On September 30, 2009, the Tenth Circuit, in Salisbury v. Hartford Life and Accident Ins. Co., 583 F.3d 1245 upheld a district court’s determination that the contractual suit limitations provision in an ERISA Plan barred a claim for benefits. On November 2, 2009, the Tenth Circuit remanded a case involving accidental paralysis and rehabilitation benefits to the district court for a de novo review because the claimant submitted evidence supporting a covered diagnosis and the administrative record was inadequate for a full consideration of eligibility for benefits. The Tenth Circuit instructed the district court to supplement the record, if it deems necessary, because of complex medical questions.