The oral argument calendar for April has been released by the U.S. Supreme Court, and MetLife v. Glenn is scheduled for April 23rd, 2008. It is one of two cases scheduled for that day – the other case is Meacham v. Knolls Atomic Power Laboratory about the burden of persuasion under the ADEA. (Hat tip to SCOTUSblog)
MetLife v. Glenn is a case from the 6th Circuit Court of Appeals about conflicts of interest for ERISA administrators. In an opinion on April 26, 2006, the 6th Circuit reversed the judgment of the district court that MetLife’s decision finding Glenn no longer totally disabled was not arbitrary and capricious, and then remanded the case to the district court for further proceedings.
Glenn was a Sears employee and a participant in their long-term disability plan when she was diagnosed with severe dilated cardiomyopathy and applied for disability benefits. The Sears disability plan covered two stages of total disability. For the first 24 month period of disability, the plan provided that the participant was totally disabled when she was completely and continuously unable to perform each of the material duties of her regular job. After the first 24 months of benefits, the plan required that the participant was completely and continously unable to perform the duties of any gainful work or service for which she was reasonably qualified taking into consideration her training, education, expereience, and past earnings. Glenn’s claim was approved and she began receiving benefits.
Two months later, MetLife, the plan administrator, steered Glenn to a law firm who represented her in obtaining Social Security benefits. MetLife then demanded reimbursement from Glenn for the overpayment of benefits due to the retroactive nature of her Social Security benefits. MetLife ultimately denied her continued long-term disability benefits under the second phase of the plan after obtaining statements from her doctor and having their doctor review her medical records. Glenn exhausted her administrative remedies under the plan, and then filed a civil action against MetLife. The district court granted MetLife’s motion for judgment on the administrative record, and Glenn appealed that decision to the Sixth Circuit.
The 6th Circuit reversed the district court’s decision, and remanded the case with directions to reinstate Glenn’s long-term disability benefits retroactive to the date on which they were terminated, and for such other relief as the district court finds appropriate. The 6th Circuit concluded:
- For the reasons set out above, we conclude that MetLife’s decision to deny long-term benefits in this case was not the product of a principled and deliberative reasoning process. MetLife acted under a conflict of interest and also in unacknowledged conflict with the determination of disability by the Social Security Administration. In denying benefits, it offered no explanation for crediting a brief form filled out by Dr. Patel while overlooking his detailed reports. This inappropriately selective consideration of Glenn’s medical record was compounded by the fact that the occupational skills analyst and the independent medical consultant were apparently not provided with full information from Dr. Patel on which to base their conclusions. Moreover, there was no adequate basis for the plan administrator’s decision not to factor in one of the major considerations in Glenn’s pathology, that of the role that stress played in aggravating her condition and, in the language of the MetLife policy, in preventing her return to “gainful work or service for which [she is] reasonably qualified taking into consideration [her] training, education, experience, and past earning.” Taken together, these factors reflect a decision by MetLife that can only be described as arbitrary and capricious.
MetLife filed a petition for cert. with the U.S. Supreme Court, which was granted. The Questions Presented in the amicus brief by the U.S. Solicitor General’s office are stated as:
- 1. Whether an administrator that both evaluates and pays claims under a plan governed by the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., is operating under a conflict of interest that must be weighed on judicial review of a benefit determination.
2. Whether an ERISA plan administrator must consider in its written benefit determination a decision of a Social Security Administration administrative law judge granting disability benefits.
- ScotusBlog has copies of MetLife’s Petition for Cert., Glenn’s Brief in Opposition, MetLife’s Reply Brief, and the Invitation brief of the United States posted here.
- Stephen D. Rosenberg of the Boston ERISA & Insurance Litigation Blog discusses this case in Supreme Court to Weigh In on Structural Conflicts of Interest.
- Roy F. Harmon III of the Health Plan Law blog discusses the case in U.S. Supreme Court Grants Certiori in ERISA Standard of Review Case.
- Paul M. Secunda of the Workplace Prof Blog discusses this case in Supreme Court Can’t Get Enough of ERISA.
[tags]Pension Protection Act, ppa, MetLife, Supreme Court, 6th Circuit, conflict of interest, ERISA[/tags]