ERISA-Eighth Circuit Holds That Suit Is Timely Filed, Based On Period For Filing Allowed By State Law

In Mulholland v. Mastercard Worldwide, No. 15-1211 (8th Cir. 2015) (Unpublished), Brenda Mulholland was appealing the district court’s adverse grant of summary judgment in her action under ERISA. The district court had determined that Mulholland’s lawsuit challenging the termination of her long term disability (“LTD”) benefits was time-barred, based on the Supreme Court’s decision in Heimeshoff v. Hartford Life & Accident Ins. Co. (“Heimeshoff“).

Under Mulholland’s LTD plan, legal action of any kind could not be brought more than three years after proof of disability was required to be filed “unless the law in the state where [the plan participant] live[s] allows a longer period of time.” Upon de novo review, the Eighth Circuit Court of Appeals (the “Court”) agreed with Mulholland that the district court overlooked the critical distinction between the contractual limitations provision in this case and the provision addressed in Heimeshoff. Specifically, the provision in Heimeshoff did not contain the additional language allowing a participant to file suit beyond three years if the law of the state provided for a longer period. As such, the Court concluded that the instant suit was not time-barred.

In so holding, the Court noted that it had previously held that in Missouri the applicable limitations period for ERISA actions is the ten-year limitations period in Mo. Rev. Stat. § 516.110(1). See Johnson v. State Mut. Life Assurance Co. of America (because ERISA contains no statute of limitations for actions to recover benefits under an employee benefit plan, looking to state law for most analogous statute of limitations) (“Johnson“). This Court subsequently determined that Johnson was binding, where the ERISA-governed benefit plan contained a contractual limitations period nearly identical to the one here. See Harris v. The Epoch Group, L.C. (applying § 516.110(1)’s longer limitations period where contractual limitations provision prohibited filing suit unless it was brought within three years from expiration of time within which proof of loss was required “or such longer period as required by applicable state laws”). Accordingly, the Court reversed the judgment of the district court and remanded the case back to the district court to consider the case’s merits.

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