Mealey's (February 18, 2020, 10:59 AM EST) -- PHILADELPHIA — The Third Circuit U.S. Court of Appeals on Feb. 13 upheld a New Jersey federal judge’s determination that a claim for benefits due under a health plan governed by the Employee Retirement Income Security Act cannot proceed in view of a plaintiff’s failure to exhaust all administrative remedies prior to filing suit (Jay Minerley v. Aetna Health Inc., et al., No. 19-2730, 3rd Cir., 2020 U.S. App. LEXIS 4626)....