ERISA plan limitations on filing suit enforceable
In Salisbury v. Hartford, Ms. Salisbury sued Hartford for denying her long term disability claim more than 3 years after the denial. The plan said all suits must be filed within 3 years. Her claim was dismissed as untimely and the 10th Circuit affirmed.
First, the court found that the state law limitation period didn't matter since the contract stated a limitation period. Then the court found the limitation period reasonable. Salisbury claimed the contractual limitation was confusing and circular, but since she failed to file suit for nearly 5 years after her claim was denied, the court dismissed her arguments.
