Padua v. Bisignano: Seventh Circuit Clarifies How ALJs Must Evaluate Fibromyalgia Claims Filed Before 2017 Under the Treating-Physician Rule

1. Introduction

In Jada M. Padua v. Frank Bisignano, decided on 1 August 2025, the U.S. Court of Appeals for the Seventh Circuit confronted a recurring problem in Social Security disability litigation: how Administrative Law Judges (ALJs) should weigh subjective pain testimony, conservative treatment records, and conflicting medical opinions when the claimant’s primary impairment is fibromyalgia. The claimant, Jada Padua, alleged disabling pain and fatigue stemming from fibromyalgia, chronic fatigue syndrome, depression, and anxiety. After an ALJ twice denied benefits, Padua sought review all the way up to the Seventh Circuit, primarily challenging (1) the ALJ’s discounting of her pain complaints, and (2) the low weight accorded to her treating internist and chiropractor.

The panel (Judges Hamilton, Kirsch, and author Judge Maldonado) affirmed, but in doing so it articulated a carefully-structured approach for ALJs faced with fibromyalgia claims filed before March 27 2017, when the Social Security Administration (SSA) still adhered to the “treating-physician rule.” The decision synthesises post-2017 regulatory changes, earlier circuit precedent, and the unique evidentiary profile of fibromyalgia, producing a precedent of lasting importance for cases still governed by the prior regulations.

2. Summary of the Judgment

• The Court applied de novo review to the district court’s judgment but reviewed the ALJ’s fact-findings under the substantial-evidence standard.
• It held that the ALJ built an “accurate and logical bridge” when:
  • Comparing Padua’s subjective complaints against benign objective findings, conservative treatment, and her daily activities;
  • Discounting or declining to give controlling weight to treating internist Dr. Carpenter due to internal inconsistencies and conflicts with the longitudinal record;
  • Giving limited weight to chiropractor Dr. Pendolino because he is a non-acceptable medical source and offered checkbox, unsupported opinions;
  • Formulating a residual functional capacity (RFC) for reduced range of light work—more restrictive than state-agency doctors recommended—and identifying significant jobs in the national economy.
• Because substantial evidence supported each contested step, the Seventh Circuit affirmed the denial of benefits.

3. Analysis

3.1 Precedents Cited and Their Role

The opinion threads together a line of Seventh Circuit cases addressing:

• Evaluation of Fibromyalgia: Hohman v. Kijakazi (2023) and Vanprooyen v. Berryhill (2017) emphasised that ALJs must appreciate fibromyalgia’s lack of objective lab findings yet may still contrast complaints with treatment efficacy and activities. The Court echoes those holdings.
• Treating-Physician Rule: 20 C.F.R. § 404.1527(c)(2) (pre-2017) and cases such as Stage v. Colvin (2016) and Warnell v. O'Malley (2024) require “good reasons” for rejecting controlling weight. The panel used these criteria to scrutinise the ALJ’s rationale.
• “Logical Bridge” Requirement: Jeske v. Saul (2020) and Stephens v. Berryhill (2018) provide the familiar standard guiding judicial review. The Court repeatedly referenced that duty.
• Reliance on Conservative Treatment: Swiecichowski v. Dudek (2025) supplies a fresh, published citation on how minimal treatment may undercut claims of disabling pain.
• Harmless-Error in Mental RFC: Jozefyk v. Berryhill (2019) informed the Court’s rejection of Padua’s under-developed mental-limitation argument.

By weaving these decisions together, the panel for the first time expressly states that an ALJ’s evaluation of fibromyalgia can rely on conservative treatment and daily activities, even where objective findings are scarce, provided the ALJ acknowledges the disease’s unique diagnostic hurdles. That synthesis is the heart of the new precedent.

3.2 Legal Reasoning

1. Subjective Symptom Analysis – The ALJ satisfied SSR 12-2p by:
   • Recognising trigger-point exams as the only objective test for fibromyalgia;
   • Still considering other evidence because the statute (42 U.S.C. § 423(d)(5)(A)) requires it;
   • Reconciling conflicting evidence with a multi-factor narrative: conservative treatment, medication efficacy, ability to drive to massage school, and personal care activities.
2. Treating-Physician Rule Application – The Court outlined a two-tier test:
   1. Is the opinion well-supported by medically acceptable techniques? (Dr. Carpenter’s were internally inconsistent.)
   2. Is it consistent with the rest of the record? (It clashed with benign clinical findings and his later own report.)
   Failure on either permits the ALJ to assign less than controlling weight, and a minimal but logical explanation suffices.
3. Non-Acceptable Medical Sources – Chiropractors like Dr. Pendolino fall outside § 404.1502(a). ALJs may still weigh their opinions as “other” evidence but need not accord them significant weight, especially if they rely on checkbox forms unaccompanied by narrative justification.
4. RFC Formulation – Because the ALJ actually tightened restrictions beyond agency physicians’ advice, the Court found no reversible error and deemed Padua’s counter-arguments undeveloped and therefore waived.

3.3 Impact of the Decision

The judgment cements a clarified analytical roadmap for pending and future Seventh Circuit cases involving:

• Legacy (“pre-2017”) claims still governed by the treating-physician rule. ALJs may discount treating opinions if (1) internally inconsistent or (2) inconsistent with the broader record, and need only minimally articulate the support once the two-step threshold fails.
• Fibromyalgia-driven applications. Even though fibromyalgia resists objective confirmation, ALJs may legitimately:
  • Compare subjective symptoms with conservative treatment success;
  • Point to discordant daily activities (e.g., commuting, schooling) to resolve credibility;
  • Use state-agency or consultative examiners to fill any specialist gap without mandatorily calling a medical expert.
• Weighing non-acceptable sources. The case fortifies the proposition that checkbox forms unsupported by underlying notes will garner little weight.
• The precedent is likely to reduce remands in the Circuit where ALJs have scrupulously documented conservative care, daily activity inconsistencies, and conflicts within treating opinions.

4. Complex Concepts Simplified

5. Conclusion

Padua v. Bisignano stands as a meticulous blueprint for how ALJs and reviewing courts should handle fibromyalgia-based disability claims that are still governed by the treating-physician rule. The Seventh Circuit confirms that:

• Subjective pain claims must be reconciled with the full record, including treatment type and daily activities;
• Internal inconsistency within a treating doctor’s reports or conflict with the broader record are “good reasons” to assign reduced weight;
• Non-acceptable medical sources deserve only the weight their supporting explanations justify;
• An ALJ’s obligation is to build a logical bridge, not to guarantee claimant victory where substantial evidence runs the other way.

Practitioners should heed this decision when assembling fibromyalgia cases: gather consistent, longitudinal medical evidence, ensure treating-source opinions are not undermined by later notes, and anticipate that conservative treatment or incongruent daily activities may erode subjective complaints of disabling pain. In short, Padua refines, but does not revolutionise, the Seventh Circuit’s disability jurisprudence; it tightens the analytical screws on ALJs, yet simultaneously shields well-reasoned denials from remand.