VanHarken v. City of Chicago, 103 F.3d 1346, 1349 (7th Cir.1997) {Patsy expressly rejected a requirement of exhausting administrative remedies before suing under § 1983); Jeremy H. v. Mt. Lebanon Sch. Dist., 95 F.3d 272, 283 n. 20 (3d Cir.1996) (“the policies of section 1983 strongly disfavor the imposition of additional exhaustion requirements”); Thornquest v. King, 61 F.3d 837, 841 n. 3 (11th Cir.1995) (“a section 1983 claim cannot be barred by a plaintiff’s failure to exhaust state administrative remedies with respect to an unreviewed administrative action”); Woods v. Smith, 60 F.3d 1161, 1165 (5th Cir.1995) (“[EJxhaustion of state judicial or administrative remedies is not a prerequisite to the bringing of a section 1983 claim.”); Wilbur v. Harris, 53 F.3d 542, 544 (2d Cir. 1995) (<HOLDING>); Hall v. Marion Sch. Dist. No. Two, 31 F.3d
holding that exhaustion of administrative ie company or planprovided remedies is an implicit prerequisite to seeking judicial relief pursuant to erisa holding that exhaustion of administrative remedies is a mandatory prerequisite to a lawsuit under foia holding that the timely filing of an administrative charge of discrimination is a prerequisite to bringing suit holding exhaustion of administrative remedies not required prior to bringing statutory claim under erisa recognizing that exhaustion of state administrative remedies is not required as a prerequisite to bringing an action pursuant to  1983