U.S. Supreme Court Holds that ERISA Plan Can Enforce Contractual Limitations Provision to Bar Benefit Claim Lawsuit

The U.S. Supreme Court in Heimeshoff v. Hartford Life & Accident Insurance Co. et al. resolved a split among the circuits when it held that a contractual limitations clause in an ERISA-governed long-term disability benefits plan is enforceable even where it causes the limitations period on a claim for benefits to commence before the participant's cause of action accrues.  In this case, the plan-based limitations period in which to file a disability claim lawsuit under ERISA Section 502(a)(1)(B) started to run when "proof of loss" was due under the plan, even though the participant's cause of action did not accrue, and a lawsuit could not be filed, until the plan's internal claim review process had been exhausted. Citing ERISA's important policy of enforcing plan terms as written, the Court held that the clause was enforceable. Continue reading this article here.

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