Eleventh Circuit Reverses Course on ERISA Administrative Exhaustion

On October 13, 2026, the US Court of Appeals for the Eleventh Circuit overturned its 1985 decision in Mason v. Continental Group, Inc., 763 F.2d 1219 (11th Cir. 1985), which imposed a mandatory administrative exhaustion requirement for all statutory claims (including those alleging a breach of fiduciary duty) brought under the Employee Retirement Income Security Act (“ERISA”).