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Ohio District Court Finds Plaintiff's LTD Claim Time Barred by the Limitations Term in the Plan
Haynes and Boone, LLP Oct. 11, 2012
"The federal district court stated that for ERISA claims, courts normally apply the most analogous state statute of limitations; however, when the plan contains a contractual statute of limitations, courts generally apply the plan's provision provided that the plan's stipulated limitations period is reasonable. In Ohio, the applicable statute of limitations for breach of written contract claims is 15 years. In this case, the Court held that the plaintiff's action with respect to the 2001 claim was time barred by the contractual limitations period in the Plan which the Court deemed to be reasonable."
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