District of Connecticut Holds Pro Se Plaintiff’s ERISA Claims Time-Barred in 20-Year Life Insurance Beneficiary Dispute

In Fromageot v. Britt, No. 3:21-cv-1165-MPS, 2025 WL 3470473 (D. Conn. Dec. 3, 2025), the U.S. District Court for the District of Connecticut issued a significant decision applying Heimeshoff’s enforceability of contractual limitations periods to bar a pro se plaintiff’s ERISA claims arising out of a decades-long dispute over life-insurance proceeds. Although the court found Article III standing, it dismissed all ERISA claims against Hartford Life as untimely and declined jurisdiction over the remaining state-law claims.

Background: A Long-Running Beneficiary Conflict

The dispute centers on life-insurance benefits issued under an ERISA-governed group plan sponsored by Alliance Capital and insured by Hartford Life. When Paul Fromageot enrolled in 1996, he designated his wife (Madeline), his parents, and his then-only child as co-equal beneficiaries. Madeline contended that Paul later updated his policies to add their three younger children and intended for her and all four children to receive the proceeds upon his death.

When Paul died in 2004, Hartford Life distributed the proceeds according to the original enrollment forms, paying Paul’s parents. Madeline approved this payment only on the belief that the funds would be placed into an education account for the children—something that allegedly never occurred.

Madeline spent nearly two decades challenging the distribution in federal and state courts, including a prior unjust enrichment action in New Jersey and multiple attempts to litigate in Connecticut. Her 2021 federal complaint asserted 12 causes of action, nine of which targeted Hartford Life and were styled (at least in part) as ERISA claims for breach of fiduciary duty, misrepresentation, and failure to comply with a probate subpoena.

Standing: Injury Established, but Pro Se Representation Limited

Judge Shea held that Madeline adequately alleged Article III injury. Because the proceeds allegedly intended for the children were never deposited into an education fund, she plausibly bore financial burdens that constitute a concrete economic injury.

However, the court emphasized that a pro se litigant may appear only for herself. It dismissed all claims brought on behalf of:

• Paul’s estate (because the estate had multiple beneficiaries),

• Madeline’s children, and

• the children’s trusts.

This limitation is well-established in the Second Circuit and applies equally in the ERISA context.

Contractual Limitations Clause Bars Madeline’s ERISA Claims

The decisive issue was timeliness. Hartford Life’s policy included a contractual limitations period requiring any legal action to be filed within three years of the date proof of loss was due. Proof of loss was required 90 days after Paul’s death in June 2004, establishing a litigation deadline of September 2, 2007.

Madeline did not sue Hartford Life until May 22, 2023—more than 15 years late.

Citing Heimeshoff v. Hartford Life & Accident Insurance Co., 571 U.S. 99 (2013), the court enforced the plan’s limitations provision, noting:

• ERISA favors the enforcement of plan terms as written.

• A three-year limitations period is neither unreasonable nor contrary to statute.

No Tolling: Fraudulent Concealment and Equitable Tolling Arguments Rejected

Madeline argued that the limitations period should be tolled due to alleged concealment of documents, misrepresentations, and a probate subpoena Hartford Life allegedly failed to honor. The court rejected these theories for several reasons:

1. No Fraud by Hartford Life

Madeline alleged that Paul’s parents, not Hartford Life, engaged in fraudulent acts. Fraudulent concealment requires concealment by the defendant.

2. Tolling Cannot Revive an Already-Expired Deadline

Any alleged misconduct occurred after 2007, long after the deadline had passed. As the Second Circuit has made clear, fraudulent concealment cannot toll a limitations period once it has already expired.

3. Madeline Had Sufficient Information Before the Deadline

In 2006, Madeline obtained SAP enrollment screenshots showing that Paul had updated his policy to include all four children. That information was enough to bring an ERISA claim for improper distribution before the September 2007 deadline.

4. Equitable Tolling Not Warranted

The court found no “extraordinary circumstance” that prevented timely filing. Alleged attorney malpractice was insufficient, particularly because Madeline failed to demonstrate diligence in pursuing ERISA claims during the limitations period.

Disposition

Because all ERISA claims were barred by the policy’s limitations period, the court dismissed them with prejudice. It then declined to exercise supplemental jurisdiction over the remaining state-law claims, dismissing them without prejudice.

Takeaways for Plan Administrators and Beneficiaries

• Contractual limitations provisions in ERISA plans remain powerful tools for plan administrators, even where disputes span decades.

• Pro se litigants face strict limits on whom they may represent, and courts will not allow non-attorneys to litigate on behalf of estates, minors, or trusts.

• Tolling doctrines are narrowly applied, particularly where a claimant possessed sufficient information to sue before a contractual deadline expired.

• The decision underscores the importance of timely ERISA litigation—and the risks claimants face when challenges are delayed.