intended to carve out a narrow exception to a general no-exhaustion rule already understood to follow from § 1983. See id. at 512, 102 S.Ct. at 2565-66. Since Patsy, the Supreme Court, this court, and other circuit courts of appeals have confirmed that, as a general rule, exhaustion of state administrative remedies is not required prior to bringing suit under § 1983. See, e.g., Wilder v. Virginia Hosp. Ass’n, 496 U.S. 498, 523, 110 S.Ct. 2510, 2524, 110 L.Ed.2d 455 (1990) (“The availability of state administrative procedures ordinarily does not foreclose resort to § 1983.”); Felder v. Casey, 487 U.S. 131, 147, 108 S.Ct. 2302, 2311, 101 L.Ed.2d 123 (1988) (“plaintiffs need not exhaust state administrative remedies before instituting § 1983 suits in federal court 190-91 (4th Cir.1994) (<HOLDING>). Thus, courts universally agree that the
holding that exhaustion of administrative remedies is a mandatory prerequisite to a lawsuit under foia recognizing that exhaustion of state administrative remedies is not a prerequisite to bringing a  1983 action holding that the timely filing of an administrative charge of discrimination is a prerequisite to bringing suit holding that a courts authority to require exhaustion of administrative remedies in actions brought under the apa is limited when neither the statute nor agency rules specifically mandate exhaustion as a prerequisite to judicial review holding exhaustion of administrative remedies not required prior to bringing statutory claim under erisa