Sisco v. Department of HHS

Sisco (plaintiff) was denied Social Security disability benefits following an administrative-law judge’s (ALJ) finding that her chronic-fatigue syndrome was not a medically identifiable impairment because it was not diagnosed in a laboratory setting. From 1985 through 1989, Sisco was seen by more than 15 doctors of various specialties, presenting with extreme fatigue and severe headaches. No doctor was able to identify a physical ailment as the cause of Sisco’s ailments; in fact, some doctors suggested hypochondriasis or personality disorders. In 1989, doctors at the Mayo clinic diagnosed Sisco with tension myalgia and chronic-fatigue syndrome, a disease that had only gained recognition by the Center for Disease Control in 1988. Sisco provided a report that was prepared by the clinic regarding her medical history and failed diagnoses. Further, Sisco’s treating physician from the clinic testified that chronic-fatigue syndrome rendered Sisco totally disabled because she could not sustain activity, even sitting, for more than 15 minutes without needing to rest and provided medical research regarding the condition to support the claim. The ALJ discounted Sisco’s symptoms as her subjective complaints that were not supported by the medical evidence. Accordingly, the ALJ concluded that Sisco could return to work full-time because there was no documentation of medically accepted clinical or laboratory techniques that supported her diagnosis of chronic-fatigue syndrome. The ALJ’s decision became the final decision of the Secretary of the Department of Health and Human Services (defendant). Sisco sought judicial review, and a district court ruled in favor of the secretary, adopting the ALJ’s decision and adding that Sisco’s diagnosis was based on literature and not objective medical findings. Sisco appealed.