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Metropolitan Life Insurance Co. v. Glenn

554 U.S. 105, 128 S. Ct. 2343, 171 L. Ed. 2d 299 (2008)

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Metropolitan Life Insurance Co. v. Glenn

United States Supreme Court

554 U.S. 105, 128 S. Ct. 2343, 171 L. Ed. 2d 299 (2008)

Facts

Wanda Glenn (plaintiff) worked for Sears, Roebuck & Company (Sears). Metropolitan Life Insurance Company (MetLife) (defendant) was both the administrator and insurer of Sears’s long-term disability-insurance plan. As the plan administrator, MetLife was vested with discretionary authority to determine whether employees’ claims for benefits were valid. Glenn applied for benefits under the plan after developing a heart condition. MetLife found that Glenn satisfied the plan’s standard for an initial 24 months of benefits because she was unable to perform the material duties of her job. MetLife also referred Glenn to a law firm to assist her with applying for Social Security disability benefits because she was unable to work. The Social Security Administration (SSA) awarded Glenn benefits after determining that her medical condition rendered her incapable of performing not only her own job but any job for which she could qualify that existed in significant numbers in the national economy. The award of federal benefits entitled MetLife to an offset against the plan’s more generous benefits. To continue receiving the additional benefits available under the Sears plan after the initial 24-month term, Glenn had to meet a slightly stricter standard and demonstrate that her condition prevented her from performing her own job and the material duties of any gainful occupation for which she was reasonably qualified. MetLife denied the extended benefits after determining that Glenn could perform full-time sedentary work. Glenn sought judicial review of MetLife’s benefit denial under the Employee Retirement Income Security Act (ERISA). The district court denied relief, and the court of appeals reversed. MetLife petitioned for certiorari.

Rule of Law

Issue

Holding and Reasoning (Breyer, J.)

Concurrence (Roberts, C.J.)

Dissent (Scalia, J.)

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