The Connecticut Plaintiff, Heimeshoff, filed an ERISA lawsuit against Hartford challenging their denial of long-term disability benefits. Hartford filed a Motion to Dismiss as Heimeshoff filed her lawsuit past the 3-year statute of limitations which was clearly stated in her policy. The District Court granted Hartford’s Motion to Dismiss and Heimeshoff appealed.
The Second Circuit Court of Appeals cited to the following: ERISA does not contain a specific limitations period for challenging the denial of benefits. See Burke v. PriceWaterHouseCoopers LLP Long Term Disability Plan, 572 F.3d 76, 78 (2d Cir. 2009). Instead, the controlling limitations period is provided by the "most nearly analogous state limitations statute." See id.
Heimeshoff argued that the 3-year statute of limitations defined in Hartford’s policy did not begin to run until the final of denial of benefits. Connecticut’s general statutes contain a 6-year statute of limitations for contract actions, which applies in this case. However, under Connecticut law, parties to an insurance contract may shorten the statute of limitations period to not less than one year. Additionally, pursuant to Burke (572 F.3d at 81), a statute of limitations specified by an ERISA plan for bringing a claim under Section 1132, may begin to run before the claimant can file a lawsuit.
Hartford’s Plan stated that the 3-year statute of limitations period began from the time that proof of loss was due pursuant to the Plan. Because the policy language was unambiguous and it is permitted under the statute to have the limitation period begin before the claim accrues, the Circuit court found that Heimeshoff’s action was time-barred.
The Supreme Court will now review this matter solely as to the question, "When should a statute of limitations accrue for judicial review of an ERISA disability adverse benefit decision?"