OPINION OF THE COURT
METROPOLITAN LIFE INS. CO. V. GLENN
554 U. S. ____ (2008)
SUPREME COURT OF THE UNITED STATES
NO. 06-923
METROPOLITAN LIFE INSURANCE COMPANY, et al.,
PETITIONERS
v. WANDA GLENN
on writ of certiorari to the united states court of
appeals for the sixth circuit
[June 19, 2008]
Justice Breyer delivered the
opinion of the Court.
The Employee Retirement Income
Security Act of 1974 (ERISA) permits a person denied benefits under
an employee benefit plan to challenge that denial in federal court.
88 Stat. 829, as amended, 29 U. S. C. §1001
et seq.;
see §1132(a)(1)(B). Often the entity that administers the plan,
such as an employer or an insurance company, both determines
whether an employee is eligible for benefits and pays benefits out
of its own pocket. We here decide that this dual role creates a
conflict of interest; that a reviewing court should consider that
conflict as a factor in determining whether the plan administrator
has abused its discretion in denying benefits; and that the
significance of the factor will depend upon the circumstances of
the particular case. See
Firestone Tire & Rubber Co.
v.
Bruch,
489 U. S. 101, 115 (1989).
I
Petitioner Metropolitan Life
Insurance Company (MetLife) serves as both an administrator and the
insurer of Sears, Roebuck & Company’s long-term disability
insurance plan, an ERISA-governed employee benefit plan. See App.
182a–183a; 29 U. S. C. §1003. The plan grants MetLife (as
administrator) discretionary authority to determine whether an
employee’s claim for benefits is valid; it simultaneously provides
that MetLife (as insurer) will itself pay valid benefit claims.
App. 181a–182a.
Respondent Wanda Glenn, a Sears
employee, was diagnosed with severe dilated cardiomyopathy, a heart
condition whose symptoms include fatigue and shortness of breath.
She applied for plan disability benefits in June 2000, and MetLife
concluded that she met the plan’s standard for an initial 24 months
of benefits, namely, that she could not “perform the material
duties of [her] own job.”
Id., at 159a–160a. MetLife also
directed Glenn to a law firm that would assist her in applying for
federal Social Security disability benefits (some of which MetLife
itself would be entitled to receive as an offset to the more
generous plan benefits). In April 2002, an Administrative Law Judge
found that Glenn’s illness prevented her not only from performing
her own job but also “from performing any jobs [for which she could
qualify] existing in significant numbers in the national economy.”
App. to Pet. for Cert. 49a; see also 20 CFR §404.1520(g) (2007).
The Social Security Administration consequently granted Glenn
permanent disability payments retroactive to April 2000. Glenn
herself kept none of the backdated benefits: three-quarters went to
MetLife, and the rest (plus some additional money) went to the
lawyers.
To continue receiving Sears plan disability
benefits after 24 months, Glenn had to meet a stricter,
Social-Security-type standard, namely, that her medical condition
rendered her incapable of performing not only her own job but of
performing “the material duties of any gainful occupation for
which” she was “reasonably qualified.” App. 160a. MetLife denied
Glenn this extended benefit because it found that she was “capable
of performing full time sedentary work.”
Id., at 31a.
After exhausting her administrative remedies,
Glenn brought this federal lawsuit, seeking judicial review of
MetLife’s denial of benefits. See 29 U. S. C. §1132(a)(1)(B);
461 F. 3d 660, 665 (CA6 2006). The District Court denied
relief. Glenn appealed to the Court of Appeals for the Sixth
Circuit. Because the plan granted MetLife “discretionary authority
to … determine benefits,” the Court of Appeals reviewed the
administrative record under a deferential standard.
Id.,
at 666. In doing so, it treated “as a relevant factor” a “conflict
of interest” arising out of the fact that MetLife was “authorized
both to decide whether an employee is eligible for benefits and to
pay those benefits.”
Ibid.
The Court of Appeals ultimately set aside
MetLife’s denial of benefits in light of a combination of several
circumstances: (1) the conflict of interest; (2) MetLife’s failure
to reconcile its own conclusion that Glenn could work in other jobs
with the Social Security Administration’s conclusion that she could
not; (3) MetLife’s focus upon one treating physician report
suggesting that Glenn could work in other jobs at the expense of
other, more detailed treating physician reports indicating that she
could not; (4) MetLife’s failure to provide all of the treating
physician reports to its own hired experts; and (5) MetLife’s
failure to take account of evidence indicating that stress
aggravated Glenn’s condition. See
id., at 674.
MetLife sought certiorari, asking us to
determine whether a plan administrator that both evaluates and pays
claims operates under a conflict of interest in making
discretionary benefit determinations. The Solicitor General
suggested that we also consider “ ‘how’ ” any such
conflict should “ ‘be taken into account on judicial review of
a discretionary benefit determination.’ ” Brief for United
States as
Amicus Curiae on Pet. for Cert. 22. We agreed to
consider both questions. See 552 U. S. __ (2008).
II
In
Firestone Tire &
Rubber Co. v.
Bruch,
489 U. S. 101, this Court
addressed “the appropriate standard of judicial review of benefit
determinations by fiduciaries or plan administrators under”
§1132(a)(1)(B), the ERISA provision at issue here.
Id., at
105; see also
id., at 108.
Firestone set forth
four principles of review relevant here.
(1) In “determining the
appropriate standard of review,” a court should be “guided by
principles of trust law”; in doing so, it should analogize a plan
administrator to the trustee of a common-law trust; and it should
consider a benefit determination to be a fiduciary act
(
i.e., an act in which the administrator owes a special
duty of loyalty to the plan beneficiaries).
Id., at
111–113. See also
Aetna Health Inc. v.
Davila,
542 U. S. 200,
218 (2004);
Central States, Southeast & Southwest Areas
Pension Fund v.
Central Transport, Inc.,
472 U. S. 559, 570
(1985).
(2) Principles of trust law require courts to
review a denial of plan benefits “under a
de novo
standard” unless the plan provides to the contrary.
Firestone, 489 U. S., at 115; see also
id., at
112 (citing,
inter alia, 3 A. Scott & W. Fratcher, Law
of Trusts §201, p. 221 (4th ed. 1988); G. Bogert & G. Bogert,
Law of Trusts and Trustees §559, pp. 162–168 (2d rev. ed. 1980)
(hereinafter Bogert); 1 Restatement (Second) of Trusts §201,
Comment
b (1957) (hereinafter Restatement)).
(3) Where the plan provides to the contrary by
granting “the administrator or fiduciary
discretionary
authority to determine eligibility for benefits,”
Firestone, 489 U. S., at 115 (emphasis added), “[t]rust
principles make a
deferential standard of review
appropriate,”
id., at 111 (citing Restatement §187
(abuse-of-discretion standard); Bogert §560, at 193–208; emphasis
added).
(4) If “a benefit plan gives discretion to an
administrator or fiduciary who
is operating under a conflict of
interest, that conflict must be
weighed as a ‘factor
in determining whether there is an abuse of discretion.’ ”
Firestone,
supra, at 115 (quoting Restatement
§187, Comment
d; emphasis added; alteration omitted).
The questions before us, while implicating the
first three principles, directly focus upon the application and the
meaning of the fourth.
III
The first question asks whether
the fact that a plan administrator both evaluates claims for
benefits and pays benefits claims creates the kind of “conflict of
interest” to which
Firestone’s fourth principle refers. In
our view, it does.
That answer is clear where it is
the employer that both funds the plan and evaluates the claims. In
such a circumstance, “every dollar provided in benefits is a dollar
spent by … the employer; and every dollar saved … is a dollar in
[the employer’s] pocket.”
Bruch v.
Firestone Tire
& Rubber Co., 828 F. 2d 134, 144 (CA3 1987). The
employer’s fiduciary interest may counsel in favor of granting a
borderline claim while its immediate financial interest counsels to
the contrary. Thus, the employer has an “interest … conflicting
with that of the beneficiaries,” the type of conflict that judges
must take into account when they review the discretionary acts of a
trustee of a common-law trust. Restatement §187, Comment
d; see also
Firestone,
supra, at 115
(citing that Restatement comment); cf. Black’s Law Dictionary 319
(8th ed. 2004) (“conflict of interest” is a “real or seeming
incompatibility between one’s private interests and one’s public or
fiduciary duties”).
Indeed,
Firestone itself involved an
employer who administered an ERISA benefit plan and who both
evaluated claims and paid for benefits. See 489 U. S.
, at
105. And thus that circumstance quite possibly was what the Court
had in mind when it mentioned conflicted administrators. See
id., at 115. The
Firestone parties, while
disagreeing about other matters, agreed that the dual role created
a conflict of interest of some kind in the employer. See Brief for
Petitioners 6–7, 27–29, Brief for Respondents 9, 26, and Brief for
United States as
Amicus Curiae 22, in
Firestone Tire
& Rubber Co. v.
Bruch, O. T. 1988, No.
87–1054.
MetLife points out that an employer who
creates a plan that it will both fund and administer foresees, and
implicitly approves, the resulting conflict. But that fact cannot
change our conclusion. At trust law, the fact that a settlor (the
person establishing the trust) approves a trustee’s conflict does
not change the legal need for a judge later to take account of that
conflict in reviewing the trustee’s discretionary decisionmaking.
See Restatement §107, Comment
f (discretionary acts of
trustee with settlor-approved conflict subject to “careful
scrutiny”);
id., §107, Comment
f, Illustration 1
(conflict is “a factor to be considered by the court in determining
later whether” there has been an “abuse of discretion”);
id., §187, Comment
d (same); 3 A. Scott, W.
Fratcher, & M. Ascher, Scott and Ascher on Trusts §18.2, pp.
1342–1343 (5th ed. 2007) (hereinafter Scott) (same). See also,
e.g., Bogert §543, at 264 (rev. 2d ed. 1993) (settlor
approval simply permits conflicted individual to act as a trustee);
id., §543(U), at 422–431 (same); Scott §17.2.11, at
1136–1139 (same).
MetLife also points out that we need not
follow trust law principles where trust law is “inconsistent with
the language of the statute, its structure, or its purposes.”
Hughes Aircraft Co. v.
Jacobson,
525 U. S. 432, 447
(1999) (internal quotation marks omitted). MetLife adds that to
find a conflict here is inconsistent (1) with ERISA’s efforts to
avoid complex review proceedings, see
Varity Corp. v.
Howe,
516
U. S. 489, 497 (1996); (2) with Congress’ efforts not to deter
employers from setting up benefit plans, see
ibid., and
(3) with an ERISA provision specifically allowing employers to
administer their own plans, see 29 U. S. C. §1108(c)(3).
But we cannot find in these considerations any
significant inconsistency. As to the first, we note that trust law
functions well with a similar standard. As to the second, we have
no reason, empirical or otherwise, to believe that our decision
will seriously discourage the creation of benefit plans. As to the
third, we have just explained why approval of a conflicted trustee
differs from review of that trustee’s conflicted decisionmaking. As
to all three taken together, we believe them outweighed by
“Congress’ desire to offer employees enhanced protection for their
benefits.”
Varity,
supra, at 497 (discussing
“competing congressional purposes” in enacting ERISA).
The answer to the conflict question is less
clear where (as here) the plan administrator is not the employer
itself but rather a professional insurance company. Such a company,
MetLife would argue, likely has a much greater incentive than a
self-insuring employer to provide accurate claims processing. That
is because the insurance company typically charges a fee that
attempts to account for the cost of claims payouts, with the result
that paying an individual claim does not come to the same extent
from the company’s own pocket. It is also because the marketplace
(and regulators) may well punish an insurance company when its
products, or ingredients of its products, fall below par. And
claims processing, an ingredient of the insurance company’s
product, falls below par when it seeks a biased result, rather than
an accurate one. Why, MetLife might ask, should one consider an
insurance company
inherently more conflicted than any
other market participant, say, a manufacturer who might earn more
money in the short run by producing a product with poor quality
steel or a lawyer with an incentive to work more slowly than
necessary, thereby accumulating more billable hours?
Conceding these differences, we nonetheless
continue to believe that for ERISA purposes a conflict exists. For
one thing, the employer’s own conflict may extend to its selection
of an insurance company to administer its plan. An employer
choosing an administrator in effect buys insurance for others and
consequently (when compared to the marketplace customer who buys
for himself) may be more interested in an insurance company with
low rates than in one with accurate claims processing. Cf.
Langbein, Trust Law as Regulatory Law, 101 Nw. U. L. Rev.
1315, 1323–1324 (2007) (observing that employees are rarely
involved in plan negotiations).
For another, ERISA imposes
higher-than-marketplace quality standards on insurers. It sets
forth a special standard of care upon a plan administrator, namely,
that the administrator “discharge [its] duties” in respect to
discretionary claims processing “solely in the interests of the
participants and beneficiaries” of the plan, §1104(a)(1); it
simultaneously underscores the particular importance of accurate
claims processing by insisting that administrators “provide a ‘full
and fair review’ of claim denials,”
Firestone, 489 U. S.,
at 113 (quoting §1133(2)); and it supplements marketplace and
regulatory controls with judicial review of individual claim
denials, see §1132(a)(1)(B).
Finally, a legal rule that treats insurance
company administrators and employers alike in respect to the
existence of a conflict can nonetheless take account of
the circumstances to which MetLife points so far as it treats
those, or similar, circumstances as diminishing the
significance or
severity of the conflict in
individual cases. See Part IV,
infra.
IV
We turn to the question of “how”
the conflict we have just identified should “be taken into account
on judicial review of a discretionary benefit determination.” 552
U. S. __ (2008). In doing so, we elucidate what this Court set
forth in
Firestone, namely, that a conflict should “be
weighed as a ‘factor in determining whether there is an abuse of
discretion.’ ” 489 U. S., at 115 (quoting Restatement §187,
Comment
d; alteration omitted).
We do not believe that
Firestone’s statement implies a change in the
standard of review, say, from deferential to
de
novo review. Trust law continues to apply a deferential
standard of review to the discretionary decisionmaking of a
conflicted trustee, while at the same time requiring the reviewing
judge to take account of the conflict when determining whether the
trustee, substantively or procedurally, has abused his discretion.
See Restatement §187, Comments
d–
j; id., §107,
Comment
f; Scott §18.2, at 1342–1344. We see no reason to
forsake
Firestone’s reliance upon trust law in this
respect. See 489 U. S., at 111–115.
Nor would we overturn
Firestone by
adopting a rule that in practice could bring about near universal
review by judges
de novo—i.e., without
deference
—of the lion’s share of ERISA plan claims
denials. See Brief for America’s Health Insurance Plans et al.
as
Amici Curiae 3–4 (many ERISA plans grant discretionary
authority to administrators that combine evaluation and payment
functions). Had Congress intended such a system of review, we
believe it would not have left to the courts the development of
review standards but would have said more on the subject. See
Firestone,
supra, at 109 (“ERISA does not set out
the appropriate standard of review for actions under
§1132(a)(1)(B)”); compare,
e.g., C. Gresenz et al., A
Flood of Litigation? 8 (1999), http://www.rand.org/pubs/
issue_papers/2006/IP184.pdf (all Internet materials as visited June
9, 2008, and available in Clerk of Court’s case file) (estimating
that 1.9 million beneficiaries of ERISA plans have health care
claims denied each year), with Caseload of Federal Courts Remains
Steady Overall (Mar. 11, 2008),
http://www.uscourts.gov/Press_Releases/2008/ caseload.cfm (257,507
total civil filings in federal court in 2007); cf.
Whitman
v.
American Trucking Assns., Inc.,
531 U. S. 457, 468
(2001) (Congress does not “hide elephants in mouseholes”).
Neither do we believe it necessary or
desirable for courts to create special burden-of-proof rules, or
other special procedural or evidentiary rules, focused narrowly
upon the evaluator/payor conflict. In principle, as we have said,
conflicts are but one factor among many that a reviewing judge must
take into account. Benefits decisions arise in too many contexts,
concern too many circumstances, and can relate in too many
different ways to conflicts—which themselves vary in kind and in
degree of seriousness—for us to come up with a one-size-fits-all
procedural system that is likely to promote fair and accurate
review. Indeed, special procedural rules would create further
complexity, adding time and expense to a process that may already
be too costly for many of those who seek redress.
We believe that
Firestone means what
the word “factor” implies, namely, that when judges review the
lawfulness of benefit denials, they will often take account of
several different considerations of which a conflict of interest is
one. This kind of review is no stranger to the judicial system. Not
only trust law, but also administrative law, can ask judges to
determine lawfulness by taking account of several different, often
case-specific, factors, reaching a result by weighing all together.
See Restatement §187, Comment
d; cf.,
e.g.,
Citizens to Preserve Overton Park, Inc. v.
Volpe,
401 U. S. 402,
415–417 (1971) (review of governmental decision for abuse of
discretion);
Universal Camera Corp. v.
NLRB,
340 U. S. 474
(1951) (review of agency factfinding).
In such instances, any one factor will act as
a tiebreaker when the other factors are closely balanced, the
degree of closeness necessary depending upon the tiebreaking
factor’s inherent or case-specific importance. The conflict of
interest at issue here, for example, should prove more important
(perhaps of great importance) where circumstances suggest a higher
likelihood that it affected the benefits decision, including, but
not limited to, cases where an insurance company administrator has
a history of biased claims administration. See Langbein,
supra, at 1317–1321 (detailing such a history for one
large insurer). 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, for example, by
walling off claims administrators from those interested in firm
finances, or by imposing management checks that penalize inaccurate
decisionmaking irrespective of whom the inaccuracy benefits. See
Herzel & Colling, The Chinese Wall and Conflict of Interest in
Banks, 34 Bus. Law 73, 114 (1978) (recommending interdepartmental
information walls to reduce bank conflicts); Brief for Blue Cross
and Blue Shield Association as
Amicus Curiae 15
(suggesting that insurers have incentives to reward claims
processors for their accuracy); cf. generally J. Mashaw,
Bureaucratic Justice (1983) (discussing internal controls as a
sound method of producing administrative accuracy).
The Court of Appeals’ opinion in the present
case illustrates the combination-of-factors method of review. The
record says little about MetLife’s efforts to assure accurate
claims assessment. The Court of Appeals gave the conflict weight to
some degree; its opinion suggests that, in context, the court would
not have found the conflict alone determinative. See 461
F. 3d, at 666, 674. The court instead focused more heavily on
other factors. In particular, the court found questionable the fact
that MetLife had encouraged Glenn to argue to the Social Security
Administration that she could do no work, received the bulk of the
benefits of her success in doing so (the remainder going to the
lawyers it recommended), and then ignored the agency’s finding in
concluding that Glenn could in fact do sedentary work. See
id., at 666–669. This course of events was not only an
important factor in its own right (because it suggested procedural
unreasonableness), but also would have justified the court in
giving more weight to the conflict (because MetLife’s seemingly
inconsistent positions were both financially advantageous). And the
court furthermore observed that MetLife had emphasized a certain
medical report that favored a denial of benefits, had deemphasized
certain other reports that suggested a contrary conclusion, and had
failed to provide its independent vocational and medical experts
with all of the relevant evidence. See
id., at 669–674.
All these serious concerns, taken together with some degree of
conflicting interests on MetLife’s part, led the court to set aside
MetLife’s discretionary decision. See
id., at 674–675. We
can find nothing improper in the way in which the court conducted
its review.
Finally, we note that our elucidation of
Firestone’s standard does not consist of a detailed set of
instructions. In this respect, we find pertinent this Court’s
comments made in a somewhat different context, the context of court
review of agency factfinding. See
Universal Camera Corp.,
supra. In explaining how a reviewing court should take
account of the agency’s reversal of its own examiner’s factual
findings, this Court did not lay down a detailed set of
instructions. It simply held that the reviewing judge should take
account of that circumstance as a factor in determining the
ultimate adequacy of the record’s support for the agency’s own
factual conclusion.
Id., at 492–497. In so holding, the
Court noted that it had not enunciated a precise standard. See,
e.g.,
id., at 493. But it warned against creating
formulas that will “falsif[y] the actual process of judging” or
serve as “instrument[s] of futile casuistry.”
Id., at 489.
The Court added that there “are no talismanic words that can avoid
the process of judgment.”
Ibid. It concluded then, as we
do now, that the “[w]ant of certainty” in judicial standards
“partly reflects the intractability of any formula to furnish
definiteness of content for all the impalpable factors involved in
judicial review.”
Id., at 477.
We affirm the decision of the Court of
Appeals.
It is so ordered.
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