Law360, New York ( March 4, 2014, 6:00 PM EST) -- In a unanimous ruling that brings circuit-wide uniformity regarding limitations on action provisions in plans under the Employee Retirement Income Security Act of 1974 and reaffirms the sanctity of written benefit plan terms, the U.S. Supreme Court, in Heimeshoff v. Hartford Life & Accident Insurance Co., recently held that a three-year contractual limitation on action provisions in an employee welfare benefit plan governed by ERISA was enforceable, even though it ran concurrently with the requirement that the plaintiff exhaust her administrative remedies prior to filing a lawsuit to recover long-term disability benefits, which effectively shortened plaintiff's period of time to file a lawsuit after a final benefit denial.  ...