Hobson v. Metropolitan Life Ins. Co.
(2nd Cir., July 29, 2009)
The Second Circuit rejected plaintiff’s argument that a de novo review was warranted given the administrator’s structural conflict of interest. In the wake of MetLife v. Glenn, the court acknowledge that a conflict is created by an administrator’s ability to both determine eligibility and pay benefits, but found there was no evidence suggesting the administrator’s decision was influenced by the conflict and, therefore, afforded it no weight.
Under …
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