Excerpt: Failure to exhaust administrative remedies, a venerable and effective ERISA defense, will not be found in the statute. The doctrine is one borrowed from administrative law and imposed by federal courts to trim the docket of cases that might have been resolved by benefit appeals. And so, in [Brown v. J.B. Hunt Transp. Servs.], the plaintiff had a difficult hurdle to overcome when the district court determined that she had failed to appeal the denial of her benefits.

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