Heimeshoff v. Hartford Life & Accident Insurance Co. and Wal-Mart Stores, Inc.

Participants in an employee benefit plan covered by ERISA may contract to a specific limitation period so long as the period is reasonable and no contrary controlling statute exists.

Petitioner filed suit against Respondent under the Employee Retirement Income Security Act (ERISA) alleging Respondent failed to provide long-term disability benefits, which she was entitled to under the employee benefit plan. The lower court and the Second Circuit held that Respondent's limitation provision set out in the policy was enforceable. The Supreme Court granted certiorari to decide whether an ERISA disability benefit claim may begin to run before the claimant can bring a legal action.

The Supreme Court affirmed and held that the statute of limitations begins to run when the cause of action “‘accrues’”— that is, when “the plaintiff can file suit and obtain relief." Bay Area Laundry and Dry Cleaning Pension Trust Fund v. Ferbar Corp. of Cal., 522 U. S. 192, 201 (1997). Accrual under ERISA starts when the plan issues a final denial. Additionally, adherence must be given to a plan's contractual terms so long as the limiting provisions are not unreasonable and there is not a controlling statute to the contrary. Respondent's plan contained a reasonable limitation period which was not contrary to any controlling statute and thus is valid.