• CIVIL

SPRINT COMMUNICATIONS CO., L. P., et al. v. APCC SERVICES, INC., et al.

Party with legal title alone to bring suit

An assignee of a legal claim for money owed has standing to pursue that claim in federal court, even when the assignee has promised to remit the proceeds of the litigation to the assignor.

• SERVICE

KENTUCKY RETIREMENT SYSTEMS et al. v. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

Age Discrimination in Employment Act of 1967 (ADEA)- 29 U. S. C. §623(a)(1)

The ADEA forbids an employer to "discriminate against any individual with respect to his compensation, terms, conditions, or privileges of employment, because of such individual's age." 29 U. S. C. §623(a)(1). Where an employer adopts a pension plan that includes age as a factor, and that employer then treats employees differently based on pension status, a plaintiff, to state a claim under the ADEA, must adduce sufficient evidence to show that the differential treatment was "actually motivated" by age, not pension status.

METROPOLITAN LIFE INSURANCE CO. et al. v. GLENN

Employee Retirement Income Security Act of 1974 (ERISA)

The plan gives MetLife (as administrator) discretionary authority to determine the validity of an employee's benefits claim and provides that MetLife (as insurer) will pay the claims. A plan administrator's dual role of both evaluating and paying benefits claims creates conflict of interest. It is not necessary or desirable for courts to create special burden-of-proof rules, or other special procedural or evidentiary rules, focused narrowly upon the evaluator/payor conflict. Both trust law and administrative law ask judges to determine lawfulness by taking account of several different, often case-specific, factors, reaching a result by weighing all together. Any one factor will act as a tiebreaker when the others are closely balanced.