FINDLAW: Daily Opinion Summaries for U.S. Supreme Court – 06/19/08


ADMINISTRATIVE LAW, ERISA, HEALTH LAW, INSURANCE LAW, LABOR & EMPLOYMENT LAW

Metro. Life Ins. Co. v. Glenn, No. 06-923
The Supreme Court rules that the dual role of ERISA plan administrators that both determine whether an employee is eligible for benefits, and pay benefits out of their own pockets, creates a conflict of interest. Thus, a reviewing court should consider such conflict as a factor in determining whether a plan administrator has abused its discretion in denying benefits, and the significance of the factor will depend upon the circumstances of the particular case.

 

CIVIL PROCEDURE, CIVIL RIGHTS, EVIDENCE, GOVERNMENT LAW, LABOR & EMPLOYMENT LAW

Meacham v. Knolls Atomic Power Lab., No. 06-1505
In the context of the Age Discrimination in Employment Act (ADEA), an employer facing a disparate-impact claim and planning to defend on the basis of “reasonable factors other than age” (RFOA) must not only produce evidence raising the defense, but also persuade the factfinder of its merit.

 

CIVIL PROCEDURE, COMMERCIAL LAW, GOVERNMENT LAW, LABOR & EMPLOYMENT LAW

Chamber of Commerce of the U.S. v. Brown, No. 06-939
Two provisions of a California statute known as “Assembly Bill 1889” (AB 1889), which, among other things, prohibits employers that receive state grants or more than $10,000 in state program funds per year from using the funds “to assist, promote, or deter union organizing”, are pre-empted by the National Labor Relations Act (NLRA).

 

CIVIL RIGHTS, GOVERNMENT BENEFITS, GOVERNMENT LAW, HEALTH LAW, LABOR & EMPLOYMENT LAW

Kentucky Retirement Sys. v. Equal Opportunity Employment Comm’n, No. 06-1037
In an Age Discrimination in Employment Act (ADEA) case, the Court rules that Kentucky’s retirement benefits system for policemen, firemen, and other “hazardous position” workers does not discriminate against workers who become disabled after becoming eligible for retirement based on age. This is so even though the system treats some disabled individuals more generously than it treats some of those who became disabled only after becoming eligible for retirement on the basis of age.

 

CONSTITUTIONAL LAW, CRIMINAL LAW & PROCEDURE, HEALTH LAW

Indiana v. Edwards, No. 07-208
In the context of the Sixth Amendment right for defendants to represent themselves, the Constitution permits states to insist upon representation by counsel for those competent enough to stand trial under applicable precedent but who suffer from severe mental illness to the point where they are not competent to conduct trial proceedings by themselves.