Does an ERISA plaintiff have to exhaust administrative remedies before commencing an action in federal court?

As discussed above, an ERISA plaintiff must exhaust administrative remedies prior to commencing an action in federal court. Barboza, 651 F.3d at 1076. However, "there are occasions when a court is obliged to exercise its jurisdiction . . . when resort to the administrative route is futile or the remedy inadequate." Amato, 618 F.2d at 568 (quoting Winterberger v. General Teamsters Auto Truck Drivers & Helpers Local Union 162, 558 F.2d 923, 925 (9th Cir. 1977)). Consequently,

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