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12-729 HEIMESHOFF V. HARTFORD LIFE INSURANCE DECISION BELOW: 496 Fed. Appx. 129 LIMITED TO QUESTION 1 PRESENTED BY THE PETITION. CERT. GRANTED 4/15/2013 QUESTION PRESENTED: 1. When should a statute of limitations accrue for judicial review of an ERISA disability adverse benefit determination? 2. What notice regarding time limits for judicial review of an adverse benefit determination should an ERISA plan or its fiduciary give the claimant with a disability claim? 3. When an ERISA plan or its fiduciary fails to give proper notice of the time limits for filing a judicial action to review denial of disability benefits, what is the remedy? LOWER COURT CASE NUMBER: 12-651
The U.S. Supreme Court case Heimeshoff v. Hartford Life & Accident Insurance Co., 2013, revolved around the issue of when a statute of limitations should begin for filing a lawsuit under the Employee Retirement Income Security Act (ERISA). Julie Heimeshoff, an employee at Walmart, filed a claim against Hartford Life & Accident Insurance Co., after they denied her long-term disability benefits. The insurance policy stated that any legal action must be taken within three years from when proof of loss was due; however, this period had expired while she was still in administrative proceedings with the company to appeal their decision. When she eventually took them to court over it, her suit was dismissed as untimely by both district and appellate courts because it fell outside this limitation period. In response to these rulings being upheld by lower courts, Heimeshoff appealed to the Supreme Court arguing that ERISA's statute of limitations should not start until all internal appeals have been exhausted or denied - which is typically how such matters are handled in other areas of law. However, in December 2013, the Supreme Court ruled unanimously against her stating that an ERISA plan can set its own limitation period as long as it’s reasonable and there’s no controlling federal statute preventing it.
In the case of Heimeshoff v. Hartford Life & Accident Ins. Co., there was no dissenting opinion recorded by any justice in the Supreme Court's 9-0 unanimous decision, which upheld that a contractual limitations period for challenging a denial of ERISA plan benefits is enforceable as long as it is reasonable and there exists no controlling statute to the contrary.