Resolving a split among the Courts of Appeal, the United States Supreme Court affirmed the Second Circuit in finding enforceable a limitations provision in a long term disability ERISA plan that set forth the length of the limitations period as well as when the period commenced. The plan at issue required participants to file suit for benefit claims within three years after “proof of loss” is due. Heimeshoff v. Hartford Life & Accident Insurance Co., 2013 WL 6569594 (S. Ct. Dec. 16, 2013).
Defendant Hartford Life & Accident Co., the administrator of Wal-Mart’s Long Term Disability Plan, issued a final denial of plaintiff Julie Heimeshoff’s claim for long term disability benefits in 2007. Less than three years later, but more than three years after proof of loss was due, plaintiff filed suit, challenging the denial of her benefits pursuant to ERISA § 502(a)(1)(B). She did so despite the plan’s limitation provision, which stated that “Legal action cannot be taken against The Hartford . . . [more than] 3 years after the time written proof of loss is required to be furnished according to the terms of the policy.”
The District Court granted defendant’s motion to dismiss, holding that plaintiff’s action was barred by the plan’s limitation provision, which the Second Circuit upheld. Affirming, the Supreme Court held that a plan limitation period is enforceable so long as it is not unreasonable or barred by statute. In so holding, the Court disagreed with plaintiff’s contention that the limitations provision would “undermine ERISA’s two-tiered remedial scheme,” finding that the provision does not disrupt ERISA’s internal review process or diminish the availability of judicial review.