The Supreme Court of the United States announced the following decision yesterday:
Heimeshoff v. Hartford Life & Accident Ins. Co., No. 12-729: Participants in an employee benefit plan covered by the Employee Retirement Income Security Act of 1974 (“ERISA”) are permitted to bring a civil action to recover benefits due under the terms of the plan. Courts generally require participants to exhaust the plan’s administrative remedies before filing suit to recover benefits. In this case, petitioner Julie Heimeshoff brought a claim for judicial review of her long-term disability benefits claim after exhausting her administrative remedies. She filed suit nearly three years after respondent Hartford issued its final denial at the end of the administrative review process. ERISA does not contain a statute of limitations for seeking judicial review of benefit claims, but the plan included a contractual limitations period of three years after “proof of loss” is due, which had already passed by the time Heimeshoff filed suit. The District Court dismissed the claim as untimely, and the Second Circuit affirmed. Today, the Court affirmed, holding that the plan’s limitations provision was enforceable.
The Court's decision is available here.
On Friday afternoon, the Court granted certiorari in two cases:
Fifth Third Bancorp v. Dudenhoeffer, No. 12-751: Whether the Sixth Circuit erred by holding that Respondents were not required to plausibly allege in their complaint that the fiduciaries of an employee stock ownership plan abused their discretion by remaining invested in employer stock, in order to overcome the presumption that their decision to invest in employer stock was reasonable, as required by the ERISA, 29 U.S.C. §§ 1101, et seq., and every other circuit to address the issue.
Loughrin v. United States, No. 13-316: Whether the Government must prove that the defendant intended to defraud a bank and expose it to risk of loss in every prosecution under 18 U.S.C. § 1344 for federal bank fraud.