Denial of Fibromyalgia Disability Claim

The Seventh Circuit recently weighed in on a Social Security disability appeal that highlights a recurring tension in our field: how ALJs handle fibromyalgia claims and treating physician opinions.

The Story

Padua applied for benefits based on fibromyalgia, chronic fatigue, depression, and anxiety. Her treating internist (Dr. Carpenter) and chiropractor (Dr. Pendolino) both supported significant work-related limitations. But the ALJ discounted their assessments, finding instead that Padua could perform a limited range of light work. The district court affirmed, and the Seventh Circuit did the same.

The Court’s Reasoning

1. Fibromyalgia evidence – The Court acknowledged SSA’s recognition that fibromyalgia requires special care since objective findings are often sparse. Still, the ALJ’s approach was upheld: she considered trigger-point testing, treatment history, and daily activities (like Padua’s ability to attend massage school), and reasonably concluded that her symptoms didn’t preclude all work.

2. Treating physician rule (pre-2017 claims) – Even under the old rule, the ALJ found Dr. Carpenter’s opinions inconsistent. At one point he limited Padua to less than an hour of activity per day, but just months later said she could sustain full-time sedentary work. The Court saw these contradictions—and his generalist background versus specialists—as sufficient reasons to give his views little weight.

3. Chiropractor evidence – The Court emphasized that a chiropractor is not an “acceptable medical source” under the regs, so Dr. Pendolino’s extreme checkbox limitations carried little weight, especially since his notes didn’t back them up.

4. RFC determination – The ALJ’s RFC was actually more restrictive than state agency consultants recommended, showing deliberation. Since Padua didn’t identify what additional limitations should have been included, her argument failed.

   
   

Why This Matters for Practitioners

• Fibromyalgia claims remain uphill battles—courts expect ALJs to consider subjective complaints, but will affirm denials if the ALJ ties their reasoning to conservative treatment and daily activities.

• Treating physician opinions are not bulletproof. Internal inconsistencies, lack of support, and provider specialty can all undermine weight, even under the old treating physician rule.

• For representatives, the lesson is clear: anticipate credibility challenges, prepare treating providers for consistency, and supplement records where daily activities might appear to contradict disabling allegations.

  
  

The Seventh Circuit closed by affirming the denial, reminding us of the “substantial evidence” standard: not whether we agree, but whether a reasonable mind could.

Q&A for Claimants and Representatives

Q: Why are fibromyalgia claims often denied?

A: Because fibromyalgia lacks objective markers, ALJs often rely on treatment history, conservative care, and daily activities to question the severity of symptoms.

Q: Do treating physician opinions guarantee approval?

A: No. Even under the older rules, contradictions, lack of support, and the doctor’s specialty can lead to reduced weight for their opinions.

Q: Can chiropractor records help in a Social Security disability claim?

A: They can provide context but are not given the same weight as “acceptable medical sources” under SSA regulations.

Q: What standard do courts apply when reviewing ALJ decisions?

A: Courts apply the “substantial evidence” standard, asking only whether a reasonable mind could support the ALJ’s conclusion—not whether the court agrees.

Got any questions? Schedule a consultation with us. I’m here to help. It’s a lot to take in, but we’ll get through it together. After all, navigating these waters is always easier when you’ve got someone to chat with.