Metropolitan Life Ins. Co. v. Glenn (2007)
- Docket
- 06-923
- Decided
- 2007-01-01
Summary
Question: Does an insurance carrier, acting both as the entity determining when awards are to be paid and actually funding those awards, have the right to represent to a court that an individual is disabled when the insurance carrier separately determines for other purposes that the individual is in fact not disabled? Conclusion: Maybe. The Court, in a 7-2 opinion, relied on its prior ruling in Firestone Tire & Rubber Co. v. Bruch to hold that a possible conflict of interest such as MetLife's should be taken into account in determining the legality of a claim denial. The significance and severity of the conflict must be determined by the facts of each individual case. Here, the Court found that the evidence was sufficient to prove that a strong conflict of interest existed. Based on the principle of deference to lower court decisions, the Court affirmed the Sixth Circuit. Justice Stephen Breyer delivered the opinion of the Court. Chief Justice John G. Roberts concurred in part and dissented in part, framing his dissent around his view that conflicts should be taken into account only where there is evidence that the benefits denial was motivated or affected by the administrator's conflict. Justice Anthony Kennedy also concurred in part and dissented in part, suggesting that the case should be remanded to the Sixth Circuit where it could apply the majority opinion to the facts of the case on its own. Justice Antonin Scalia, joined by Justice Clarence Thomas, dissented, finding the mere fact that an entity both determines claims and funds those claims insufficient to prove a conflict of interest.