Heimeshoff v. Hartford Life & Accident Ins. Co.
The Supreme Court unanimously ruled that a disability insurance plan can enforce a contract clause requiring lawsuits to be filed within three years of when proof of loss was due, even though that deadline starts running before the plan's own internal appeals process is finished.
Because such deadlines are common in disability and health plans nationwide, the ruling confirms that workers challenging denied benefits must watch the clock closely during the administrative appeals process, not just after it ends.
How it got here: A federal trial court dismissed Heimeshoff's suit as untimely; the Second Circuit affirmed; the Supreme Court took the case to resolve a circuit split.
The Case in Depth
What happened
Julie Heimeshoff, a Wal-Mart public relations manager, stopped working due to lupus and fibromyalgia and filed for long-term disability benefits with Hartford, the plan administrator. After a lengthy internal review including a denial, extension request, and final denial in November 2007, she filed a lawsuit in November 2010. Hartford argued her suit came too late under the plan's three-year filing deadline, which ran from when her proof of loss was originally due, not from the final denial.
The question before the Court
Can a disability insurance plan require workers to file lawsuits within three years of when their paperwork was due, even if that clock starts running before the plan finishes reviewing their claim?
The Court's answer
Yes — the Court unanimously held that the plan's three-year filing deadline is enforceable even though it starts running before a worker can even complete the plan's required internal appeals process. Contractual filing deadlines are generally valid as long as they give a reasonable amount of time to sue and no federal statute overrides them.
Here, federal regulations expect most internal reviews to wrap up within about a year, so this deadline typically leaves roughly two years to sue afterward — and even in Heimeshoff's unusually long review, she still had about a year. Nothing in the federal law governing these plans (ERISA) required a different result, so the deadline stands and her lawsuit, filed after the three years expired, was too late.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
Millions of workers covered by employer disability plans governed by federal law will need to track filing deadlines that start ticking before their internal appeal is even resolved. Employers and insurers can keep using this common three-year clause without rewriting plan documents, but employees who delay during the appeals process risk losing their right to sue entirely.
What changes now
This is a final merits ruling, not a remand for further factfinding. Heimeshoff's suit remains barred as untimely, and the three-year contractual filing deadline used by Hartford's plan — and many similar disability and insurance plans nationwide — remains enforceable as written. Workers with similar disputes must still track filing deadlines during, not just after, their plan's internal appeals process.
What this does not decide
The Court did not decide whether Heimeshoff or any other participant could use defenses like waiver, estoppel, or equitable tolling to excuse a late filing in a specific case, and it left open whether ERISA's statute of limitations for breach-of-fiduciary-duty claims applies differently here.
How the Court got there
The legal reasoning, step by step
- The Court applied the rule from a 1947 case (Order of United Commercial Travelers v. Wolfe) that a contractual deadline for filing suit is enforceable as long as it is reasonably long and no controlling statute forbids it, even if that deadline runs from a date before the lawsuit could actually be filed.
- Because this framework already lets parties agree on how long a deadline lasts, the Court reasoned it must also let them agree on when that deadline starts running, since a time limit only makes sense once you know its starting point.
- The Court then asked whether the plan's three-year deadline, which effectively left about one year to sue after internal review, was unreasonably short. It found that federal regulations expect most internal reviews to take about a year, so this deadline gave workers a normal amount of time in typical cases.
- The Court rejected the argument that a federal law governing employee benefit plans (ERISA) itself blocked this deadline, finding nothing in the statute's text or regulations that overrides such contractual filing periods.
- The Court concluded that enforcing the plan's own written deadline was consistent with ERISA's emphasis on enforcing plans exactly as written, and that existing legal tools like waiver, estoppel, and equitable pauses on deadlines already protect workers who are unfairly blocked from suing on time.
Doctrinal impact
Cases affected by this decision
Reaffirms Order of United Commercial Travelers of America v. Wolfe (331 U. S. 586)
The Court relies on Wolfe's framework as the correct standard for enforcing contractual filing deadlines.
Distinguishes Occidental Life Ins. Co. of Cal. v. EEOC (432 U. S. 355)
The Court says this case does not apply because there is no evidence of similar backlogs blocking timely lawsuits here.
Distinguishes Hardin v. Straub (490 U. S. 536)
The Court says this case doesn't apply because the deadline here comes from a contract, not a borrowed state statute.