What a Recent Seventh Circuit Decision Teaches Us About Disability Claims and SSR 12-2p

In September 2025, the Seventh Circuit Court of Appeals reviewed a case involving a claimant with fibromyalgia and related conditions. The case highlights how courts are scrutinizing Administrative Law Judge (ALJ) decisions when they fail to apply Social Security Ruling (SSR) 12-2p properly.

For claimants and advocates, this decision underscores the importance of understanding how fibromyalgia and other conditions with primarily subjective symptoms must be evaluated over time, not just at isolated points. At Green and Greenberg, we keep a close watch on these rulings to better protect our clients’ rights.

Why This Case Matters

The claimant stopped working after decades of employment due to fibromyalgia, depression, and musculoskeletal pain. The ALJ recognized fibromyalgia as a severe impairment but ultimately denied benefits.

On appeal, the Seventh Circuit found problems with how the ALJ weighed the evidence:

• Too much focus was placed on occasional “normal” physical exam findings.
• The ALJ minimized consistent complaints of pain, fatigue, and functional limits across many visits.
• The decision suggested that “conservative treatment” meant the impairments were not disabling.

The court sent the case back, reminding ALJs that fibromyalgia requires a longitudinal evaluation under SSR 12-2p. In other words, the record must be reviewed as a whole, showing how symptoms persist and fluctuate, not just in isolated snapshots.

Understanding SSR 12-2p

SSR 12-2p is the Social Security Administration’s guidance on how to evaluate fibromyalgia. Its key principles include:

• Fibromyalgia symptoms often do not show up on objective tests like MRIs or X-rays.
• Symptoms vary from day to day, so “good days” and “bad days” must be considered.
• The decision maker must examine the medical record over time (longitudinally).
• ALJs must clearly explain how they reached their conclusions, linking medical evidence, testimony, and functional limitations.

The Seventh Circuit reinforced that skipping these requirements, or “cherry-picking” isolated findings, violates the ruling.

Key Takeaways for Disability Applicants and Representatives

This decision offers several practical takeaways:

• Normal test results don’t automatically disprove disability.
  In conditions like fibromyalgia, normal reflexes, strength, or imaging are common, yet symptoms can still be disabling.
• Consistency in the record matters.
  Repeated reports of pain, fatigue, or limited activity—even if spread over years—carry significant weight.
• Conservative care is still legitimate care.
  Pain conditions are often managed with medication, physical therapy, or injections. Courts have cautioned that calling this “conservative” does not mean the impairment is minor.
• Medical opinions should describe real-world limits.
  Doctors can strengthen a case by noting how symptoms limit walking, standing, concentrating, or performing daily activities.
• Vocational evidence must reflect real limitations.
  If the ALJ’s hypothetical to the vocational expert leaves out limitations supported by the full record, that can be grounds for appeal.

Green and Greenberg’s Proven Success with Fibromyalgia Claims

This area of law isn’t just theoretical for us, it’s something we’ve fought and won. In fact, Green and Greenberg attorney James Gannon successfully argued a fibromyalgia case before the U.S. Court of Appeals for the First Circuit.

That victory demonstrated what we continue to advocate today: fibromyalgia must be judged by how it impacts daily functioning over time, not by whether objective medical findings “prove” the condition. Courts at every level have increasingly emphasized this principle, and Green and Greenberg has been at the forefront of ensuring our clients benefit from these legal protections.

What This Means for You

If you are applying for disability benefits in 2025, especially for conditions like fibromyalgia, chronic pain, or mental impairments, the rules are complex. Courts have made it clear that your full medical history matters, not just a few visits or test results.

Trying to prove this on your own can feel overwhelming. That’s where we come in. At Green and Greenberg, we know how to:

• Gather and present your records in a way that supports your claim.
• Challenge decisions that ignore the full picture of your health.
• Apply the latest court rulings and SSA policies to strengthen your case.

Don’t risk losing the benefits you deserve because of a technicality or incomplete record. Call Green and Greenberg today to schedule a consultation and let us fight for your rights.