By Niya Ge
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This Note argues that when a cause-of-action is based on a statutory breach, employee benefit plan participants and beneficiaries under ERISA should not be mandated to exhaust internal administrative remedies provided by the plan before filing suit in district court. This Note provides a brief background of the relevant ERISA provisions, and will then overview various court decisions and rationales falling on both sides of the issue. This Note argues that an administrative exhaustion requirement does not align with the plain language and Congressional intent of ERISA, and such a reading will only force aggrieved participants and beneficiaries to partake in an inefficient and futile procedural obstacle.