Heimeshoff v. Hartford Insurance
At issue in this case is whether an ERISA plan can start the clock ticking on a beneficiary’s federal cause of action challenging her denial of disability benefits before the suit could be brought in court (due to administrative exhaustion requirements), thereby permitting the plan to run the clock down and nearly out on the beneficiary’s ability to file her statutorily guaranteed federal claims.
This question impacts virtually every beneficiary of an ERISA disability benefits plan and has been the subject of a deep circuit split for over a decade.
Julie Heimeshoff worked for Wal-Mart for almost twenty years, rising to the position of Senior Public Relations manager. As part of her benefits package, she became eligible for Wal-Mart’s Group Long Term Disability Plan. When Ms. Heimeshoff began suffering from significant pain and fatigue, she had trouble working and was later diagnosed with fibromyalgia, irritable bowel syndrome, lupus, and several other chronic pain sources. In June 2005, her pain became so severe that she stopped working altogether. Ultimately, her plan denied her claim for benefits, but it took more than two years to do so.
Under ERISA’s remedial scheme, a beneficiary who is denied benefits and exhausts her internal appeals has the right to file a claim in federal court challenging the plan’s denial of benefits on several different grounds. Ms. Heimeshoff availed herself of this federal right, filing a claim alleging, among other things, that the plan improperly denied her benefits under the terms of her LTD plan However, even though this suit was timely when measured from the date she could have filed her claim, it was outside of the artificial accrual and limitations period imposed by the plan, which started the clock running on her federal claim before she could ever have filed it in court.
The Second Circuit held that this contractually imposed accrual date meant that Ms. Heimeshoff’s claim was time-barred. That holding — that a plan can impose an accrual date that starts the clock running on a beneficiary’s federal claim before the beneficiary can actually file her claim — perpetuated a preexisting split among the circuits. On this basis, the U.S. Supreme Court agreed to hear the case. Public Justice will argue it in the fall.
