The exhaustion of administrative remedies is not required in an ERISA benefits case when a participant can “reasonably interpret” the plan to not require exhaustion

This case concerns the calculation of a participant’s benefit, and whether that benefit should include (among other things) an early retirement credit. The plan’s administrative procedures apply when a participant wants to “file a benefit claim,” but this participant wasn’t yet ready to file a claim or start receiving her benefit; she simply wanted to challenge the refusal to include the early retirement credit. So the participant sued rather than filing an administrative claim, and the lawsuit was dismissed by the district court because she failed to exhaust her administrative remedies before going to court.

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