WOOTEN v. ASTRUE, 2:11-cv-07592

Wooten filed a disability claim on June 6, 2008, alleging onset May 1, 1998 and had prior SSI disability benefits in 2002.
Benefits terminated in 2005 by operation of law due to incarceration; he reapplied after release.
ALJ held a hearing May 5, 2010 with Wooten pro se and a vocational expert.
Record included prison medical, spinal injury, and post-incarceration mental health records, plus two differing psychological assessments (Sept 2008 and Oct 2008).
ALJ discounted the Sept 2008 consultative evaluation and relied on a record-reviewing state psychologist; overall RFC found light work without disabling mental limitations.
Court remanded to develop the record, specifically to obtain and evaluate evidence supporting the prior disability determination.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ALJ failed to develop the record regarding the prior disability determination.	Wooten argues prior records are highly relevant to current eligibility and must be evaluated.	Wooten's prior records were not necessary for current determination.	Remand to develop and consider prior disability records.
Whether ALJ's RFC finding of light work is supported by the record.	Challenge to reliance on non-treating opinions and lack of treatment history.	RFC supported by available evidence and treatment history.	Remand to reassess RFC in light of full record and prior evidence.

Hagans v. Comm'r of Soc. Sec., 694 F.3d 287 (3d Cir. 2012) (obligation to obtain all medical evidence necessary to properly decide a determination)
Reefer v. Barnhart, 326 F.3d 376 (3d Cir. 2003) (ALJ must develop record; pro se claimants require heightened duty)
Mimms v. Heckler, 750 F.2d 180 (2d Cir. 1984) (prior disability records highly relevant to later claim)
Colavito v. Apfel, 75 F. Supp. 2d 385 (E.D. Pa. 1999) (ALJ's duty to obtain treating-source records to develop the record)
Hess v. Sec'y of Health, Educ. & Welfare, 497 F.2d 837 (2d Cir. 1974) (duty to develop evidence when record is deficient)