Excerpt: The United States Supreme Court recently decided Metropolitan Life Insurance Co. v. Glenn ('MetLife'), giving critical guidance to ERISA fiduciaries who consider and decide benefit claims. The Court held that a conflict of interest inherently exists when a fiduciary both makes benefit eligibility decisions under a plan and funds those benefits (referred to by the Court as the 'evaluator/payor conflict'); that courts should consider this conflict as a factor when determining whether the fiduciary abused its discretion in denying benefits; and that the significance of the factor will depend upon the circumstances of the particular case.  MORE >>