## Facts

- Calvin P. Wiltz, III was treated for migraine headaches as a minor and received prescription medication for them.
- The headache pain allegedly caused frequent absences from school and later interfered with attempts to work.
- Wiltz applied for childhood Supplemental Security Income (SSI), alleging disability based on migraine headaches, learning problems, sinusitis, and an adjustment disorder.
- The Social Security Administration denied the application initially, and Wiltz pursued administrative review.
- A later administrative hearing occurred after Wiltz had turned 18, requiring the agency to consider disability under the child standard for the period before age 18 and under the adult standard after age 18.
- The Administrative Law Judge (ALJ) denied benefits, reasoning that the migraine allegations were not supported by sufficient objective medical evidence and concluding Wiltz retained the capacity to work.
- After the agency’s review process concluded, Wiltz sought judicial review in the United States District Court for the Western District of Louisiana under 42 U.S.C. § 405(g).

## Issues

1. Whether the ALJ applied the correct legal standards and whether substantial evidence supported the denial of SSI where the ALJ discounted alleged disabling migraine headaches mainly due to limited objective medical findings.
2. Whether the ALJ’s evaluation of Wiltz’s symptom complaints and functional limits (including school/work absences linked to headaches) was legally sufficient.
3. Whether the ALJ’s residual functional capacity and related employability findings were supported given the record of ongoing migraine treatment and reported episodic limitations.

## Decision

- The district court reversed the Commissioner’s final decision denying benefits.
- The court remanded the case to the Social Security Administration for further proceedings under sentence four of 42 U.S.C. § 405(g).
- The court found the ALJ’s analysis deficient because it treated the absence of objective corroboration as a main reason to reject migraine-related limitations, even though migraines are often assessed through clinical history, treatment records, and reported functional effects.
- Because the migraine evidence was not properly evaluated, the court concluded the RFC and the conclusion that Wiltz could work were not supported on the record as addressed by the ALJ, requiring a new administrative evaluation.

## Legal Principles

- A federal court reviewing a Social Security decision under 42 U.S.C. § 405(g) asks whether the Commissioner applied the correct legal standards and whether the decision is supported by substantial evidence.
- Substantial evidence is more than a scintilla and means such relevant evidence as a reasonable mind might accept as adequate to support a conclusion; the court does not reweigh evidence or substitute its judgment for the agency’s.
- For a claimant under 18 seeking SSI, disability turns on whether medically determinable impairments cause marked and severe functional limitations for the required duration; after age 18, the adult sequential evaluation applies, including an RFC finding and step-five consideration of work.
- An ALJ may not reject migraine-related symptom limits simply because the condition lacks definitive laboratory or imaging findings; the ALJ must evaluate the full record, including longitudinal treatment, medication history, consistency of complaints, and functional consequences.
- An RFC and any work-ability finding must account for episodic conditions when supported by the record; if the symptom evaluation is legally flawed, the RFC finding cannot stand and remand is appropriate for reconsideration and any needed additional vocational development.

## Conclusion

The district court in *Wiltz v. Barnhart* reversed and remanded the SSI denial because the ALJ discounted the claimed disabling effects of longstanding migraine headaches largely for lack of objective medical proof and, as a result, reached an unsupported assessment of Wiltz’s functional capacity and ability to work; the case was returned to the agency for a proper evaluation under the correct standards.


Wiltz v. Barnhart, 484 F. Supp. 2d 524 (2006)