By 1974, the U.S. Congress recognized that employer-provided retirement pension plans had “become an important factor affecting the stabilization of employment and the successful development of industrial relations” and enacted the Employee Retirement Income Security Act (ERISA) with the aim of protecting “the interests of participants in employee benefit plans and their beneficiaries.” In enacting ERISA, Congress established “standards of conduct, responsibility, and obligation[s] for fiduciaries of employee benefit plans” and provided for “appropriate remedies, sanctions and ready access to the Federal courts.” Apart from creating federal causes of action to ensure efficient and equitable administration of private pension plans, Congress also mandated that pension plan providers establish certain administrative procedures through which beneficiaries may seek redress in the event of conflict. The dual and, at times, conflicting aims of providing plan participants access to federal courts while simultaneously attempting to strengthen internal remedies made available by the providers have created significant debate in federal courts. On the one hand, some federal courts, focusing on the analyses on Congress’ intention that pension plan providers create and develop internal procedures through which aggrieved participants may seek relief, have held that the exhaustion of these internal remedies by employees is a prerequisite to bringing a federal court claim under ERISA. On the other hand, the majority of federal circuit courts have held that Congress’ explicit intent to provide pension plan participants a form of relief under federal law does not require that they first exhaust all internal administrative remedies provided to them by plan providers before bring an ERIDA claim. These two competing viewpoints have created a split among the federal circuits, and Stephens v. Pension Benefit Guaranty Corp. is a recent case that considered the exhaustion doctrine and furthered deepened the rift among the courts.

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