The following excerpt is from Aubeuf v. Schweiker, 649 F.2d 107 (2nd Cir. 1981):
7 Tyler v. Weinberger, 409 F.Supp. 776, 789 (E.D.Va.1976) ("Clearly, a 'sit and squirm' index, as plaintiff calls it, applied by a judge who is not a medical expert will not only result in unreliable conclusions when observing claimants with honest intentions, but may encourage claimants to manufacture convincing observable manifestations of pain or, worse yet, discourage them from exercising their right to appear before an Administrative Law Judge for fear that they may not appear to the unexpert eye to be as bad as they feel.").
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