Janelle C. v. Frank Bisignano, Commissioner of Social Security

Summary

This memorandum opinion and order concerns judicial review of the denial of Social Security Disability Insurance and Supplemental Security Income benefits to Janelle C. The court examines whether the Administrative Law Judge properly evaluated Plaintiff’s subjective complaints concerning fibromyalgia and chronic pain, particularly in light of Fourth Circuit precedent prohibiting reliance on a lack of objective evidence to discount fibromyalgia symptoms.

Holdings

1. An ALJ may not rely on objective medical evidence, or the lack thereof, even as one of multiple factors, to discount a claimant's subjective complaints about fibromyalgia symptoms because fibromyalgia generally does not produce objective evidence corresponding to symptom severity, persistence, or functional limitation.
2. The ALJ's symptom evaluation and RFC assessment were legally deficient because the decision relied on the absence of objective evidence in assessing Plaintiff's fibromyalgia-related symptoms.

Questions Presented

1. Whether the ALJ improperly discounted Plaintiff's subjective complaints concerning fibromyalgia by relying on the lack of objective medical evidence.
2. Whether the ALJ's evaluation of Plaintiff's symptoms and residual functional capacity complied with Arakas v. Commissioner of Social Security and Hultz v. Bisignano.
3. Whether the case should be remanded for further administrative proceedings or an immediate award of benefits.

Disposition

reversed_and_remanded