Eleventh Circuit Eliminates Mandatory Administrative Exhaustion Requirement for Statutory ERISA Claims

A significant ruling from the U.S. Court of Appeals for the Eleventh Circuit changes the landscape of ERISA litigation for plan sponsors and fiduciaries in Alabama, Florida and Georgia. In Bolton v. Inland Fresh Seafood Corp. of America, Inc., the court overturned 40 years of precedent, ruling that plaintiffs alleging statutory ERISA violations, including fiduciary breaches, are no longer required to exhaust administrative remedies before filing suit in federal court. While exhaustion requirements for traditional benefit claims remain intact, the decision could accelerate fiduciary-breach litigation and underscores the importance of reviewing plan documents, claims procedures and fiduciary governance practices.

For a closer look at the ruling and its implications for plan sponsors and fiduciaries, read our full update.