Law360 interviews Jeff Hahn

Stris & Maher partner Jeff Hahn was featured in a recent Law360 article analyzing the Eleventh Circuit’s influential decision in Rani Bolton et al. v. Inland Fresh Seafood Corporation of America, Inc. et al., which could reshape how courts handle administrative exhaustion requirements under the Employee Retirement Income Security Act (ERISA).

The article, titled “11th Circ. Ruling Could Unravel Strict ERISA Exhaustion Rule,” explores a unanimous Eleventh Circuit panel opinion that reaffirmed the circuit’s decades-old precedent requiring administrative exhaustion of ERISA claims — but also included a notable concurrence from two judges urging the full court to revisit and potentially overturn that rule.

In his comments to Law360, Hahn described the concurrence as a significant moment for plaintiffs: “Two judges on the panel endorsing en banc review of the case in a concurrence was a win for the plaintiffs,” Hahn said, calling the 1985 precedent “a textbook candidate for en banc review.”

Hahn further explained that the Eleventh Circuit’s longstanding rule imposes “an additional procedural hurdle that plaintiffs have to go through that potentially can result in their claims being time-barred.”

If the Eleventh Circuit reconsiders and overturns its precedent, it could bring the circuit in line with most other federal appeals courts, which do not require administrative exhaustion for fiduciary breach or statutory claims under ERISA. Such a shift would significantly affect the landscape of ERISA litigation for both employees and plan fiduciaries across the Southeast.

Stris & Maher’s ERISA and employee benefits team continues to play a central role in landmark cases shaping this evolving area of law.

To read the full Law360 article, click here (subscription required).