May 22, 2019
The decision in MetLife v. Glenn came out this morning! You can find it here courtesy of the fine folks at Scotusblog.
The decision completely rejects the "just trust the insurer" approach favored by MetLife and its amici. Rather, the Court makes clear that the need for insurers to compete in the marketplace and look after their own bottom lines is inherently at odds with their obligation as ERISA fiduciaries to act solely in the interest of ERISA plan participants and beneficiaries and for the exclusive purpose of providing them benefits. However the Court also rejects the idea that every insurer-funded ERISA plan requires a de novo standard of review.
Having placed itself squarely in the middle of the spectrum of how to deal with conflicted fiduciaries, the Court identifies some factors and ideas lower courts are instructed to keep in mind as they find their way through the standard of review maze on a case by case basis. But Chief Justice Roberts may summarize the decision best in his concurrence when he says, "[i]n a triumph of understatement, the Court acknowledges that its approach 'does not consist of a detailed set of instructions."
I'll have more thoughts on Glenn in the next day or two.
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