Supreme Court hears oral argument in Long Term Disability case
The U.S. Supreme Court heard oral argument in the case of Heimeshoff v. Hartford Life Ins. The issue is when a limitations period should begin to run in an ERISA LTD case – should it start to run when the claim is finally denied or when proof of loss is required?
Facts of the Case
Julie Heimeshoff worked for Wal-Mart as Senior Public Relations Manager from April 1986 through June 2005. In January 2005, she began suffering from pain from fibromyalgia as well as Irritable Bowel Syndrome and lupus. By June, her condition was so severe that she had to leave work. In August 2005, Heimsehoff filed a claim with Hartford Life & Accident Insurance Co. (Hartford) for Long Term Disability benefits. Heimsehoff’s doctor failed to provide an analysis of her condition to Harford, so Hartford denied her claim in December 2005. In May 2006, Heimsehoff obtained counsel to assist her in obtaining benefits. After several evaluations by other doctors, Hartford denied Heimsehoff’s claim again in November 2006, finding that she could perform the duties of her former position. Heimsehoff appealed the decision, but Hartford denied her claim for a final time in November 2007.
Heimsehoff sued in district court, alleging that Hartford violated the Employment Retirement Income Security Act (ERISA) in denying her claim. The district court dismissed the suit as time barred because the plan unambiguously prohibited legal action more than three years after proof of loss is required. Heimsehoff argued that the three-year statute of limitations should instead run from the date when Hartford denied her claim for the final time. The U.S. Court of Appeals for the Second Circuit affirmed.
When should the statute of limitations period for judicial review of an ERISA disability benefit decision begin?