Elliott L. Jones v. Commissioner of Social Security, 695 F. App'x 495

Elliott Jones applied for Supplemental Security Income; administrative proceedings spanned many years with two hearings central to this appeal.
First hearing: Jones’s counsel set a 2008 disability onset; ALJ admitted medical records from as early as 2005 and heard a vocational expert.
Second hearing: additional medical records, Jones’s testimony on work history and limitations, a medical expert, a mental-health consult, and a different vocational expert testified.
Jones’s counsel requested and obtained an additional mental-health consultation and asked the ALJ if the physical record was sufficient; the ALJ said yes and Jones offered no further evidence.
After the consult, the ALJ denied benefits; Jones later submitted two older medical documents (from 2001–2002) to the district court that were not in the administrative record.
The magistrate judge and district court affirmed the denial; Jones appealed only the claim that the ALJ failed to fully and fairly develop the record.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the ALJ failed to develop a full and fair administrative record	Jones: ALJ omitted two older medical records (2001–2002) from the record, prejudicing his claim	Commissioner: ALJ properly developed the record; Jones failed to raise or supply those older records at hearing and bore the burden to produce evidence	Court: ALJ met duty to develop a full and fair record; omission of the 2001–2002 documents caused no unfairness or clear prejudice

Ellison v. Barnhart, 355 F.3d 1272 (11th Cir. 2003) (ALJ’s duty to develop a full and fair record and claimant’s burden to produce evidence)
Brown v. Shalala, 44 F.3d 931 (11th Cir. 1995) (remand appropriate only where evidentiary gaps result in unfairness or clear prejudice)
Jones v. Apfel, 190 F.3d 1224 (11th Cir. 1999) (appellate review limited to issues presented to the district court)