Heimeshoff v. Hartford Life & Accident Ins. Co.

*102 A participant in an employee benefit plan covered by the Employee Retirement Income Security Act of 1974 (ERISA), 88 Stat. 829 , as amended, 29 U.S.C. § 1001 et seq., may bring a civil action under § 502(a)(1)(B) to recover benefits due under the terms of the plan. 29 U.S.C. § 1132 (a)(1) (B). Courts have generally required participants to exhaust the plan's administrative remedies before filing suit to recover benefits. ERISA does not, however, specify a statute of limitations for filing suit under § 502(a) (1)(B). Filling that gap, the plan at issue here requires participants to bring suit…