ATLANTA - A federal district court properly exercised its discretion in not excusing a health benefits plan participant's failure to exhaust her administrative remedies before filing an action under the Employee Retirement Income Security Act challenging the plan's denial of benefits, the 11th Circuit U.S. Court of Appeals affirmed Nov. 6 in an unpublished opinion (Florida Health Sciences Center, Inc., et al. v. Total Plastics, Inc., No. 12-11537, 11th Cir.; 2012 U.S. App. LEXIS 22770).