NOT RECOMMENDED FOR PUBLICATION File Name: 06a0304n.06 Filed: May 3, 2006 No. 05-3380 UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT

CHARLES BUCHANAN, Plaintiff-Appellant,

v. AETNA LIFE INSURANCE COMPANY, Defendant-Appellee. / On Appeal from the United States District Court for the Northern District of Ohio

BEFORE: RYAN, CLAY, and GILMAN, Circuit Judges. RYAN, Circuit Judge. The plaintiff, Charles Buchanan, appeals the district court’s judgment in favor of the defendant, Ae tna Life Insurance Company, on his ERISA claim for disability benefits, and on Aetna’s count erclaim for reimbursement of benefits it overpaid Buchanan. We AFFIRM the court’s judgment in favor of Aetna on Buchanan’s claim, but REVERSE the grant of summary judgment in favor of Aetna on its counterclaim. I. Buchanan began working as a computer pr ogrammer for Progressive Casualty Insurance Company in September 1996 and was a participant under Progressive’s Managed Disability Benefits Plan, which was admin istered by Aetna. Under the plan, a participant was eligible to receive disability benefits after a period of 24 months only if he was “not able, solely because of disease or injury, to work at any reasonable occupation.”(No. 05-3380) - 2 - The plan defined “reasonable occupati on” as “any gainful activityfor which you are, or may reasonably become, fitted by educati on, training or experience.” An eligible plan participant received a monthly disability benefit equal to a percentage of his monthly salary, and the pl an permitted Aetna to reduce that monthly benefit by “other income benefits,” which in cluded Social Security Disability Insurance (SSDI) benefits. The plan also provided that the participant was required to repay to Aetna any overpayment of benefits thatresulted from the receipt of other income benefits. II. In June 1997, Buchanan left work due to hypertension and syncope, and began to receive monthly disability benefits from Aetna in October 1997. In addition, he began receiving SSDI benefits in January 1998. Aetna claims it di d not learn about Buchanan’s SSDI payments until September 1999. In a letter dated October 7, 1999, Aetna informed Buchanan that it had overpaid him by a total of $15,120 as a result of his receiving SSDI benefits in addition to Aetna’s full monthly benefit. In order to recover at l east part of that over payment, Aetna began to withhold benefit payments, but Aetna alleges that approxim ately $11,000 remains unpaid. In 2000, Aetna conducted a review of Bu chanan’s claim and concluded that he was no longer entitled to disabilit y benefits because he had received benefits for more than 24 months, and the evidence showed that he was able to perform the duties of a reasonable occupation as defined by the plan. In a letter dated July 2000, Aetna informed Buchanan that his benefits were terminated effectiv e May 31, 2000. Buchanan asked Aetna to reconsider its decision, but, in a letter to Buchanan dated April 2, 2001, Aetna upheld its original decision.(No. 05-3380) - 3 - Buchanan filed a claim in the federal district court to recover benefits under ERISA § 502(a)(1)(B), 29 U.S.C. § 1132(a)(1)(B), and Aetna filed a counter claim under ERISA for reimbursement of benefits it allegedly overpaid. Buchanan filed a motion to supplement the administrative record with, among other things, a 1997 MR I film and report that Aetna and its independent medical examinerhad allegedly refused to acc ept. The district court denied that motion. Both parties then filed motions for judgment, and the court granted judgment in favor of Aetna on Buchanan’ s claims and Aetna’s counterclaim. III. Traditional summary judgment concepts are inapposite to the adjudication of an ERISA action for benefits, br ought under 29 U.S.C. § 1132(a)(1 )(B), because the district court is limited to the evidence before the plan administrator at the time of its decision, and therefore, the court does not adjudicate an ERISA action as itwould other federal civil litigation. See Wilkins v. Baptist Healthcare Sys., Inc. , 150 F.3d 609, 617-19 (6th Cir. 1998). We review de novothe district court’s ru ling regarding an ERISA plan administrator’s denial of benefit s, applying the same legal st andard as the district court. Whitaker v. Hartford Life & Acc. Ins. Co. , 404 F.3d 947, 949 (6th Cir. 2005). When the plan provides the administrator di scretionary authority to determi ne eligibility for benefits, the arbitrary and capricious standar d of review applies. Id. The district court held that Aetna had discretionary authority under the plan to determine benefit eligibility, and Buchanan appears to agree. Therefore, we review Aetna’s decision denying benefits under the arbitrary and capricious standard of review. An administrator’s conflict ofinterest does not alter t he standard of review; rather, the court should take that conflict in to account when determining whether the(No. 05-3380) - 4 - administrator’s decision was arbitrary and capricious. Pe ruzzi v. Summa Med. Plan , 137 F.3d 431, 433 (6th Cir. 1998). We must uphold Aet na’s decision “if it is the result of a deliberate, principled reasoning process and ifit is supported by substantial evidence.” Baker v. United Mine Workers of Am. Health & Ret. Funds , 929 F.2d 1140, 1144 (6th Cir. 1991). Because Aetna was both the insurer and the plan administrator, it had a conflict of interest. Although the district court discussed tr aditional summary judgment standards at some length, the court nevert heless properly applied the arbi trary and capricious standard of review using the evidence available to Aet na at the time of its decision. The court acknowledged Aetna’s conflict of in terest and the requirement that it factor that conflict into its review. The court then det ermined that Aetna did not act in an arbitrary and capricious manner when it terminated Buchanan’s benefi ts because reports from two independent medical examiners provided a “reasoned ex planation” for Aetna’s decision. Buchanan points out that, in a letter, his doctor stated: “The resulting disability produced by this condition has produced a severe degree of cognitive impairment and fatigability which I strongly feel makes him di sabled from working. . . . I believe Mr. Buchanan is disabled from his previous type of employment (and perhaps from manytypes of meaningful employment).” (Emphasis added.) But the te st, according to the plan language, is whether Buchanan was able to wo rk at a “reasonable occupation,” which is defined in the plan as “anygainful activity.” (Emphasis added.) The record shows that two independent medical examiners concluded that Buchanan could perform meaningful work. Although Aetna’s April 2, 2001, letter upholdi ng its original decision to terminate Buchanan’s benefits indicates that Aetna review ed a portion of medical records belonging(No. 05-3380) - 5 - to someone other than Buchanan, we respectfu lly disagree with our dissenting colleague’s position that Aetna’s error rendered it s decision arbitrary and capricious. The April 2, 2001, letter contains an inco rrect address and social security number, and it states that there is “no record provided of the cardiac cath findings,” but that “[t]here are clear reports . . . of panic attacks and anxiety disorder, which responded to Xanax.” Buchanan insists that he has neverreceived a cardiac catheter or taken Xanax to control anxiety, and there is no evidence in the record suggesting he has. The letter also references the two i ndependent medical examinat ions Aetna ordered and the letter from Buchanan’s doctor, which pr ovide substantial evidence in support of Aetna’s decision to terminate Buchanan’s disabilit y benefits. There is also no indication that Aetna’s mistake of reviewing a porti on of medical records belonging to someone other than Buchanan resulted in a selective, i nadequate, or otherwise unpr incipled review of Buchanan’s medical records. Therefore, we agree with the district court that the record contains substantial evidence supporting Ae tna’s decision to terminate Buchanan’s disability benefits and that Aet na employed “a deliberate, pr incipled reasoning process” to reach that decision. We also conclude that the court did not err in denying Buchanan’s motion to supplement the administrative record with, among other things, a 1997 MRI film and report indicating that he suffered a stroke. The distri ct court may consider evidence outside of the administrative record only if “consideration ofthat evidence is necessary to resolve an ERISA claimant’s procedural challenge to the adm inistrator’s decision, such as an alleged lack of due process afforded by the administrat or or alleged bias on its part.” Wilkins , 150 F.3d at 618. Buchanan did not raise a procedur al challenge to Aetna’s decision in his(No. 05-3380) - 6 - motion to supplement the record. He simplyargued that “the record is flawed and not developed properly,” and he offered no evidence in support of the motion beyond the mere allegation that Aetna refused to a ccept the proper MRI film and report. IV. Traditional summary judgment concepts do apply to the adjudication of Aetna’s counterclaim for reimbursement. We review t he district court’s legal conclusions and its grant of summary judgmentin favor of Aetna de novo , using the same Fed. R. Civ. P. 56(c) standard as the district court. Summary j udgment is proper only where “the pleadings, depositions, answers to interrogatories, and admissions on file , together with the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law.” Fed. R. Civ. P. 56(c) ; Appalachian Res. Dev. Corp. v. McCabe , 387 F.3d 461, 463 (6th Cir. 2004). The parties do not dispute the facts. Th e terms of the plan clearly provide that Buchanan is obligated to reimburse Aetna for t he benefits it overpaid as a result of his receipt of SSDI benefits. Buchanan argues only that the law does notprovide Aetna with a remedy. Unfortunately, we must agree. The Supreme Court’s decision in Great-West Life & Annuity Insurance Co. v. Knudson , 534 U.S. 204 (2002), and our later decision in Qualchoice, Inc. v. Rowland , 367 F.3d 638 (6th Cir. 2004), cert. denied , 125 S. Ct. 1639 (2005), prohibit Aetna from recove ring the money it overpaid. 29 U.S.C. § 1132(a)(3) provides that an ERISA civil action may be brought: by a participant, beneficiary, or fi duciary (A) to enjoin any act or practice which violates any provision ofthis subchapter or the terms of the plan, or (B) to obtain otherappropriate equitable relief(i) to redress such violations or (ii) to enfor ce any provisions of thissubchapter or the terms of the plan.(No. 05-3380) - 7 - (Emphasis added.) In Knudson , the Supreme Court held that the term “equitable relief” in 29 U.S.C. § 1132(a)(3) refers to the categories of relief typicallyavailable in equity. Knudson , 534 U.S. at 209-10. The C ourt further explained that notall forms of restitution were available in equity and that “a plaintiff could seek restitution in equity , . . . where money or property identified as belonging in good conscience to the plaintiff could clearly be traced to particular funds or propertyin the defendant’s possession.” Id. at 213. The money Aetna claims it overpaid to Bu chanan is not clearly traceable to particular funds in his possession. Although Aetna c haracterizes its claim as one for unjust enrichment, it actually seeks “legal relief—t he imposition of personal liability . . . for a contractual obligation to pay money.” Id. at 221. As we held in Qualchoice , “a plan fiduciary’s action to enforce a plan-reimbursem ent provision is a legal action,” which 29 U.S.C. § 1132(a)(3) does not authorize. Qualchoice , 367 F.3d at 650. V. For these reasons, we AFFIRM the district court’s judgment in favor of Aetna on Buchanan’s claim for benefits under 29 U.S.C. § 1132(a)(1)(B), and we REVERSE the court’s grant of summary judgm ent in favor of Aetna on the counterclaim for reimbursement of benefits it overpaid and REMAND to the district court.(No. 05-3380) - 8 -

1 syncope: a temporary suspension of consciousness due to generalized cerebral ischemia (deficiency in blood). Dorland’s Illustrated Medical Dictionary 1514 (25th ed. 1974). Clay, Circuit Judge, dissenting in part. I agree that the di strict court improperly granted summary judgment to Defendant on Defendant’s recoupment of overpayments claim. I disagree with the majority, however , that Defendant’s denial of benefits was the result of a “deliberate, pr incipled reasoning process” becaus e the evidence clearly shows that Defendant considered, in part, someone else’s medical records when it evaluated Plaintiff’s case. I would therefore vacate the grant of summary j udgment for Defendant on Plaintiff’s denial of benefits clai m and remand the case to the di strict court, with instructions for further remand to the plan adm inistrator for a proper consider ation of Plaintiff’s claim for benefits. I. BACKGROUND On September 16, 1996 Plaintiff was hir ed by Progressive Insurance Co. as a computer programmer/analyst. Plaintiff then enrolled in Progressive’s ERISA-governed disability benefits plan, for which Def endant was the claims administrator. Plaintiff had a history of hypertension, whic h Plaintiff alleges was under control until February 1997, at which time Plaintiff underwent an appendectomy. Subsequent to the appendectomy, Plaintiff's recovery was difficult and resulted in an increase in his hypertension and a “cerebrovascular accident.” Plaintiff left work on June 5, 1997 due to hypertension and syncope, 1 and in October 1997 Plaintiff's treating physician diagnosed(No. 05-3380) - 9 -

2 infarct: an area of coagulation necrosis in a tissue due to local ischemia resulting from obstruction of circ ulation to the area. Dorland’s Illustrated Medical Dictionary, supra note 1 , at 778. the likely cause of the syncope as a stroke, or brain stem infarct, 2in early June 1997. After performing an MRI to confirm the infarct, Plaint iff's physician, Dr. Gr ubb, diagnosed Plaintiff with autonomic dysfunction resulting from damage to the brain stem area controlling autonomic function. Plainti ff’s condition resulted in extreme migraines and fatigability, in addition to syncopal episodes. Plaintiff applied for and received disability benefits commencing in October 1997. On October 7, 1999, Defendantrequested reimbursement fr om Plaintiff for alleged overpayments for the period of January 1, 1998 through Sept ember 30, 1999, during which time Plaintiff was also receiv ing social security disability payments. Defendant alleged that long term disability payments were offset under t he plan to the extent of any social security disability monies received. After 24 months of disability, Plainti ff’s disability plan provided for continuing payments only if a claimant “cannot perform a ll of the material duties of any gainful occupation for which [claimant] [is] or may become reasonably fitted bytraining, education or experience.” (J.A. at 201.) Defendant t herefore undertook a review of Plaintiff’s disability status in 2000. In a letter dated July 13, 2000, Defendant informed Plaintiff that its review of Plaintiff's condition did not s upport Plaintiff's continued status as disabled. Defendant stated that informati on provided by Plaintiff’s a ttending physician, a Dr. Grubb, indicated that there was no objective in formation which supported Plaintiff's ongoing disability. Defendant furthernoted that based on information fr om Dr. Grubb, it “appears(No. 05-3380) - 10 - your condition is under reasonable control and you would be able to perform the duties of sitting, computer keyboarding [and] pr ogramming, and phone work.” (J.A. at 201.) Defendant therefore terminated Plaintiff's disability benefits as of May 31, 2000. On July 24, 2000 Plaintiff appealed Defendant 's termination of benefits through Defendant's administrative appeal s procedure. Defendant subm itted a letter from Dr. Grubb which referenced the MRI confirming the brain stem stroke and repeating his diagnosis of autonomic disorder manifesting in cognitive impairment, se vere migraines, and fatigability. The letter also stated Dr. Grubb’s opinion that Plaintiff “is disabled from his previous employment (and perhaps from many types of meaningf ul employment ).” (J.A. at 171.) Defendant then referred Plaintiff fo r evaluation by independent medical personnel of the North American Medical Evaluations, Inc. Plaintiff was given a psychological evaluation and a medical exam. The psychol ogist determined that Plaintiff performed in the average range of cognitive f unction, exhibited mild impairm ent in some motor function, exhibited mild depression, and showed difficulty in maintaining alertness. The psychological report concluded that Plaintiff could return to work if given accommodations such as frequent breaks to refresh alertness. Plaintiff’s independent medical examination took place on November 21, 2000. In the letter notifying Plaintiff of the medical appoi ntment, Defendant invited Plaintiff to “obtain and bring any medical records, X-ray films, MRI films and any test results to assist in this evaluation.” (J.A. at 169.) Defendant allegesthat Plaintiff produced no MRI showing his brain stem infarct. Plaintiff alleges that Plaintiff brought the rele vant MRI, dated September 29, 1997, with him to the medical evaluation, but that the physician refused to take the film from Plaintiff, saying instead that the physici an would procure the MRI from the hospital.(No. 05-3380) - 11 - Plaintiff further alleges that his wife sent a copy of the re levant MRI to Defendant at some time. The independent medical evaluation concluded that “[t]he patienthas hypertension and depression. There is no clearcut explanat ion of his episodic complaints. Of note, however, I see no clearcut reason why this patient could not perform his previous employment.” (J.A. at 151.) Earlier in t he letter, the physician noted that Plaintiff took Celexa for his depression. The physician furt her noted that while Pl aintiff’s wife reported to him an MRI revealing a stroke, the “offici al report . . . on t he head MRI study obtained through . . . Akron General Medical Center [dated] October 23, 1998 was negative except for ‘mild bilateral maxillary and et hmoid sinusitis.’” (J.A. at 150.) There is no indication in Plaintiff’s medica l records from his treating physicians that Celexa was described for depression. Rat her, Celexa, while a popular antidepressant, appears to have been prescribed by Dr. Grubb to address Plaintiff’s headaches and extreme fatigue. ( See J.A. at 190.) Nothing in Plaintiff’s medical records reveals a diagnosis of depression by his attending physicians. ( See J.A. at 223, Medical Provider Statement by Dr. Grubb, not ing diagnosis of syncope and autonomic disorder, but not depression, and recording Celexa as a prescribed medication).) In a letter dated April 2, 2001, Defendant denied Plaintiff’s appeal of the termination of his disability benefits. The letter was addr essed to Plaintiff, but contained the wrong address and the wrong social security number. The letter summarized Defendant’s assessment of Plaintiff's claim: Your diagnosis is autonomic dysfunction syndrome, stroke secondary to anesthesia during surgery and cervical pain.(No. 05-3380) - 12 -

3 Defendant had Plaintiff surveilled on May 11, 13, and 15, 2000. The surveillance reports indicated that Plaintiff was observed on May 11 operating a Mazda pick-up three times, and on May 13 he operated the same tru ck for a single trip to the local middle school. (J.A. at 198-200.) You have been out of work as a Co mputer Programmer/Analyst since June 5, 1997 due to hypertension syncope. Office notes indicate that you were told in October, 1997 that you may have had a stroke over the summer. Rehabilitation followed your case wit h the onsite individual from October 1997. In June, 1998, it appear ed that you were released to return to work but you developed panic attacks therefore a p sychiatric referral was made. You had medication changes that made you ill that psychiatric referral was cancelled and was not rescheduled. Ot her notes indicate that you had a cardiac cath[eter] on August 4, 1999 with discharge on August 5, 1999 with possible surgery indicated, but no su rgery was noted. On February 15, 2000 notes your doctor reported that y ou have had no recent syncopal episodes and your blood pressure was well contro lled. You stated you may possibly have sleep apnea but sleep studies were normal. There are numerous reports from you and your wife regarding your symptoms but there is verylittle objective medical information. The objective information that is present was all pr ovided in the first 2 years of your disability. There is no clinical reco rd provided to substantiate seizure disorder, no MRI report confirming a stro ke and no record provided of cardiac cath findings. There are clear reports from your doctor’s officer of panic attacks and anxiety disorders, which responded to Xanax. There have been no observable, objective tests, which substantiate total disability to any reasonable occupation. You reported you were unable to driv e due to severity of fatigue and sleepiness, but surveillance is report ed to clearly document otherwise. 3 (J.A. at 374-75.) There is no indication in Plaintiff’s medica l records that Plaintiff ever received a cardiac catheter or was ever even referr ed for such a procedure, and Plaintiff denies undergoing any. Plaintiff further alleges that the denial letter references medications that Plaintiff never took. Plaintiff’s address was, at all relevant times, 372 East Cassell Ave., Barberton, OH 44203. The letter was addre ssed to Plaintiff at 6020 Periwinkle Dale,(No. 05-3380) - 13 - Seneca, SC 29672. Plaintiff’s social securi ty number is xxx-xx-2752. The letter referenced social security number xxx-xx-6220. (full social security numbers omitted for confidentiality purposes) II. ANALYSIS A. The District Court Erred by Refusing to Permit Wilkins Discovery This Court reviews the district court’ s decision on whether to permit discovery beyond the administrative record de novo

. Cf. Putney v. Medical Mut. , 111 Fed. Appx. 803, 806 (6th Cir. 2004) (unpublished opinion). Plaintiff argues that the dist rict court should have granted Plaintiff’s motion to either supplement the administrative record or re mand for correction because Defendant violated Plaintiff's procedural due process rights when itrefused to consider the September 27, 1997 MRI. Plaintiff presents evidence that the MRI had been available to Defendant (Plaintiff's wife having proffered the MRI to the physician performing the independent medical evaluation) in the form of an affidavit fr om Plaintiff and Plainti ff’s wife; the affidavit had the referenced MRI attached. ( See J.A. at 48-50.) Defendant asserts in briefs to this Court that the MRI's lack of pr esence in the administrative re cord proves its unavailability to Defendant, but puts forth no evidence, save t he state of the administr ative record itself, in support of that assertion. In Wilkins , this Court clarified when and to w hat extent a district court may go beyond the administrative record in revi ewing an ERISA administrator’s decision. Wilkins(No. 05-3380) - 14 - v. Baptist Healthcare Sys., Inc. , 150 F.3d 609, 618-19 (6th Cir. 1998) . This Court instructed district courts to follow a two-step proc ess in adjudicating an ERISA benefit action: 1. As to the merits of the action, the district court should conduct a de novo [or arbitrary and capricious] review based solely upon the administrative record, and render findings of fact and c onclusions of law accordingly. The district court may consider the parties’ arguments concerning the proper analysis of the evidentiary materials c ontained in the administrative record, but may not admit or consider anyevidence not presented to the administrator. 2. The district court may consider evidence outside of the administrative record only if that evidence is offer ed 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. This also means that any prehearing discovery at the district court level should be limited to such procedural challenges. Id. Plaintiff has alleged a procedural violat ion by Defendant. If true, the procedural violation is significant, for it wrongfully pr ecluded the only fully objective medical evidence of the cause of Plaintiff's condition from a ppearing in the administrative record. Under Wilkins , the district court should have permitted di scovery to the extent the parties could adduce evidence as to whetherDefendant had the September 1997 MRI available to it when ruling on Plaintiff’s claim for continued benefits. Should discovery have revealed that Defendantdid have the MRI available to it, the district court could have followed one of two rec ourses. First, the district court could have permitted the parties to supplement the adminis trative record with the MRI and any relevant medical interpretati ons of the MRI. Id. Second, and perhaps more appropriately, the district court could have remanded the case to the administrator . Vanderklok v. Provident Life & Accident Ins. Co. , 956 F.2d 610, 619 (6th Cir. 1992). While remand is appropriate(No. 05-3380) - 15 -

4 Plaintiff argues that the dist rict court did not properly consider Defendant’s conflict of interest insofar as Defendant is both the clai ms administrator and the insurer. This Court has repeatedly held that such a conflict of interest does notchange the standard of review, but is factored into the analysis going to whetherthe administrator’s decision was arbitrary and capricious. See Darland v. Fortis Benefits Ins. Co. , 317 F.3d 516, 527 (6th Cir. 2003). only in those cases where some useful purpose would be served from remand, the inclusion of the MRI in the administrative re cord, as the only objective evidence of the cause of Plaintiff's condition, is central tothe benefits determination and therefore justifies such remand . See Kent v. United of Omaha Life Ins. Co. , 96 F.3d 803, 807-08 (6th Cir. 1996). B. The District Court Erred in Gran ting Summary Judgment to Defendants on Plaintiff's Claim for Benefits 1. Standard of Review In an ERISA benefits case, this Court revi ews de novo a district court's decision on the administrative record . See Spangler v. Lockheed Martin Energy Sys. , 313 F.3d 356, 361 (6th Cir. 2002). The general ru le is to review a plan administrator’s denial of ERISA benefits de novo. Firestone Tire & Rubber Co. v. Bruch , 489 U.S. 101, 115 (1989). However, where, as is the case here, a plan vests the administrator with complete discretion in making eligibility determinati ons, such determinations will stand unless they are arbitrary or capricious. Id. 4A benefit denial is arbitr ary and capricious if the administrative record cannot support the ra tionale of the benefits denial as a “reasoned explanation.” See Moon v. Unum Provident Corp. , 405 F.3d 373, 381 (6th Cir. 2005). The “explanation must be consistent with the quant ity and quality of the medical evidence that is available on the record.” Id. (internal quotation and citation omitted).(No. 05-3380) - 16 - Absent a procedural challenge, the reviewof the courts is confined to the administrative record as itexisted on the date of the administrator's decision. See Wilkins , 150 F.3d at 615. If the administr ative record so limited supports the administrator's action as a "reasoned" decision, the decision is not arbitrary or capricious. Williams v. Int’l Paper Co. , 227 F.3d 706, 712 (6th Cir. 2000). As this C ourt has recently observed, however, “the arbitrary-and-capricious . . . standard does notrequire us merely to rubber stamp the administrator’s decision.” Jones v. Metro. Life Ins. Co. , 385 F.3d 654, 661 (6th Cir. 2004). Indeed, “deferential review is not no review, and deference need not be abject.” McDonald v. Western-Southern Life Ins. Co. , 347 F.3d 161, 172 (6th Cir. 2003). 2. Significant References to Medical Re cords Other Than Plaintiff’s Renders the Administrator’s Denial Arbitrary and Capricious Defendant’s decision is unsupported by the re cord because Defendant’s denial letter contains such egregious errors going both to Plaintiff’s identify and Plaintiff's medical records that Defendant's decision c an only be arbitrary and capricious. By all indications, Defendant consider ed someone else's medical records in conjunction with Plaintiff's records in maki ng its 2001 benefits determinat ion. The April 2, 2001 denial letter referenced the wrong address, the wrong social security number, and included references to medical treatments and conditions which Plaintiff never had, including a heart catheter, depression, and a number of drug prescriptions. Few administrator decisions could be more “arbitrary and caprici ous” than a denial of benefits in partial reliance on the medical records of someone else. A Fourth Circuit district c ourt has dealt with just such an administrator's decision and concluded that a benefits decisi on based, in part, on medical records not belonging to the(No. 05-3380) - 17 - claimant revealed a decision process so flawed that it was “unprincipled and unreasonable.” See Watson v. Unum Provident Corp. , 185 F. Supp. 2d 579, 586 (D. Md. 2002). This Court has always required thatthe record support the reasoning of an administrator’s decision. See Moon , 405 F.3d 373, 378 (6th Cir . 2005). Someone else’s medical records cannot support a “reasoned decision” going to Plaintiff’s claim for benefits. Summary judgment for Defendant was improper. I therefore dissent from the majority’s affirmance of the district court’s summary judgment for Defendant on Plaint iff’s denial of benefits claim.