In Mirza v. Insurance Administrator of America, Inc., No. 13-3535 (3d Cir. 2015), the Third Circuit Court of Appeals (the “Court”) noted that the regulations implementing ERISA provide that when a plan administrator denies a request for benefits, it must set forth a “description of the plan’s review procedures and the time limits applicable to such procedures, including a statement of the claimant’s right to bring a civil action.” 29 C.F.R. § 2560.503- 1(g)(1)(iv). The Court then said that the ERISA plan at issue in this case contains a one-year deadline for filing a civil action.
Appellant Dr. Neville Mirza received a benefits denial letter advising him of his right to judicial review, but it did not mention the time limit for doing so. The principal question the Court addresses in the case is whether plan administrators must inform claimants, of plan imposed deadlines for judicial review, in their notifications denying benefits. The Court held that they must, and that the appropriate remedy for this regulatory violation is to set aside the plan’s time limit and apply the limitations period from the most analogous state-law cause of action–here, New Jersey’s six-year deadline for breach of contract claims. Because Mirza filed his complaint before the expiration of this six-year limitations period, the Court found that his suit was filed on a timely basis.