The recent Supreme Court decision in Levers v. Anderson held that the rule that one must exhaust his administrative remedies before he is entitled to judicial review does not operate automatically so as to preclude judicial relief when such relief has been expressly permitted by statute. Stated in this way, it is difficult to see how one could reach a different conclusion. Nevertheless, it is believed that this decision, which resulted in a reversal of a circuit court's judgment, did much to remove certain confusion in this field.
James E. Dunlap S.Ed.,
ADMINISTRATIVE LAW-EXHAUSTION OF ADMINISTRATIVE REMEDIES AS A PREREQUISITE TO JUDICIAL REVIEW-DISCRETIONARY TREATMENT BY FEDERAL COURTS,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol44/iss6/7