Ninth circuit - the most liberal of all?

From the article:
"The Court of Appeals for the Ninth Circuit noted in Burke v. Pitney Bowes, Inc. Long Term Disability Plan, 554 F.3d 1016 (9th Cir. 2009), that even before Glenn, in the
Ninth Circuit a district court could always “‘consider evidence outside the administrative record to decide the nature, extent, and effect on the decision-making process of any conflict of interest’

Plaintiffs suing under Ninth Circuit are somewhat lucky to have more liberal court permitting discovery on the bad faith insurance companies.