Corey Rosen
11th Circuit Overturns Administrative Remedy Exhaustion Requirement for ERISA Plaintiffs
In an en banc decision, Bolton v. Inland Fresh Seafood Corp. of Am., Inc., No. 24-10084 (11th Cir. Oct. 13, 2026) (en banc), the 11th Circuit Court of Appeals overturned a lower court ruling that required ESOP participants to exhaust all their administrative remedies before bringing fiduciary claims under ERISA in court. The decision brings the 11th Circuit in line with most of the other circuit courts.