What is sufficient disability to toll the statute of limitations?

In Varney v. CONSOL, Inc., Judge Jones of the W.D. Va. noted that plaintiff's claim for benefits under ERISA was subject to the five-year Virginia statute of limitations for written contract claims that is "borrowed" under ERISA, declined to rule on the very interesting question raised by the plaintiff's claim that the limitations period was tolled on account of his physical impairments, upheld the plan's initial decision that plaintiff was limited to 24 months of benefits for depression under the terms of the plan, and rejected the plaintiff's new disability claims based on sleep apnea.