Monday, April 15, 2013

SCOTUS Grants Cert. in ERISA Statute of Limitations Case

Earlier today, the Supreme Court granted certiorari in Heimeshoff v. Hartford Life Insurance. Per the Court's Order, SCOTUS will only hear question one. Per the Court's Questions Presented, question one is:
When should a statute of limitations accrue for judicial review of an ERISA disability adverse benefit determination?
The case is on appeal from the Second Circuit, 496 F. App'x 129, which enforced a contractual agreement to shorten the statute of limitations to three years for a claim brought under ERISA where the normal state contract statute of limitations was six years. The contract further provided that the limitations period began to run when the employee's proof of loss was due, not upon the final denial of request for benefits.

As you can see, the Court has a few different directions it could go in here. SCOTUSblog hasn't posted a copy of the Petition for Writ of Certiorari yet (and I haven't located it anywhere else), so I'm not sure what angle the parties are pressing yet. It will also be interesting to see what impact (if any) the Court's decision will have on contractual agreements to alter limitations periods in other contexts.

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