In Martinez-Claib v. Business Men's Assurance Co. of America and Met. Life Ins. Corp., 2009 U.S. App. Lexis 23074 (11th Cir.), the Eleventh Circuit held that post-hoc arguments or explanations for a claim decision are permitted in cases governed by the de novo review. The Court held that the bar to post-hoc explanations is limited to cases where a court is reviewing the adminstrator's decision under the deferential arbitrary and capricous standard of review.