Question: Petitioner Metropolitan Life Insurance Company (MetLife) is an administrator and the insurer of Sears, Roebuck & Company's long-term 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 twenty-four 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. In challenging Met Life's decision, Glenn contends that the court should consider Met Life's conflict of interest as both the administrator and the payor under the plan. Do you agree? If so, how much weight should the judge give this factor in assigning burdens of proof? See Metropolitan Life Insurance Company v. Glenn, 128 S.Ct. 2343 (2008).