Heimeshoff v. Hartford Life & Accident INS. Co. (571 U.S. 99)

U.S. Supreme Court · decided December 16, 2013 · Supreme Court Database (Spaeth)

Citation
571 U.S. 99 · 134 S. Ct. 604
Decided
December 16, 2013
Term
October Term 2013
Vote
9–0
Majority author
Justice Thomas
Issue area
Economic Activity
Disposition
Affirmed
Outcome
Petitioning party lost
Ideological direction
Conservative

Opinion excerpt

Justice THOMAS delivered the opinion of the Court. A participant in an employee benefit plan covered by the Employee Retirement Income Security Act of 1974 (ERISA), 88 Stat. 829, as amended, 29 U.S.C. § 1001 et seq., may bring a civil action under § 502(a)(1)(B) to recover benefits due under the terms of the plan. 29 U.S.C. § 1132(a)(1)(B). Courts have generally required participants to exhaust the plan's administrative remedies before filing suit to recover benefits. ERISA does not, however, specify a statute of limitations for filing suit under § 502(a)(1)(B). Filling that gap, the plan at issue here requires participants to bring suit within three years after "proof of loss" is due. Because proof of loss is due before a plan's administrative process can be completed, the administrative exhaustion requirement will, in practice, shorten the contractual limitations period. The question presented is whether the contractual limitations provision is enforceable. We hold that it is. I In 2005, petitioner Julie Heimeshoff began to report chronic pain and fatigue that interfered with her duties as a senior public relations manager for Wal-Mart Stores, Inc. Her physician later diagnosed her with lupus and fibromyalgia. Heimeshoff stopped working on June 8. On August 22, 2005, Heimeshoff filed a claim for long-term disability benefits with Hartford Life & Accident Insurance Co., the…

Excerpt of a 30,639-character opinion. The full text and citation network load in the interactive viewer above.

← Back to the decisions database