Action under 42 USC § 1983 for withholding material & exculpatory information under Brady v Maryland & Giglio v United States; Whether Heck v Humphrey barred the claim. Whether the court could disregard the state court’s final judgment on the ground the state court did not follow its own procedures; Qualified immunity on the Brady claim; The “clearly established” prong; Moldowan v City of Warren; Defendant’s failure to properly raise a claim in his Rule 50(a) motion; Sykes v Anderson; Conviction Integrity Unit (CIU)

[This appeal was from the ED-MI.] The court affirmed the jury verdict for plaintiff-Ansari that found defendant-police detective (Jimenez) violated Ansari’s constitutional rights by “withholding material and exculpatory information” under Brady and Giglio. Ansari was convicted of first-degree murder and AWIM, for which he was sentenced to life in prison without the possibility of parole. He was later found to be innocent after an investigation by the Wayne County Prosecutor’s Office CIU. The CIU named another individual as the orchestrator of the shooting and its memo criticized Jimenez’s conduct during the investigation. It revealed that Jimenez feared that family he had in Mexico would be killed should he investigate the actual perpetrator. Ansari sued under § 1983, alleging that Jimenez violated his constitutional rights. The first trial ended in a mistrial, but the second trial resulted in a $10 million award for Ansari. On appeal, the court first held that the Heck bar did not apply to Ansari’s claim where he was seeking damages, and the procedural history showed that his “convictions and sentence have in fact been ‘invalidat[ed].’” The court noted that whether or not Ansari and the state court complied with Michigan’s “procedures for setting aside a judgment when overturning Ansari’s convictions and sentence[,]” Heck did not give it “license to disregard the state court’s final judgment on the ground that the state court failed to follow its own procedures.” It rejected Jimenez’s argument that the state court order was a “legal nullity” where no state appellate court has made such a determination. As to qualified immunity on the Brady claim, Jimenez acknowledged “Moldawan held in 2009 that police officers’ Brady-derived duties were ‘clearly established’ as far back as 1990.” And it noted it has held that its “‘cases do not require plaintiffs to identify a decision that addressed exactly the same type of Brady evidence.’” Further, Jimenez did not preserve his argument about “the particular ‘kind of information at issue’” because he did not raise it in his Rule 50(a) motion in the district court. Finally, he was not entitled to a new trial based on the district court not allowing certain pieces of evidence, his challenges to the verdict form and jury instructions, or his claim that “Ansari’s counsel made improper and inflammatory” closing arguments.

Family & Medical Leave Act (FMLA); Interference claim; 29 USC § 2615(a)(1); Whether plaintiff established that he suffered from a “serious health condition”; § 2611(11); Retaliation claim; § 2615(a)(2); Prima facie case; “Protected activity”; “Pretext”; The McDonnell Douglas Corp v Green burden-shifting framework; Labor Management Relations Act (LMRA) claims; Alleged union breach of the duty of fair representation; Insufficient allegations; Waiver

[This appeal was from the ED-MI.] The court held that while the district court erred by ruling that plaintiff-Paris failed to make a prima facie case of FMLA retaliation, he could not show that his termination was pretextual. His FMLA interference claim failed because he did not establish a “serious health condition.” And his LMRA claims were properly dismissed because he failed to plausibly allege that defendant-Union “violated the duty of fair representation and” he waived several arguments. During his employment at defendant-MacAllister, Paris received several negative performance reviews, some involving his productivity, and others based on tardiness, early departures, and absences. He accrued disciplinary points and signed a “Last Chance Agreement” (LCA). His job position was changed from “Field Technician” to “Tech I,” which came with a salary deduction. After an incident with another employee, Paris requested time off for depression. He asked for and was given an FMLA application, but never returned it. He admitted that he never returned anything from a health care provider. Weeks later, he was terminated, with the Union stating it was unable to file a grievance for him based on the LCA. Paris then filed this suit. The district court dismissed his LMRA claims against MacAllister and the Union and later granted MacAllister summary judgment on the FMLA claims. On appeal, the court first held that the district court did not err by granting summary judgment on his FMLA interference claim because he failed to establish that he suffered from a “serious health condition.” There was no dispute that he “did not receive treatment or counseling for ‘any mental, psychiatric, psychological, or emotional issues[.]’” As to his FMLA retaliation claim, the court disagreed with the district court’s ruling that he did not establish his prima facie case. It held that Paris’s request for FMLA paperwork constituted engaging in a “protected activity” under the FMLA. But the court affirmed summary judgment for MacAllister because Paris could not show under the McDonnell Douglas burden-shifting framework “that his termination was pretextual.” Affirmed.

Fourth Amendment excessive force claim under 42 USC § 1983; Qualified immunity; Whether the police officers’ use of “deadly force” was “objectively reasonable”; Whether plaintiff established any genuine issues of material fact regarding the shooting

The court affirmed the district court’s grant of qualified immunity, holding that defendants-police officers’ “split-second choice to repeatedly use deadly force” against plaintiff’s decedent, “Isaifan—an armed suspect who refused to comply with orders while reaching for a weapon—was reasonable.” The police received a report of an abandoned car blocking traffic on the highway. A caller reported that the driver had been wearing camouflage and what looked like a bulletproof vest, and a visual of the interior of the vehicle showed a weapon and ammunition. Defendants (Akers and Rea) received the dispatch call and found him walking. Isaifan jogged into a wooded area when he saw them pulling over, and they followed, identifying themselves. “As Isaifan came into view, the officers ordered him to raise his hands and get on the ground. [He] initially started to raise his hands, holding unidentified objects in both. But he then stopped ‘following any commands whatsoever.’” One of the officers “saw the barrel of Isaifan’s gun fully clear his holster. From the side, Rea watched Isaifan’s arm settle, as though he had finished drawing the weapon and was holding it at his hip. At that point, Rea thought it was ‘100 percent clear’ that Isaifan ‘was turning with his firearm in his hand towards Officer Akers.’” When Isaifan turned, “both officers fired at point-blank range.” The five seconds leading up to and including the shooting was not recorded because trees obstructed the surveillance camera’s view. Isaifan’s ex-wife, plaintiff, acting on behalf of his estate, sued under § 1983 for violations of Isaifan’s Fourth Amendment rights. At issue on appeal was the district court’s qualified immunity ruling on the excessive force claim. The court noted it has consistently ruled that “officers may reasonably use deadly force against a noncompliant suspect drawing a firearm.” Defendants here “believed they were interacting with a suspect armed with a gun (and holding a grenade). That suspect then ignored commands to show his hands, walked menacingly toward officers, and resisted their efforts to detain him.” He unholstered his gun and turned toward them. The court also noted that in “similar circumstances, courts have held that an officer’s decision to shoot until a suspect was neutralized was reasonable.” And it found that plaintiff failed to establish any genuine disputes of material fact. “Based on this record, a reasonable juror couldn’t find that the officers violated Isaifan’s Fourth Amendment rights.”

Action under 42 USC § 1983 for withholding material & exculpatory information under Brady v Maryland & Giglio v United States; Whether Heck v Humphrey barred the claim. Whether the court could disregard the state court’s final judgment on the ground the state court did not follow its own procedures; Qualified immunity on the Brady claim; The “clearly established” prong; Moldowan v City of Warren; Defendant’s failure to properly raise a claim in his Rule 50(a) motion; Sykes v Anderson; Conviction Integrity Unit (CIU)

[This appeal was from the ED-MI.] The court affirmed the jury verdict for plaintiff-Ansari that found defendant-police detective (Jimenez) violated Ansari’s constitutional rights by “withholding material and exculpatory information” under Brady and Giglio. Ansari was convicted of first-degree murder and AWIM, for which he was sentenced to life in prison without the possibility of parole. He was later found to be innocent after an investigation by the Wayne County Prosecutor’s Office CIU. The CIU named another individual as the orchestrator of the shooting and its memo criticized Jimenez’s conduct during the investigation. It revealed that Jimenez feared that family he had in Mexico would be killed should he investigate the actual perpetrator. Ansari sued under § 1983, alleging that Jimenez violated his constitutional rights. The first trial ended in a mistrial, but the second trial resulted in a $10 million award for Ansari. On appeal, the court first held that the Heck bar did not apply to Ansari’s claim where he was seeking damages, and the procedural history showed that his “convictions and sentence have in fact been ‘invalidat[ed].’” The court noted that whether or not Ansari and the state court complied with Michigan’s “procedures for setting aside a judgment when overturning Ansari’s convictions and sentence[,]” Heck did not give it “license to disregard the state court’s final judgment on the ground that the state court failed to follow its own procedures.” It rejected Jimenez’s argument that the state court order was a “legal nullity” where no state appellate court has made such a determination. As to qualified immunity on the Brady claim, Jimenez acknowledged “Moldawan held in 2009 that police officers’ Brady-derived duties were ‘clearly established’ as far back as 1990.” And it noted it has held that its “‘cases do not require plaintiffs to identify a decision that addressed exactly the same type of Brady evidence.’” Further, Jimenez did not preserve his argument about “the particular ‘kind of information at issue’” because he did not raise it in his Rule 50(a) motion in the district court. Finally, he was not entitled to a new trial based on the district court not allowing certain pieces of evidence, his challenges to the verdict form and jury instructions, or his claim that “Ansari’s counsel made improper and inflammatory” closing arguments.

Fourth Amendment excessive force claim under 42 USC § 1983; Qualified immunity; Whether the police officers’ use of “deadly force” was “objectively reasonable”; Whether plaintiff established any genuine issues of material fact regarding the shooting

The court affirmed the district court’s grant of qualified immunity, holding that defendants-police officers’ “split-second choice to repeatedly use deadly force” against plaintiff’s decedent, “Isaifan—an armed suspect who refused to comply with orders while reaching for a weapon—was reasonable.” The police received a report of an abandoned car blocking traffic on the highway. A caller reported that the driver had been wearing camouflage and what looked like a bulletproof vest, and a visual of the interior of the vehicle showed a weapon and ammunition. Defendants (Akers and Rea) received the dispatch call and found him walking. Isaifan jogged into a wooded area when he saw them pulling over, and they followed, identifying themselves. “As Isaifan came into view, the officers ordered him to raise his hands and get on the ground. [He] initially started to raise his hands, holding unidentified objects in both. But he then stopped ‘following any commands whatsoever.’” One of the officers “saw the barrel of Isaifan’s gun fully clear his holster. From the side, Rea watched Isaifan’s arm settle, as though he had finished drawing the weapon and was holding it at his hip. At that point, Rea thought it was ‘100 percent clear’ that Isaifan ‘was turning with his firearm in his hand towards Officer Akers.’” When Isaifan turned, “both officers fired at point-blank range.” The five seconds leading up to and including the shooting was not recorded because trees obstructed the surveillance camera’s view. Isaifan’s ex-wife, plaintiff, acting on behalf of his estate, sued under § 1983 for violations of Isaifan’s Fourth Amendment rights. At issue on appeal was the district court’s qualified immunity ruling on the excessive force claim. The court noted it has consistently ruled that “officers may reasonably use deadly force against a noncompliant suspect drawing a firearm.” Defendants here “believed they were interacting with a suspect armed with a gun (and holding a grenade). That suspect then ignored commands to show his hands, walked menacingly toward officers, and resisted their efforts to detain him.” He unholstered his gun and turned toward them. The court also noted that in “similar circumstances, courts have held that an officer’s decision to shoot until a suspect was neutralized was reasonable.” And it found that plaintiff failed to establish any genuine disputes of material fact. “Based on this record, a reasonable juror couldn’t find that the officers violated Isaifan’s Fourth Amendment rights.”

Long-term disability (LTD) benefits; The Employee Retirement Income Security Act’s (ERISA) inapplicability to government employee benefit plans; 29 USC § 1003(b)(1); Contract breach & breach of fiduciary duty claims: “Arbitrary & capricious” standard; Motions for discovery; Whether the district court could look “beyond the administrative record”; O’Kelly v Federal Reserve Bank of Cleveland (Unpub 6th Cir); Moore v Lafayette Life Ins Co

The court held that the district court properly applied the “arbitrary and capricious” standard when denying plaintiff-Martin’s requests for discovery in this breach of contract and fiduciary duty action for LTD benefits under a non-ERISA benefit plan. Martin, an employee of defendant-Federal Reserve Bank of Cleveland, suffered from long-haul COVID-19. The Bank’s benefits administrator, defendant-Matrix Absence Management, denied her application for LTD benefits, and the denial was upheld on appeal. Because ERISA does not cover governmental employee benefit plans, she sued for contract breach and breach of fiduciary duty. The district court denied Martin’s motion for discovery “outside the administrative record,” and granted defendants judgment based on the record. Martin argued on appeal that her motions for discovery were improperly denied. But the court disagreed and upheld the denials. The arbitrary and capricious standard “applies both where an ERISA plan vests significant decision-making authority in an administrator and here, where a non-ERISA plan vests such authority in the administrator.” The court concluded that “the district court was correct to deny Martin’s request for open discovery because it could not review Matrix’s decision based on information that was not available to Matrix when it denied Martin’s benefits.” As to her request for limited discovery, under Moore, a district court may exercise discretion to look at evidence beyond the administrative record only if it “‘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.’” The court found that “Martin insufficiently alleged a conflict of interest[,]” or bias or another indicator “of a procedural defect in Matrix’s determination.” The court further held that Matrix did not arbitrarily deny Martin LTD benefits under the plan. The “core inquiry” was whether it “offered a ‘reasoned explanation, based on the evidence,’ for its denial” and the court found that “Matrix offered such an explanation for its denial and considered Martin’s medical evidence[.]” Affirmed.

Warrantless seizure of defendant’s cell phone; Scope of a search incident to arrest; “Dual purpose”; People v Giacalone; Defendant’s statement to police; Ineffective assistance of counsel; Prejudice; Motion to suppress; Failure to move to quash added charges or seek a preliminary exam; Failure to present potentially exculpatory financial documents & to prevent or minimize the introduction of damaging statements; Hearsay; MRE 804(b)(3); Evidence seized from execution of a search warrant for defendant’s house; Good-faith exception; Prosecutorial vindictiveness/added charges; Presumed vindictiveness theory; Double jeopardy; Judgment of sentence (JOS); Michigan Department of Corrections (MDOC)

On remand from the Supreme Court, the court held that the police were entitled to seize defendant’s cell phone as part of a search incident to his arrest, and that appellate relief was unwarranted as to his custodial statement claim. It rejected his prosecutorial vindictiveness argument, and his ineffective assistance of counsel claims. It also concluded that the good-faith exception to the exclusionary rule applied to the evidence seized from execution of the search warrant for his house. Thus, in accordance with the Supreme Court’s direction, the court vacated his convictions of receiving or concealing stolen property and conspiracy to commit that crime on double jeopardy grounds, remanded for the limited purpose of correcting his JOS and relaying the correct information to the MDOC, and otherwise affirmed. He was also convicted of safe breaking; larceny of property valued at $20,000 or more; larceny from a building; and conspiracy to commit those crimes. A jury found that defendant and his romantic partner “stole nearly $70,000 from their neighbor’s safe.” As to the seizure of his cell phone, the trial court determined that the arresting officers seized it “as part of a ‘dual purpose’ to their arrest after he chose to go to his bedroom and place his cell phone within his ‘immediate area of control,’ and therefore, the seizure was pursuant to a valid search incident to a lawful arrest.” The court found no fault with that analysis. As to his response to an officer’s question, confirming that the cell phone was his, the trial court concluded that even if his “response had been suppressed, there was additional evidence of his ownership of the phone, noting that” it was seized from his bedroom, and the “‘jury reviewed text messages that were downloaded from the phone. Many of those messages identified defendant as the sender and recipient by virtue of the content of the conversations.’” To the extent it was plain error to allow the officer to testify that defendant confirmed the phone was his, relief was “not warranted under the plain-error rule.” The court further concluded that, given “the prosecutor’s broad discretion to bring charges and the investigation’s suggestion that a conspiracy might be involved, the record doesn’t support the idea that the conspiracy counts were added out of vindictiveness. And failure to advance a meritless argument does not constitute ineffective assistance of counsel.”

Ineffective assistance of counsel related to a codefendant’s statements from an investigative interview; A statement against interest (MRE 804(b)(3)); People v Barrera; Requirement that the statement be supported by corroborating circumstances clearly indicating its trustworthiness; Failure to make a futile motion; Prejudice; Prosecutorial error; Rebuttal argument

The court held that defense counsel was not ineffective related to a codefendant’s (B) statements from an investigative interview. It also rejected defendant’s prosecutorial error claim arising from the prosecutor’s rebuttal argument. Thus, it affirmed defendant’s convictions of meth and marijuana delivery. Defense counsel had an investigator interview B “about defendant’s role in the drug transaction.” The defense theory was that defendant “did not know that he was delivering drugs.” The court concluded that, under Barrera, B’s statements were against his penal interest. But even “if an unavailable declarant’s statement is against his penal interest, it must be supported by corroborating circumstances that clearly indicate its trustworthiness to be admissible.” The court concluded “there were insufficient corroborating circumstances to admit [B’s] statements under the former MRE 804(b)(3). Although [B] voluntarily gave the statements and may have had no personal reason to try to help defendant, other circumstances more clearly indicate that the statements were unreliable. Notably, the interviewe[r]s were defendant’s attorney and investigator, and [B] gave the least amount of information possible to get through the interview. Many of the statements were made in response to ‘yes or no,’ leading questions, so it would not be difficult for [B] to give the ‘right’ answer, and [B’s] incentive, if any, was simply to tell the attorney and [investigator] whatever they wanted to hear. And when the investigator asked [B] if he had anything else to share, [B] said that he did not, so the investigator ended the interview. These circumstances undermined the reliability of [B’s] statements,” with the result the court held “that they were not admissible under [the] ‘statement against interest’” hearsay exception. It also concluded that the prosecutor did not commit misconduct in commenting “on defendant’s experience with drugs during his rebuttal argument."

Sentencing after revoking supervised release; Procedural & substantive reasonableness; Predetermining defendant’s post-revocation prison term at an earlier violation hearing; Inverting the sentencing sequence; 18 USC § 3583(e)(3); Whether the sentence-in-advance method inherently results in non-individualized prison terms; Consideration of the § 3553(a) factors

The court vacated defendant-Barton’s sentence and remanded, holding “that when a district court predetermines a supervisee’s revocation prison term at an earlier violation hearing,” the imposed prison term “is both procedurally and substantively unreasonable.” Barton pled guilty to a child pornography offense and served his prison time. He violated his supervised release by committing a misdemeanor disorderly conduct violation, leaving the state, and possessing an internet-connected tablet that he used to view adult pornography. The district court gave him the choice of either serving an additional six-month Guidelines term of imprisonment, or continuing his supervised release with a caveat: “if Barton committed a future violation, the district court would impose a statutory-maximum two-year term of imprisonment.” It also added a condition prohibiting viewing “sexually explicit material.” Barton chose supervised release but committed another violation by possessing another internet-connected tablet that he used to view adult pornography. At the second violation hearing, the district court referenced both the advisory range and the two-year statutory maximum. It then discussed its prior two-year sentence ultimatum, emphasizing that Barton had made his choice. It then imposed the statutory-maximum two-year term in prison, followed by 10 years of supervised release. The court first held that “the district court’s sentence-in-advance method” was procedurally unreasonable for two reasons. The “district court inverted the proper sentencing sequence[,]” i.e., the post-revocation prison term must be imposed “at the end” of a sequence that begins with calculating the Guidelines and considering the § 3553(a) factors, not at the start of it. The court also held that “the sentence-in-advance method inherently results in non-individualized” prison terms. The district court “‘simply default[ed] to its prior comments at the [earlier] hearing’” in imposing sentence, making it procedurally unreasonable. Further, the court found the sentence substantively unreasonable. There was no “presumption of reasonableness” where Barton’s sentence was above the Guidelines, and the court concluded the district court gave “the § 3553(a) factors virtually no weight whatsoever.” District courts must “craft individualized revocation terms of imprisonment after considering the” parties’ evidence and arguments.

Family & Medical Leave Act (FMLA); Interference claim; 29 USC § 2615(a)(1); Whether plaintiff established that he suffered from a “serious health condition”; § 2611(11); Retaliation claim; § 2615(a)(2); Prima facie case; “Protected activity”; “Pretext”; The McDonnell Douglas Corp v Green burden-shifting framework; Labor Management Relations Act (LMRA) claims; Alleged union breach of the duty of fair representation; Insufficient allegations; Waiver

[This appeal was from the ED-MI.] The court held that while the district court erred by ruling that plaintiff-Paris failed to make a prima facie case of FMLA retaliation, he could not show that his termination was pretextual. His FMLA interference claim failed because he did not establish a “serious health condition.” And his LMRA claims were properly dismissed because he failed to plausibly allege that defendant-Union “violated the duty of fair representation and” he waived several arguments. During his employment at defendant-MacAllister, Paris received several negative performance reviews, some involving his productivity, and others based on tardiness, early departures, and absences. He accrued disciplinary points and signed a “Last Chance Agreement” (LCA). His job position was changed from “Field Technician” to “Tech I,” which came with a salary deduction. After an incident with another employee, Paris requested time off for depression. He asked for and was given an FMLA application, but never returned it. He admitted that he never returned anything from a health care provider. Weeks later, he was terminated, with the Union stating it was unable to file a grievance for him based on the LCA. Paris then filed this suit. The district court dismissed his LMRA claims against MacAllister and the Union and later granted MacAllister summary judgment on the FMLA claims. On appeal, the court first held that the district court did not err by granting summary judgment on his FMLA interference claim because he failed to establish that he suffered from a “serious health condition.” There was no dispute that he “did not receive treatment or counseling for ‘any mental, psychiatric, psychological, or emotional issues[.]’” As to his FMLA retaliation claim, the court disagreed with the district court’s ruling that he did not establish his prima facie case. It held that Paris’s request for FMLA paperwork constituted engaging in a “protected activity” under the FMLA. But the court affirmed summary judgment for MacAllister because Paris could not show under the McDonnell Douglas burden-shifting framework “that his termination was pretextual.” Affirmed.

No-fault insurance; Optional collision coverage; Rescission; Material misrepresentation; Howard v LM Gen Ins Co; Hearsay; MRE 801(a); MRE 802; Admissions; MCR 2.312; Dykes v William Beaumont Hosp; Distinguishing Sherman v Progressive MI Ins Co

The court held that the trial court did not err by granting defendants summary disposition because plaintiff-insurer failed to establish that the alleged misrepresentation about one vehicle was material to collision coverage on the different vehicle involved in the accident. Plaintiff sought to void defendant-Witt’s no-fault policy ab initio after she allegedly misrepresented ownership of a Nissan, although the collision claim involved damage to a Kia. On appeal, the court held that Howard controlled and plaintiff had to show “that the misrepresentation was material to the coverage of the vehicle in question.” The court rejected plaintiff’s rescission letter as evidence because it was hearsay, and it could not qualify as a business record where “‘the source of information or the method or circumstances of preparation indicate a lack of trustworthiness.’” The letter was prepared after the collision “as a means to avoid liability on its collision coverage.” The court also held that plaintiff’s affidavit did not create a genuine issue of material fact because it conflicted with plaintiff’s earlier binding admission that it sometimes issues policies to insureds who do not own the covered vehicle. Relying on Dykes, the court noted that when a party certifies a fact in a civil action, it may not create a factual issue “by merely asserting the contrary in an affidavit.” Because plaintiff’s only reliance evidence was inadmissible or rebutted by its own admission, the court found no genuine issue of material fact. Affirmed.

Long-term disability (LTD) benefits; The Employee Retirement Income Security Act’s (ERISA) inapplicability to government employee benefit plans; 29 USC § 1003(b)(1); Contract breach & breach of fiduciary duty claims: “Arbitrary & capricious” standard; Motions for discovery; Whether the district court could look “beyond the administrative record”; O’Kelly v Federal Reserve Bank of Cleveland (Unpub 6th Cir); Moore v Lafayette Life Ins Co

The court held that the district court properly applied the “arbitrary and capricious” standard when denying plaintiff-Martin’s requests for discovery in this breach of contract and fiduciary duty action for LTD benefits under a non-ERISA benefit plan. Martin, an employee of defendant-Federal Reserve Bank of Cleveland, suffered from long-haul COVID-19. The Bank’s benefits administrator, defendant-Matrix Absence Management, denied her application for LTD benefits, and the denial was upheld on appeal. Because ERISA does not cover governmental employee benefit plans, she sued for contract breach and breach of fiduciary duty. The district court denied Martin’s motion for discovery “outside the administrative record,” and granted defendants judgment based on the record. Martin argued on appeal that her motions for discovery were improperly denied. But the court disagreed and upheld the denials. The arbitrary and capricious standard “applies both where an ERISA plan vests significant decision-making authority in an administrator and here, where a non-ERISA plan vests such authority in the administrator.” The court concluded that “the district court was correct to deny Martin’s request for open discovery because it could not review Matrix’s decision based on information that was not available to Matrix when it denied Martin’s benefits.” As to her request for limited discovery, under Moore, a district court may exercise discretion to look at evidence beyond the administrative record only if it “‘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.’” The court found that “Martin insufficiently alleged a conflict of interest[,]” or bias or another indicator “of a procedural defect in Matrix’s determination.” The court further held that Matrix did not arbitrarily deny Martin LTD benefits under the plan. The “core inquiry” was whether it “offered a ‘reasoned explanation, based on the evidence,’ for its denial” and the court found that “Matrix offered such an explanation for its denial and considered Martin’s medical evidence[.]” Affirmed.