, such as a history of biased claims administration, and less where the insurer has walled off claims staff from finance or otherwise promoted accuracy. The Court affirmed the decision against MetLife, noting its inconsistent positions and its selective use of medical reports.
Why it matters for life insurance claims
Glenn was a disability case, but the same review rules apply to group life and AD&D claims under ERISA plans, where the insurer usually both decides and pays. Evidence of one-sided record review, ignored evidence, or incomplete files given to reviewers can matter a great deal.
Read the opinion
Metropolitan Life Ins. Co. v. Glenn, 554 U.S. 105 (2008) (Justia).
Not legal advice. This page summarizes general rules and the specific statutes cited. Your policy's wording, the state whose law applies, and whether the coverage came through an employer can all change the result. See the disclaimer and editorial policy.