In Munro-Kienstra v. Carpenters’ Health and Welfare Trust Fund of St. Louis, No. 14-1655 (8th Cir. 2015), Debra Munro-Kienstra had alleged, under ERISA, wrongful denial of health care benefits by the Carpenters’ Health and Welfare Trust Fund of St. Louis’ Employee Welfare Benefit Plan (the “Plan”). The Plan stated that any ERISA action for denial of benefits must be brought within two years of the date of denial. Munro-Kienstra learned that she had been denied coverage in July 2009, and she filed this action over two years later in January 2012. The district court concluded that Munro-Kienstra’s claim was time barred and granted summary judgment for Carpenters. Munro-Kienstra appeals.
After reviewing the case, the Eighth Circuit Court of Appeals (the “Court”), affirmed the district court’s decision. The Court noted that ERISA contains no statute of limitations for actions to recover plan benefits. It said that parties may fill this gap by agreeing to a reasonable limitations period in their contract, i.e., a plan covered by ERISA. In the absence of a contractual limitations period, or if the parties have expressly agreed to incorporate a state law limitations period into a plan, a Court will apply the most analogous state statute of limitations. Here, the Plan provided a two year filing period, and it is undisputed that Munro-Kienstra failed to file her claim within this two year period.
The Court further said that where, as here, the Plan contains its own limitations period, the analogous state statute of limitations-here the 10 year filing period allowed by Missouri- will not apply, unless either (1) the Plan’s period is unreasonably short, or (2) a controlling state statute prevents the limitations provision from taking effect. The Court found that neither (1) or (2) applies in this case. As to (2), the Court noted that State law does not apply of its own force to a suit based on federal law, especially a suit under ERISA, with its comprehensive preemption provision. Applying the Missouri statute here would negate an ERISA plan provision, negatively impact the administration of ERISA plans, and create inconsistencies with other ERISA provisions. As such, the Court concluded that the 10 year filing period under Missouri law could not apply, as it would violate ERISA’s comprehensive preemption provision. The Court also noted that the ERISA “savings clause”, under which ERISA does not preempt state insurance law or laws that apply to multiple employer arrangements, did not apply here, since the Plan is self-insured and a collectively bargained plan.