Background
Andrea M. Fain applied for Title II disability insurance benefits in January 2021, alleging PTSD, panic disorder, ADHD, major depressive disorder, fibromyalgia, and irritable bowel disease. An administrative law judge found several of those conditions severe but concluded that Fain could perform a limited range of light work, including her past work as a mail clerk.
The ALJ rejected portions of the opinion of Fain’s treating physician, Dr. Brandy Thomas, discounted Fain’s symptom testimony, and gave no reason for not crediting statements from Fain’s partner about her symptoms and functional limitations. The district court affirmed the Commissioner’s denial of benefits.
The Court’s Holding
The Ninth Circuit reversed. The court held that the ALJ gave invalid reasons for finding Dr. Thomas’s fibromyalgia opinion unpersuasive, including reliance on normal gait, strength, and range-of-motion findings that may be consistent with disabling fibromyalgia. The ALJ also mistakenly stated that Fain taught online yoga classes when the record showed only that she took them.
The court upheld the ALJ’s evaluation of three other medical opinions and found adequate reasons to discount Fain’s testimony about mental-health symptoms. But it held that the ALJ lacked convincing reasons to reject Fain’s testimony concerning physical symptoms from fibromyalgia, and that the ALJ harmfuly erred by giving no reason for rejecting her partner’s lay testimony. The 2017 Social Security regulations did not eliminate the requirement that an ALJ give germane reasons for discounting lay testimony. The court remanded for further administrative proceedings rather than an award of benefits.
Key Takeaways
- Normal strength, gait, and range of motion do not by themselves undermine claimed limitations from fibromyalgia.
- An ALJ must give germane reasons for discounting lay-witness testimony in post-March 27, 2017 claims.
- Further proceedings were necessary because the record did not warrant an immediate benefits award.
Why It Matters
The decision confirms that the 2017 revisions governing medical-opinion evidence did not authorize ALJs to disregard lay evidence without explanation. It also reinforces the Ninth Circuit’s instruction that fibromyalgia evidence must be assessed in light of the condition’s distinctive symptoms and diagnostic methods.