Supreme Court to Hear ERISA Statute of Limitations Case Concerning Benefit Claim

The U.S. Supreme Court is scheduled to hear oral arguments today on a case concerning when should a statute of limitations accrue for judicial review of an adverse benefit determination under ERISA (Heimeshoff v. Hartford Life & Accident Insurance Co.). The Court granted certiorari on April 15. The case will resolve a conflict between the appeals courts.

The U.S. Court of Appeals for the Second Circuit in September 2012 affirmed a long-term disability plan's denial of a participant's claim for benefits on the grounds that the participant's lawsuit was barred by the plan's contractual three-year limitations period, which began on the date the participant first filed a claim. The Second Circuit upheld the plan's starting date for the contractual limitations period to begin accruing before the participant was eligible to bring a legal action challenging her claim denial. The plan argues that accrual from the “proof of loss” date comported with ERISA and complied with state insurance regulations. The plaintiff argues that under ERISA the right to sue cannot occur until after administrative procedures of the plan have been exhausted because “accrual” represents the date on which a claim can be filed in court and no benefit claim under ERISA may be filed in court until exhaustion of plan procedures is complete.

The Supreme Court declined to hear two additional questions presented by the petition concerning the extent to which an ERISA fiduciary must notify a claimant of the deadline for filing suit or the proper remedy for a fiduciary's failure to provide adequate notice of this deadline.

The 2nd Circuit Court of Appeals' summary order is available here.
Additional information on SCOTUSblog is available here.