Under administrative-law principles, when may a plaintiff avoid exhausting administrative remedies?

Under administrative-law principles, when may a plaintiff avoid exhausting administrative remedies?

• A. If the agency has already granted relief.
• B. If the agency lacks authority to grant the requested relief.
• C. If the plaintiff's claim is purely legal and doesn't depend on agency action.
• D. If the relief sought would be duplicative of something already obtained in court.

Answer: (B)

Exhausting administrative remedies is generally required because agencies need the opportunity to interpret and apply the statutes they administer before courts intervene. The key exception is when the agency lacks authority to grant the relief the plaintiff seeks. If the agency cannot grant the requested remedy—because it lies outside its statutory power—there is nothing meaningful for the agency to decide, so requiring exhaustion would be futile and courts may review directly. The other scenarios don’t provide a valid bypass of the exhaustion rule. If the agency has already granted relief, the dispute may be moot or simply resolved, but that doesn’t establish a general rule allowing bypass of exhaustion. A claim that is purely legal and doesn’t depend on agency action might still involve the agency’s actions or interpretation somewhere in the process, and exhaustion isn’t automatically waived on that basis. And whether relief would be duplicative of what has already been obtained in court concerns duplicative relief, not the prerequisite of administrative review.

Exhausting administrative remedies is generally required because agencies need the opportunity to interpret and apply the statutes they administer before courts intervene. The key exception is when the agency lacks authority to grant the relief the plaintiff seeks. If the agency cannot grant the requested remedy—because it lies outside its statutory power—there is nothing meaningful for the agency to decide, so requiring exhaustion would be futile and courts may review directly.

The other scenarios don’t provide a valid bypass of the exhaustion rule. If the agency has already granted relief, the dispute may be moot or simply resolved, but that doesn’t establish a general rule allowing bypass of exhaustion. A claim that is purely legal and doesn’t depend on agency action might still involve the agency’s actions or interpretation somewhere in the process, and exhaustion isn’t automatically waived on that basis. And whether relief would be duplicative of what has already been obtained in court concerns duplicative relief, not the prerequisite of administrative review.