Metropolitan Life Insurance v. Glenn

Background

Respondent was a Sears employee with a serious heart condition who received initial plan disability benefits. MetLife served as both the plan administrator and the insurer. MetLife helped her apply for Social Security disability; an Administrative Law Judge and the Social Security Administration found her disabled and awarded retroactive benefits, most of which were offset to MetLife. After 24 months the plan required a stricter disability showing to continue benefits; MetLife reviewed the claim, concluded she could do full-time sedentary work, and denied extended benefits. Glenn sued under the federal employee-benefits law to challenge that denial.

Reasoning

The Court held that when the same company both evaluates and pays claims, that dual role creates a conflict of interest courts must treat as a factor when reviewing discretionary denials. The Court stressed that this factor does not automatically replace deferential review with full retrial; instead judges should weigh the conflict alongside other evidence. The Sixth Circuit had set aside MetLife’s denial after finding a combination of problems: MetLife encouraged the Social Security claim then disregarded the agency’s disability finding, emphasized one medical report while downplaying others, failed to give its experts all treating records, and did not fully account for stress-related harms. The Supreme Court affirmed that weighing those circumstances together justified reversal.

Real world impact

Lower courts must now consider insurer-administrator conflicts when reviewing benefit denials. That change can help claimants where procedural flaws, biased fact‑handling, or ignored evidence combine with a structural conflict. At the same time the Court preserved deferential review in many cases and signaled insurers may avoid extra scrutiny by adopting safeguards to reduce bias.

Dissents or concurrances

Chief Justice Roberts would have required evidence that the conflict actually affected the decision; Justice Kennedy would remand to allow consideration of an administrator’s structural safeguards; Justice Scalia emphasized applying traditional trust-law motive rules.