Fibromyalgia and Social Security Disability: Lessons from Hultz v. Bisignano

Fibromyalgia can make it difficult to work consistently, even when routine medical tests do not explain the severity of a person’s pain and fatigue. For someone seeking Social Security disability benefits, that can make an already demanding process especially frustrating.

A federal appeals decision illustrates why a disability evaluation must account for the way fibromyalgia affects everyday life. The U.S. Court of Appeals decided Hultz v. Bisignano, reversing a denial of benefits and sending the case back for calculation of benefits. [1]

What happened in the Hultz case?

Crystal Hultz, a former computer operator, applied for Social Security Disability. She had several medical conditions, including fibromyalgia and lupus. Her application was denied, and her case went through multiple hearings and court proceedings.

Hultz described unpredictable flares of pain and fatigue that could leave her in bed for days. She also reported difficulty with memory and concentration. Her grandmother confirmed that she needed substantial help with cooking, cleaning, laundry, and caring for her children.

The Administrative Law Judge denied benefits, relying in part on medical findings, treatment gaps, and reports that Hultz could sometimes perform daily activities. The appeals court concluded that the judge had evaluated the evidence incorrectly. [1]

Why did the court reverse the denial?

The Appeals Court held that the Administrative law Judge could not use objective medical evidence, or its absence, to discount Hultz’s descriptions of her fibromyalgia symptoms.

The Court also examined the full history of her condition. Some treatment had improved other medical problems, but that did not establish that her fibromyalgia had improved enough for her to work. Occasional shopping, cooking, or other activities also needed to be considered alongside her flares, need for rest, and reliance on family members. [1]

What evidence matters in a fibromyalgia disability claim?

Social Security’s rules on fibromyalgia requires appropriate medical evidence to establish the impairment. A diagnosis alone is insufficient. Once the impairment is established, Social Security evaluates symptoms and their effects on the person’s ability to work using the full record. [2]

Useful documentation can include medical records over time, descriptions of pain and fatigue, the frequency and duration of flares, and the help needed for daily tasks. Information from relatives or others who observe those limitations may also be relevant. [2]

The practical lesson is to explain what happens when you attempt an activity: how long you can continue, what help you need, and how much recovery time follows. For example, being able to make one grocery trip may leave unanswered questions about whether you can sustain a regular work schedule.

Need help after a disability denial?

If fibromyalgia is affecting your ability to work and your Social Security disability claim has been denied, the Law Office of Dennis Elfert and Gulf Coast Disability Center can review your situation and discuss your options. Call 985.580.6000 or request a free case evaluation at gulfcoastdisabilitylaw.com.

This article provides general information, not legal advice. Eligibility depends on the facts and evidence of each claim. A result in another person’s case does not guarantee a similar outcome.