WASHINGTON, D.C. - The U.S. Supreme Court on Nov. 4 declined to review an 11th Circuit U.S. Court of Appeals unpublished ruling that an action under the Employee Retirement Income Security Act to recover disability benefits is time-barred because the claimant failed to file a claim within the plan's one-year notification period (Beatriz Martinez-Claib, M.D. v. Business Men's Assurance Company of America, et al., No. 12-1403, U.S. Sup.).