Pages 11-14 of 17 pages. "In reaching its conclusions, the Eighth Circuit made no distinction between the application of exhaustion requirements in individual and class claims. Insofar as class claims are predicated on an alleged systemic violation by the plan, one might question the need for developing an administrative record regarding theparticular facts and circumstances of the named plaintiff's claim. Nevertheless, the Chorosevic decision confirms that, absent exhaustion of at least the named plaintiff's claim, there is no basis for proceeding with individual or class claims."  MORE >>