In Doria Mining & Eng'g Corp. v. Morton, 608 F.2d 1255, 1257-59 (9th Cir.1979), the Ninth Circuit held that extrinsic evidence could be considered when a claimant alleged it had discovered new evidence showing that the decision under review was obtained by fraud in the administrative proceeding. In Doria, the claimant sought district court review of a decision of the Interior Board of Land Appeals. Id. at 1256. Thirteen months after commencing the review action, the claimant moved for leave to amend its complaint to add allegations that new evidence brought to light in a collateral state proceeding indicated that the respondent had committed fraud and perjury during the administrative proceeding. Id. at 1257. The district court denied the motion to amend on the grounds that the court was without jurisdiction to consider evidence not found in the administrative record. Id. The Ninth Circuit reversed, stating: It is true that the appropriate standard for review of administrative proceedings is whether the administrative findings are supported by substantial evidence in the record as a whole. When, however, the party seeking review alleges that it has discovered new evidence showing that the decision before the court for review was obtained by a fraud on the administrative proceeding, we hold that the reviewing court may consider evidence extrinsic to the record in determining whether such allegations are meritorious. . . . ... Newly discovered evidence of fraud and perjury in an administrative proceeding will not be found in the administrative record. If the reviewing court, in the face of an allegation that such evidence exists and that administrative remedies have been exhausted, nevertheless confines itself to consideration only of evidence in the record, the party seeking review is left without any forum in which to argue the allegedly fraudulent basis of the administrative judgment. Id. at 1257-59.