December 16, 2013 United States Supreme Court opinion

Heimeshoff v Hartford Life & Accident Insurance Co.

Heimeshoff field for disability benefits under an ERISA governed plan. Her claim was ultimately denied. She sued Hartford more than 3 years after her proof of loss was due but less than 3 years after her claim was denied. The district court dismissed on statute of limitations grounds and the 2nd Circuit affirmed. The Court, resolving a circuit split, also unanimously affirmed. It held that just as parties can contract for shorter limitation periods absent a controlling statute, parties can contract for a different starting date than accrual of action provided the limitation period is reasonable. The court noted this is particularly true in the ERISA context where the plan is the center of everything involved in the benefit program. The Court held the limitation period here, 3 years from the due date of the proof on loss, was reasonable as it is consistent with the vast majority of similar state limitations periods and allows one year for the administrative process and two years to bring suit which is longer than the minimum window for judicial review required under regulation. The Court rejected counterarguments noting that regulations require prompt resolution of ERISA claims, that there is no substantial evidence of diligent claimants losing their right to judicial review and allowing tolling as a matter of course would undermine the ERISAS framework of written plan documents.

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