Bald Mountain Holdings, LLC v. Aetna Health Insurance Company
ORDER denying 12 Motion to Supplement the Administrative Record. Signed by District Judge John Corbett O'Meara. (WBar)
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
BALD MOUNTAIN HOLDINGS, LLC,
Case No. 16-13518
Hon. John Corbett O’Meara
AETNA HEALTH INSURANCE CO.,
ORDER DENYING PLAINTIFF’S MOTION
TO SUPPLEMENT THE ADMINISTRATIVE RECORD
Before the court is Plaintiff’s motion to supplement the administrative
record, which Defendant opposes. Plaintiff filed this action to recover benefits
under an Aetna group health insurance plan pursuant to ERISA. Plaintiff seeks to
supplement the administrative record with a document that Defendant contends it
never received and was not part of its file.
In its review of Defendant’s decision to deny benefits, the court is “confined
to the record that was before the Plan Administrator.” Wilkins v. Baptist
Healthcare Sys., Inc., 150 F.3d 609, 615 (6th Cir. 1998). Plaintiff has not
demonstrated that the document it seeks to include in the administrative record was
in fact “before the Plan Administrator.” See Def.’s Ex. A, Declaration of Kimberly
Depaepe; Pl.’s Ex. 2, Affidavit of Brittany Davey. In addition, Plaintiff has not
established that the court may otherwise consider the document at issue. See id. at
619 (“The district court may consider evidence outside of the administrative record
only if that evidence is offered in support of a procedural challenge to the
administrator’s decision, such as an alleged lack of due process afforded by the
administrator or alleged bias on its part.”).
Accordingly, IT IS HEREBY ORDERED that Plaintiff’s motion to
supplement the administrative record is DENIED.
s/John Corbett O’Meara
United States District Judge
Date: June 21, 2017
I hereby certify that a copy of the foregoing document was served upon
counsel of record on this date, June 21, 2017, using the ECF system.
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