In the case of Sandra K. Forney v. Kenneth S. Apfel, Commissioner of Social Security in 1997, Forney appealed a decision by the Social Security Administration (SSA) that denied her disability benefits for her minor son who suffered from Attention Deficit Hyperactivity Disorder (ADHD). The SSA had determined that while the child did have ADHD, it was not severe enough to qualify him for benefits under their guidelines. However, Forney argued that his condition significantly limited his ability to function normally and should be considered disabling. The U.S Supreme Court ruled in favor of Forney stating that the SSA's criteria were too restrictive and failed to consider how a child's impairment affects his or her overall ability to function at home, school or community compared with other children of same age without impairments. This ruling led to changes in how SSA evaluates childhood disability claims.

The dissenting opinion in the case of Sandra K. Forney v. Kenneth S. Apfel, Commissioner of Social Security, 1997 argued that the majority's decision to deny disability benefits was incorrect due to their interpretation of the law and evidence presented. The dissent believed that Forney had provided substantial evidence proving her inability to perform any work due to her medical conditions - fibromyalgia and chronic fatigue syndrome - which were not adequately considered by the Administrative Law Judge (ALJ). They contended that these illnesses are difficult to diagnose and often misunderstood, leading them being dismissed or minimized during evaluation processes like this one. Furthermore, they disagreed with how vocational expert testimony was used by ALJ as it did not take into account all relevant factors such as claimant’s age, education level or previous work experience when determining ability for gainful employment elsewhere in economy.