After six years of litigation, Wanda Glenn now knows for certain that her ex-employer Sears Roebuck should not have turned down her application for long-term disability benefits.
At least that much is clear from the Supreme Court's eagerly anticipated June 19 ruling in MetLife v. Glenn. The top court affirmed a 6th Circuit decision that set aside the denial of Glenn's benefit claim by MetLife, Sears' insurer and plan administrator. MetLife had deemed Glenn to be capable of sedentary work despite her severe heart condition.
The majority held that a structural conflict like MetLife's is but one of a number of factors judges should take into account when deciding whether a plan administrator abused its discretion.
According to Breyer, such a conflict is likely to be more important where circumstances suggest a higher likelihood that the conflict affected the benefits decision. "It should prove less important (perhaps to the vanishing point) where the administrator has taken active steps to reduce potential bias and to promote accuracy," he elaborated.