## Facts

- Mercedes Pastrana applied for Social Security disability benefits in July 1988, alleging disability since July 1980 based on back and heart pain and psychiatric symptoms.
- The agency denied the claim initially and on reconsideration; after a hearing, an Administrative Law Judge (ALJ) found Pastrana not disabled.
- The Appeals Council denied review in January 1990, making the ALJ’s decision the agency’s final decision at that time.
- A federal court previously remanded the matter because the ALJ failed to evaluate Pastrana’s subjective complaints of pain under the standards required by circuit precedent, which calls for a detailed inquiry into work history, daily activities, functional limits, and medications.
- On remand, the claim returned to the same ALJ, who held a second hearing and again denied benefits; the Appeals Council affirmed, creating the final agency decision under review.
- During the second hearing, the ALJ made disparaging remarks about the remand order and pain-evaluation requirements, voiced broad negative generalizations about Puerto Rican claimants and their work ethic, and made demeaning comments about Pastrana’s treating psychiatrist’s competence and motives.
- Pastrana sought judicial review under 42 U.S.C. § 405(g), arguing she was denied a fair hearing and that the decision did not apply proper legal standards and lacked substantial evidentiary support.

## Issues

1. Whether the ALJ’s statements and conduct deprived Pastrana of a fair hearing before an impartial adjudicator, in violation of due process requirements applicable to Social Security proceedings.
2. Whether the agency’s final decision applied the proper legal standards for assessing subjective complaints of pain and weighing medical-opinion evidence.

## Decision

- The court held that Pastrana did not receive a fair hearing before an impartial ALJ.
- The court remanded the case under 42 U.S.C. § 405(g) for a new hearing.
- The court directed that the new hearing be conducted by a different ALJ, given the appearance and substance of bias reflected in the record.

## Legal Principles

- Social Security claimants are entitled to a full and fair hearing before an impartial ALJ; adjudicative bias or hostility that undermines neutrality requires corrective relief.
- An ALJ must treat claimants with respect and dignity regardless of the perceived merits of the claim; demeaning conduct is incompatible with the ALJ’s quasi-judicial role.
- Subjective pain complaints must be evaluated through an individualized, evidence-based inquiry considering factors such as work history, daily activities, functional restrictions, and medications, rather than through general assumptions about categories of claimants.
- Treating-source opinions must be assessed using the governing regulatory framework and record-based reasoning; rejection cannot rest on personal conjecture or disparagement unrelated to medical evidence.

## Conclusion

The court remanded for a new disability hearing before a different ALJ because the ALJ’s biased and disparaging conduct compromised the fairness and impartiality required in Social Security adjudication and tainted the evaluation of symptoms and medical evidence.


Pastrana v. Chater, 917 F. Supp. 103 (D.P.R. 1996)