In this case out of the federal court in Connecticut Prudential had denied a claim based on fibromyalgia. Prudential had relied on Dr. Paul Howard and his analysis that included a statement that "the pain of fibromyalgia is never sufficient to result in a qualifying disability." That particular position has been rebutted time and time again.
The court said that Prudential's sole reliance upon Dr. Howard's report which articulated a test for disability under which debilitating fibromyalgia induced pain alone could never qualify constituted an arbitrary and capricious eligibility determination. In short the court rejected Prudential's claim that no matter how severe the pain from fibromyalgia is the cannot be disabling.
This case is Lanoue v. Prudential insurance Co. of America and it was decided on September 25, 2009.