(September 23, 2015, 5:33 PM EDT) -- PHILADELPHIA — A district court erred in dismissing a putative class action complaint alleging wrongful denial of benefits under the Employee Retirement Income Security Act because a chiropractor has standing to pursue his claims against the health benefits provider and questions of fact exist regarding whether a plan participant exhausted her administrative remedies prior to filing suit, the Third Circuit U.S. Court of Appeals said Sept. 11 (American Chiropractic Association, et al. v. American Specialty Health Inc., No. 14-1832, 3rd Cir.; 2015 U.S. App. LEXIS 16196)....