Heimeshoff v. Hartford Life Insurance Co.

Whether judicial review of the statute of limitations in an Employee Retirement Income Security Act (ERISA) disability benefit claim may begin to run before the claimant can bring a legal action.

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 granted Respondent's motion to dismiss the claim because Petitioner's action was time-barred by the three-year statute of limitations period set out in the benefit plan policy. Petitioner appealed.

The United States Court of Appeals for the Second Circuit held that a statute of limitations specified by an ERISA plan may begin to run before a claimant can bring a legal action. The court found that the contractual three-year limitations period governing Petitioner's ERISA claim began to run when her proof of loss was due under the benefit plan, and that her claim was thus time-barred from judicial review. The Supreme Court granted certiorari to determine whether judicial review of the statute of limitations in an ERISA disability benefit claim may begin to run before the claimant can bring a legal action.