Heimeshoff v. Hartford Life & Accident Ins. Co.

Background

A Wal-Mart employee who developed lupus and fibromyalgia filed a long-term disability claim with her employer's insurer in 2005. Hartford, the plan administrator, denied benefits after medical reviews and issued a final denial in November 2007. The plan required any lawsuit to be filed within three years after proof of loss was due. The employee sued in November 2010, and the lower courts held the suit time-barred because the three-year period had already expired. The Supreme Court took the case to resolve a split among federal appeals courts.

Reasoning

The Court addressed whether a plan can enforce a contractual deadline that starts before a claimant can complete required internal appeals. Because ERISA does not specify its own limitations period, the Justices concluded that parties may agree to a reasonable contractual deadline, even if it begins before the legal right to sue fully accrues. The Court emphasized enforcing written plan terms, found the three-year period reasonable in light of regulatory timelines for internal review, and affirmed dismissal of the late suit.

Real world impact

The decision allows many employer disability and insurance plans to enforce similar three-year proof-of-loss deadlines, which may bar some late lawsuits after prolonged administrative review. The opinion notes that internal review is typically structured to finish in about a year and that traditional protections—waiver, estoppel, and equitable tolling—remain available if administrators act unfairly. Plans that offer voluntary extra appeals must toll contractual deadlines during those extra procedures.