## Facts

- Prentis Battles, Jr. applied for Supplemental Security Income in December 1991, alleging disability from back and “right side” problems.
- Battles reported a seventh-grade education, a long absence from work, homelessness, social isolation, and limited literacy.
- At a July 1992 administrative hearing (with counsel), Battles testified he could not work due to back pain, kidney problems, and breathing issues, and described surviving by scavenging and sleeping in others’ cars.
- The administrative record initially contained only a February 1992 consultative exam showing normal lumbar spine and chest x-rays, diagnosing rib-region pain of unknown origin and chronic obstructive lung disease.
- The Administrative Law Judge (ALJ) found Battles’s disabling pain allegations not credible and denied benefits.
- On administrative appeal, Battles submitted additional evidence, including an orthopedist’s report finding no musculoskeletal explanation and recommending pulmonary evaluation, and a later psychological evaluation diagnosing schizotypal personality disorder, severe dyslexia, borderline intellectual functioning, and long-term alcoholism.
- The Appeals Council upheld the ALJ’s denial, making it the Secretary’s final decision; the district court affirmed and denied remand under 42 U.S.C. § 405(g).

## Issues

1. Whether the ALJ failed to fully and fairly develop the administrative record concerning evidence suggesting a mental impairment affecting disability.
2. Whether remand under 42 U.S.C. § 405(g) was required based on new, material psychological evidence and good cause for its late submission.

## Decision

- The Eighth Circuit reversed the district court’s judgment affirming the denial of benefits.
- The court held the Secretary failed to develop the record adequately regarding Battles’s mental condition despite indications of mental limitations.
- The court ordered remand for further proceedings, including evaluation of mental impairments and consideration of the combined effect of physical and mental conditions on ability to work.
- The court concluded the psychological report qualified as new and material evidence supporting remand under 42 U.S.C. § 405(g), with good cause for not presenting it earlier.

## Legal Principles

- In Social Security disability proceedings, the ALJ has an affirmative duty to develop the record fully and fairly, particularly when the claimant’s circumstances suggest limited education, homelessness, or possible mental limitations.
- Evidence indicating possible mental impairment may require psychological development of the record; reliance on sparse physical evidence and a credibility finding may be insufficient where mental limitations could affect symptom reporting and treatment history.
- Disability analysis must consider the combined effect of all impairments, including mental and physical conditions, on the capacity for substantial gainful activity.
- Remand under 42 U.S.C. § 405(g) is appropriate when post-hearing evidence is new and material (reasonably likely to affect the outcome) and the claimant shows good cause for not submitting it earlier.

## Conclusion

The Eighth Circuit required remand because the administrative decision rested on an underdeveloped record that failed to investigate serious indications of mental impairment, and because later psychological evidence was new, material, and supported further evaluation of disability based on the combined effects of mental and physical limitations.


Battles v. Shalala, 36 F.3d 43 (8th Cir. 1994)