Supreme Court upholds ERISA Plan’s contractual limitations period – three years after “proof of loss”

It's reasonable, and there's no contrary statute. A unanimous opinion in Heimeshoff v. Hartford Life & Accident Insurance Co (US Supreme Court 12/16/2013).

Wal-Mart's Group Long Term Disability Plan (Plan)  requires any suit to recover benefits to be filed within three years after “proof of loss” is due.

Employee Heimeshoff filed a claim for long-term disability benefits and exhausted the mandatory administrative review process, and the Plan issued its final denial. Almost three years after that final denial but more than three years after proof of loss was due, Heimeshoff filed a claim for judicial review. The District Court denied the claim as untimely, and the 2nd Circuit affirmed.

The US Supreme Court held - unanimously - thatthe Plan’s limitations provision is enforceable.

Although aplan participant’s cause of action under ERISA §502(a)(1)(B) does not accrue until the plan issues a final denial, an agreement to commence the limitations period before that time is enforceable so long as the limitations period is of reasonable length and there is no controlling statute to the contrary.

In this case the Plan’s administrative review processrequired more time than usual but still left Heimeshoff with approximately one year to file suit.

[For a list of current employment law cases, see Supreme Court Watch.]