Reply – Re: Benefits for disabled carpenters
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Re: Benefits for disabled carpenters
— by Ted Ted

NOTE: Where it is feasible, a syllabus (headnote) will be released, as is
being done in connection with this case, at the time the opinion is issued.
The syllabus constitutes no part of the opinion of the Court but has been
prepared by the Reporter of Decisions for the convenience of the reader.
See United States v. Detroit Timber & Lumber Co., 200 U. S. 321, 337.

No. 06–923. Argued April 23, 2008—Decided June 19, 2008

Petitioner Metropolitan Life Insurance Company (MetLife) is an administrator
and the insurer of Sears, Roebuck & Company’s longterm
disability insurance plan, which is governed by the Employee
Retirement Income Security Act of 1974 (ERISA). The plan gives
MetLife (as administrator) discretionary authority to determine the
validity of an employee’s benefits claim and provides that MetLife (as
insurer) will pay the claims. Respondent Wanda Glenn, a Sears employee,
was granted an initial 24 months of benefits under the plan
following a diagnosis of a heart disorder. MetLife encouraged her to
apply for, and she began receiving, Social Security disability benefits
based on an agency determination that she could do no work. But
when MetLife itself had to determine whether she could work, in order
to establish eligibility for extended plan benefits, it found her capable
of doing sedentary work and denied her the benefits. Glenn
sought federal-court review under ERISA, see 29 U. S. C.
§1132(a)(1)(B), but the District Court denied relief. In reversing, the
Sixth Circuit used a deferential standard of review and considered it
a conflict of interest that MetLife both determined an employee’s eligibility
for benefits and paid the benefits out of its own pocket. Based
on a combination of this conflict and other circumstances, it set aside
MetLife’s benefits denial.


1. Firestone Tire & Rubber Co. v. Bruch, 489 U. S. 101, sets out
four principles as to the appropriate standard of judicial review under
§1132(a)(1)(B): (1) A court should be “guided by principles of trust
law,” analogizing a plan administrator to a trustee and considering a
benefit determination a fiduciary act, id., at 111–113; (2) trust law

principles require de novo review unless a benefits plan provides otherwise,
id., at 115; (3) where the plan so provides, by granting “the
administrator or fiduciary discretionary authority to determine eligibility,”
“a deferential standard of review [is] appropriate,” id., at 111,
115; and (4) if the administrator or fiduciary having discretion “is operating
under a conflict of interest, that conflict must be weighed as a
‘facto[r] in determining whether there is an abuse of discretion,’ ” id.,
at 115. Pp. 3–5.

2. A plan administrator’s dual role of both evaluating and paying
benefits claims creates the kind of conflict of interest referred to in
 That conclusion is clear where it is the employer itself that
both funds the plan and evaluates the claim, but a conflict also exists
where, as here, the plan administrator is an insurance company. For
one thing, the employer’s own conflict may extend to its selection of
an insurance company to administer its plan. For another, ERISA
imposes higher-than-marketplace quality standards on insurers, requiring
a plan administrator to “discharge [its] duties” in respect to
discretionary claims processing “solely in the interests of the [plan’s]
participants and beneficiaries,” 29 U. S. C. §1104(a)(1); underscoring
the particular importance of accurate claims processing by insisting
that administrators “provide a ‘full and fair review’ of claim denials,”
Firestone, supra, at 113; and supplementing marketplace and regulatory
controls with judicial review of individual claim denials, see
 Finally, a legal rule that treats insurers and employers
alike in respect to the existence of a conflict can nonetheless take
account of different circumstances by treating the circumstances as
diminishing the conflict’s significance or severity in individual cases.
Pp. 5–8.

3. The significance of the conflict of interest factor will depend upon
the circumstances of the particular case. Firestone’s “weighed as a
‘factor’ ” language, 489 U. S., at 115, does not imply a change in the
standard of review, say, from deferential to de novo. Nor should this
Court overturn Firestone by adopting a rule that could bring about
near universal de novo review of most ERISA plan claims denials.
And it is not necessary or desirable for courts to create special burden-
of-proof rules, or other special procedural or evidentiary rules, focused
narrowly upon the evaluator/payor conflict. Firestone means
what the word “factor” implies, namely, that judges reviewing a benefit
denial’s lawfulness may take account of several different considerations,
conflict of interest being one. This kind of review is no
stranger to the judicial system. Both trust law and administrative
law ask judges to determine lawfulness by taking account of several
different, often case-specific, factors, reaching a result by weighing all
together. Any one factor will act as a tiebreaker when the others are

Cite as: 554 U. S. ____ (2008) 3

closely balanced. Here, the Sixth Circuit gave the conflict some
weight, but focused more heavily on other factors: that MetLife had
encouraged Glenn to argue to the Social Security Administration that
she could do no work, received the bulk of the benefits of her success
in doing so (being entitled to receive an offset from her retroactive
Social Security award), and then ignored the agency’s finding in concluding
that she could do sedentary work; and that MetLife had emphasized
one medical report favoring denial of benefits, had deemphasized
other reports suggesting a contrary conclusion, and had
failed to provide its independent vocational and medical experts with
all of the relevant evidence. These serious concerns, taken together
with some degree of conflicting interests on MetLife’s part, led the
court to set aside MetLife’s discretionary decision. There is nothing
improper in the way this review was conducted. Finally, the Firestone
standard’s elucidation does not consist of detailed instructions,
because there “are no talismanic words that can avoid the process of
judgment.” Universal Camera Corp. v. NLRB, 340 U. S. 474, 489.

Pp. 8–13.
461 F. 3d 660, affirmed.

BREYER, J., delivered the opinion of the Court, in which STEVENS,
SOUTER, GINSBURG, and ALITO, JJ., joined, and in which ROBERTS, C. J.,
joined as to all but Part IV. ROBERTS, C. J., filed an opinion concurring
in part and concurring in the judgment.
 KENNEDY, J., filed an opinion
concurring in part and dissenting in part. SCALIA, J., filed a dissenting
opinion, in which THOMAS, J., joined.