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Eleventh Circuit Reaffirms Strict ERISA Exhaustion Requirement for Fiduciary-Breach Claims
Roberts Disability Law 
Oct. 17, 2025 "[T]he court emphasized that exhaustion applies 'across the spectrum of ERISA claims' -- including those alleging statutory violations or fiduciary breaches. While acknowledging that most other circuits do not require exhaustion for statutory ERISA claims, the Eleventh Circuit reaffirmed its unique position, holding itself bound by Mason until abrogated by the Supreme Court or by the court en banc." [Bolton v. Inland Fresh Seafood Corp. of Am., Inc., No. 24-10084 (11th Cir. Oct. 15, 2025)] MORE >> |
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