"ERISA contains specific limitations periods for fiduciary claims ... But ERISA is silent for nonfiduciary suits such as health benefit claims, claims of interference with ERISA rights or document request claims.... To avoid the need to consult state law, a plan may specify that a claimant must bring suit within a certain period after a triggering event ... or within a certain period after completing the internal appeals process. Courts have long upheld such provisions, though courts in different jurisdictions have varied in their approach."  MORE >>