Thompkins
Thompkins v. BC LIFE AND HEALTH INS. CO.
Opinion
Opinion
Cooper, J.
ORDER ON ADMINISTRATIVE REVIEW
This matter is before the Court on administrative review. The Court has reviewed the parties’ briefs and the administrative record. As explained herein, the Court reviews the administrative decision de novo and concludes that Plaintiff is entitled to benefits under the Plan.
I. Background
This action arises out of a dispute over entitlement to benefits under a policy of insurance governed by the Employee Retirement Income Security Act, 29 U.S.C. §§ 1001 — 1461 (“ERISA”). The parties dispute what law governs regarding the level of benefits that must be provided for psychological conditions such as that suffered by Plaintiff Amy Thompkins. The parties also dispute the relevant standard of review. Ultimately, the Court concludes that California’s parity law applies and that the relevant standard of review is de novo. Employing the de novo standard of review, the Court concludes that Plaintiff is entitled to benefits under the Plan.
II. Consideration of Additional Evidence
Upon de novo administrative review in an ERISA case, a district court may consider evidence not in the administrative record where such evidence will “enable [the court to]…