When an ERISA Plan Doesn’t State the Deadline: Court Refuses to Enforce a One-Year Limitations Period and Penalizes an Employer for Failing to Produce the Plan

In Thomas v. Amazon.com Services, Inc., No. 4:21-CV-02997, 2026 WL 2934940 (S.D. Tex. Sept. 29, 2026), a Texas federal court issued findings of fact and conclusions of law after a bench trial in an ERISA dispute over benefits under an employer injury-benefit plan. The court reached a split result: it refused to enforce the plan’s one-year deadline to sue, upheld two of three benefit denials, found the third denial an abuse of discretion but awarded no money on it, and imposed a statutory penalty against the employer for failing to furnish the plan documents a participant had requested.

What happened in this ERISA injury-benefit case?

Plaintiff worked as a warehouse associate and was covered under the AmazonTXCare Employee Injury Benefit Plan, an ERISA-governed plan for which Amazon served as Plan Administrator and Anchor Risk Management served as Claims Administrator. Plaintiff reported three work-related injuries and sought benefits for each. Anchor terminated benefits for the first injury after an independent medical examination, and it denied the claims for the second and third injuries. After Plaintiff was released to unrestricted duty and did not return to work, Amazon terminated his employment.

Proceeding without counsel, Plaintiff sued more than a year after the final benefits denial, bringing a claim under 29 U.S.C. § 1132(a)(1)(B) for improper denial of benefits against both Amazon and Anchor, and a claim under 29 U.S.C. § 1132(c) against Amazon for failing to provide him a copy of the plan and the summary plan description.

Was the plan’s one-year deadline to sue enforceable?

The plan required any civil action to be filed within one year of the final determination on appeal. The court agreed that a one-year contractual limitations period is generally reasonable under Heimeshoff v. Hartford Life & Accident Insurance Co., but it held that the period was unenforceable as to all three claims.

Because each claim sought disability benefits, the claims were subject to the Department of Labor’s disability-claim procedures for claims filed after April 1, 2018. Those regulations require an adverse determination on review to disclose any applicable contractual limitations period and to state the calendar date on which that period expires, and they require strict adherence. The court explained that the substantial-compliance standard from Bunner v. Dearborn National Life Insurance Co. did not apply, because the claim in that case predated the April 1, 2018 effective date.

As to the first injury, the record did not contain the appeal-decision letter, so Amazon could not establish that the determination disclosed the limitations period or expiration date. As to the third injury, the final appeal letter told Plaintiff he could bring an ERISA action but disclosed neither the one-year period nor its expiration date. As to the second injury, the determination stated the one-year period but omitted the calendar expiration date that the regulation separately requires. Noting that no circuit has resolved the precise consequence of omitting the calendar date, the court found the reasoning of Santana-Díaz v. Metropolitan Life Insurance Co., Mirza v. Insurance Administrator of America, Inc., and Moyer v. Metropolitan Life Insurance Co. persuasive, and it declined to enforce the contractual period. Applying Texas’s four-year breach-of-contract limitations period instead, the court held all three claims timely.

Did the benefit denials survive review for abuse of discretion?

Because the plan gave the administrator discretionary authority to construe its terms and determine eligibility, the court reviewed the denials for abuse of discretion under Firestone Tire & Rubber Co. v. Bruch, asking whether each decision rested on substantial evidence and a rational connection to the facts.

The court upheld the termination of benefits for the first injury. The IME physician, an orthopedic surgeon, found that Plaintiff’s condition reflected age-related degenerative changes rather than a traumatic or work-related injury, that there was no objective evidence of nerve root compression, and that Plaintiff had reached maximum improvement and could return to unrestricted duty. The administrator was entitled to credit that opinion over the treating clinic’s under Rittinger v. Healthy Alliance Life Insurance Co., and the court rejected Plaintiff’s arguments that the IME physician was not an “Approved Provider.” A one-day timing discrepancy in the termination date did not make the decision an abuse of discretion, because a separate provision allowed disability benefits to cease when a participant was released from care.

The court held that the denial of the second injury was an abuse of discretion. The denial rested on the conclusion that Plaintiff had not sustained a new “Accident” but had only aggravated his existing injury. The plan, however, covered injuries resulting from an Accident, Occupational Disease, or Cumulative Trauma, and the claims adjuster himself testified that he viewed the condition as a cumulative-type problem and an exacerbation. Treating the absence of a new Accident as a basis for denial effectively read the plan’s separate Cumulative Trauma coverage out of the benefits provisions, which fell outside the permissible range of interpretation.

That finding did not translate into a recovery. A claimant under § 1132(a)(1)(B) bears the burden of proving benefits actually due under the plan. Plaintiff presented no evidence of medical expenses attributable to the second injury that should have been paid, and the record showed he had already received short-term disability benefits for the relevant period. Because he did not prove that any additional benefits remained payable, the court awarded no monetary relief on the second injury.

The court upheld the denial of the third injury. The plan required a participant to report an injury generally by the end of the shift and in no event more than three days after the event. The incident report from the day of the event did not state that Plaintiff had been injured, and he first reported the injury eleven days later. The determination that the claim was untimely had a rational basis and was supported by substantial evidence.

Did Amazon owe a penalty for failing to furnish the plan?

The court held that § 1132(c) liability lies only against the designated plan administrator, which was Amazon, not the claims administrator Anchor. Plaintiff made a written request for a complete copy of the plan, triggering a 30-day deadline to furnish it. Amazon’s claims adjuster emailed the plan as an attachment within that window, but the court credited Plaintiff’s testimony that he could not open, download, or access the attachment.

The court held that the email did not satisfy Amazon’s disclosure obligation. The governing regulations require measures reasonably calculated to ensure actual receipt, and they call for requested materials to be mailed or personally delivered unless the administrator satisfies the conditions of an electronic-disclosure safe harbor. Amazon neither mailed nor personally delivered the plan, and it did not establish that Plaintiff fell within the workplace-access category, that he consented to electronic delivery, or that the adjuster used any safeguard to confirm receipt.

Exercising its discretion, the court imposed a penalty. It found no bad faith and characterized the failure as negligence at most, but it emphasized that the delay was substantial and that the failure to produce the plan materially impaired Plaintiff’s ability to understand and challenge the denials, particularly the second claim implicating the Cumulative Trauma provision. The court assessed a total statutory penalty of $6,050 against Amazon, below the maximum available for the period of noncompliance, together with post-judgment interest. Plaintiff took nothing against Anchor.