If you’ve filed a disability insurance claim and been told that your condition isn’t “objectively proven,” you’re not alone — and you’re not out of options. Many individuals suffering from debilitating conditions such as chronic pain, fatigue, depression, migraines, or fibromyalgia are unfairly denied benefits because insurance companies claim there’s not enough “objective evidence.” Fortunately, the courts have addressed this issue — and the law is on your side.

The Truth About Subjective Symptoms in Disability Claims

Not every medical condition shows up on an X-ray or blood test. In fact, some of the most disabling conditions — chronic fatigue syndrome, fibromyalgia, and mental health disorders — are diagnosed primarily through clinical evaluation and self-reported symptoms.

The good news? Federal courts have consistently ruled that subjective complaints like pain, fatigue, and cognitive impairment can be legally sufficient to prove disability.

What Do the Courts Say? Case Law Highlights

Here are some of the most important court decisions that support your right to have subjective symptoms taken seriously in a disability claim:

Ninth Circuit (California and Western States)

  • Salomaa v. Honda LTD Plan
    “The Plan may not deny benefits simply because the symptoms are not corroborated by objective medical evidence.”
    — The court ruled for a claimant with Chronic Fatigue Syndrome, emphasizing that subjective symptoms must be considered. (642 F.3d 666)
  • Montour v. Hartford Life & Accident Ins. Co.
    “Conditions such as fibromyalgia, chronic fatigue syndrome, and mental illnesses are not easily amenable to objective verification.”
    — The insurer wrongly disregarded symptoms of CFS and mental illness. (588 F.3d 623)
  • Saffon v. Wells Fargo LTD Plan
    “Disability insurers should not insist on objective proof when the condition itself is diagnosed primarily based on subjective symptoms.”
    — Applied to radiculopathy and chronic pain. (522 F.3d 863)
  • Fair v. Bowen (Social Security case, widely cited)
    “A claimant’s pain testimony cannot be rejected simply because it is not supported by objective evidence.” (885 F.2d 597)

Other Courts Across the Country

  • Hawkins v. First Union LTD Plan (7th Cir.)
    “Pain is not an objective phenomenon.”
    — Benefits cannot be denied solely for lack of lab findings. (326 F.3d 914)
  • Mitchell v. Eastman Kodak (3rd Cir.)
    “Subjective evidence can establish disability where the condition does not lend itself to objective diagnosis.” (113 F.3d 433)
  • Cook v. Liberty Life (1st Cir.)
    “Subjective complaints of pain and fatigue must be considered in fibromyalgia claims.” (320 F.3d 11)
  • Keller v. Standard Ins. Co. (D. Mont.)
    “Subjective complaints consistent with the diagnosis and treatment history must be credited.” (989 F. Supp. 2d 1193)

What This Means for You

If your disability claim has been denied because your condition “can’t be proven,” don’t give up. Courts have repeatedly said that subjective symptoms — when consistent, credible, and supported by your doctor — are enough. You don’t need a lab test to prove what your lived experience and your physicians already know: you’re too impaired to work.

Whether you’re dealing with fibromyalgia, post-COVID fatigue, depression, migraines, or another condition that doesn’t show up in a blood test, you still have rights under the law.

Need Help? Contact an Attorney Who Understands This Area of Law

If your long-term disability claim was denied because of “lack of objective evidence,” we may be able to help. We specialize in fighting insurance denials — and we know how to build a case using the medical evidence that matters.
Contact us today for a consultation.