Williams v. Lawrence Livermore National Security, LLC Benefits and Investment Committee

facts, governing legal standards, and arguments made by the parties. The Plan’s Limitations Period. LLNS argues that Williams’ claim is untimely because the Plan states that a “claimant may not submit a dispute to a court with respect to a denied claim under this plan prior to exhausting the claims and appeal procedure or more than one year after the date the benefit appeals committee renders its final decision upon appeal,” and Williams filed his claim after that year elapsed. As a threshold matter, Williams argues that the Plan’s limitations period is unenforceable because ERISA Section 1113 sets out a statute of limitations for breach of fiduciary duty claims. Even though Section 1113 is a default statute of limitations, parties may contract around that default rule as long as the contractual limitations period is “reasonable.” Heimeshoff v. Hartford Life & Accident Insurance Co., 571 U.S. 99, 106 (2013); see also Hewitt v. Western & Southern Financial Group Flexible Benefits Plan, No. 17-5862, 2018 WL 3064564, at *2 (6th Cir. Apr. 18, 2018). Here, Williams does not contend that the Plan’s limitations period is unreasonable. Even though the limitations period is enforceable, it…