The Supreme Court Requires Deference to Plan Administrator’s Interpretation of ERISA Plan Notwithstanding Administrator’s Prior Invalid Interpretation
In Conkright v. Frommert, No. 08-810, issued on March 21, the United States Supreme Court addressed the proper standard of review that applies to a plan administrator’s interpretation of a plan covered by the Employee Retirement Income Security Act. The Court held 5-3 that the district court should have deferred to the plan administrator’s interpretation of the plan at issue notwithstanding the fact that a prior related interpretation by the administrator was found to be invalid. In its decision, authored by Chief Justice Roberts, the Court rejected a “one-strike-and-you’re out” approach under which administrators would only be entitled to deference in connection with their initial interpretations of ERISA plans.