"Pension plan beneficiaries need not exhaust internal remedial procedures before proceeding to federal court when they assert violations of ERISA's substantive guarantees.... Because Appellants assert a right granted them by ERISA's regulations -- the right to receive a lump sum payment without unreasonable delay -- they assert a statutory claim not subject to the exhaustion requirement. In other words, Appellants assert a statutory claim because the district court on remand will have to evaluate the plan's administration under a reasonableness standard created and defined by federal law." [Stephens and Mahoney v. PBGC, No. 13-5129 (D.C. Cir. June 24, 2014)]

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