ERISA-Sixth Circuit Rules That Claim For Long-Term Disability Benefits Must Be Dismissed Because It was Not Timely Filed

In Engleson v. Unum Life Insurance Company of America, No. 12-4049 (6th Cir. 2013), the plaintiff, Jerry Engleson (“Engleson”), was appealing the district court’s dismissal of his case, a claim under ERISA for long-term disability (“LTD”) benefits, on the grounds that it was not timely filed.

In this case, Engleson had waited over eight years before seeking judicial review of his denied claim for LTD benefits. The terms of his disability plan, however, gave him a little more than three years to file such a suit. The Sixth Circuit Court of Appeals (the “Court”) said that neither the law nor principles of equity allow the Court to excuse the tardiness of his suit. As a result, the Court affirmed the district court’s dismissal of the case.

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