Pastrana v. Chater

Mercedes Pastrana (plaintiff) was denied Social Security disability benefits following a hearing before an administrative-law judge (ALJ). The ALJ’s decision was the first decision of the Commissioner of the Social Security Administration, Shirley Chater (defendant). Pastrana successfully sought judicial review of that decision, and it was remanded due to the ALJ’s failure to apply the correct legal standard for evaluating Pastrana’s pain. On remand, the ALJ denied Pastrana’s claim again, expressing hostility toward the remanding judge and the presiding legal standard. The ALJ condemned the work ethic of typical Puerto Rican workers, making unflattering comparisons to the work ethic of average Americans, and urged that the prevailing legal standard could not be strictly applied to Puerto Ricans. The ALJ believed that the average Puerto Rican worker was unwilling to perform manual labor or any work that was considered undignified and that the society fostered an entitlement to luxuries without work. The ALJ summarily rejected Pastrana’s treating psychiatrist’s opinion, calling the doctor’s competence into question based on a personal relationship and the ALJ’s judgment that the doctor only practiced psychiatry because he could not speak English and was afraid of killing someone practicing internal medicine. The appeals council reviewed the ALJ’s second decision and noted the ALJ’s prejudicial comments toward Pastrana’s treating psychiatrist. However, the council concluded that there was no evidence that Pastrana was treated by the psychiatrist and upheld the ALJ’s second determination, making it the second final decision of the commissioner. Pastrana sought judicial review of the second decision, and a United States district court upheld the second decision, concluding that the ALJ’s written opinion compensated for his biased approach towards Pastrana’s claim. Pastrana appealed.