ERISA-Fourth Circuit Holds That Plaintiff Did Not Timely File Suit For LTD Benefits

In Belrose v. The Hartford Life & Accident Insurance Company, No. 10-2405 (4th Cir. 2012) (Unpublished), the plaintiff, Benjamin Belrose (“Belrose”), was appealing the district court’s order granting the motion by the defendant, Hartford Life & Accident Insurance Company (“Hartford”), to dismiss Belrose’s action challenging the termination of his long-term disability (“LTD”) benefits.

In this case, Belrose became a full-time employee of the Camber Corporation (“Camber”) on August 1, 2002, and became eligible for disability benefits under the Camber Group Benefit Plan (the “Plan”). Hartford both administered claims for and insured the Plan. On September 10, 2002, In December 2002, due to various heart conditions, Belrose applied for and began receiving LTD benefits under the Plan. The benefits continued until October 5, 2005, when Hartford terminated the benefits. Belrose appealed the termination. The decision to terminate Belrose’s LTD benefits was affirmed on administrative appeal, and Hartford issued a final denial letter to Belrose on June 14, 2006. He filed this suit on July 9, 2010 . The question for the Fourth Circuit Court of Appeals (the “Court”): was the district court correct in dismissing Belrose’s case?

The issue in the case was whether Belrose filed the suit before the statute of limitations expired. In analyzing this issue, the Court explained that ERISA does not specify a statute of limitations for a plan participant suing for benefits. ERISA allows a plan to set its own limitations period. However, if the plan does not do so, the courts may impose the applicable state statute of limitations. Further, an ERISA claim, and therefore the statute, does not accrue or begin to run until a claim of benefits has been made and formally denied.

Here, the Plan contained a three-year limitations period, which the Plan stated commenced on the date Hartford required the beneficiary to furnish proof of loss. However, in granting Hartford’s motion to dismiss, the district court reasoned that because the limitations period for an ERISA claim does not begin to run until the insurer issues a formal denial–despite the terms of claims accrual which may be contained within the Plan–Hartford’s three-year limitations period was not unreasonable or contrary to public policy. The Court agreed with this reasoning. Therefore, the statute of limitations began to run on June 14, 2006, the date on which the final denial letter was issued. Belrose had until June 14, 2009 to file this suit. He did not meet the deadline, since he did not file until July 9, 2010 . Accordingly, the Court affirmed the district court’s ruling.

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