Heimeshoff v. Hartford Life & Accident Insurance Co. and Wal-Mart Stores, Inc.

Case Updates

The Court affirmed the Second Circuit and held that the plan's limitations provision is enforceable.

In its brief, the U.S. Chamber asked the Supreme Court to uphold a provision in a disability benefits plan that required claimants to bring any claim for benefits within three years after the claimant’s proof of loss was due. The Chamber noted that insurance provisions linking the timing requirements for filing suit to the claimant's proof of loss deadline are a standard feature of the insurance industry and reflect longstanding practice. The Chamber argued that nothing in the federal Employee Retirement Income Security Act (“ERISA”) invalidates these timing provisions. In fact, by declining to specify a statute of limitations provisions in ERISA, Congress signaled its intent to leave these procedural matters to the individual plans. Finally, the Chamber noted that basing deadlines on the proof-of-loss date “serves important interests in finality and financial stability that benefit both plans and their participants.”

William M. Jay and Joshua M. Daniels of Goodwin Proctor represented the U.S. Chamber of Commerce as co-counsel to the Chamber Litigation Center.