South Florida Blood Bank, Inc. v. Futch

In the lawsuit below, appellee/cross-ap-pellant Clara Futch obtained a judgment against her employer, South Florida Blood Banks, Inc., for medical costs under the Blood Bank’s health plan. We reverse, because Futch’s failure to exhaust her administrative remedies under the health plan rendered her suit premature.

The Blood Bank’s health plan was administered by Hospital Benefits, Inc. On June 28, 1995, the president of Hospital Benefits wrote Futch and told her that there was no coverage available for certain medical claims based on the plan’s “preexisting conditions limitation.” The letter…