The U.S. District Court for the Northern District of Ohio, Eastern Division recently held that a plaintiff’s action to recover long-term disability benefits for a 2001 benefit claim was barred by the plan’s three-year contractual statute of limitations clause. In this case, the plaintiff was denied long-term disability benefits in 2001, even though he was diagnosed with severe, steroid-dependent Crohn’s Disease and anemia, among other disabling medical conditions. The plaintiff filed two administrative appeals, but the plan upheld its determination to deny benefits. If the plaintiff wanted to file a legal action in connection with the plan’s denial of his 2001 claim for long-term disability benefits, the plan required him to do so within three years. The plaintiff did not file a legal action within the three-year period. However, the plaintiff asserts that he never received a copy of the plan, and the summary plan description (SPD) he did receive did not contain any language regarding the three-year statute of limitations provision.
In 2008, the plaintiff filed a second claim for long-term disability benefits. This time, the claim was approved by the plan. The plan’s approval letter also indicated that the plaintiff could submit additional information to support a request for disability benefits based on an earlier date of disability. The plaintiff responded with a letter reflecting his belief that the plan’s denial of his long-term disability claim in 2001 was incorrect, and that 2001, not the 2008 date, should be the disability date for the 2008 disability claim.
The Employee Retirement Income Security Act of 1974 (ERISA) does not contain a statute of limitations for claims for benefits, and courts normally apply the most analogous state statute of limitations. However, when a plan contains a reasonable contractual statute of limitations, courts generally apply the contractual statute of limitations. In this case, the court held that the plaintiff’s legal action to recover benefits under the 2001 claim was barred by the plan’s three-year statute of limitations provision. The court noted that even if the plaintiff received only the SPD (that did not contain a reference to the three-year statute of limitations), the SPD cannot change the terms of the plan itself, which does contain a three-year statute of limitations provision. Furthermore, the court stated that the plaintiff’s ignorance of the three-year limitation is not sufficient, on its own, to render the plan’s statute of limitations provision unenforceable.
This case illustrates how including a statute of limitations provision in an ERISA plan document can protect the plan from a lawsuit despite other administrative procedural errors that may have occurred. (Engleson v. Unum Life Insurance Co. of America, N.D. Ohio 2012)