Rani Bolton, et al v. Inland Fresh Seafood Corporation of America, Inc., et al
Split Score
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Case Summary
Disposition
Affirmed
The Eleventh Circuit affirmed the district court’s dismissal of class-based ERISA fiduciary-breach claims because the plaintiffs failed to exhaust the plan’s internal administrative remedies before suing. The panel held that, under binding circuit precedent, exhaustion is mandatory for statutory and fiduciary-breach claims and none of the plaintiffs’ excuses—futility, plan language, or inadequate remedy—applied; it remanded only so the trial court can clarify whether the dismissal is without prejudice.
Circuit Split Identified
Legal Issue
Whether ERISA plaintiffs asserting statutory or fiduciary-breach claims (as opposed to simple benefit-denial claims) must exhaust a plan’s internal administrative remedies before filing suit in federal court.
Circuit Positions
Mandatory exhaustion of administrative remedies for ERISA fiduciary-breach/statutory claims.
Exhaustion not required for ERISA fiduciary-breach/statutory claims.
Exhaustion generally favored but left to district-court discretion for fiduciary-breach/statutory claims.
Conflict Summary
The Eleventh Circuit continues to require mandatory, pre-suit exhaustion for all ERISA claims, including statutory and fiduciary-breach causes of action. In contrast, the Third, Fourth, Fifth, Sixth, Ninth, Tenth, and D.C. Circuits hold that exhaustion is not required for statutory/fiduciary-breach actions, and the Seventh Circuit treats exhaustion for such claims as discretionary rather than mandatory.