When does the timer begin to tick?
Julie Heimeshoff filed a claim for long-term disability benefits with Hartford Life & Accident Insurance Co., the administrator of Walmart's Group Long Term Disability Plan, due to her diagnosis of lupus and fibromyalgia. Her claim was denied after multiple doctors, hired by Hartford, found that even with her condition, she could continue to work her largely sedentary position as a senior public relations manager. The decision took nearly two years, after both sides hired multiple doctors and ordered multiple tests.
The governing ERISA plan requires the claimant to initiate judicial action within three years after "proof of loss" is due, i.e. when she was required to submit the relevant medical evidence. She filed suit three years after her final administrative appeal was denied (or approximately five years after the "proof of loss" was due). Her argument? The clock should start when the judicial cause of action accrues -- not before. And at first blush, her argument makes sense. After all, what happens if the administrative process and appeals eats up the entire term limit?
Unfortunately for her, the Supreme Court sided with the insurer, but for good reason.