Latest / FLG Disability Insights / Fibromyalgia, Daily Activities, and a Flawed SSDI Denial
Transcript
- Can making a simple meal or taking a short shopping trip really prove that someone can sustain a full workday? A federal court in California recently said the answer requires much more context. Welcome to FLG Disability Insights. I’m Nick Feden of Feden Law Group. In Debbie F.C. versus Bisignano, the claimant had severe fibromyalgia along with shoulder, neck, and spine conditions. She testified that sitting or standing for more than five to ten minutes caused severe pain and forced her to change positions. The administrative law judge found that she could perform restricted light work and return to her past work as a portfolio manager and analyst. Part of the ALJ’s reasoning focused on limited driving, preparing simple meals, light shopping, and occasionally caring for a dog. But the court found no adequate explanation of how those activities contradicted her testimony or demonstrated skills transferable to work. A task performed briefly, with breaks, and on a person’s own schedule does not automatically show an ability to perform reliably throughout a workday. Duration, frequency, assistance, and the need to rest all matter. The court also questioned the ALJ’s reliance on normal examination findings without an adequate, medically supported explanation connecting those findings to the severity of fibromyalgia pain. Fibromyalgia symptoms can fluctuate. That does not make every normal finding irrelevant, but it does mean the finding must be considered in relation to the condition and the symptom being evaluated. The court likewise found a pre-onset MRI of limited relevance and noted that a preoperative statement about climbing stairs or heavy housework appeared to address cardiovascular status. Even the ALJ’s brief observations during a video hearing did not fix the problem. Watching someone sit or stand for a short period did not clearly contradict reported difficulty maintaining those positions over time. Applying Ninth Circuit law, the Central District of California reversed the denial and sent the case back for further proceedings. It did not award benefits or decide that the claimant could perform no work. This is a district court decision under the circumstances presented, not a nationwide rule. The practical takeaway is simple: describe daily activities with precision. Explain how long they take, how often they happen, what breaks or position changes are needed, and what happens afterward. Those details can show the difference between completing a limited task and sustaining competitive work. Visit FedenLawGroup dot com and try FLG Case Analyst Beta. Get a full report generated by an attorney-trained, cutting-edge AI model, then connect with our firm about your next step. This podcast provides general information, not legal advice. I’m Nick Feden. Thanks for listening to FLG Disability Insights.