In Axiom Resource Management, Inc. v. United States, 564 F.3d 1374 (Fed. Cir. 2009), the United States Court of Appeals for the Federal Circuit adopted a restrictive standard for supplementation of the administrative record. In its elaboration of the standard, the appeals court favorably cited Murakami v. United States, 46 Fed. Cl. 731 (2000), affd, 398 F.3d 1342 (Fed. Cir. 2005). Axiom, 564 F.3d at 1380. The Axiom standard for supplementation of the administrative record is a direct quotation from Murakami, stating that supplementation of the record should be limited to cases in which the omission of extra-record evidence precludes effective judicial review. Id. (quoting Murakami, 46 Fed. Cl. at 735). The purpose of limiting review to the record actually before the agency is to guard against courts using new evidence to convert the arbitrary and capricious standard into effectively de novo review. Id. (quoting Murakami, 46 Fed. Cl. at 735). In Axiom Res. Mgmt., Inc. v. United States, 564 F.3d 1374 (Fed. Cir. 2009), the trial court allowed the plaintiff to supplement the administrative record filed by the government with various documents that were not before the agency when it made its decision. See id. at 1379. On review, the Federal Circuit held that this court may not add documents to the record without evaluating whether the record before the agency was sufficient to permit meaningful judicial review. Id. at 1380.