Metlife Court And 'Totality Of The Circumstances'

Law360 (July 9, 2008, 12:00 AM EDT) -- In an important case for employers sponsoring ERISA-covered plans, such as a disability plan, where an insurer also acts as an administrator adjudicating claims, the U.S. Supreme Court ("Court") announced its 6-3 decision in Metropolitan Life Insurance Co. v. Glenn, U.S. No. 06-923, on June 19, 2008.

The Court held that benefit determinations ("Determinations") by such insurers continue to be subject to review using the deferential standard established in Firestone Tire & Rubber Co. v. Bruch, 49 U.S. 101, 115 (1989), but hold that the conflict...
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