Disability benefit lawsuit deadlines
Heimeshoff v. Hartford Life & Accident Insurance
In brief
The Supreme Court upheld the Second Circuit and found Hartford’s plan could enforce its three-year filing deadline.
- Where it stands
- Decided
Decided · December 16, 2013 · Opinion by Justice Thomas
- What it’s about
- Julie Heimeshoff challenged Hartford Life & Accident Insurance Co.’s denial of her long-term disability benefits, arguing that the plan’s three-year deadline should not run while her internal appeal was pending.
- Who it affects
- The plan’s three-year lawsuit deadline remained enforceable for Heimeshoff’s claim against Hartford.
Summary: written with AI from the case record.

What it's about
The Supreme Court ruled that the deadline was enforceable and agreed with the Second Circuit that her lawsuit was too late.
Heimeshoff argued that the three-year deadline should not run while her internal appeal was pending.
The dispute concerned a deadline written into the plan governing Heimeshoff’s disability benefits.
Question presented
When should the statute of limitations period for judicial review of an ERISA disability benefit decision begin?
What the Court decided
Holding
The Plan’s limitations provision is enforceable. 129, affirmed.
- Result
- Affirmed
The Court's reasoning
The Court said ERISA does not set a filing deadline, so parties may agree to one in a benefits plan. It found this plan’s three-year limit enforceable.
The vote
- Majority author
- Clarence Thomas
What's next
The Supreme Court has finished the case, leaving the Second Circuit’s ruling in place.
Documents
Opinions
Docket activity
New analysis added
AI analysis generated: Case Briefing
AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
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Opinion added: Heimeshoff
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.