[JURIST] The US Supreme Court [official website; JURIST news archive] handed down five decisions Thursday, including MetLife v. Glenn [Duke Law backgrounder; JURIST report], in which the Court ruled 6-3 that an employee benefit plan administrator has an illegal conflict of interest under the Employee Retirement Income Security Act [text; US DOL backgrounder] if he has both the authority to pay benefits and to determine employees' eligibility for benefits. The Court found:
In such instances, any one factor will act as a tiebreaker when the other factors are closely balanced, the degree of closeness necessary depending upon the tiebreaking factor's inherent or case-specific importance. The conflict of interest at issue here, for example, should prove more important (perhaps of great importance) where circumstances suggest a higher likelihood that it affected the benefits decision, including, but not limited to, cases where an insurance company administrator has a history of biased claims administration.The decision upholds a US Court of Appeals for the Sixth Circuit ruling [PDF text]. Read the Court's opinion per Justice Breyer, a dissent filed by Justice Scalia, a concurrence by Chief Justice Roberts, and a dissent and concurrence in part [texts] by Justice Kennedy. AP has more.
The Court also ruled 5-4 in Kentucky Retirement Systems v. EEOC [Duke Law backgrounder; JURIST report], finding that the use of age as a factor in a retirement plan is not facially discriminatory and does not violate the Age Discrimination in Employment Act (ADEA) [text]. The Equal Employment Opportunity Commission [official website] brought suit against a number of Kentucky state agencies who administer the state retirement program because it distinguishes among recipients based on age. The Court found that the process was not discriminatory:
The Plan's "assumptions" that no disabled worker would have continued to work beyond the point at which he was both disabled and pension eligible do not involve age-related stereotypes, but apply equally to all workers regardless of age.The decision reverses a ruling [PDF text] by the US Court of Appeals for the Sixth Circuit. Read the Court's opinion per Justice Breyer, and a dissent [texts] filed by Justice Kennedy. AP has more.
In Indiana v. Edwards [Duke Law backgrounder; JURIST report], the Court ruled 7-2 that states may adopt a higher standard for measuring competency to represent oneself at trial than for measuring competency to stand trial. The Court found:
[T]he Constitution permits judges to take realistic account of the particular defendants mental capacities by asking whether a defendant who seeks to conduct his own defense at trial is mentally competent to do so.The ruling reverses and remands an Indiana Supreme Court decision [opinion, PDF] that a court which found a schizophrenic defendant competent to stand trial could not subsequently deny that defendant the right to represent himself under the Sixth Amendment [text]. Read the Court's opinion per Justice Breyer and a dissent [texts] filed by Justice Scalia. AP has more.
In Meacham v. Knolls Atomic Power Laboratory [Duke Law backgrounder; JURIST report], the Court ruled 8-1 that an employer has the burden of proof in an age discrimination case where a worker says he was fired for no valid reason. The Court found that Congress had intended that the ADEA require employers to show that workers were dismissed for reasonable factors other than age and explained that "we have to read it the way Congress wrote it." The ruling reverses and remands a US Court of Appeals for the Second Circuit holding [PDF text] that the burden of proof rests on the worker. Read the Court's opinion per Justice Souter, a concurrence filed by Justice Scalia, and a concurrence and dissent in part [texts] filed by Justice Thomas. Justice Breyer did not take part in the judgment. AP has more.
In Chamber of Commerce v. Brown [Duke Law backgrounder; JURIST report], the Court ruled 7-2 that a 2000 California law [Assembly Bill 1889 text] that prohibits employers from using certain funds they receive from the state to influence union elections is unconstitutional. In 2006, the US Court of Appeals for the Ninth Circuit upheld [PDF text] the California law, ruling that it was neither preempted by the National Labor Relations Act [text] nor rendered unenforceable by the US Constitution's Supremacy Clause. The Court reversed and remanded that decision Thursday, holding that the law "imposes a targeted negative restriction on employer speech about unionization." Read the Court's opinion per Justice Stevens and a dissent [texts] filed by Justice Breyer. AP has more.