What standard did the Supreme Court endorse in Heimeshoff v. Hartford regarding contractual limitations periods in ERISA plans?

• A. A fixed nationwide statute
• B. A reasonable length contractual limitation, not subject to a controlling statute to the contrary
• C. A reasonable length contractual limitation that is not subject to a controlling statute to the contrary
• D. The limitations period cannot be shorter than one year

Answer: (C)

The main idea being tested is how ERISA plan limitations periods are treated by the courts. In Heimeshoff v. Hartford, the Supreme Court said that the enforceability of a deadline to sue for plan benefits comes from the plan’s own contract terms, as long as the deadline is a reasonable length and there isn’t a controlling statute that overrides it. In other words, a reasonable contractual limitations period embedded in the ERISA plan can govern, rather than requiring a universal federal or fixed nationwide statute.

This matters because ERISA is a contract-based regime. The plan can set a deadline to filebenefits claims, and that deadline will be binding if it’s reasonable. The “not subject to a controlling statute to the contrary” clause means that if there’s a statute that would override the contract, then that statute takes precedence; otherwise, the plan’s own deadline controls. Heimeshoff thus endorses a standard where the plan’s reasonable, contractually stated time limit governs a claim, aligning with the contract-focused nature of ERISA benefits.

So, the correct view is that a reasonable length contractual limitations period that is not subject to a controlling statute to the contrary is enforceable. A fixed nationwide statute would ignore the contract-based approach ERISA permits, and a one-year minimum rule isn’t what the court adopted in this context.