Markham v. Social Security Administration, Commissioner

On September 17, 2018, the U.S. Court of Appeals for the Eleventh Circuit issued its decision in the case of Stephanie Markham, who had appealed the denial of her application for disability insurance benefits. Markham alleged disability due to fibromyalgia, chronic fatigue, and other impairments. An Administrative Law Judge (ALJ) denied her claim, finding that her subjective complaints of pain and limitation were not supported by objective medical evidence. The district court affirmed that decision. The Eleventh Circuit reversed, holding that the ALJ committed legal error by insisting upon objective medical evidence to corroborate Markham’s fibromyalgia symptoms. The court emphasized that fibromyalgia is a condition that often lacks objective clinical findings and is diagnosed primarily based on a patient’s subjective reports. Moreover, the court found that the ALJ did not articulate good cause for discounting the opinion of Markham’s treating physician. The case was remanded to the Social Security Administration for further proceedings consistent with the opinion.

The United States Court of Appeals for the Eleventh Circuit reversed the district court's judgment and remanded the case to the Social Security Administration for further proceedings.

Whether the Administrative Law Judge erred by requiring objective medical evidence to substantiate subjective complaints of pain from fibromyalgia and by failing to properly weigh the treating physician's opinion.

The decision reinforced that for conditions like fibromyalgia, which are primarily diagnosed through subjective patient reports, an ALJ cannot rely solely on a lack of objective medical evidence to discount a claimant's testimony. It serves as an important precedent guiding the adjudication of disability claims involving chronic pain syndromes and underscores the requirement for ALJs to fully articulate reasons for rejecting treating source opinions.