Faught v. Social Security Administration, Commissioner

Joe Faught applied for Social Security Disability Insurance benefits, claiming severe back pain and related limitations. An Administrative Law Judge (ALJ) denied his claim, finding that while his impairments could reasonably be expected to cause the alleged symptoms, his statements regarding the intensity, persistence, and limiting effects of pain were not entirely consistent with the objective medical evidence. The ALJ discredited Faught’s subjective complaints without adequate explanation or full consideration of the pain standard. The district court affirmed the denial. On appeal, the Eleventh Circuit reviewed whether the ALJ properly evaluated subjective symptoms under the applicable regulations and Eleventh Circuit precedent. The court found the ALJ’s credibility determination lacking specific, articulable reasons and improperly requiring strict objective medical corroboration. The case was reversed and remanded for further administrative proceedings consistent with the opinion.

The United States Court of Appeals for the Eleventh Circuit reversed the district court’s judgment and remanded the case to the Social Security Administration for further proceedings, instructing the ALJ to properly evaluate the claimant’s subjective symptoms under the correct legal standards.

Whether the Administrative Law Judge erred by discounting the claimant’s subjective complaints of pain and other symptoms without providing sufficient rationale and by improperly requiring objective medical evidence to fully corroborate the alleged severity, contrary to the pain standard established by Eleventh Circuit precedent.

The decision reinforces the procedural safeguards requiring ALJs to explicitly articulate grounds for discrediting subjective symptom testimony, rejecting a rigid objective-evidence requirement. It clarifies the pain standard’s application, influencing how disability claims based on chronic pain are adjudicated and providing clearer protection for claimants whose conditions cannot be fully measured by imaging or laboratory tests.