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Heimeshoff v. Hartford Life & Accident Insurance Co.

Issues: 

Does the statute of limitations for judicial review of an adverse determination on a disability benefits claim begin to accrue at the time specified by an insurance policy or when the claimant files an ERISA disability claim?

Julie Heimeshoff was a longtime Wal-Mart employee who became ill and applied for long-term disability benefits from the Hartford Life & Accident Insurance Company (“Hartford”). Hartford denied her claim and Heimeshoff sued under ERISA to challenge the insurance determination. The district court granted Hartford’s motion to dismiss because Heimeshoff had missed the filing deadline, and the Second Circuit affirmed. The Supreme Court will now consider when the statute of limitations starts to accrue for judicial review of an adverse determination on a disability benefits claim. Heimeshoff argues that a bright-line rule is necessary under federal law so that potential plaintiffs will be able to understand the filing deadline. Hartford contends that the statute of limitations on an ERISA disability claim should be determined by an insurance plan’s accrual provision unless the provision is unreasonable. The Supreme Court’s decision will impact the administration of long-term disability plans. A bright-line rule would lead to more compressed time periods in which claimants would be required to seek judicial review, while a reasonableness rule would lead to possible inefficiencies and inconsistencies in administration. The Court’s decision will impact insurance companies’ control over the statute of limitations on review of ERISA disability claims and the period during which disabled employees can seek relief through the courts.

Questions as Framed for the Court by the Parties: 

When should a statute of limitations accrue for judicial review of an ERISA disability adverse benefit determination?

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