UNITED STATES SUPREME COURT UPHOLDS PLAN PROVISION SHORTENING
LIMITATIONS PERIOD
On December 16, 2013, the Supreme Court settled a long-standing
split among various Circuit Courts of Appeals, holding that an
ERISA plan may impose a limitation on the time period during which
a participant can sue for benefits that begins to run prior to the
date on which the participant's final appeal is denied. See
Heimeshoff v. Hartford Life & Accident Insurance Co.
ERISA section 502(a)(1)(B) allows participants in ERISA benefit
plans to sue to recover benefits under the plan that are wrongfully
denied. Unlike ERISA claims for breach of fiduciary duty, ERISA
itself does not provide a limitation period for a claim under ERISA
section 502(a)(1)(B). Rather, courts have looked to plan documents
themselves, when applicable, or to analogous state statutes to
determine the applicable limitation periods. Additionally, courts
have held that a claim under ERISA section 501(a)(1)(B) does
