COURT RULES FAIR TREATMENT OVERCOMES CONFLICT OF INTEREST

In one of the first cases involving conflict of interest since the Supreme Court’s ruling last year, the Court of Appeals for the Fourth Circuit ruled that defendants did not abuse their discretion when they terminated disability benefits. Under the Supreme Court’s recent decision in Metropolitan Life Insurance Co. v. Glenn, 128 S. Ct. 2343 (2008), courts must consider a conflict only as a factor in determining whether a plan’s determination was reasonable.