MetLife v. Glenn: U.S. Supreme Court Says Insurance Company’s Conflict of Interest One Factor in Wrong Denial of Disability Benefits

It’s no secret that insurance companies sometimes put their own interests above that of their customers. Even if you make all your premium payments on time and promptly fill out your forms, you might still struggle to obtain payments from your insurer. And while the practice of denying claims and benefits is nothing new, the methods are.

MetLife v. Glenn evaluates one of the new methods, specifically voiding a policy after a claim is filed and instead advising the insured to pursue benefits from other sources. Wanda Glenn sought judicial review after MetLife cancelled her disability benefits.

For two years Glenn had received disability benefits after being diagnosed with a heart condition and deemed unable to perform her job. During that time MetLife encouraged Glenn to apply for Social Security disability benefits. This required a review of her condition by an outside agency under stringent criteria. However, this agency found that Glenn not only was unable to perform her own job, but was unable to do any type of work- she was granted Social Security disability. Shortly thereafter her MetLife benefits came up for review. As a result of this review MetLife determined that Glenn was still unable to perform her old job, but was now capable of performing other jobs. Based on this determination MetLife cancelled her disability benefits.

The Supreme Court considered several factors when evaluating MetLife’s denial of benefits, including its conflict of interest. This conflict of interest was based on the fact that MetLife was authorized to determine whether a claimant was eligible for benefits and was also responsible for paying those benefits.

In its review of Glenn, the Supreme Court was careful not to give too much credit to the conflict of interest. Rather than pointing to it as the sole reason that MetLife’s review must have been faulty, the court considered the conflict of interest as one of many factors to consider.

In its decision the U.S. Supreme Court cited that the insurer has an obligation to act solely in the interest of those insured. In doing so, they are obligated to fully review any denial in a fair manner.

Upon reviewing the facts that MetLife relied on to deny Glenn’s benefits the court found inconsistencies in their methods. Particularly, MetLife failed to provide their experts reviewing Glenn’s claim with a complete set of records from her treating physicians. Additionally, MetLife focused on a report by one of Glenn’s doctors stating that she could return to work, but discounted a detailed and more thorough report by a different treating physician stating that she could not. These actions support the claim that MetLife was acting in their own interest and not that of their insured.

Also, MetLife had urged Glenn to apply for Social Security disability right before denying her claim. Yet MetLife failed to take into account the Social Security Administration’s conclusion that Glenn could not work in other jobs when considering their own review even though MetLife’s review is set to mimic that of the SSA. In short, MetLife’s denial did not flush with the facts before them and again demonstrates that MetLife acted not in Glenn’s best interest, but their own. The Supreme Court affirmed the lower court’s ruling setting aside MetLife’s discretionary decision.

In a perfect world our insurance company would always have our best interests at heart. Sadly this is not the case. But through the legal system we can seek a fair and unbiased resolution.

Kreisman Law Offices has been fighting for our client’s rights for over 30 years in Cook County and its surrounding areas, including Bridgeview, Franklin Park, Norwood Park, and Chicago.

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