Heimeshoff v. Hartford Life & Accident Ins. Co., 134 S. Ct. 604

Background

Julie Heimeshoff filed a long‑term disability claim under Wal‑Mart’s ERISA plan administered by Hartford; claim was denied after internal review and final denial issued Nov. 26, 2007.
The Plan required "written proof of loss" within 90 days and contained a contractual bar: suits asserting benefits must be filed within 3 years after proof of loss is due.
Heimeshoff exhausted the Plan’s administrative remedies and filed suit under ERISA §502(a)(1)(B) on Nov. 18, 2010 — almost three years after final denial but more than three years after proof‑of‑loss was due.
District Court dismissed the suit as time‑barred under the Plan’s 3‑year provision; the Second Circuit affirmed, and the Supreme Court granted certiorari to resolve a circuit split.
The central legal question: whether a contractual limitations period that begins before an ERISA §502(a)(1)(B) cause of action accrues (i.e., before administrative exhaustion) is enforceable.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether parties may contractually start a limitations period before ERISA claim accrues	Heimeshoff: such a provision is invalid because ERISA claims accrue only after final denial, so limitations must begin at accrual	Hartford/Wal‑Mart: parties may contract to fix both length and start‑date of limitations absent a controlling statute	Court: Enforceable — parties may set start date by contract so long as reasonable and not precluded by statute
Whether the 3‑year period here is unreasonably short given administrative exhaustion delays	Heimeshoff: internal review can be lengthy and may leave insufficient time to litigate; analogous to Occidental Life context	Defendants: ERISA regs aim to resolve mainstream claims in ~1 year, leaving ample time to sue; plaintiff had ~1 year here	Court: Not unreasonably short; regulations foresee ~1 year for suit and the provision is reasonable
Whether enforcing the provision undermines ERISA’s two‑tier remedial scheme (internal review then judicial review)	Heimeshoff/United States: provision pressures claimants to forego full internal review or allows administrators to delay to bar suits	Defendants: internal review has incentives (administrative record, deferential review) to preserve claims; regs penalize unjustified delay; courts can apply waiver, estoppel, equitable tolling	Court: No undermining demonstrated; doctrines (waiver, estoppel, equitable tolling) and regulatory safeguards address concerns
Whether state tolling rules must be borrowed to toll the contractual period during exhaustion	Heimeshoff: under Hardin, federal claim borrowing state SOLs requires borrowing state tolling rules	Defendants: this limitations period is a contract term, not a borrowed state statute; no need to import state tolling rules	Court: No borrowing required; contractual limitations not subject to state tolling rules absent necessity

Key Cases Cited

Order of United Commercial Travelers of America v. Wolfe, 331 U.S. 586 (1947) (contracting parties may shorten limitations periods if period itself is reasonable)
CIGNA Corp. v. Amara, 563 U.S. 421 (2011) (ERISA §502 emphasizes enforcing written plan terms)
Occidental Life Insurance Co. of California v. EEOC, 432 U.S. 355 (1977) (refused to apply a 1‑year limitations period where administrative backlog made timely suit infeasible)
Irwin v. Department of Veterans Affairs, 498 U.S. 89 (1990) (limitations defenses between private litigants are subject to equitable tolling)
Hardin v. Straub, 490 U.S. 536 (1989) (when federal claims borrow state statutes of limitations, courts ordinarily borrow state tolling rules too)
Bay Area Laundry & Dry Cleaning Pension Trust Fund v. Ferbar Corp. of Cal., 522 U.S. 192 (1997) (limitations period generally commences when cause of action accrues)
Firestone Tire & Rubber Co. v. Bruch, 489 U.S. 101 (1989) (plan may vest administrator with discretionary authority; standard of judicial review matters)