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In this article, Jenner & Block Partner Joseph J. Torres explains that courts have long required that claimants in ERISA disputes exhaust any applicable claims procedures contained in the plan before filing suit. He highlights the Sixth Circuit’s recent decision in Wallace v. Oakwood Healthcare, Inc., which raises intriguing arguments about the validity of such a judge-made requirement. “And even if the exhaustion requirement is not going away, the principal opinion in Wallace provides some important reminders for plan administrators who seek the benefits of the exhaustion obligation,” he observes. Mr. Torres addresses the cautionary tale and considers the arguments regarding exhaustion’s continued viability.