Standard of review-effect of conflict on standard of review. Metropolitan Life Insurance Co. v. Glenn, _S. Ct._, 2008 WL 2444796 (6/19/08).

An ERISA plan administrator, whether it is an insurance company or a self-insured employer, has a conflict of interest if it both decides who receives benefits and makes benefits payments. That conflict of interest is one factor that should be taken into account in determining whether the administrator has abused its discretion in a case.