Fibromyalgia and the Need for a Longitudinal Review

Fibromyalgia continues to challenge both claimants and adjudicators in Social Security disability law. The Seventh Circuit’s recent decision in Swiecichowski v. Leland (7th Cir. 2025) underscores the importance of how Administrative Law Judges (ALJs) must approach these cases, specifically, the requirement for a longitudinal review under SSR 12-2p.

Background

Christine Swiecichowski worked in a warehouse for over thirty years before stopping in 2018 due to fibromyalgia, depression, spinal disorders, and arm/wrist issues. She applied for disability insurance benefits, alleging her symptoms prevented sustained employment.

The ALJ recognized fibromyalgia as a severe medically determinable impairment but denied benefits. The denial rested on several findings:

• Diagnostic testing (EMGs, MRIs) showed only “mild” abnormalities.

• Clinical exams were described as “mixed,” with many reports noting normal strength, sensation, and reflexes.

• Swiecichowski’s activities of daily living (limited housework, simple meal prep, driving short distances) were viewed as inconsistent with disabling pain.

  
  

On that basis, the ALJ concluded she could perform light work with restrictions. The district court affirmed.

The Seventh Circuit’s Majority Opinion

The appellate court vacated and remanded. While acknowledging the ALJ’s detailed record review, the majority emphasized that fibromyalgia is unique:

• Symptoms are subjective and often fluctuate (“good days and bad days”).

• Objective tests (like MRIs) are rarely useful; the trigger-point exam remains the only recognized diagnostic tool.

• SSR 12-2p requires ALJs to take a longitudinal approach—evaluating the totality of the record over time, not just isolated medical visits.

  
  

Here, the ALJ cited only a handful of visits to conclude the clinical findings were “mixed.” But the record reflected dozens of visits with consistent complaints of widespread pain, tenderness, and functional limitations. By failing to acknowledge this longitudinal context, the ALJ did not build the “logical bridge” required between evidence and conclusions.

The majority also cautioned against over-reliance on “conservative treatment” to discredit pain testimony. In fibromyalgia cases, injections, therapy, and medication are often the standard—not evidence that symptoms are mild.

The Dissent

Judge Kirsch dissented, arguing that while the ALJ could have been clearer, the decision still met the deferential substantial evidence standard. He emphasized the limited scope of appellate review, warning against imposing an undefined threshold for how much longitudinal evidence must be discussed.

The Real Battle in Fibromyalgia Cases

In most disability cases, the key dispute is whether the claimant actually has the condition they allege. That’s not usually the sticking point with fibromyalgia. By the time the case reaches the ALJ, the diagnosis is often well-established through trigger-point testing and physician notes.

The real challenge lies in how adjudicators interpret the condition’s impact. Fibromyalgia doesn’t present neatly on an MRI or lab report. Instead, it shows up in ways that are:

• Variable – symptoms wax and wane, producing both “good days” and “bad days.”

• Inconsistent – claimants may manage certain tasks one day but be unable to function the next.

• Invisible – physical exams often look normal even when pain is debilitating.

This disconnect leads ALJs to discount subjective complaints as inconsistent with the record, even when those fluctuations are hallmark features of fibromyalgia itself. That’s why SSR 12-2p is critical: it requires ALJs to evaluate the condition longitudinally, considering patterns over time rather than cherry-picking isolated exams.

Practical Takeaways for Attorneys

1. Preserve Issues Early – Most of Swiecichowski’s challenges were waived because they weren’t raised in district court. Make sure you raise all the issues.

2. Push for Longitudinal Analysis – Point ALJs to SSR 12-2p and highlight the waxing/waning nature of fibromyalgia. A single “good day” entry shouldn’t dominate the record.

3. Challenge Over-Reliance on Normal Exams – Normal reflexes, gait, and strength are not inconsistent with disabling fibromyalgia.

4. Address Treatment Critiques – Preempt “conservative treatment” arguments by showing the limited medical options available for fibromyalgia patients.

   
   

This decision reinforces what many practitioners already know: fibromyalgia requires a different lens. For claimants, the battle often isn’t about proving the diagnosis, it’s about ensuring adjudicators view the condition as it truly is: variable, inconsistent, and invisible, yet capable of being profoundly disabling.

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.