## Facts

- Maria Tejada applied for Supplemental Security Income (SSI), claiming disability from diabetes and related complications, plus leg edema, arthralgia, osteoarthritis, and severe hypertension.
- Tejada had no formal schooling, could not communicate in English, and could not read or write in Spanish; she proceeded pro se in federal court.
- From 1990 to 1992, Tejada worked on a car-parts assembly line, which required standing most of an eight-hour day, frequent bending and reaching, and occasional lifting up to ten pounds.
- Tejada stopped working in December 1992, citing health problems.
- Medical records documented longstanding diabetes described as difficult to manage, medication adjustments over time, and diagnoses including diabetes mellitus with peripheral neuropathy; later records also noted diabetic neuropathy.
- An Administrative Law Judge (ALJ) found Tejada not disabled, concluded she could perform “light work,” and determined at step four that she could return to her past assembly-line work.
- The Appeals Council denied review, making the ALJ’s decision final; the district court granted judgment on the pleadings for the Commissioner.
- Tejada appealed, arguing the record was inadequately developed and the past-work finding lacked evidentiary support.

## Issues

1. Whether the ALJ failed to fulfill the duty to develop the administrative record, particularly given the claimant’s limited literacy and pro se status, by not obtaining and evaluating medical evidence on multiple impairments and functional limits.
2. Whether the ALJ’s step-four determination that Tejada could perform her past relevant work was supported by substantial evidence, including adequate findings on residual functional capacity (RFC) and the demands of the prior job.

## Decision

- The Second Circuit vacated the district court’s judgment and remanded to the Commissioner for further administrative proceedings.
- The court held the ALJ did not adequately develop the record regarding Tejada’s documented impairments, including leg edema, arthralgia, osteoarthritis, diabetes mellitus, and severe hypertension.
- The court held the step-four finding that Tejada could return to her past assembly-line work was not supported by substantial evidence because the ALJ did not sufficiently compare Tejada’s functional limitations to the job’s standing, bending, and reaching requirements.
- The court ordered further proceedings rather than immediate benefits because the errors concerned record development and analysis, not a definitive disability determination on the existing record.

## Legal Principles

- An ALJ has an affirmative duty to develop the administrative record; remand is appropriate where gaps in the record remain and additional development is needed.
- The duty to develop the record is heightened when the claimant has limited education or literacy or proceeds without counsel.
- Treating-source evidence must be sought and evaluated; diagnosing impairments is insufficient without assessing their work-related functional effects, including combined effects of multiple conditions.
- At step four, the ALJ must make specific findings on RFC and the physical and mental demands of past relevant work and must compare the two; generalized job characterizations and conclusory past-work findings are inadequate.
- A denial must be supported by substantial evidence, meaning relevant evidence a reasonable factfinder could accept as adequate to support the conclusion.

## Conclusion

The Second Circuit required remand because the ALJ did not reasonably develop the medical and functional record and did not support the step-four past-work determination with specific findings and substantial evidence, particularly as to Tejada’s ability to sustain the standing, bending, and reaching demands of her prior assembly-line job.


Tejada v. Apfel, 167 F.3d 770 (2d Cir. 1999)