Perez v. Commissioner of Social Security, 6:23-cv-00258

Mildred Perez filed claims for Disability Insurance Benefits (DIB) and Supplemental Security Income (SSI) with the Social Security Administration (SSA), alleging multiple impairments including fibromyalgia and depression, with an alleged onset date of September 3, 2020.
Her claims were denied initially and upon reconsideration by the SSA.
An Administrative Law Judge (ALJ) held a hearing in April 2022, at which Perez and a vocational expert testified; the ALJ found Perez "not disabled" at step four (capable of past relevant work).
The ALJ found Perez had several severe impairments (including fibromyalgia), but determined her subjective symptom complaints were not entirely consistent with the medical evidence and activities of daily living.
Perez appealed to the district court, challenging the ALJ’s analysis of her symptoms and medical opinion evidence concerning her fibromyalgia.
The district court reversed and remanded, finding the ALJ failed to adequately address fibromyalgia-specific guidance and mischaracterized provider findings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Adequacy of ALJ's fibromyalgia evaluation	ALJ failed to provide sufficient rationale when evaluating Perez’s testimony, given diagnosis of fibromyalgia and SSR 12-2p guidance on symptom fluctuation	ALJ properly considered and applied the social security ruling and evidence in evaluating symptoms	Court found ALJ did not sufficiently consider fibromyalgia’s nature (“good days and bad days”) and did not follow SSR 12-2p adequately
Evaluation of medical opinions (Weiss & Meyer)	ALJ disregarded treating providers' objective findings and explanations without substantial evidence or required analysis	ALJ gave reasoned basis for rejecting providers’ opinions as inconsistent with imaging, exam findings, and treatment history	Court held ALJ’s analysis contained inaccurate findings, failed to account for longitudinal record, and mischaracterized evidence, requiring remand

Wilson v. Barnhart, 284 F.3d 1219 (11th Cir. 2002) (establishes the standard for subjective pain testimony in disability claims)
Dyer v. Barnhart, 395 F.3d 1206 (11th Cir. 2005) (substantial evidence standard and necessity of adequate reasons for credibility determinations)
Crawford v. Comm’r of Soc. Sec., 363 F.3d 1155 (11th Cir. 2004) (appellate review standard for social security decisions)
Phillips v. Barnhart, 357 F.3d 1232 (11th Cir. 2004) (explains five-step sequential evaluation for disability)
Bowen v. Yuckert, 482 U.S. 137 (1987) (burden of proof in disability determination shifted at step five)