Grove, who had been battling with Berger for the starting job, nursed shoulder and knee injuries during the preseason and missed four games last season.
The Dolphins ended the five-year contract Grove signed as a free agent last year. He received at least $14 million guaranteed in that deal.
Miami parted with several key 2009 acquisitions in recent days, including second-round draft pick Pat White and third-round pick Patrick Turner.
To fill Grove's roster spot, the Dolphins re-signed guard Cory Procter, who was released last week.
Copyright 2010 by The Associated Press
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