26/12/2025
Article:
Their complaints are often ignored or brushed aside, but fibromyalgia sufferers see some hope in a recent court ruling that Social Security Administration officials were wrong to discount an Anne Arundel County woman’s description of the suffering the condition caused her.
Crystal Hultz was first denied Social Security disability benefits back in 2014. Throughout her many attempts to challenge the decision, administrative law judges believed her subjective testimony was not properly supported by medical evidence.
But in a Dec. 15 opinion, a three-judge panel of the 4th U.S. Circuit Court of Appeals ruled that in cases where there are no objective medical tests or markers to identify debilitating conditions, like fibromyalgia, subjective testimony must have more weight.
“This case is about crediting a patient’s accounts of the chronic, debilitating, and little-understood illness fibromyalgia,” Circuit Judge Roger L. Gregory wrote in the opinion.
“Fibromyalgia is a serious and mysterious condition, disproportionately affecting women, that our current science is incapable of observing through objective medical testing. Accordingly, we must give due weight to Ms. Hultz’s subjective testimony about the severity of her symptoms,” Gregory wrote.
He said the administrative law judges and lower courts that supported the initial denial were wrong to disregard her struggle with fibromyalgia, reversed the denial and sent the case back for administrators to calculate Hultz’s benefits.
Jeffrey R. Scholnick, the attorney representing Hultz, said she cried on the phone when he called her last week about the ruling.
I called her on Monday and said, ‘Congratulations, people believe you now,’” he said in a recent interview.
Scholnick said the ruling will help other people get disability benefits when they are struggling with debilitating conditions that cannot be detected through definitive medical tests.
“It’s the nature of this disease (fibromyalgia). Because people don’t see it, they don’t believe you,” he said.
Hultz is one of about 4 million people in the United States who struggle with fibromyalgia, a condition that causes pain all over the body, and can lead to fatigue as well as emotional and mental distress, according to the U.S. Centers for Disease Control and Prevention. Diagnosing fibromyalgia largely relies on a patient’s subjective description of symptoms, as there are no medical tests that can objectively confirm the condition.
Hultz’s symptoms began in 2013, severely limiting her ability to work. She applied for disability the next year.
According to court documents, fibromyalgia and lupus interfered with her ability to do daily tasks, such as “opening jars, handwriting, turning keys, preparing meals, performing heavy household chores, accomplishing yard work, and carrying heavier objects with the hand that suffered from pain and numbness.”
After appealing the initial denial in 2014, what followed was a series of court hearings, denials and appeals spanning over a decade.
Throughout the process, administrative law judges disregarded fibromyalgia as a feature of her disability. One judge omitted the condition entirely when denying her benefit, and one physician consulted for Hultz’s case believed she had a “component of ‘malingering.’”
Lynne Kennedy Matallana, CEO and founder of the National Fibromyalgia Association, said that people in Hultz’s situation often get “lost in the system” and can give up trying to seek out disability benefits.
“We still have situations where the diagnosis of fibromyalgia and the understanding of it continues to be debated,” she said. “Those of us dealing with it are initially in such horrible straits, because we went from living very happy lives and being able to take care of families and things to all of a sudden having an illness.
“There are those people, like this woman, that get lost in the system and never get the help that they need,” Matallana said.
Fibromyalgia is a serious and mysterious condition, disproportionately affecting women, that our current science is incapable of observing through objective medical testing. Accordingly, we must give due weight to Ms. Hultz’s subjective testimony about the severity of her symptoms.
– U.S. 4th Circuit Judge Roger L. Gregory
Meanwhile, other physicians working with Hultz, along with family members, testified that her fibromyalgia led to days of fatigue and pain that often left her bedridden.
Her luck began to change in 2020, when Gregory ruled in a similar case, Arakas v. Commissioner, affirming that Social Security officials must take subjective testimony into account for conditions that do not have a tangible test or medical marker to identify them.
Gregory wrote in Hultz’s case that the court “must be guided by our precedent in Arakas v. Commissioner, which held that ALJs (administrative law judges) may not rely on objective medical evidence even as just one of multiple factors to discount a claimant’s subjective complaints regarding symptoms of fibromyalgia.”
Judge G. Steven Agee agreed with the majority that the administrative law judges in Hultz’s case should have put more weight on her subjective testimony. But in a partial dissent, he said he believed the court went too far in its remedy.
“Rather than simply vacate the ALJ’s decision and remand for reconsideration of Hultz’s claim, it went a step further, opting to outright reverse the ALJ’s decision and deem Hultz entitled to disability benefits in the first instance,” Agee wrote. “In doing so, it departed from the process courts typically employ when an ALJ errs.”
Matallana says it’s important for people with fibromyalgia and other disabilities to push through court challenges to receive benefits.
“I do recommend that people find an attorney who will represent them,” she said. “When you’re sick, you don’t know how to get up the energy and the strength to fight something like this.”
Link: https:// marylandmatters .org/ 2025/12/24/federal-court-says-social-security-cant-dismiss-complaints-of-fibromyalgia-sufferers/
