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District Court Holds Administrative Exhaustion Is Required Even When Not Mentioned in Plan Document
Jackson Lewis P.C. Link to more items from this source
June 7, 2021

"The Court emphasized the practical reasons favoring exhaustion mean that 'claimants with notice of an available review procedure should know that they must take advantage of that procedure if they wish to bring wrongful benefit denial claims to court.' Thus, the Plaintiff was required to exhaust the administrative remedy described in permissive terms in the denial letter, even though there was no administrative appeal provision in the plan." [Yates v. Symetra Life Ins Co., No. 19-154 (E.D. Mo. May 26, 2021)]

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