Battles v. Shalala

Prentis Battles Jr. (plaintiff) applied for Social Security supplemental security income benefits, alleging that he was disabled due to back, kidney, and breathing problems. Following a hearing before an administrative-law judge (ALJ), Battles’s application was denied based on a finding that his allegations of disabling pain were incredible. The ALJ based his decision on the only medical report submitted at the time, wherein a consultative physician found Battles’s x-rays to be normal and diagnosed Battles with pain of an unknown origin and chronic obstructive lung disease. Battles appealed the decision to the appeals council, submitting two more medical reports, one from an orthopedist who rendered a diagnosis similar to that of the consultative physician and another from a psychologist who indicated that Battles had a well-established pattern of schizotypal personality disorder, an almost lifelong history of alcoholism, and severe dyslexia. The council upheld the ALJ’s decision, making it the final decision of the Secretary of Health and Human Services, Donna Shalala (defendant). Battles sought judicial review of the ALJ’s decision in a United States district court, seeking a remand for the ALJ’s failure to fully develop the record regarding his mental impairment. The district court denied the motion for remand and upheld the denial. Battles appealed.