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U.S. Supreme Court Upholds Plan’s Internal Statute of Limitations


December 2013

The U.S. Supreme Court, in a unanimous 9-0 opinion in Heimeshoff v. Hartford Life & Accident Ins. Co., upheld an ERISA plan’s contractual three-year statute of limitations against a plan participant who filed a lawsuit to recover benefits more than three years after the participant provided proof of loss to the plan. The statute of limitations was included in the plan document and therefore applied by contract. The court held that a contractual limitations period in an ERISA plan is enforceable as long as the length of the limitations period is reasonable and there is no controlling statute to the contrary. The Heimeshoff decision is an important one for plan sponsors and plan drafters because it validates the long-standing and increasingly common practice of including in plan documents reasonable limitations periods for benefit claims.  

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