Mealey's (January 28, 2022, 10:41 AM EST) -- NEW YORK — The Second Circuit U.S. Court of Appeals on Jan. 27 affirmed a district court’s denial of a disability claimant’s motion to amend a complaint to assert a cause of action under the Employee Retirement Income Security Act, agreeing with the lower court’s conclusion that amendment would be futile as the claimant failed to exhaust all administrative remedies prior to filing suit....