[JURIST] The US Supreme Court [official website] ruled [opinion, PDF] Monday in Heimeshoff v. Hartford Life Insurance [SCOTUSblog backgrounder] that a woman was not entitled to disability benefits under the Employee Retirement Income Security Act (ERISA) [official website] because the applicable statute of limitations had run. Petitioner Julie Heimeshoff argued [JURIST op-ed] that her claim was timely because it was made less than three years after the insurance company's final denial, even though it was more than three years after proof of loss was due, and that the applicable state law tolled the statute of limitations. However, Justice Clarence Thomas, writing for a unanimous Supreme Court, found Heimeshoff's arguments unpersuasive:
Heimeshoff contends that we must inquire whether state law would toll the limitations period throughout the exhaustion process. ... But here ... the parties have adopted a limitations period by contract. Under these circumstances, where there is no need to borrow a state statute of limitations there is no need to borrow concomitant state tolling rules. We hold that the Plan's limitations provision is enforceable.The Supreme Court's decision affirmed an opinion [text] by the US Court of Appeals for the Second Circuit [official website].
ERISA [JURIST backgrounder] has been the frequent subject of Supreme Court litigation since its passage in 1974. In September the US Department of Labor [official website] issued guidance [JURIST report] stating that the terms "spouse" and "marriage" in Title I of ERISA should be read to include same-sex couples who were legally married in any US state or jurisdiction that recognizes same-sex marriages. In April the Supreme Court ruled [opinion, PDF; JURIST report] in US Airways, Inc. v. McCutcheon that the terms of a contract in a health benefit plan should not be overturned through the application of equitable principles under Section 502(a)(3) of ERISA. ruling is predicted to have the impact [Cornell LII backgrounder] of reinforcing the viability of employee health plans, and thwarting a landslide of ERISA legislation that may have arisen if the court had upheld the lower court decision.