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Mya Brooks v. Metropolitan Life Ins. Co., et al.
State: Maryland
Court: Maryland District Court
Case Date: 10/09/2007
Preview:IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND MYRA BROOKS, Plaintiff * vs. * METROPOLITAN LIFE INSURANCE COMPANY and KPMG LLP EMPLOYEES LONG TERM DISABILITY PLAN, Defendants * * * * MEMORANDUM Now pending in this ERISA case is plaintiff Myra Brooks's ("Brooks") Motion to Augment the Administrative Record (Docket No. 20). According to Brooks, the record in this case is incomplete because it does not contain defendant Metropolitan Life Insurance Company's ("MetLife") internal claims processing guidelines. The parties have extensively briefed this issue, and the Court held a hearing on the motion on August 2, 2007. For the reasons stated herein, Brooks's motion is DENIED. I. Background Brooks is a participant in the KPMG LLP Employee Long Term Disability Plan ("the Plan"), which is insured and administered by MetLife. She applied for and received long term disability benefits in May 2004, but her benefits were terminated later that year. She successfully appealed the Plan's determination, and her benefits were reinstated in January 2005. In August 2005, however, the Plan again terminated Brooks's benefits and denied her appeal. Having exhausted her administrative remedies, Brooks now seeks review of the Plan's decision. -1Civil Action No. L-06-1527 *

II.

Discussion The parties agree that our review of the Plan's decision to terminate Brooks's benefits is

limited to the administrative record. See, e.g., Sheppard & Enoch Pratt Hosp., Inc. v. Travelers Ins. Co., 32 F.3d 120, 125 (4th Cir. 1994). "Generally, the Fourth Circuit defines the administrative record as those facts known to the administrator at the time the administrator made the benefits eligibility determination." Brodish v. Federal Express Corp., 384 F.Supp.2d 827, 823 (D.Md. 2005). The parties disagree, however, about the scope of the administrative record, which currently consists of KPMG's plan documents and MetLife's "claim file" for Brooks's claim. According to Brooks, the administrative record should also include MetLife's Claims Management Guidelines (the "CMG"), an internal corporate database offering general guidance to claims-processing personnel. In support of this argument, Brooks points to the regulations implementing the Employee Retirement Income Security Act of 1974 (ERISA). Pursuant to 29 C.F.R.
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