Williams v. Colvin: Determining the Date of Disability for the Purpose of SSDI

Williams v. Colvin, an appeal from the U.S. Court of Appeals for the Seventh Circuit, involved a 44-year-old claimant who applied for Social Security Disability Insurance (SSDI) benefits due to what she called a cascade of physical and psychological events that occurred in 2002. She claimed that she was no longer able to work due to fibromyalgia, which is a neurological condition that can cause extreme neurological pain and emotional distress.

Some of the symptoms of fibromyalgia, as noted by the U.S. Court of Appeals, are musculoskeletal pain, fatigue, memory loss, mood disorders, and general problems with the way in which the brain processes pain. This is a very serious condition that has affected millions of Americans, though it has only recently been accepted as a legitimate illness. For many years, patients suffered unimaginable and debilitating pain, while basically being told they were imagining the illness.

The administrative law judge (ALJ) at the Social Security Administration (SSA) made a finding in 2012 that fibromyalgia did in fact leave the claimant in this case unable to work, but he found that her date of disability for the purposes of obtaining benefits was 2008 rather than 2012.

As your Boston disability attorney can explain, upon a finding of disability by an ALJ, you may be entitled to a retroactive award of benefits, so the date in which you were determined to be disabled is obviously significant.

In Williams, the claimant had died of an unrelated medical condition prior to the ruling by the ALJ. Her father stepped in as her substitute for the purposes of appealing the ruling the U.S. District Court. The appeal was based on grounds that the claimant was actually disabled well before the 2008 date determined by the ALJ.

The first determination that the claimant was not disabled was made in 2004. The claimant appealed, and the case was remanded to the ALJ, who again ruled that she was not disabled. The claimant appealed again and this time, the case was to be heard by a different ALJ. This time, the ALJ found that she was disabled in 2008 because, by that point, she could not walk without a cane, and that made her disabled.

The ALJ was looking at the physical illness and mental illness caused by the fibromyalgia as separate conditions, rather than looking at her condition as a whole in determining when she became disabled.

The appellate court ultimately held that the second ALJ did not make a decision based upon the medical history and information at his disposal and basically stated that the 2008 date was not supported by the evidence. This case was reversed and remanded for further proceedings to determine her actual date of disability.

If you are seeking Social Security Disability Insurance in Boston, call for a free and confidential appointment at (617) 777-7777.

Additional Resources:

Williams v. Colvin, July 2, 2014, U.S. Court of Appeals for the Seventh Circuit
More Blog Entries:

Hill v. Colvin – Mental Disorders Can be Challenge to Prove, July 1, 2014