Andree S. v. Commissioner of Social Security

Summary

The United States District Court for the Eastern District of Michigan recommends granting plaintiff Andree S.’s motion for summary judgment, denying the Commissioner of Social Security’s motion, and remanding the disability-benefits matter under sentence four of 42 U.S.C. § 405(g). The court concludes that the administrative law judge failed to adequately explain the rejection of plaintiff’s subjective complaints of pain and fatigue, particularly in light of her fibromyalgia. The recommendation was issued by Magistrate Judge Elizabeth A. Stafford on January 27, 2026.

Holdings

1. An ALJ must adequately explain the reasons for discounting a claimant's subjective complaints of pain and fatigue, and may not rely improperly on an absence of objective medical findings of the type ordinarily associated with other physical impairments when evaluating fibromyalgia symptoms.

Questions Presented

1. Whether the ALJ properly evaluated plaintiff's subjective complaints of pain and fatigue associated with fibromyalgia.
2. Whether the Commissioner's final disability determination was supported by substantial evidence and made under proper legal standards.

Disposition

reversed_and_remanded