20 C.F.R. § 404.1520
Evaluation of disability in adults: the cases that interpreted this section
33,077 citing cases reviewed of 71,843 in the citation index: 6,452 interpreted the section (annotated below), 26,625 cited it only in passing. Cases filed after 2026-06-25 may not have been reviewed yet.
Have a situation under 20 C.F.R. § 404.1520?
These notes show how courts have ruled. Ask about your specific facts and see which of these rulings apply, with citations you can check.
Duration requirement at step two
Section 404.1520(a)(4)(ii) requires the ALJ, at step two, to determine whether the claimant has a severe medically determinable impairment; only the most trivial impairments may be rejected at this threshold stage.
Bruns v. Commissioner of Social Security · filed 2019-08-16(a)(4)(ii)
At step two of the sequential evaluation process, the ALJ must gauge whether the claimant has a medically determinable impairment (or combination of impairments) that is severe. 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4). This step in the disability evaluation process is a “threshold inquiry,” under which “only the most trivial impairments are to be rejected.”Read the full opinion on CourtListener →
Section 404.1520 requires the ALJ at step two to determine whether a claimant has a medically severe impairment, which is an impairment that significantly limits the ability to perform basic work activities.
Hiller v. Commissioner Social Security Administration · filed 2019-08-13(a)(4)(ii), (c)
At step two, the ALJ determines whether the plaintiff has a medically severe impairment or combination of impairments, based upon medical evidence. Webb v. Barnhart, 433 F.3d 683, 687 (9th Cir. 2005); 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii). A severe impairment is an “impairment or combination of impairments which significantly limits [the plaintiff’s] physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1520(c), 416.920(c).Read the full opinion on CourtListener →
At step two, § 404.1520 requires the ALJ to assess the medical severity of the claimant’s impairments, treating an impairment as non-severe only if it is a slight abnormality with minimal effect that would not be expected to interfere with the ability to work; an error in applying that standard may be harmless when the ALJ proceeds beyond step two and considers the impairments later.
McFarland v. Commissioner of Social Security · filed 2019-08-20(a)(4)(ii), (c)
At step two of the sequential evaluation process, the ALJ “must consider the medical severity of [the claimant’s] impairments.” 20 C.F.R. § 404.1520(a)(4)(ii), (c). ... Under the Commissioner’s regulations, a severe impairment is “any impairment or combination of impairments which significantly limits [a claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c). ... Finding that a literal application of this regulation would be inconsistent with the Social Security Act, the Fifth Circuit has held that an impairment is not severe “only if it is a slight abnormality having such minimal effect on the individual that it would not be expected to interfere with the individual’s ability to work.” ... To ensure that the regulatory standard for severity does not limit a claimant’s rights, the Fifth Circuit held in Stone that it would assume that the “ALJ and Appeals Council have applied an incorrect standard to the severity requirement unless the correct standard is set forth by reference to this opinion or another of the same effect, or by an express statement that the construction we give to 20 C.F.R. § 404.1520(c) is used.” ... As the magistrate judge correctly noted in rejecting Plaintiff’s argument that reversal was mandatory due to the ALJ’s Stone error, in the Fifth Circuit, Stone error does not mandate automatic reversal and remand. Rather, application of harmless error analysis is appropriate in cases where the ALJ proceeds past step two in the sequential evaluation process and considers the impairments in the subsequent stages of the five-step analysis. ... For these reasons, the Court overrules Plaintiff’s objection. The Court agrees with and accepts the magistrate judge’s finding that, although the ALJ committed a Stone error at step two of the five-step sequential analysis, any error was harmless because the ALJ proceeded beyond step two and determined that Plaintiff, despite severe impairments of degenerative disc disease of the lumbar spine and osteoarthritis of the left shoulder, and a non-severe impairment of depression, retained the residual functional capacity to do other work.Read the full opinion on CourtListener →
Section 404.1520(a)(ii) requires the ALJ at step two to assess the medical severity of the claimant’s impairments; an impairment is not non-severe when the evidence shows more than a slight abnormality with more than a minimal effect on the ability to work.
Banda v. Commissioner of Social Security Administration · filed 2019-08-30(a)(ii)
At step two of the sequential evaluation process, the ALJ considers the medical severity of the claimant’s impairments. 20 C.F.R. § 404.1520(a)(ii). This step is essentially “a de minimis screening device [used] to dispose of groundless claims.” ... “An impairment or combination of impairments can be found ‘not severe’ only if the evidence establishes a slight abnormality that has ‘no more than a minimal effect on an individual’s ability to work.’” ... The Court thus finds that the evidence demonstrates Plaintiff’s diverticulitis constituted more than a “slight abnormality,” and will remand the issue for further proceedings.Read the full opinion on CourtListener →
Section (a)(4)(ii) directs the agency at step two to consider the medical severity of the claimant’s impairment(s).
Tiegland v. Saul · filed 2019-08-30(a)(4)(ii)
At step two, the Social Security Administration considers “the medical severity of [a claimant’s] impairment(s).” 20 C.F.R. § 404.1520(a)(4)(ii). An impairment must meet a twelve-month durational requirement to be considered severe.Read the full opinion on CourtListener →
Section 404.1520(c) requires a claimant to show at step two that a medically determinable impairment or combination of impairments significantly limits the ability to perform basic work activities.
Latva v. Commissioner of Social Security · filed 2019-09-03(c)
At step two, a claimant must make a threshold showing that her medically determinable impairments significantly limit her ability to perform basic work activities. See Bowen v. Yuckert, 482 U.S. 137, 145 (1987); 20 C.F.R. § 404.1520(c).Read the full opinion on CourtListener →
Section 404.1520(c) requires a claimant at step two to show that a medically determinable impairment significantly limits the ability to perform basic work activities.
Gaffney v. Commissioner of Social Security · filed 2019-09-04(c)
At step two, a claimant must make a threshold showing that her medically determinable impairments significantly limit her ability to perform basic work activities. See Bowen v. Yuckert, 482 U.S. 137, 145 (1987); 20 C.F.R. § 404.1520(c).Read the full opinion on CourtListener →
Section 404.1520(c) treats an impairment as non-severe only when it does not significantly limit basic work abilities, but an erroneous non-severity finding is harmless when the ALJ accounts for the impairment in the RFC.
Elliott v. Commissioner of Social Security · filed 2019-09-09(c)
At step two, an impairment does not meet the requirements for “severe” if it does not “significantly limit” a claimant's mental or physical abilities to do basic work activities. ... Even if the ALJ erred in finding Plaintiff’s migraines non-severe, this would constitute harmless error. ... In this case, the ALJ decided step two in Plaintiff’s favor, finding that Plaintiff had the severe impairments of fibromyalgia and obesity. ... in the present case, the ALJ considered plaintiff’s migraines when determining the RFC (including balancing limitations in Plaintiff’s RFC to account for the combined effects of her migraines, obesity, and fibromyalgia). AR 41-42. The Court therefore finds this error was harmless.Read the full opinion on CourtListener →
At step two, § 404.1520(c) requires determining whether a claimant’s impairment is severe; an impairment is not severe if it causes no more than a minimal effect on the claimant’s ability to work.
Anderson v. Saul · filed 2019-09-11(c)
At Step Two of the sequential analysis, the ALJ is required to determine whether a claimant’s impairments are severe. See 20 C.F.R. § 404.1520(c). While “severity is not an onerous requirement for the claimant to meet . . . it is also not a toothless standard.” Wright v. Colvin, 789 F.3d 847, 855 (8th Cir. 2015) (citations omitted). An impairment is not severe if it amounts only to a slight abnormality that would not significantly limit the claimant’s physical or mental ability to do basic work activities. See Bowen v. Yuckert, 482 U.S. 137, 153 (1987). If the impairment would have no more than a minimal effect on the claimant’s ability to work, then it does not satisfy the requirement of step two. See Page v. Astrue, 484 F.3d 1040, 1043 (8th Cir. 2007) (citations omitted).Read the full opinion on CourtListener →
At step two, the regulation requires determining whether a medically determinable impairment or combination of impairments is severe and meets the duration requirement.
Pagano v. Berryhill · filed 2019-09-12(a)(4)(ii)
As indicated above, the second step of the sequential process requires a determination of whether the claimant has a medically determinable impairment, or combination of impairments, that is severe and meets the duration requirement. See supra (citing 20 C.F.R. § 404.1520(a)(4)(ii), 416.920(a)(4)(ii)). ... In sum, it is not accurate to say – as Petitioner implies is the case here – that the ALJ ignored the entirety of Petitioner’s impairments when he considered some (but not all) of them to be severe. ... the ALJ provided sufficient reasons for differentiating between those impairments that significantly limit her ability to perform basic work activities, and those that do not. ... his analysis is supported by substantial evidence and based on proper legal standards.Read the full opinion on CourtListener →
At step two, § 404.1520 requires consideration of whether the claimant has a medically determinable impairment that significantly limits the ability to perform basic work activities; if that threshold is met, the evaluation proceeds to the next steps with all limitations considered.
Mena v. Commissioner of Social Security · filed 2019-09-16(a)(4)(ii), (c)
A claimant bears the burden at step two to demonstrate that she has medically determinable physical impairments which (1) have lasted or are expected to last for a continuous twelve-month period and (2) significantly limits her ability to do basic work activities. 20 C.F.R. §§ 404.1520(a)(4)(ii), 404.1520(c), 404.1509. An impairment does not limit an ability to do basic work activities where it “would have no more than a minimal effect on an individual’s ability to work.” ... Importantly, if the ALJ finds the claimant has a medically determinable impairment that significantly limits the claimant’s ability to do basic work activities, the ALJ proceeds to the following steps where the ALJ must consider all of the claimant’s limitations, regardless of the label.Read the full opinion on CourtListener →
At step two, the regulation permits rejecting a disability claim only when no impairment or combination significantly limits the claimant’s physical or mental ability to perform basic work activities.
Vogt v. Commissioner of Social Security · filed 2019-09-16(c)
At step two of the sequential evaluation process, a disability claim is rejected only “[i]f [a claimant does] not have any impairment or combination of impairments which significantly limits [a claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c).Read the full opinion on CourtListener →
Section 404.1520(c) treats step two as a threshold inquiry into whether the claimant has a severe impairment significantly limiting basic work activities, while requiring the ALJ to consider all impairments in the RFC analysis once the claimant has any severe impairment.
Arbizu v. Commissioner of Social Security Administration · filed 2019-09-17(c)
Assuming, arguendo, Plaintiff is correct and the ALJ did improperly determine that Plaintiff’s fibromyalgia was not a severe impairment under step two, the error is harmless. At step two of the evaluation process, the ALJ asks whether the claimant has a severe impairment that significantly limits the claimant’s ability to do basic work activities. 20 C.F.R. §§ 404.1520(c), 416.920(c). “Step two is merely a threshold determination meant to screen out weak claims. . . . It is not meant to identify the impairments that should be taken into account when determining the RFC.” Buck v. Berryhill, 869 F.3d 1040, 1048-49 (9th Cir. 2017) (holding that a step-two determination in a claimant’s favor where one impairment was not found to be severe did not impact the claimant’s RFC analysis). Because the ALJ found Plaintiff did suffer severe impairments at step two, the ALJ was required to account for all of Plaintiff’s impairments in any RFC determination in steps three and four. See id. Thus any error by the ALJ in step two with regard to the classification of Plaintiff’s fibromyalgia resulted in harmless error.Read the full opinion on CourtListener →
Section 404.1520(a)(4)(ii) and (c) require an impairment to be severe—significantly limiting basic work activities and expected to persist for at least twelve months—for the disability evaluation to proceed beyond step two.
Bristow v. Berryhill (CONSENT) · filed 2019-09-20(a)(4)(ii), (c)
At the second step, the ALJ considers the medical severity of the claimant’s impairments. See Bowen, 482 U.S. at 140-141; see also 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii). An impairment is “severe” if it significantly limits the claimant’s ability to perform basic work activities and is expected to persist for a period of twelve months or longer. See Bowen, 482 U.S. at 141; see also 20 C.F.R. §§ 404.1520(c), 416.920(c). ... Absent any suggestion in the medical evidence that Bristow’s kidney condition caused severe and lasting impairment in her ability to work, her kidney disease diagnosis has no bearing on the assessment of her RFC. ... It follows that the ALJ did not err either in finding that her kidney disease did not cause Bristow to suffer severe impairments in her capacity to work or in failing to discuss the references to her history of kidney disease in assessing her RFC.Read the full opinion on CourtListener →
Section 404.1520(a)(4)(ii) requires the Commissioner to evaluate the severity of a claimant’s impairments at step two.
Dunbar v. Berryhill · filed 2019-09-20(a)(4)(ii)
At step two, the Commissioner considers the severity of the claimant’s impairments. ... Accordingly, the ALJ erred at step two when he found plaintiff did not suffer from a severe mental impairment. The ALJ’s finding was inconsistent with his own determination that plaintiff suffered from moderate limitations in two functional areas and was unsupported by the medical evidence.Read the full opinion on CourtListener →
Section 404.1520(a)(4)(ii) requires the ALJ to consider the severity of a claimant’s impairments at step two of the sequential evaluation.
Schwalje v. Saul · filed 2019-09-20(a)(4)(ii)
Step two of the sequential evaluation requires the ALJ to consider the severity of a claimant’s impairments. 20 C.F.R. § 404.1520(a)(4)(ii). ... The Court finds the ALJ’s failure to find Plaintiff’s bipolar disorder severe at step two was not harmless error, and reversal and remand on that basis is warranted. ... Only where an ALJ thoroughly considers and discusses a claimant’s complaints and symptoms relating to all her mental impairments, as well as her mental health providers’ observations and treatment, will a court conclude the failure to find this condition severe was harmless.Read the full opinion on CourtListener →
Section 404.1520(c) requires the Commissioner at step two to determine whether an impairment significantly limits the claimant’s physical or mental ability to do basic work activities.
Ramirez v. Commissioner of Social Security · filed 2019-09-23(c)
At step two of the sequential process, the ALJ must determine whether the claimant suffers from a “severe” impairment, i.e., one that significantly limits her physical or mental ability to do basic work activities. 20 C.F.R. §§ 404.1520(c), 416.920(c). ... The ALJ erred when he failed to include a gastrointestinal condition as a medically determinable impairment at step two. This error is not harmless.Read the full opinion on CourtListener →
At step two, an impairment is severe only if it significantly limits the claimant’s ability to perform basic work activities; age, education, and work experience are not considered.
Larson v. Saul · filed 2019-09-23(c)
At step two, the claimant must show she has an impairment that significantly limits her ability to work in most jobs. ... “An impairment is not severe if it amounts only to a slight abnormality that would not significantly limit the claimant’s physical or mental ability to do basic work activities.” ... A claimant’s “age, education, and work experience” are not relevant to the step two inquiry. See 20 C.F.R. § 404.1520(c). Rather, “medical evidence alone is evaluated in order to assess the effects of the impairment(s) on ability to do basic work activities.”Read the full opinion on CourtListener →
Section 404.1520(c) requires a claimant to show an impairment that significantly limits the ability to work, and a step-two error may be harmless when the ALJ considers all impairments later in the sequential evaluation.
Vang v. Saul · filed 2019-09-26(c)
At step two, the claimant must show he has an impairment that significantly limits his ability to work in most jobs. ... A claimant’s “age, education, and work experience” are not relevant to the step two inquiry. See 20 C.F.R. § 404.1520(c); 20 C.F.R. § 416.920(c). Rather, “medical evidence alone is evaluated in order to assess the effects of the impairment(s) on ability to do basic work activities.” ... It is true that an error at step two in failing to assess a claimed severe impairment “is harmless if the claimant ‘makes a threshold showing of any “severe” impairment [and] the ALJ continues with the sequential evaluation process and considers all impairments, both severe and nonsevere.’” ... Thus, even if the ALJ erred at step two, the error is harmless because the ALJ fully considered Plaintiff’s actual cognitive impairments at step four, as discussed below.Read the full opinion on CourtListener →
At step two, an impairment is severe when it significantly limits a claimant’s ability to perform basic work activities, but an error in omitting one impairment is harmless if the ALJ considers all impairments together at the later steps.
Silas v. Commissioner of Social Security · filed 2019-09-26(a)(4)(ii)
At step two of the sequential evaluation process, a claimant must show that he or she suffers from an impairment or combination of impairments that significantly limits his or her physical or mental ability to do basic work activities. See 20 C.F.R. §§ 404.1520(a)(4)(ii), 404.1521, 416.920(a)(4)(ii), 416.921. ... The ALJ’s error at step two is, however, harmless. Notably, the finding of any severe impairment is enough to satisfy the ALJ’s duty at step two, if the ALJ considers all impairments, regardless of their severity, in conjunction with one another in performing the latter steps of the sequential evaluation. See Schink v. Commr. of Soc. Sec., No. 17-14992, ___ F.3d___, 2019 WL 4023639, at *15 (11th Cir. Aug. 27, 2019); Tuggerson-Brown, 572 F. App’x at 951.Read the full opinion on CourtListener →
At Step Two, the ALJ must consider whether a medically determinable impairment is severe.
Folkers v. Commissioner of Social Security · filed 2019-09-27(a)(4)(ii)
At Step Two, the ALJ must consider whether a medically determinable impairment is “severe.”Read the full opinion on CourtListener →
At step two, § 404.1520(a)(4)(ii) requires consideration of the severity of the claimant’s impairment as a de minimis screen for groundless claims.
Mcphillps v. Berryhill · filed 2019-09-30(a)(4)(ii)
At step two, the Commissioner considers the severity of the claimant’s impairment. 20 C.F.R. § 404.1520(a)(4)(ii).3 “[T]he step-two inquiry is a de minimis screening device to dispose of groundless claims. Smolen v. Chater, 80 F.3d 1273, 1290 (9th Cir. 1996).Read the full opinion on CourtListener →
Section 404.1520(c) requires the Commissioner to determine at step two whether an impairment significantly limits the claimant’s ability to perform basic work activities, and the court held that the ALJ must meaningfully consider the relevant treatment records in making that determination.
Ryals v. Commissioner, Social Security Administration · filed 2019-09-30(c)
At step two of the sequential evaluation process, the ALJ found Plaintiff’s degenerative disc disease of the lumbar spine to be a severe impairment. (Tr. 17). The ALJ also found Plaintiff’s mental impairments of depressive disorder and bipolar disorder, considered singly and in combination, did not cause more than minimal limitation in Plaintiff’s ability to perform basic mental work activities, and therefore were non-severe. (Id.). ... Here, the ALJ’s failure to discuss, in any meaningful way, Plaintiff’s mental health treatment records at step two is reversible error.Read the full opinion on CourtListener →
At step two, an impairment is severe only if it significantly limits a claimant’s ability to perform basic work activities; an impairment with no more than a minimal effect does not qualify.
Sohn v. Saul · filed 2019-09-30(c)
To be considered severe, an impairment must significantly limit a claimant’s ability to do basic work activities. See 20 C.F.R § 404.1520(c). “Step two [of the five-step] evaluation states that a claimant is not disabled if his impairments are not severe.” Kirby v. Astrue, 500 F.3d 705, 707 (8th Cir. 2007) (citing Simmons v. Massanari, 264 F.3d 751, 754 (8th Cir. 2001)). “An impairment is not severe if it amounts only to a slight abnormality that would not significantly limit the claimant’s physical or mental ability to do basic work activities.” Kirby, 500 F.3d at 707. “If the impairment would have no more than a minimal effect on the claimant’s ability to work, then it does not satisfy the requirement of step two.” Id. (citing Page v. Astrue, 484 F.3d 1040, 1043 (8th Cir. 2007)). “It is the claimant’s burden to establish that his impairment or combination of impairments are severe.” Kirby, 500 F.3d at 707 (citing Mittlestedt v. Apfel, 204 F.3d 847, 852 (8th Cir. 2000)). “Severity is not an onerous requirement for the claimant to meet, . . . but it is also not a toothless standard.” Kirby, 500 F.3d at 708.Read the full opinion on CourtListener →
At step two, a claimant must establish an impairment or combination of impairments that significantly limits basic work activities and satisfies the durational requirements; the court must ensure the ALJ properly evaluates that severity determination.
Vancil v. Saul · filed 2019-09-30(a)(4)(ii)
After the ALJ has determined that a claimant is not engaged in substantial gainful activity, the ALJ then determines whether the claimant has a severe impairment or combination of impairments that has or is expected to last twelve months or will result in death. 20 C.F.R. §§ 404.1509, 404.1520(a)(4)(i)-(ii)2. ... To be considered severe, an impairment must significantly limit a claimant’s ability to do basic work activities. See 20 C.F.R § 404.1520(c). ... Because of the ALJ’s confusing language in step two and no indication that the effects of the headaches were included in the RFC determination, the Court does not find that substantial evidence supports the ALJ’s finding that the migraine headaches were not a severe impairment. The Court will reverse and remand this action for the ALJ to properly evaluate whether Vancil’s headaches meet the requirement for a severe impairment at step two.Read the full opinion on CourtListener →
Section 404.1520(c) requires an impairment to cause more than a minimal limitation in basic work activities to be severe; once a claimant has at least one severe impairment, the sequential evaluation continues and the adjudicator considers the effects of all impairments.
Gross v. Berryhill · filed 2019-10-08(c)
At step two, the ALJ properly found that Renee G.’s “medically determinable mental impairment of affective disorder does not cause more than minimal limitation in the claimant’s ability to perform basic mental work activities and is therefore nonsevere.” (Tr. 19.) This finding is consistent with the ALJ’s RFC determination, which limits Renee G. to “interact[ing] with the public, supervisors, coworkers, and peers frequently.” This determination is supported by substantial evidence. (See Tr. 19-22, 330-40.) To the extent that Renee G. argues that the ALJ should have classified her mental impairments as severe, this argument is also without merit. Because Renee G. made the threshold showing that she had at least one severe impairment, the ALJ continued with the sequential evaluation process and properly considered all impairments, both severe and non-severe, that significantly impacted her ability to work. The ALJ discussed Renee G.’s mental impairment throughout the decision. It is apparent that the ALJ considered the effect of Renee G.’s mental impairment on its own and in combination with her other impairments when formulating the RFC. Any step two error, therefore, does not necessitate remand.Read the full opinion on CourtListener →
Section 404.1520(a)(4)(ii) requires the ALJ, at step two, to determine whether the claimant has a medically determinable impairment that is severe.
Strange v. Commissioner of Social Security · filed 2019-10-09(a)(4)(ii)
At step two of the sequential evaluation, the ALJ must determine if the claimant suffers from any medically determinable impairments that are “severe.” 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii). An impairment is not considered to be “severe” if it does not “significantly limit” a claimant's mental or physical abilities to do basic work activities. 20 C.F.R. §§ 404.1520(c), 416.920(c); SSR 96-3p, 1996 WL 374181, at *1. Basic work activities are those “abilities and aptitudes necessary to do most jobs.” 20 C.F.R. §§ 404.1522(b), 416.920(c); SSR 85-28, 1985 WL 56856, at *3. An impairment is not severe if the evidence establishes only a slight abnormality that has “no more than a minimal effect on an individual[’]s ability to work.” SSR 85-28, 1985 WL 56856, at *3; Smolen v. Chater, 80 F.3d 1273, 1290 (9th Cir. 1996).Read the full opinion on CourtListener →
Section 404.1520 requires disability claims to be evaluated through a five-step sequence, with step two asking whether the claimant's impairment or combination of impairments is severe.
MENDEZ v. COMMISSIONER OF SOCIAL SECURITY · filed 2019-10-21(c)
If not, the Commissioner moves to step two to determine if the claimant’s alleged impairment, or combination of impairments, is “severe.” Jd. §§ 404.1520(c), 416.920(c). ... For these reasons, the Court finds that substantial evidence supports the ALJ’s determination regarding the severity of Plaintiff's mental impairment. Accordingly, the Court DENIES Plaintiff's appeal of the ALJ’s decision at Step Two.Read the full opinion on CourtListener →
Section 404.1520(c) requires an impairment to significantly limit basic work activities, and the court held that medication resolving an impairment's limiting effects may be considered in deciding whether that severity threshold is met.
Chase v. Commissioner of Social Security · filed 2019-10-25(c)
If medication resolves the limiting effects of an impairment, it would be illogical not to take this into account in determining whether an impairment causes more than a minimal effect on a basic work activity—as is required for a severe, medically determinable impairment.Read the full opinion on CourtListener →
At step two, § 404.1520(a)(4)(ii) requires the ALJ to determine the severity of the claimant’s impairments.
Miller v. Berryhill · filed 2019-10-25(a)(4)(ii)
A Step Two determination requires the ALJ to determine the severity of the plaintiff’s impairments. 20 C.F.R. §§404.1520(a)(4)(ii); see also id. at (c).Read the full opinion on CourtListener →
Section 404.1520(c) requires a claimant to make a threshold showing that medically determinable impairments significantly limit the ability to perform basic work activities.
Lee v. Commissioner of Social Security · filed 2019-11-18(c)
At step two, a claimant must make a threshold showing that her medically determinable impairments significantly limit her ability to perform basic work activities. See Bowen v. Yuckert, 482 U.S. 137, 145 (1987); 20 C.F.R. § 404.1520(c).Read the full opinion on CourtListener →
At step two, § 404.1520(c) requires a claimant to show both a medically determinable impairment (or combination of impairments) and that the impairment or combination is severe.
Lewis v. Commissioner of Social Security · filed 2019-11-19(c)
At step two, a claimant must make a threshold showing that (1) she has a medically determinable impairment or combination of impairments and (2) the impairment or combination of impairments is severe.Read the full opinion on CourtListener →
At step two, the ALJ must determine whether an impairment is severe, and an impairment is not severe when it does not significantly limit the claimant’s ability to perform basic work activities.
Furginson v. Berryhill · filed 2019-11-26(a), (c)
Step two of the Commissioner’s five-step evaluation requires the ALJ to determine whether an impairment is severe or not severe. See 20 C.F.R. § 404.1520(a). ... An impairment is not severe if it does not significantly limit the claimant’s physical or mental ability to do basic work activities. See 20 C.F.R. § 404.1520(c).Read the full opinion on CourtListener →
At step two, the ALJ must determine the medical severity of the claimant’s medically determinable impairments, and an impairment is not severe only when it has no more than a minimal effect on basic work activities.
Herrera v. Berryhill · filed 2019-12-04(a)(4)(ii)
Step two of the Commissioner’s sequential evaluation process requires the ALJ to determine the medical severity of the claimant’s medically determinable impairments. See 20 C.F.R. § 404.1520(a)(4)(ii). ... The Court therefore finds (a) that plaintiff did present sufficient evidence to the ALJ to support a finding that her lumbago and cervicalgia and the limitations/symptoms associated with those conditions had more than a minimal effect on her ability to work; and (b) that the ALJ consequently erred in finding that plaintiff’s lumbago and cervicalgia were nonsevere.Read the full opinion on CourtListener →
At step two, § 404.1520(a)(4)(ii) requires determining whether the claimant has a severe impairment or combination of impairments; once a severe impairment is found, the evaluation proceeds to the next step.
Clark v. Berryhill · filed 2019-12-10(a)(4)(ii)
Step two requires “a threshold determination of whether a [plaintiff] is suffering from a severe impairment or a combination of impairments.” Lewis v. Comm’r of Soc. Sec., SAG-15-84, 2015 WL 5905276, at *2 (D.Md. Oct. 6, 2015) (citing Bowen v. Yuckert, 482 U.S. 137, 147-48 (1987)). “Ifa [plaintiff] is found to be suffering from a severe impairment(s), the analysis simply proceeds to the next step.” /d. (citing 20 C.F.R. §§ 404.1520(a\(4)Gi), 416.920(ay(4)Gi)).Read the full opinion on CourtListener →
Section 404.1520(a)(4)(ii) makes step two a threshold inquiry into whether the claimant has at least one severe medically determinable impairment, or a severe combination of impairments, that meets the duration requirement; if that threshold is met, the evaluation proceeds to the remaining steps.
Peters v. Commissioner of Social Security · filed 2019-12-11(a)(4)(ii)
At step two of the analysis, an ALJ is required only to determine if the plaintiff has a severe medically determinable physical or mental impairment, or a combination of impairments that is severe and meets the duration requirement. See 20 C.F.R. § 404.1520(a)(4)(ii). Should the ALJ find one of those prongs satisfied, the analysis then proceeds further. See id. This circuit has stated that “[d]eciding whether impairments are severe at Step 2 is a threshold issue only; an ALJ must continue on to the remaining steps of the evaluation process as long as there exists even one severe impairment.” Arnett v. Astrue, 676 F.3d 586, 591 (7th Cir. 2012) (emphasis in original). Any error at step two analysis is harmless so long as one condition is found to be severe or if the combination of impairments is found to be severe. See id.Read the full opinion on CourtListener →
Section 404.1520 requires disability claims to proceed through a five-step evaluation, including a step-two determination of whether an impairment significantly limits basic work activities.
Bossard v. O'Malley · filed 2020-01-02(c)
The Commissioner has established a five-step sequential analysis to determine whether a claimant satisfies the above criteria. See 20 C.F.R. §§ 404.1520(a)(4)(i)-(v), 416.920(a)(4)(i)-(v). ... If the claimant suffers from “any impairment or combination of impairments which significantly limits [his or her] physical or mental ability to do basic work activities,” the analysis proceeds to step three. 20 C.F.R. §§ 404.1520(c), 416.920(c). If the claimant’s impairment does not satisfy this severity threshold, however, the Commissioner must find that the claimant is not disabled. 20 C.F.R. §§ 404.1520(c), 416.920(c). ... For all of these reasons, the Court finds the ALJ erred in considering whether Plaintiff’s claimed right upper extremity impairment was a medically determinable impairment at step two.Read the full opinion on CourtListener →
At step two, § 404.1520(c) requires an impairment to significantly limit the claimant's physical or mental ability to perform basic work activities to be considered severe.
Carter v. Commissioner of Social Security · filed 2020-01-09(c)
It is the claimant’s burden to show at step two that he has a “severe” impairment or combination of impairments, meaning an impairment or combination of impairments that “significantly limits [her] physical or mental ability to do basic work activities,” 20 C.F.R. § 404.1520(c); see 20 C.F.R. § 404.1522, “for a continuous period of at least 12 months,” 20 C.F.R. § 404.1509.Read the full opinion on CourtListener →
Section 404.1520(c) treats an impairment as non-severe when it does not significantly limit a claimant’s ability to do basic work activities.
(SS) Green v. Commissioner of Social Security · filed 2020-01-06(c)
“At step two of the five-step sequential inquiry, the Commissioner determines whether the claimant has a medically severe impairment or combination of impairments.” ... “[A]n impairment is not severe if it does not significantly limit [the claimant’s] . . . ability to do basic work activities.” ... “The Court finds that the ALJ’s step two determination was supported by substantial evidence in the record and an extensive discussion and analysis of the paragraph B criteria.”Read the full opinion on CourtListener →
At step two, § 404.1520(a)(ii) requires a claimant’s severe impairment to have lasted or be expected to last continuously for at least twelve months.
Goodford v. Commissioner of Social Security · filed 2021-11-02(a)(ii)
Plaintiff must also show that his severe impairment lasted (or is expected to last) for a continuous period of at least twelve months. See 20 C.F.R. § 404.1520(a)(ii) (if a claimant does not have a severe impairment that lasted, or is expected to last, for a continuous period of at least twelve months, then the claimant is not disabled).Read the full opinion on CourtListener →
At step two, § 404.1520 requires a claimant to show a severe impairment that has lasted or is expected to last at least 12 months.
Cavens v. Commissioner of Social Security · filed 2023-07-18(a)(4)(ii)
At step two of the sequential evaluation, an ALJ considers the “medical severity” of a claimant’s medically determinable impairments. 20 C.F.R. § 404.1520(a)(4)(ii). ... Still, an impairment must be both severe and of sufficient duration or there will be a finding of non-disability. 20 C.F.R. § 404.1520(a)(4)(ii).Read the full opinion on CourtListener →
Section 404.1520(a)(4)(ii) allows the step-two duration requirement to be assessed using retrospective evidence, including evidence showing that an impairment in fact lasted more than 12 months.
Archambault v. Commissioner of Social Security · filed 2023-12-11(a)(4)(ii)
Thus, the issue is whether, considering the additional evidence submitted to the Appeals Council, the ALJ’s determination at Step Two—that Plaintiff’s foot injury was not a severe impairment meeting the duration requirement—was supported by substantial evidence. An ALJ can disregard an impairment at step two either if it is not severe or if it does not meet the duration requirement. See 20 C.F.R. § 404.1520(a)(4)(ii). ... This argument assumes an interpretation of the duration requirement in which the expectation of how long an impairment will last cannot be measured with the benefit of hindsight. The Court disagrees with this interpretation. This interpretation is not compelled by the statute—the “language ‘can be expected to last’ 12 months . . . simply does not say as of what time the law measures the ‘expectation.’” Barnhart v. Walton, 535 U.S. 212, 224 (2002). ... If the Commissioner can assess, post hoc, that a claimant did not meet the duration requirement, as the regulations at issue in Barnhart allowed him to do, there is no reason why the Agency cannot also assess, post hoc, that a claimant met that requirement.Read the full opinion on CourtListener →
Considering non-severe impairments after step two
Section 404.1520(a)(4) requires an ALJ to carry the combined effects of medically determinable impairments, including non-severe impairments, through the disability analysis and RFC assessment.
Pruski · filed 2025-11-17(a)(4)
Even when an ALJ concludes that an impairment is not severe, the ALJ must consider the combined effects of that and all other medically determinable impairments in proceeding through the disability analysis and assessing the RFC. 20 C.F.R. §§ 404.1520(a)(4), 404.1523(c).Read the full opinion on CourtListener →
Section 404.1520 establishes a five-step sequential evaluation for disability claims, and a finding that an impairment is non-severe at step two does not eliminate it from consideration in the later RFC assessment.
Colon v. Saul · filed 2022-08-26(a)(4)(ii)
In step two of the evaluation process, an ALJ is required to consider whether a claimant's impairments are (1) medically determinable3 and (2) severe. 20 C.F.R. §§ 404.1520(a)(4)(ii), 404.1521; 20 C.F.R. §§ 416.920(a)(4)(ii), 416.921. An impairment is not considered severe if it does not significantly impact a claimant's physical or mental ability to do basic work activities. See 20 C.F.R. § 404.1520(c); 20 C.F.R. § 416.920(c). ... However, finding that an impairment is non-severe at step two “does not obviate the need for a separate analysis of how Plaintiff's impairment affects her RFC.” ... Indeed, under the regulations, an ALJ is required to assess all of a claimant's medically determinable impairments – including those that are not severe – in combination when making the subsequent RFC determination.Read the full opinion on CourtListener →
Section 404.1520 requires the ALJ to assess the claimant's remaining work capacity after finding a severe impairment and to consider all impairments, including those that are not severe; failing to label an additional impairment severe is not reversible error if all impairments are considered.
Landess v. Social Security Administration, Commissioner of · filed 2022-09-26(a)(4)(iv)
Plaintiff’s assertion that the ALJ improperly determined her low back pain was a non-severe impairment is inapposite because the ALJ found she had seven other “severe” impairments [Tr. 13]. The Sixth Circuit has instructed that if an individual has at least one severe impairment, then the ALJ is required to assess how much work the individual can still do. See Kirkland v. Comm’r of Soc. Sec., 528 F. App’x 425, 427 (6th Cir. 2013) (citing 20 C.F.R. § 404.1520(a)(4)(iv)). “When making that assessment, ‘the ALJ must consider limitations and restrictions imposed by all of [the] individual’s impairments, even those that are not severe.’” Id. (quoting Fisk v. Astrue, 253 F. App’x 580, 583 (6th Cir. 2007)) (emphasis added). Thus, “as long as the ALJ considers all of the individual’s impairments, the ‘failure to find additional severe impairments . . . does not constitute reversible error.’” Id. (quoting Fisk, 253 F. App’x at 583).Read the full opinion on CourtListener →
Section 404.1520(c)'s step-two severity inquiry is only a threshold screen; all impairments must still be considered in determining residual functional capacity, even if they are not severe.
Jones v. Berryhill · filed 2020-01-10(c)
She, however, misunderstands the purpose of step two in the analysis. Step two is merely a threshold determination meant to screen out weak claims. It is not meant to identify the impairments that should be taken into account when determining the RFC. In fact, “[i]n assessing RFC, the adjudicator must consider limitations and restrictions imposed by all of an individual’s impairments, even those that are not ‘severe.’” The RFC therefore should be exactly the same regardless of whether certain impairments are considered “severe” or not.Read the full opinion on CourtListener →
Section 404.1520(a)(4)(ii) requires the ALJ at step two to determine the medical severity of the claimant’s medically determinable impairments.
Shaw v. Berryhill · filed 2020-01-21(a)(4)(ii)
Step two of the Commissioner’s sequential evaluation process requires the ALJ to determine the medical severity of the claimant’s medically determinable impairments. See 20 C.F.R. § 404.1520(a)(4)(ii).Read the full opinion on CourtListener →
Section 404.1520(c) treats an impairment as severe when it significantly limits a claimant’s physical or mental ability to perform basic work activities, as part of the step-two screening.
(SS) Hoffmann v. Commissioner of Social Security · filed 2020-01-22(c)
Under step 2, the ALJ is to classify any impairments as either “severe” or “non–severe.” See 20 C.F.R. §§ 404.1520, 404.1571–76. A “severe” impairment is one that significantly limits the physical or mental ability to perform basic work activities. 20 C.F.R. § 404.1520(c). The step 2 assessment is a “de minimus screening to dispose of groundless claims.” Edlund, 253 F3d at 1158. ... Here, the ALJ stated that because Plaintiff’s “medically determinable mental impairments cause no more than ‘mild’ limitation in any of the functional areas, they are non–severe.” (AT 20 (citing 20 CFR 404.1520a(d)(l)). In reaching this determination, the ALJ addressed the four functional areas set out in the “Paragraph B” regulations for evaluating mental disorders. (AT 19.) A review of the record supports the ALJ’s finding, and because other error is apparent in the ALJ’s decision, the undersigned will not dwell on this point.Read the full opinion on CourtListener →
Section 404.1520(c) places the burden on the claimant at step two to show a severe impairment that significantly limits the ability to do basic work; impairments causing only slight or minimal limitations are not severe.
Johnson v. Commissioner of Social Security · filed 2020-01-23(c)
As for impairments consideration at Step Two, plaintiff bears the burden of establishing that he or she has a severe impairment, “which is ‘any impairment or combination of impairments which significantly limits [the claimant’s] ability to do basic work,’” Miller v. Berryhill, No. 16CV6467, 2017 U.S. Dist. LEXIS 153578, at *20 (W.D.N.Y. Sept. 20, 2017) (Telesca, J.) (citation omitted); see 20 C.F.R. § 404.1520(c). An impairment or combination of impairments found to be “not severe” when medical evidence establishes only a slight abnormality or a combination of slight abnormalities which would have no more than a minimal effect on an individual’s ability to work, SSR 85-28, 1985 SSR LEXIS 19 (1985).Read the full opinion on CourtListener →
At step two, the ALJ must determine whether an impairment is medically determinable and severe, but failure to classify one impairment as severe is harmless when another severe impairment allows the sequential evaluation to continue.
Harrell v. SSA, Commissioner of · filed 2020-01-28(a)(4), (c)
Also, at step two of the sequential evaluation process, the ALJ must consider whether a claimant’s medically determinable impairment is a severe impairment and whether the impairment(s) meet the twelve-month durational requirement in 20 C.F.R. § 404.1509. See 20 C.F.R. §§ 404.1520(a)(4), 416.920(a)(4); see also Simpson v. Comm’r of Soc. Sec., 344 Fed. Appx. 181, 188 (6th Cir. 2009). ... Failure to find an impairment severe at step two of the sequential analysis is not reversible error if the ALJ found another impairment severe and thus continued with the five-step evaluation.Read the full opinion on CourtListener →
Section 404.1520 requires disability claims to be evaluated through a five-step sequence, including a step-two determination whether the impairment is severe.
Ricks v. Commissioner of Social Security · filed 2020-01-30(c)
In determining disability, the Commissioner (through an ALJ) works through a five-step sequential evaluation process. See 20 C.F.R. § 404.1520(a)(4). ... Second, the claimant must prove his or her impairment is “severe” in that it “significantly limits your physical or mental ability to do basic work activities…” 20 C.F.R. § 404.1520(c). ... The ALJ appears to conclude that Plaintiff has a medically determinable physical impairment of cervical degenerative disc disease, which is supported by the objective medical records summarized above. (Tr. 17). The ALJ does not, however, address his findings with regard to whether her cervical degenerative disc disease constitutes a severe impairment, how it fails to meet the duration requirement in light of the evidence discussed above, and if so, what resulting functional limitations are present.Read the full opinion on CourtListener →
Section 404.1520(c) treats an impairment as severe at step two only if it significantly limits the claimant’s ability to do basic work activities.
(SS) Rodriguez v. Commissioner of Social Security · filed 2020-02-03(c)
[A]n impairment is not severe if it does not significantly limit [the claimant’s] . . . ability to do basic work activities.” Id. at 1290 (citing 20 C.F.R. §§ 404.1520(c) & 404.1521(a)). ... The Court finds that the ALJ’s step two determination was supported by substantial evidence in the record and an extensive discussion and analysis of the relevant criteria. ... Thus, the Court finds that the ALJ’s step two determination is supported by substantial evidence and the Court will not disturb the ALJ’s finding.Read the full opinion on CourtListener →
Section 404.1520 requires a five-step disability evaluation, including a step-two determination whether the claimant has a severe impairment that significantly limits the ability to perform basic work activities.
Bell v. Commissioner of Social Security Administration · filed 2020-02-05(a)(4)(ii)
At step two of the sequential evaluation, an ALJ must determine whether a claimant has a “severe” impairment. See 20 C.F.R. §§ 404.1520(a) (40)(ii). To determine if a claimant has a severe impairment, the ALJ must find that an impairment, or combination of impairments, significantly limits the claimant’s physical or mental ability to do “basic work activities.” See 20 C.F.R. § 416.920(c).Read the full opinion on CourtListener →
Section 404.1520(c) treats an impairment as severe only if it significantly limits the claimant’s physical or mental ability to perform basic work activities, making step two a threshold screen for de minimis claims.
Bourdier v. Berryhill · filed 2020-02-12(c)
At step two of the five-step inquiry, the ALJ determines whether a claimant has a medically severe impairment or combination of impairments that “significantly limits [her] physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c); see also 20 C.F.R. §§ 404.1520(a)(4)(ii), 404.1521(a). ... The severity assessment at the second step is a threshold matter limited to screening out de minimis claims. See Parker-Grose v. Astrue, 462 F. App’x 16, 17 (2d Cir. 2012) (summary order) (citing Dixon v. Shalala, 54 F.3d 1019, 1030 (2d Cir. 1995)).Read the full opinion on CourtListener →
At step two, § 404.1520(a)(4)(ii) requires an ALJ to determine whether a claimant has a severe medically determinable impairment that meets the duration requirement and significantly limits basic work activities.
Gennings v. Commissioner of Social Security · filed 2020-02-18(a)(4)(ii)
At step two of the disability analysis, an ALJ determines whether the claimant has “a severe medically determinable physical or mental impairment that meets the duration requirement . . . and significantly limits the claimant’s ability to do basic work activities.” ... An impairment is nonsevere if the medical evidence establishes a slight abnormality that would only minimally affect the claimant’s ability to work. ... As discussed above, LCSW Clark’s treatment notes and the evaluations of two consultative examiners indicate that Plaintiff's PTSD would only minimally affect his ability to work, and therefore was not a severe impairment. ... Thus, the ALJ’s failure to discuss PTSD as a severe impairment is ultimately harmless error.Read the full opinion on CourtListener →
At step two, § 404.1520(a)(4)(ii) requires the ALJ to determine whether the claimant has a severe impairment.
Lumpkin v. Commissioner of Social Security · filed 2020-02-25(a)(4)(ii)
A Step Two determination requires the ALJ to determine the severity of the Plaintiff’s impairments. 20 C.F.R. §§404.1520(a)(4)(ii); see also id. at (c).Read the full opinion on CourtListener →
Section 404.1520(c) requires an impairment to significantly limit a claimant’s physical or mental ability to perform basic work activities to qualify as severe at step two.
Parrish v. Saul · filed 2020-02-27(c)
In order to be found disabled, a disability claimant must have a “severe” impairment. 20 C.F.R. § 404.1520(c). A severe impairment is one "which significantly limits your physical or mental ability to do basic work activities . . . ." ... In other words, step two consists of a “de minimus screening device” used to dispose of groundless claims. See Bowen v. Yuckert, 482 U.S. 137, 153-54 (1987); Smolen v. Chater, 80 F.3d 1273, 1290 (9th Cir. 1996). ... Therefore, the Court finds that the ALJ could properly determine that Plaintiff 's migraines were not severe at step two of the five-step disability analysis.Read the full opinion on CourtListener →
Section 404.1520(c) requires an impairment to significantly limit basic work activities to qualify as severe at step two.
Bowen v. Saul · filed 2020-03-02(c)
Furthermore, for that medically determinable impairment to be considered “severe” at step two of the sequential analysis, it must significantly limit an individual’s ability to perform basic work activities. 20 C.F.R. §§ 404.1520(c), 416.920(c); Smolen, 80 F.3d at 1290.Read the full opinion on CourtListener →
At step two, the ALJ must determine whether a claimant has a severe impairment that significantly limits the claimant’s ability to perform basic work activities; an error in identifying an impairment is harmless when step two is resolved in the claimant’s favor.
Parton v. Saul · filed 2020-03-02(c)
At step two of the sequential process, the ALJ must determine whether claimant suffers from a “severe” impairment, i.e., one that significantly limits her physical or mental ability to do basic work activities. 20 C.F.R. §§ 404.1520(c), 416.920(c). ... Plaintiff contends the ALJ should have identified Plaintiff’s right arm pain and lumbar spine pain as severe impairments at step two. ... Even if the ALJ should have identified these impairments as severe, any error would be harmless because the step was resolved in Plaintiff’s favor.Read the full opinion on CourtListener →
At step two, § 404.1520(c) requires only a minimal showing that the claimant's impairment or combination of impairments is severe; once that threshold is met, the sequential evaluation must proceed.
Jin v. Berryhill · filed 2020-03-02(c)
Indeed, all that is required at step two is a minimal showing of severity, one that is satisfied by two examining opinions regarding Plaintiff’s physical limitations and two examining opinions pertaining to his mental limitations, which, in combination, demonstrate that Plaintiff experiences more than minimal work limitations sufficient to satisfy step two.Read the full opinion on CourtListener →
Section 404.1520(c) requires a claimant at step two to show a medically determinable impairment that is severe, meaning it significantly limits the ability to perform basic work activities.
(SS) Perez v. Commissioner of Social Security · filed 2020-03-04(c)
The inquiry at step two is a de minimus screening for severe impairments “to dispose of groundless claims.” Smolen v. Chater, 80 F.3d 1273, 1290 (9th Cir. 1996) (citing Bowen v. Yuckert, 482 U.S. 137, 153-54 (1987)). The purpose is to identify claimants whose medical impairment makes it unlikely they would be disabled even if age, education, and experience are considered. Bowen, 482 U.S. at 153 (1987). At step two, a claimant must make a “threshold showing” that (1) she has a medically determinable impairment or combination of impairments and (2) the impairment or combination of impairments is severe. Id. at 146-47; see also 20 C.F.R. §§ 404.1520(c), 416.920(c). Thus, the burden of proof is on the claimant to establish a medically determinable severe impairment.Read the full opinion on CourtListener →
At step two, an impairment is severe when it significantly limits a claimant’s physical or mental ability to perform basic work activities.
Knowlton v. Commissioner of Social Security · filed 2020-03-04(c)
A severe impairment is one that significantly limits the plaintiff’s physical and/or mental ability to do basic work activities. See 20 C.F.R. § 404.1520(c); see also 20 C.F.R. § 404.1521(a).Read the full opinion on CourtListener →
Subsection (c) requires the adjudicator to determine at step two whether an impairment or combination of impairments significantly limits the claimant’s ability to perform basic work activities.
Pfleuger v. Commissioner of Social Security · filed 2020-03-05(c)
At step two of the disability analysis, the ALJ must determine whether the plaintiff has a severe impairment that significantly limits his or her physical or mental ability to do basic work activities. 20 C.F.R. § 404.1520(c). ... Based on the foregoing, this Court finds that the ALJ did not err in failing to find chronic pain disorder and left cervical shoulder girdle myofascial pain syndrome at step two. Even if he did, any error was harmless as he considered all of Plaintiff’s symptoms at step three and in formulating the RFC.Read the full opinion on CourtListener →
Section 404.1520(c) requires a claimant at step two to show that medically determinable impairments significantly limit the ability to perform basic work activities.
Johnson v. Commissioner of Social Security · filed 2020-03-10(c)
At step two, a claimant must make a threshold showing that his medically determinable impairments significantly limit his ability to perform basic work activities. See Bowen v. Yuckert, 482 U.S. 137, 145 (1987); 20 C.F.R. §§ 404.1520(c), 416.920(c).Read the full opinion on CourtListener →
Section 404.1520(c) makes step two a threshold inquiry into whether the claimant has a severe impairment, and an error at that step is harmless when the ALJ considers all impairments and symptoms in determining residual functional capacity.
Jensen v. Commissioner of Social Security · filed 2020-03-13(c)
Step two assesses whether the claimant has a medically severe impairment or combination of impairments. 20 C.F.R. §§ 404.1520(c), 416.920(c). If the claimant does not, the disability claim is denied. If the claimant does, the evaluation proceeds to the third step. ... Step two is a threshold determination to screen out weak claims. Bowen v. Yuckert, 482 U.S. 137, 146–47 (1987). The ALJ must consider all symptoms, whether from conditions found to be “severe” at step two or otherwise, when assessing RFC. Buck v. Berryhill, 869 F.3d 1040, 1048 (9th Cir. 2017). Here, because the ALJ’s step two analysis was favorable to Plaintiff and the ALJ considered all of Plaintiff’s impairments and symptoms in determining his RFC, any error in failing to find that specific impairments were not severe was harmless. See Buck, 869 F.3d at 1048.Read the full opinion on CourtListener →
Section 404.1520(a)(4)(ii) requires the Commissioner, at step two, to determine whether the claimant has a severe impairment that significantly limits the ability to perform basic work activities.
Jorge v. Berryhill · filed 2020-03-13(a)(4)(ii)
To be “disabled” within the meaning of the Act, a claimant’s impairments must be “severe,” meaning that they “significantly limit[ ] [her] physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(a)(4)(ii), (c).Read the full opinion on CourtListener →
At step two, the claimant bears the burden of showing that an impairment significantly limits the ability to perform basic work activities.
Grant v. Berryhill · filed 2020-03-18(c)
The Court disagrees. First, as noted above, it is Grant’s burden to show that her sleep disorder significantly limited her “ability to do basic work activities . . . .” 20 C.F.R. § 404.1520(c). But, Grant simply restates a portion of her October 2009 sleep study results without explaining whether or how those results indicate that her sleep disorder significantly limited her ability to work.Read the full opinion on CourtListener →
Section 404.1520(c) requires the step-two severity inquiry to determine whether an impairment significantly limits a claimant’s ability to do basic work activities.
(SS) Yarnell v. Commissioner of Social Security · filed 2020-03-19(c)
For an impairment to be “severe,” it must “significantly limit[]” the claimant’s “ability to do basic work activities.” 20 C.F.R. §§ 404.1520(c), 416.920(c). ... The ALJ, however, had the benefit of knowing Plaintiff’s ultimate diagnosis with Chronic Fatigue Syndrome, yet did not address whether her fatigue affected her ability to do basic work activities at step two. ... Thus, the Court finds the ALJ erred by ignoring Plaintiff’s fatigue—and subsequent diagnosis with Chronic Fatigue Syndrome—in evaluating the medical record.Read the full opinion on CourtListener →
Section 404.1520(c) requires a claimant at step two to make a threshold showing that medically determinable impairments significantly limit the ability to perform basic work activities.
Shouse v. Commissioner of Social Security · filed 2020-03-20(c)
At step two, a claimant must make a threshold showing that her medically determinable impairments significantly limit her ability to perform basic work activities. See Bowen v. Yuckert, 482 U.S. 137, 145 (1987); 20 C.F.R. §§ 404.1520(c), 416.920(c).Read the full opinion on CourtListener →
Section 404.1520(a)(4)(ii) requires an ALJ to decide at step two whether the claimant has a severe medically determinable impairment or combination of impairments; if so, the sequential evaluation continues.
Matos v. Saul · filed 2020-03-23(a)(4)(ii), (c)
Step two of the Commissioner’s sequential evaluation process requires the ALJ to determine the severity of the claimant’s medically determinable impairments. 20 C.F.R. § 404.1520(a)(4)(ii). It serves as a “de minimis screening device to dispose of groundless claims.” Smolen v. Chater, 80 F.3d 1273, 1290 (9th Cir. 1996). The ALJ is to determine whether the claimant has a “medically severe impairment or combination of impairments.” Id. A severe impairment is that “which significantly limits [a claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c). The claimant has the burden at step two to show that he has a severe impairment. Bray v. Comm’r of Soc. Sec. Admin., 554 F.3d 1219, 1222 (9th Cir. 2009).Read the full opinion on CourtListener →
At step two, an impairment is severe when it significantly limits an individual's physical or mental ability to perform basic work activities.
Fleming v. Commissioner of Social Security · filed 2020-03-24(a)(4)(ii)
Regardless, an impairment is considered “severe” at step two of the sequential evaluation “if it significantly limits an individual’s physical or mental abilities to do basic work activities ….” Soc. Sec. R. 96-3p, 1996 WL 374181, at *2 (July 2, 1996); see 20 C.F.R. § 404.1520(a)(4)(ii). The severity requirement permits the Administration “to screen out claims that are ‘totally groundless’ solely from a medical standpoint.” Higgs v. Bowen, 880 F.2d 860, 863 (6th Cir. 1988) (citation omitted). “Severity,” therefore, presents a “de minimis hurdle”: “[A]n impairment can be considered not severe only if it is a slight abnormality that minimally affects work ability regardless of age, education, and experience.” Id. at 862 (citation omitted).Read the full opinion on CourtListener →
At step two, § 404.1520(a)(4)(ii) requires determining whether the claimant has a severe impairment or combination of impairments, using a de minimis screen for impairments that significantly limit basic work activities.
Roberson v. Berryhill · filed 2020-03-25(a)(4)(ii)
At step two of the sequential evaluation, the ALJ determines whether the claimant has a medically “severe” impairment or combination of impairments. See 20 C.F.R. §§ 404.1520(a)(4) (ii); see also Smolen, 80 F.3d 1273, 1289–90 (9th Cir. 1996) (citing Bowen v. Yuckert, 482 U.S. 140–41 (1987)). An impairment is severe when it significantly limits a claimant’s “physical or mental ability to do basic work activities” and lasted or is expected to last “for a continuous period of at least 12 months.” See 20 C.F.R. §§ 404.1509, 404.1520(a)(4)(ii), (c), 404.1521(a); accord 20 C.F.R. §§ 416.920(a)(4)(ii), (c), 416.909. ... Ultimately, the purpose of a step-two evaluation is to dispose of “groundless claims” and the evidence in the record before the ALJ was sufficient to conclude that Plaintiff’s depression is a severe impairment under the de minimis test.Read the full opinion on CourtListener →
At step two, the ALJ must assess the medical severity of the claimant’s impairments and determine whether each is severe or not severe.
Aguero v. Berryhill · filed 2020-03-26(a)(4)(ii), (c)
At step two of the sequential evaluation process, the ALJ “must consider the medical severity of [the claimant’s] impairments.” 20 C.F.R. § 404.1520(a)(4)(ii), (c). To comply with this regulation, the ALJ “must determine whether any identified impairments are ‘severe’ or ‘not severe.’” ... The failure to determine the severity of Plaintiff’s incontinence at step two as required by 20 C.F.R. § 404.1520(a)(4)(ii),(c) was legal error.Read the full opinion on CourtListener →
At step two, the Commissioner determines whether the claimant has a severe impairment that significantly limits the ability to do basic work activities.
Daughrity v. Commissioner of Social Security · filed 2020-03-30(c)
At step two of the sequential process, the ALJ must determine whether the claimant suffers from a “severe” impairment, i.e., one that significantly limits his physical or mental ability to do basic work activities. 20 C.F.R. §§ 404.1520(c), 416.920(c).Read the full opinion on CourtListener →
At step two, the regulation requires the ALJ to determine whether the claimant has a severe impairment that significantly limits the ability to perform basic work activities.
Monteith v. Commissioner of Social Security · filed 2020-02-17(a)(4)(ii) and (c)
At step two of the five-step sequential evaluation for disability claims, the ALJ must determine whether the claimant has one or more severe impairments that significantly limit a claimant’s ability to perform basic work activities. 20 C.F.R. §§ 404.1520(a)(4)(ii) and (c); 416.920(a)(4)(ii) and (c).Read the full opinion on CourtListener →
At step two, the claimant bears the burden of showing an impairment or combination of impairments that significantly limits the physical or mental ability to perform basic work activities.
Krudop v. Social Security Administration · filed 2020-03-27(c)
At step two, Claimant bears the burden of showing the existence of an impairment or combination of impairments which “significantly limits [his] physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c).Read the full opinion on CourtListener →
Section 404.1520(c) places the burden on the claimant at step two to show an impairment or combination of impairments that significantly limits the ability to perform basic work activities.
Woods v. Social Security Administration · filed 2020-03-31(c)
At step two, Claimant bears the burden of showing the existence of an impairment or combination of impairments which “significantly limits [his] physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c).Read the full opinion on CourtListener →
Section 404.1520(c) requires the ALJ at step two to determine whether a claimant has a severe impairment that significantly limits the claimant’s physical or mental ability to do basic work activities.
Uppinghouse v. Saul · filed 2020-04-07(c)
At step two of the sequential process, the ALJ must determine whether claimant suffers from a “severe” impairment, i.e., one that significantly limits her physical or mental ability to do basic work activities. 20 C.F.R. § 404.1520(c). ... The ALJ gave specific and legitimate reasons for rejecting the finding that fibromyalgia is a severe medically determinable impairment, and her step-two analysis is supported by substantial evidence. ... Thus, the ALJ’s step two finding is legally sufficient.Read the full opinion on CourtListener →
At step two, § 404.1520 requires the ALJ to consider the medical severity of the claimant’s impairments and screen out impairments that do not significantly limit basic work activities.
FOX v. COMMISSIONER OF SOCIAL SECURITY · filed 2020-04-16(a)(4)(ii)
At step two, the ALJ has to “consider the medical severity of a claimant’s impairment(s).” 20 C.F.R. § 404.1520(a)(4)(ii). “The severity test at step two is a ‘de minimis screening device to dispose of groundless claims.’” McCrea v. Comm'r of Soc. Sec., 370 F.3d 357, 360–61 (3d Cir. 2004) (citation omitted). ... In order to have a severe impairment, the impairment or combination thereof must significantly limit a person’s “physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c). ... The Court finds that substantial evidence supports both of these findings.Read the full opinion on CourtListener →
At step two, the ALJ determines whether the claimant has a medically determinable severe impairment.
Moser v. Saul · filed 2020-04-27(a)(4)
At step two of the sequential evaluation process, the ALJ must determine whether the claimant has any medically determinable severe impairments. 20 C.F.R. §§ 404.1520(a)(ii), 416.920(a)(ii). ... Even if the failure to list obesity as a severe impairment was an error, the error would be harmless because step two was resolved in Plaintiff’s favor, and Plaintiff fails to identify any credited limitation associated with obesity that was not considered by the ALJ and incorporated into the RFC finding.Read the full opinion on CourtListener →
At step two, § 404.1520 requires the decision maker to determine whether the claimant has a medically severe impairment or combination of impairments, and the disability claim is denied if no severe impairment exists.
Sandoval v. Commissioner of Social Security · filed 2020-05-18(a)(4)(ii)
If the claimant is not engaged in substantial gainful activities, the decision maker proceeds to step two and determines whether the claimant has a medically severe impairment or combination of impairments. 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii). If the claimant does not have a severe impairment or combination of impairments, the disability claim is denied. ... At the step two inquiry, an ALJ may find an impairment or combination of impairments to be non-severe only if the evidence shows only a “slight abnormality” that has no more than a minimal effect on an individual’s ability to work. ... Therefore, the Court finds that the ALJ did not err in finding that Plaintiff’s degenerative disc disease is a non-severe impairment.Read the full opinion on CourtListener →
At step two, § 404.1520(c) treats an impairment as severe only if it significantly limits the claimant’s ability to perform basic work activities.
Bolin v. Saul · filed 2020-05-29(c)
To be considered severe, an impairment must significantly limit a claimant’s ability to do basic work activities. See 20 C.F.R. §§ 404.1520(c), 416.920(c). ... The Court finds that the ALJ should have found that Bolin’s neuropathy was a separate severe impairment. ... Based on the foregoing, the Court finds that although the ALJ may have erred in finding the Bolin’s diabetic neuropathy was not a severe impairment, the ALJ’s error was harmless.Read the full opinion on CourtListener →
Section 404.1520(a)(4) requires the ALJ, at step two of the sequential evaluation, to consider the medical severity of the claimant's impairments.
Davis v. Commissioner of Social Security · filed 2020-06-05(a)(4)
At step two of the five-step sequential evaluation process, the ALJ considers the “medical severity of [the claimant’s] impairments.” 20 C.F.R. § 404.1520(a)(4).Read the full opinion on CourtListener →
At step two, § 404.1520(c) requires a claimant to show that her medically determinable impairments significantly limit her ability to perform basic work activities.
Foster v. Commissioner of Social Security · filed 2020-05-22(c)
At step two, a claimant must make a threshold showing that her medically determinable impairments significantly limit her ability to perform basic work activities. See Bowen v. Yuckert, 482 U.S. 137, 145 (1987); 20 C.F.R. §§ 404.1520(c), 416.920(c). The ALJ found at step two that Plaintiff’s mental impairments were not severe.Read the full opinion on CourtListener →
Section 404.1520(c) makes step two a threshold inquiry into medically severe impairments; failing to label an impairment severe is harmless when the ALJ considers its symptoms in the RFC.
Valencia v. Kijakazi · filed 2020-06-25(c)
Step two is a threshold determination to screen out weak claims of disability. ... This step is “not meant to identify the impairments that should be taken into account when determining the RFC.” ... Rather, when assessing RFC, the ALJ must consider all symptoms, whether from conditions found to be “severe” at step two or otherwise. ... Thus, any error in failing to find that specific impairments were not severe was harmless. See Buck, 869 F.3d at 1048.Read the full opinion on CourtListener →
Section 404.1520 requires the ALJ to classify impairments as severe or non-severe at step two, and an impairment is severe only if it significantly limits the claimant’s ability to perform basic work activities.
(SS) Marquez v. Commissioner of Social Security · filed 2020-06-26(c)
Under step two, the ALJ is to classify any impairments as either “severe” or “non-severe.” See 20 C.F.R. §§ 404.1520, 1571-76. A “severe” impairment is one that significantly limits the physical or mental ability to perform basic work activities. § 404.1520(c). This assessment is a “de minimus screening to dispose of groundless claims.” Edlund, 253 F.3d at 1158.Read the full opinion on CourtListener →
At step two, an ALJ must determine whether the claimant has a severe impairment, meaning an impairment or combination of impairments that significantly limits the claimant's physical or mental ability to do basic work activities.
Balata v. Social Security Administration · filed 2020-06-26(a)(4)(ii), (c)
At step two, an ALJ must consider whether a claimant’s impairments are severe. See 20 C.F.R. § 404.1520(a)(4)(ii); Smith v. Colvin, 821 F.3d 1264, 1266 (10th Cir. 2016). To be “severe,” an impairment or combination of impairments must “significantly limit[ a claimant’s] physical or mental ability to do basic work activities . . . .” 20 C.F.R. § 404.1520(c). Mr. Balata has the burden of proof at step two to establish that he has an impairment severe enough to interfere with his ability to work.Read the full opinion on CourtListener →
Section 404.1520(c) requires an ALJ at step two to determine whether a claimant has a severe impairment that significantly limits the ability to perform basic work activities.
DePasquale v. Commissioner of Social Security · filed 2020-07-07(c)
At step two of the disability analysis, the ALJ must determine whether the plaintiff has a severe impairment that significantly limits his or her physical or mental ability to do basic work activities. 20 C.F.R. § 404.1520(c). “The claimant bears the burden of presenting evidence establishing severity.” Taylor v. Astrue, 32 F. Supp. 3d 253, 265 (N.D.N.Y. 2012), adopted, 32 F. Supp. 3d 253 (N.D.N.Y. 2012). The step two severity standard “is de minimis and is meant only to screen out the weakest of claims.”Read the full opinion on CourtListener →
Section 404.1520(c) treats an impairment as severe at step two when it significantly limits a claimant’s physical or mental ability to do basic work activities.
(SS) Phillips v. Commissioner of Social Security · filed 2020-07-09(c)
Under the Commissioner’s regulations, an impairment or combination of impairments is deemed to be severe at Step Two if it “significantly limits [a claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1520(c), 404.1521(a). ... The ALJ therefore properly accounted for plaintiff’s limitations posed by her dyslexia. Accordingly, the court finds no prejudicial error at Step Two.Read the full opinion on CourtListener →
Section 404.1520 requires a five-step disability evaluation, and at Step Two an impairment is severe when it significantly limits basic work activities; the Step Two determination must account for medical evidence that may show worsening.
Robert E. v. Saul · filed 2020-07-09(c)
The ALJ must follow five steps in evaluating a claim of disability. See 20 C.F.R. § 404.1520. ... Second, if a claimant does not have any impairment or combination of impairments that significantly limit physical or mental ability to do basic work activities, then the claimant does not have a severe impairment and is not disabled. 20 C.F.R. § 404.1520(c). ... These 2018 treating notes plainly contain “indications of worsening,” making it impossible for the Court to know whether the SA experts would have rendered the same Step Two opinions if they had seen them. Their omission from consideration requires remand for medical interpretation of them and reassessment of the severity of Plaintiff’s impairments in light of them.Read the full opinion on CourtListener →
Section 404.1520’s step-two inquiry asks whether the claimant has a severe impairment or combination of impairments that significantly limits the ability to perform basic work activities.
Wade v. Commissioner of Social Security Administration · filed 2020-07-13(a)(4)(ii), (c)
At step two, the ALJ determines whether the claimant has shown a “severe” impairment or combination of impairments which “significantly limits [his] physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1520(a)(4)(ii), 404.1520(c); see also 20 C.F.R. § 404.1522(b) (defining “basic work activities”). The Court finds no reversible error in the step two analysis as it pertains to Mr. Wade’s back and neck conditions. ... Third, and most importantly, even though the ALJ did not find Plaintiff’s orthopedic impairments “severe” at step two, the ALJ nonetheless resolved step two in Plaintiff’s favor and adequately addressed these impairments later in the RFC assessment at steps four and five. Any error in their omission at step two is therefore harmless.Read the full opinion on CourtListener →
Section 404.1520(c) treats an impairment as severe when it significantly limits a claimant’s physical or mental ability to perform basic work activities, and the court applied that step-two standard to the claimant’s TMJ and neuralgia.
(SS) Evanovich v. Commissioner of Social Security · filed 2020-07-17(c)
At step two of the sequential evaluation, the ALJ determines which of claimant’s alleged impairments are “severe” within the meaning of 20 C.F.R. §§ 404.1520(c), 416.920(c). A severe impairment is one that “significantly limits” a claimant’s “physical or mental ability to do basic work activities.” Id. An ALJ must consider all the evidence at step two to determine whether a medically determinable impairment significantly limits the claimant’s ability to perform basic work activities. Id. §§ 404.1520(a), 416.920(a); Bowen v. Yuckert, 482 U.S. 137, 153 (1987). ... However, even if the ALJ erred by failing to conclude that Plaintiff’s TMJ and related neuralgia are severe, such error was at most harmless. ... Step two was resolved in Plaintiff’s favor when the ALJ determined that her severe impairments included ulcerative colitis, depression, personality disorder, and post-traumatic stress disorder and she proceeded to the step three analysis. ... The Court therefore finds no error at step two.Read the full opinion on CourtListener →
At Step Two, the regulation requires the ALJ to determine whether the claimant has a severe medically determinable physical or mental impairment; an impairment is severe when it significantly limits the claimant’s physical or mental ability to perform basic work activities.
Gracie v. Commissioner of Social Security · filed 2020-07-24(a)(4)(ii), (a)(4)(iii)
At Step Two of the sequential evaluation process, the ALJ must determine if a claimant has a “severe medically determinable physical or mental impairment.” ... A medically determinable impairment is considered “severe” if it “significantly limits [a claimant’s] physical or mental ability to do basic work activities.”Read the full opinion on CourtListener →
Section 404.1520(c) requires a claimant to have a severe impairment or combination of impairments—one that imposes significant restrictions on basic work activities—to proceed past step two of the disability evaluation.
Price v. Commissioner of Social Security · filed 2020-07-27(c)
At step two of the disability analysis, the ALJ determines whether the plaintiff has an impairment, or combination of impairments, that is “severe” within the meaning of the Act, in that it imposes significant restrictions on the claimant's ability to perform basic work activities. 20 C.F.R. § 404.1520(c)2. ... Step two's “severity” requirement is de minimis and is meant only to screen out the weakest of claims. ... Overall, the ALJ’s step two determination was proper and supported by substantial evidence.Read the full opinion on CourtListener →
Section 404.1520(c) defines a severe impairment as one that significantly limits basic work activities, and the step-two severity threshold is a de minimis hurdle.
Cooke v. Commissioner of the Social Security Administration · filed 2020-07-29(c)
A severe impairment is defined as “any impairment or combination of impairments which significantly limits your physical or mental ability to do basic work activities,” 20 C.F.R. §§ 404.1520(c), 416.920(c), and which lasts or can be expected to last “for a continuous period of not less than 12 months.” ... In the Sixth Circuit, “the step two severity regulation codified at 20 C.F.R. §§ 404.1520(c) and 404.1521 has been construed as a de minimis hurdle in the disability determination process.” ... The Undersigned finds no error in the ALJ’s conclusion at step two that, during the relevant time period, Plaintiff’s osteoporosis and celiac disease were non-severe impairments.Read the full opinion on CourtListener →
At step two, § 404.1520(c)'s severity requirement is only a de minimis hurdle in determining disability.
Jeley v. Commissioner of Social Security · filed 2020-08-06(c)
In the Sixth Circuit, “the step two severity regulation codified at 20 C.F.R. §§ 404.1520(c) and 404.1521 has been construed as a de minimis hurdle in the disability determination process.”Read the full opinion on CourtListener →
Section 404.1520(c) requires a claimant at step two to show that medically determinable impairments significantly limit the ability to perform basic work activities.
McGuire v. Commissioner of Social Security · filed 2020-08-10(c)
At step two, a claimant must make a threshold showing that her medically determinable impairments significantly limit her ability to perform basic work activities. See Bowen v. Yuckert, 482 U.S. 137, 145 (1987); 20 C.F.R. § 404.1520(c). ... Plaintiff contends the ALJ erred by failing to include sciatica as a severe impairment at step two and erred by failing to include related impairments in the RFC and in the hypothetical posed to the vocational expert. Any error is harmless, at step two as well as later steps. Because the ALJ found in Plaintiff’s favor at step two, he “could not possibly have been prejudiced” at that step. Buck v. Berryhill, 869 F.3d 1040, 1049 (9th Cir. 2017). ... The Court concludes the ALJ did not harmfully err in addressing plaintiff’s sciatica.Read the full opinion on CourtListener →
Section 404.1520 requires a five-step disability analysis, including a step-two determination whether the claimant has a severe medically determinable impairment; an omission at step two is harmless when the claimant’s limitations are considered at step four.
Mills v. Commissioner of Social Security Administration · filed 2020-08-14(a)(4)(ii)
At step two of the five-step analysis, an ALJ must determine whether a claimant’s impairments are severe. § 404.1520(a)(4)(ii). This is a “de minimis screening device [used] to dispose of groundless claims.” Smolen v. Chater, 80 F.3d 1273, 1290 (9th Cir. 1996) (citing Bowen v. Yuckert, 482 U.S. 137, 153–54 (1987)). Here, the ALJ found that Mr. Mills’ sleep apnea was not severe. (R. at 20.) ... More importantly, even though the ALJ did not find the sleep apnea severe, he ultimately resolved step two in Mr. Mills’ favor and adequately addressed the impairments at step four of the disability analysis. Any error in their omission at step two is therefore harmless. Lewis v. Astrue, 498 F.3d 909, 911 (9th Cir. 2007) (holding that an ALJ’s failure to include an impairment at step two was harmless error where the record reflected that the ALJ considered any limitations posed by the impairment at step four).Read the full opinion on CourtListener →
Section 404.1520(a)(4)(ii) requires the ALJ at step two to determine whether the claimant has a severe impairment that significantly limits the ability to perform basic work activities.
Morton v. Saul · filed 2020-08-20(a)(4)(ii)
At step two of the sequential process, the ALJ must determine whether the claimant suffers from a “severe” impairment, i.e., one that significantly limits her physical or mental ability to do basic work activities. 20 C.F.R. § 404.1520(a)(4)(ii); 20 C.F.R. § 404.1522. ... Accordingly, the Court concludes the ALJ’s step two analysis as to Plaintiff’s mental impairments was sufficient.Read the full opinion on CourtListener →
Section 404.1520(c) requires the ALJ at step two to determine whether an impairment significantly limits the claimant’s ability to perform basic work activities and to provide a meaningful analysis supporting that determination.
Beatty v. Saul · filed 2020-08-24(c)
At step two of the sequential process, the ALJ must determine whether the claimant suffers from a “severe” impairment, i.e., one that significantly limits her physical or mental ability to do basic work activities. 20 C.F.R. §§ 404.1520(c), 416.920(c). ... Given its impact on later steps, the Court finds the ALJ harmfully erred in failing to analyze the evidence of Plaintiff’s PTSD. On remand, the ALJ is instructed to reconsider whether Plaintiff’s PTSD is a severe medically determinable impairment; if the ALJ again finds PTSD is not a severe medically determinable impairment, the ALJ is instructed to provide a meaningful step-two analysis.Read the full opinion on CourtListener →
Section 404.1520(a)(4)(ii) requires the evaluator at step two to determine whether the claimant has a severe medically determinable impairment or combination of impairments; an impairment is not severe when it has no more than a minimal effect on the ability to work.
Hill v. Social Security Administration, Commissioner · filed 2020-09-01(a)(4)(ii)
At step two, the ALJ had to determine whether Plaintiff had a medically determinable impairment or combination of impairments that is “severe.” 20 C.F.R. §§ 404.1520(c), 416.920(c). An impairment or combination of impairments is “severe” within the meaning of the regulations if it significantly limits an individual’s ability to perform basic work activities. 20 C.F.R. § 404.1520(c). An impairment or combination of impairments is “not severe” when medical and other evidence establishes only a slight abnormality or a combination of slight abnormalities that would have no more than a minimal effect on an individual’s ability to work.Read the full opinion on CourtListener →
At step two, a claimant must show that an impairment is medically determinable and severe, meaning it significantly limits the ability to perform basic work activities.
(SS) Akin v. Commissioner of Social Security · filed 2020-09-01(c)
Assuming Plaintiff met the burden of show her fibromyalgia was a medically determinable impairment, she must next show the impairment was severe. Bowen, 482 U.S. at 153 (1987); 20 C.F.R. § 404.1520(c). The Ninth Circuit determined that “[t]he mere existence of an impairment is insufficient proof of a disability.” Matthews v. Shalala, 10 F.3d 678 (9th Cir. 1993). In other words, a medical diagnosis alone does not make an impairment “severe.” Plaintiff failed to demonstrate that this impairment is severe. She does not identify any medical evidence that demonstrates fibromyalgia limits her “abilities and aptitudes necessary to do most jobs.” 20 C.F.R. §§ 404.1522(b), 416.922(b). Because Plaintiff does not identify any functional limitations that may be attributed to fibromyalgia, she also fails to carry the burdens at step two. See Bowen, 482 U.S. at 153 (1987); 20 C.F.R. § 404.1520(c).Read the full opinion on CourtListener →
Section 404.1520(c) requires a claimant to have a severe impairment or combination of impairments that significantly limits the ability to perform basic work activities to proceed beyond step two.
Gewalt v. Saul · filed 2020-09-02(c)
At step two, the ALJ considers the medical severity of the claimant’s impairment(s). The claimant “must have a severe impairment . . . or combination of impairments which significantly limits [their] physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1520(c), 416.920(c); see also Bowen v. Yuckert, 482 U.S. 137, 146 (1987).Read the full opinion on CourtListener →
Section 404.1520(a)(4)(ii) requires determining at step two whether a claimant has a severe impairment, and § 404.1520(c) defines a severe impairment as one that significantly limits the ability to perform basic work activities; finding at least one severe impairment permits the evaluation to proceed.
Wagner v. Saul · filed 2020-09-09(a)(4)(ii), (c)
At step two of the sequential analysis the ALJ is required to determine whether the claimant has an impairment or combination of impairments that is “severe.” 20 C.F.R. § 404.1520(a)(4)(ii). A “severe” impairment is an impairment or combination of impairments that “significantly limits [one’s] physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c). The burden is on the claimant to prove that an impairment is severe. Zurawski v. Halter, 245 F.3d 881, 885-86 (7th Cir. 2001). The Commissioner argues that it was only necessary for the ALJ to find one severe impairment before proceeding with the sequential analysis. The Commissioner is correct. “As long as the ALJ determines that the claimant has one severe impairment, the ALJ will proceed to the remaining steps of the evaluation process.” Castile v. Astrue, 617 F.3d 923, 926-27 (7th Cir. 2010). This step two determination of severity is “merely a threshold requirement.” Hickman v. Apfel, 187 F.3d 683, 688 (7th Cir. 1999). Here, the ALJ found the following severe impairments: degenerative disc disease, degenerative joint disease, and depression. R. 19. The ALJ met this threshold requirement by finding at least one severe impairment and moved on to the next step.Read the full opinion on CourtListener →
Section 404.1520(c) requires an impairment to significantly limit a claimant’s ability to perform basic work activities to qualify as severe at step two, and a finding of no severe impairment must be clearly established by the medical evidence.
(SS) Telly v. Commissioner of Social Security · filed 2020-09-16(c)
“[A]n impairment is not severe if it does not significantly limit [the claimant’s] . . . ability to do basic work activities.” Id. ... Viewing the record as a whole, the medical and opinion evidence in this case does not “clearly establish” that Plaintiff lacks a medically severe impairment or combination of impairments. Webb, 433 F.3d at 687. ... Accordingly, the ALJ’s step two findings cannot stand.Read the full opinion on CourtListener →
Section 404.1520(a)(4)(ii) requires the Commissioner at Step Two to determine whether the claimant has a severe medically determinable impairment meeting the duration requirement; failing to evaluate a potentially severe impairment is not harmless when the impairment and its effects are omitted from the rest of the analysis.
Haynes v. Saul · filed 2020-09-17(a)(4)(ii)
As discussed above, at Step Two, the Commissioner must determine whether the claimant has a “severe medically determinable physical or mental impairment that meets the [twelve-month] duration requirement in § 404.1509, or a combination of impairments that is severe and meets the duration requirement . . . .” 20 C.F.R. §§ 404.1509, 404.1520(a)(4)(ii). ... Here, however, the Court cannot say that the ALJ’s error in failing to evaluate Plaintiff’s fibromyalgia at Step Two was harmless. This is not a situation where the ALJ failed to list an impairment as severe but nevertheless considered the impairment and its effects later in his analysis. Here, the ALJ did not discuss Plaintiff’s fibromyalgia or its effects at any step of the decision.Read the full opinion on CourtListener →
At step two, the ALJ must consider all of a claimant’s conditions and determine whether each is severe or non-severe.
Calpito v. Commissioner of Social Security · filed 2020-09-18(c)
Under step two, an ALJ must consider all conditions a claimant has and determine whether they are “severe” or “non-severe.” 20 C.F.R. § 404.1520(c).Read the full opinion on CourtListener →
Section 404.1520(c) requires a claimant at step two to show that medically determinable impairments significantly limit the ability to perform basic work activities; the inquiry is de minimis and considers the combined effect of impairments.
Yem v. Commissioner of Social Security · filed 2020-09-23(c)
At step two, a claimant must make a threshold showing that her medically determinable impairments significantly limit her ability to perform basic work activities. See Bowen v. Yuckert, 482 U.S. 137, 145 (1987); 20 C.F.R. §§ 404.1520(c), 416.920(c). “Basic work activities” refers to “the abilities and aptitudes necessary to do most jobs.” 20 C.F.R. §§ 404.1522(b), 416.922(b). “An impairment or combination of impairments can be found ‘not severe’ only if the evidence establishes a slight abnormality that has ‘no more than a minimal effect on an individual’s ability to work.’” Smolen v. Chater, 80 F.3d 1273, 1290 (9th Cir. 1996) (quoting Social Security Ruling (SSR) 85-28). “[T]he step two inquiry is a de minimis screening device to dispose of groundless claims.” Id. (citing Bowen, 482 U.S. at 153-54). An ALJ is also required to consider the “combined effect” of an individual’s impairments in considering severity.Read the full opinion on CourtListener →
At step two, a claimant must show that an impairment or combination of impairments significantly limits the ability to perform basic work activities; impairments that do not do so are non-severe.
Bishop v. Social Security Administration · filed 2020-09-28(c)
At step two, Claimant bears the burden of showing the existence of an impairment or combination of impairments which “significantly limits [her] physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1520(c), 416.920(c). ... Claimant has not sustained her burden of demonstrating that her medically determinable conditions would have anything more than a mild effect upon her ability to engage in basic work activity. As such, there is no error in the ALJ’s step-two determination that Claimant’s physical and mental impairments, considered singly and in combination, do not significantly limit her ability to perform basic work activities, and are therefore, non-severe.Read the full opinion on CourtListener →
At step two, § 404.1520 requires the ALJ to assess the medical severity of a claimant's impairments; misclassifying one impairment as non-severe is harmless when the ALJ considers it in the later steps.
Major v. Saul · filed 2020-09-29(a)(4)(ii)
At step two, the ALJ “consider[s] the medical severity of” a claimant’s “impairment(s).” 20 C.F.R. §404.1520(a)(4)(ii). ... Accordingly, even if the ALJ erred in his step two severity findings, any error would be harmless and would not require remand.Read the full opinion on CourtListener →
At step two, a claimant must prove that an impairment or combination of impairments significantly limits the ability to perform basic work activities.
LAPOINTE v. SOCIAL SECURITY ADMINISTRATION COMMISSIONER · filed 2020-09-30(c)
Plaintiff bears the burden of proving that he “has a medically severe impairment or combination of impairments,” Bowen v. Yuckert, 482 U.S. 137, 146 n. 5 (1987), that “significantly limit[] [his] physical or mental ability to do basic work activities,” 20 C.F.R. §§ 404.1520(c), 416.920(c).Read the full opinion on CourtListener →
Section 404.1520(c) requires a claimant at step two to show that medically determinable impairments significantly limit basic work activities; failure to identify an impairment at that step is harmless absent a specific unaddressed limitation.
Schonhardt v. Commissioner of Social Security · filed 2020-10-09(c)
At step two, a claimant must make a threshold showing that her medically determinable impairments significantly limit her ability to perform basic work activities. See Bowen v. Yuckert, 482 U.S. 137, 145 (1987); 20 C.F.R. §§ 404.1520(c), 416.920(c). ... The ALJ at step-two found Plaintiff had been diagnosed with various mental health impairments, including depression, PTSD, and anxiety. Tr. 18-19. The ALJ failed to mention panic disorder but Plaintiff has not identified any specific limitation attributable to her panic disorder that was not discussed by the ALJ in subsequent portions of the decision, and thus has failed to establish the ALJ harmfully erred in failing to find panic disorder as one of Plaintiff’s mental disorders at step two. See Buck v. Berryhill, 869 F.3d 1040, 1048-49 (9th Cir. 2017). The Court accordingly finds that even if the ALJ should have noted panic disorder at step two, the failure to do so is harmless.Read the full opinion on CourtListener →
At step two, § 404.1520(c) requires a claimant to show that a medically determinable impairment significantly limits the ability to perform basic work activities.
Abdi v. Commissioner of Social Security · filed 2020-10-09(c)
At step two, a claimant must make a threshold showing that her medically determinable impairments significantly limit her ability to perform basic work activities. See Bowen v. Yuckert, 482 U.S. 137, 145 (1987); 20 C.F.R. §§ 404.1520(c), 416.920(c).Read the full opinion on CourtListener →
Section 404.1520 makes step two a threshold inquiry into whether an impairment is medically determinable and severe, and a failure to identify a standalone impairment at that step is harmless when the impairment's limitations are considered in the RFC.
Rettzo v. Berryhill · filed 2020-10-13(a)(4)
At step two of the sequential evaluation process, the ALJ considers whether a claimant’s impairment is (1) medically determinable or non-medically determinable, and (2) severe or non-severe; this step is essentially a threshold test. 20 C.F.R. § 404.1520(a)(4)(ii); SSR 85-28, 1985 WL 56856. ... Because Plaintiff’s back pain was discussed by the ALJ in his RFC assessment, I fail to see how the ALJ’s decision not to recognize it as a standalone impairment at step two resulted in any prejudice to Plaintiff. As such, I am not persuaded that remand is required for further evaluation of Plaintiff’s back pain.Read the full opinion on CourtListener →
At step two, a claimant must have a severe medically determinable impairment or combination of impairments that meets the duration requirement.
Womack v. Commissioner of Social Security · filed 2020-10-15(a)(4)(ii)
At the second step in the sequential evaluation process, a claimant must demonstrate she suffers from a “severe medically determinable physical or mental impairment that meets the duration requirement . . . or a combination of impairments that is severe and meets the duration requirement . . .” 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii); Social Security Ruling 16-3p, 2017 WL 5180304, at *11 (Oct. 25, 2017); Higgs v. Bowen, 880 F.2d 860, 863 (6th Cir. 1988) (per curiam).Read the full opinion on CourtListener →
Section 404.1520(c) requires the ALJ at step two to determine whether an impairment significantly limits the claimant’s physical or mental ability to perform basic work activities, using a de minimis severity threshold that screens out only the weakest claims.
Moskeland v. Commissioner of Social Security · filed 2020-10-22(c)
At step two of the disability analysis, the ALJ must determine whether the plaintiff has one or more severe impairments that significantly limit his or her physical or mental ability to do basic work activities. 20 C.F.R. §404.1520(c). ... The standard at step two is “de minimis and is meant only to screen out the weakest of claims.” ... Rather, “to be considered severe, an impairment or combination of impairments must cause more than minimal limitations in [a claimant’s] ability to perform work-related functions.”Read the full opinion on CourtListener →
Section 404.1520(c) requires the Commissioner to find a claimant not disabled when the claimant’s impairment does not meet the step-two severity threshold.
Tella v. Saul · filed 2020-10-26(c)
If the claimant’s impairment does not satisfy this severity threshold, however, the Commissioner must find that the claimant is not disabled. 20 C.F.R. § 404.1520(c). ... The ALJ did not err by not identifying ileus as a medically determinable or severe impairment. The findings identified by Plaintiff are qualified and do not rise to the level of objective findings of ileus.Read the full opinion on CourtListener →
Section 404.1520(c) requires the ALJ to determine whether an impairment is severe at Step Two, and failure to identify an impairment as severe is not harmless when the ALJ then fails to consider it at later steps.
Friscone-Repasky v. Commissioner of Social Security · filed 2020-10-26(c)
At Step Two of the sequential analysis, an ALJ must determine a claimant’s “severe” impairments. A severe impairment is one which significantly limits an individual’s ability to perform basic work activities. 20 C.F.R. § 404.1520(c). ... The ALJ did not discuss Plaintiff’s migraines – either as a severe impairment, or a non-severe impairment, at Step Two or any subsequent step. ... Because the ALJ did not consider Plaintiff’s migraines anywhere in the opinion (as discussed further below), the ALJ’s failure to identify them as a severe impairment at Step Two error is not harmless.Read the full opinion on CourtListener →
At step two of the sequential evaluation, § 404.1520 requires consideration of whether a claimant has a severe impairment, and the inquiry is a de minimis screen requiring an adequate explanation of the severity determination.
REILLY v. COMMISSIONER OF SOCIAL SECURITY · filed 2020-11-19(c)
“Step Two denials do not often reach this Court via the appeal process. No doubt that scarcity is attributable, in part, to the fact that “the burden placed on an applicant at step two is not an exacting one.” ... “Although the regulatory language speaks in terms of ‘severity,’ the Commissioner has clarified that an applicant need only demonstrate something beyond ‘a slight abnormality or a combination of slight abnormalities which would have no more than a minimal effect on an individual’s ability to work.’” ... “The step-two inquiry is a de minimis screening device to dispose of groundless claims.” ... Given “this limited function,” a decision to deny benefits at step two should receive “close scrutiny.” ... I am remanding in any event for a more thorough explanation of why Reilly’s conditions—either alone or in combination with one another—do or do not constitute a severe impairment.”Read the full opinion on CourtListener →
At step two, § 404.1520(a)(4)(ii) requires the Commissioner to assess impairment severity using a de minimis screen; an impairment is not severe only if it is a slight abnormality with no more than a minimal effect on an individual’s ability to work.
Spray v. Berryhill · filed 2020-11-23(a)(4)(ii)
At step two, the Commissioner considers the severity of the claimant’s impairments. 20 C.F.R. § 404.1520(a)(4)(ii). “[T]he step-two inquiry is a de minimis screening device to dispose of groundless claims.” Smolen v. Chater, 80 F.3d 1273, 1290 (9th Cir. 1996). “An impairment or combination of impairments can be found not severe only if the evidence establishes a slight abnormality that has no more than a minimal effect on an individual’s ability to work.” Id. (citation and quotation marks omitted).Read the full opinion on CourtListener →
Section 404.1520(a)(4)(ii) requires the adjudicator at step two to assess whether the claimant has a severe impairment.
Roscioli v. Saul · filed 2020-11-25(a)(4)(ii)
At step two of the five-step sequential analysis, the ALJ must assess the medical severity of a claimant’s impairments. 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii); see also Webb v. Barnhart, 433 F.3d 683, 686 (9th Cir. 2005).Read the full opinion on CourtListener →
Section 404.1520(a)(4)(ii) requires the Commissioner at step two to assess the severity of a claimant's impairments as a de minimis screen; an impairment is not severe when it has no more than a minimal effect on the claimant's ability to work.
Younger v. Saul · filed 2020-11-30(a)(4)(ii)
At step two, the Commissioner considers the severity of the claimant’s impairments. 20 C.F.R. § 404.1520 (a)(4)(ii). “[T]he step-two inquiry is a de minimis screening device to dispose of groundless claims.” Smolen, 80 F.3d at 1290. The purpose is to identify “at an early stage those claimants whose medical impairments are so slight that it is unlikely they would be disabled even if their age, education, and experience were taken into account.” Bowen v. Yuckert, 482 U.S. 137, 153, 107 S. Ct. 2287, 96 L. Ed. 2d 119 (1987). An impairment is “not severe” when the impairment would have no more than a minimal effect on a claimant’s ability to work. Webb v. Barnhart, 433 F.3d 683, 686 (9th Cir. 2005); SSR 85-28, 1985 WL 56856, at *3.Read the full opinion on CourtListener →
Section 404.1520(c) requires the ALJ at step two to determine whether a medically determinable impairment, alone or in combination, is severe, meaning it significantly limits the claimant’s ability to perform basic work activities.
Nikkila v. Saul · filed 2020-11-30(c)
At step two, the ALJ must decide whether the claimant has a medically determinable impairment that is severe or a combination of impairments that are severe. 20 CFR § 404.1520(c). ... The regulations describe “severe impairment” in the negative. “An impairment or combination of impairments is not severe if it does not significantly limit your physical or mental ability to do basic work activities.” 20 CFR § 404.1521(a). ... Thus, a severe impairment is one which significantly limits a claimant’s physical or mental ability to do basic work activities.Read the full opinion on CourtListener →
Section 404.1520(a)(4)(ii) requires the ALJ at step two to determine whether a claimant has a medically severe impairment or combination of impairments.
Stewart v. Commissioner Social Security Administration · filed 2020-12-07(a)(4)(ii)
At Step Two, the ALJ is required to determine whether a claimant has “a medically severe impairment or combination of impairments.” Smolen v. Chater, 80 F.3d 1273, 1289–90 (9th Cir. 1996) (internal citation omitted); 20 C.F.R. §§ 404.1520(a)(4) (ii), 416.920(a)(4)(ii) (1996).Read the full opinion on CourtListener →
At step two, an impairment is severe only if it significantly limits the claimant’s physical or mental ability to perform basic work activities; an error in finding some impairments non-severe is harmless when the ALJ finds at least one severe impairment and considers all impairments at later steps.
SADOWSKI v. COMMISSIONER OF SOCIAL SECURITY · filed 2020-12-14(c)
A “severe” impairment significantly limits a claimant’s physical or mental ability to perform basic work activities. 20 C.F.R. §§ 416.920(c) & 404.1520(c). An “impairment or combination of impairments” is not “severe” unless it “significantly limits [the claimant’s] physical or mental ability to do basic work activities.” See, e.g., McCrea v. Comm’r of Soc. Sec. Admin., 370 F.3d 357, 360 (3d Cir. 2004) (quoting 20 C.F.R. §§ 404.1520(c) & 416.920(c)). ... However, any error in that regard at step two was harmless. See Salles v. Comm’r of Soc. Sec. Admin., 229 F. App’x 140, 145 n.2 (3d Cir. 2007) (“Because the ALJ found in Salles’s favor at Step Two, even if he had erroneously concluded that some of her other impairments were non-severe, any error was harmless.” (citing Rutherford v. Barnhart, 399 F.3d 546, 553 (3d Cir. 2005))). Indeed, “[t]he step-two inquiry is a de minimis screening device to dispose of groundless claims.” Newell v. Comm’r of Soc. Sec. Admin., 347 F.3d 541, 546 (3d Cir. 2003). “As long as an ALJ finds at least one impairment to be severe, the ALJ considers all of a claimant’s impairments in combination—severe and non-severe—at step three.” Figueroa v. Comm’r of Soc. Sec. Admin., No. 17-8239, 2018 WL 6918869, at *3 (D.N.J. Dec. 28, 2018).Read the full opinion on CourtListener →
At step two, the ALJ must determine whether an impairment is severe, and an impairment is not severe if it does not significantly limit the claimant’s physical or mental ability to perform basic work activities.
Rosenblum v. Kijakazi · filed 2020-12-17(a)(4)(ii), (c)
“At step two, the ALJ must determine whether the claimant has an impairment, or combination of impairments, that is “severe” or “not severe.” See 20 C.F.R. § 404.1520(a)(4)(ii). An impairment is not severe if it does not significantly limit the claimant’s physical or mental ability to do basic work activities. See 20 C.F.R. § 404.1520(c). ... Given the de minimis standard applied at step two and its purpose to screen out groundless claims, and the ALJ’s heightened duty to develop the record when a claimant is unrepresented, the Court finds that the ALJ’s rejection of Plaintiff’s claim at step two was not supported by substantial evidence.”Read the full opinion on CourtListener →
At step two, a claimant must have a severe medically determinable impairment meeting the duration requirement, and finding at least one severe impairment permits the evaluation to proceed to the remaining steps.
Melloan v. Commissioner of Social Security · filed 2021-01-06(a)(4)(ii)
At the second step in the sequential evaluation process a claimant must demonstrate she suffers from a “severe medically determinable physical or mental impairment that meets the duration requirement . . . or a combination of impairments that is severe and meets the duration requirement . . .” 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii); SSR 16-3p, 2017 WL 5180304, at *11 (Oct. 25, 2017); Higgs v. Bowen, 880 F.2d 860, 863 (6th Cir. 1988) (per curiam). ... The undersigned finds it unnecessary to decide whether the ALJ erred in failing to find Plaintiff’s medically determinable impairment is severe. The Sixth Circuit has found it “legally irrelevant” that some of a claimant’s impairments are found non-severe, when other impairments are found to be severe, because a finding of severity as to even one impairment clears the claimant of step two of the analysis and the administrative law judge should consider both the severe and non-severe impairments in the remaining steps.Read the full opinion on CourtListener →
Section 404.1520(a)(4)(ii) requires the ALJ at step two to determine whether the claimant has a medically severe impairment or combination of impairments.
Donahue v. Saul · filed 2021-01-13(a)(4)(ii)
At step two, the ALJ must determine if the claimant has a medically severe impairment or combination of impairments. 20 C.F.R. § 404.1520(a)(4)(ii). ... There is no indication in the ALJ’s written decision that he considered fibromyalgia at all at step two. ... Accordingly, the Court finds that the ALJ erred at step two.Read the full opinion on CourtListener →
At step two, an impairment is severe only if it significantly limits the claimant’s physical or mental ability to do basic work activities.
(SS) Espinosa v. Commissioner of Social Security · filed 2021-01-29(c)
Under the Commissioner’s regulations, an impairment or combination of impairments is deemed to be severe at step two if it “significantly limits your physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1520(c), 404.1522(a).Read the full opinion on CourtListener →
Section 404.1520(c) requires a claimant to show at step two that the claimant’s medically determinable impairments significantly limit the ability to perform basic work activities.
Bedingfield v. Commissioner of Social Security · filed 2021-02-23(c)
At step two, a claimant must make a threshold showing that his medically determinable impairments significantly limit his ability to perform basic work activities. See Bowen v. Yuckert, 482 U.S. 137, 145 (1987); 20 C.F.R. § 404.1520(c).Read the full opinion on CourtListener →
At step two, § 404.1520(c) requires a claimant's medically determinable impairments to significantly limit basic work activities to be considered severe.
Rios v. Commissioner of Social Security · filed 2021-02-25(c)
At step two, a claimant must make a threshold showing that her medically determinable impairments significantly limit her ability to perform basic work activities. See Bowen v. Yuckert, 482 U.S. 137, 145 (1987); 20 C.F.R. §§ 404.1520(c), 416.920(c). ... “An impairment or combination of impairments can be found ‘not severe’ only if the evidence establishes a slight abnormality that has ‘no more than a minimal effect on an individual’s ability to work.’” Smolen v. Chater, 80 F.3d 1273, 1290 (9th Cir. 1996) (quoting Social Security Ruling 85-28). “[T]he step two inquiry is a de minimis screening device to dispose of groundless claims.” Id. (citing Bowen, 482 U.S. at 153-54). An ALJ is also required to consider the “combined effect” of an individual’s impairments in considering severity. Id. A diagnosis alone is not sufficient to establish a severe impairment. Instead, a claimant must show his medically determinable impairments are severe. 20 C.F.R. §§ 404.1521, 416.921.Read the full opinion on CourtListener →
At step two, § 404.1520(c) treats an impairment as not severe when it does not significantly limit a claimant’s ability to perform basic work activities.
(SS) Kendall v. Commissioner of Social Security · filed 2021-02-25(c)
“[A]n impairment is not severe if it does not significantly limit [the claimant’s] . . . ability to do basic work activities.” Smolen, 80 F.3d at 1290 (citing 20 C.F.R. §§ 404.1520(c) & 404.1521(a)).Read the full opinion on CourtListener →
Section 404.1520(c) treats step two as a threshold inquiry into whether the claimant has a severe impairment, with severity requiring more than a slight abnormality having only a minimal effect on basic work activities.
(SS) Corpuz v. Commissioner of Social Security · filed 2021-03-02(c)
At step two of the sequential evaluation, the ALJ determines which of claimant’s alleged impairments are “severe” within the meaning of 20 C.F.R. § 404.1520(c). “An impairment is not severe if it is merely ‘a slight abnormality (or combination of slight abnormalities) that has no more than a minimal effect on the ability to do basic work activities.’” Webb v. Barnhart, 433 F.3d 683, 686 (9th Cir. 2005) (quoting Social Security Ruling (“SSR”) 96–3p (1996)). The step-two severity determination is “merely a threshold determination of whether the claimant is able to perform his past work. Thus, a finding that a claimant is severe at step two only raises a prima facie case of a disability.” Hoopai v. Astrue, 499 F.3d 1071, 1076 (9th Cir. 2007).Read the full opinion on CourtListener →
Section 404.1520(c) treats an impairment as severe at step two when it significantly limits the claimant’s physical or mental ability to perform basic work activities; an omitted express severity finding may be harmless when the impairment’s limitations are considered later.
(SS) Castro v. Commissioner of Social Security · filed 2021-03-02(c)
Under the Commissioner’s regulations, an impairment or combination of impairments is deemed to be severe at step two if it “significantly limits your physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1520(c), 404.1522(a). An impairment or combination of impairments may be found “not severe only if the evidence establishes a slight abnormality that has no more than a minimal effect on an individual’s ability to work.” ... Although the ALJ should have made an express finding on the severity of plaintiff’s venous reflux at step two, his failure to do so was harmless in this case. ... Therefore, the court finds no reversible error in the ALJ’s step two analysis.Read the full opinion on CourtListener →
At step two, § 404.1520(a)(4)(ii) requires a claimant to have a severe medically determinable impairment or combination of impairments before proceeding to step three; under § 404.1520(c), severity means significantly limiting basic work activities.
(SS) Frazier v. Commissioner of Social Security · filed 2021-03-24(a)(4)(ii), (c)
At step two, the ALJ considers whether a claimant has “a severe medically determinable physical or mental impairment” or combination of such impairments that meets the regulations’ twelve-month durational requirement. 20 C.F.R. §§ 404.1509, 404.1520(a)(4)(ii). An impairment or combination of impairments is severe if it significantly limits a claimant’s physical or mental ability to undertake basic work activities. 20 C.F.R. § 404.1520(c). Progression to step three depends upon whether a claimant has a severe impairment. 20 C.F.R. § 404.1520(a)(4)(ii).Read the full opinion on CourtListener →
Section 404.1520(c) requires the ALJ at step two to determine whether an impairment lasting or expected to last at least 12 months significantly limits the claimant’s ability to perform basic work activities; an impairment that does not meet that standard is non-severe.
Southwick v. Commissioner of Social Security · filed 2021-03-28(c)
As a general matter, at Step Two of the sequential analysis, the ALJ is required to determine whether an impairment or combination of impairments that has lasted or is expected to last for a continuous period of at least 12 months limits a claimant’s physical or mental ability to perform basic work activities. See 20 C.F.R. §§ 404.1509, 404.1520(c). ... The Court does not find an error in the ALJ’s analysis at Step Two because the record does not support Plaintiff’s conclusion that her functioning in the adapting or managing herself domain was more limiting than was identified by the ALJ.Read the full opinion on CourtListener →
Section 404.1520(a)(4)(ii) requires the Commissioner at step two to screen the claimant’s impairments for severity, finding an impairment non-severe only when it has no more than a minimal effect on the claimant’s ability to work.
Robinson v. Saul · filed 2021-03-30(a)(4)(ii)
At step two, the Commissioner considers the severity of the claimant’s impairments. 20 C.F.R. § 404.1520(a)(4)(ii). “[T]he step-two inquiry is a de minimis screening device to dispose of groundless claims.” Smolen v. Chater, 80 F.3d 1273, 1290 (9th Cir. 1996). “An impairment or combination of impairments can be found not severe only if the evidence establishes a slight abnormality that has no more than a minimal effect on an individual’s ability to work.”Read the full opinion on CourtListener →
At step two, the disability analysis uses a threshold determination to screen out weak claims; the impairments considered severe at that step are not necessarily the impairments that must be included as limitations in the RFC at step four.
Ambush v. Saul · filed 2021-03-31(a)(4)(ii)
As mentioned above, at step two of the Five–Step Analysis, the Commissioner determines whether the claimant has a medically severe impairment or combination of impairments. 20 C.F.R. § 404.1520(a)(4) (2012). “Step two is merely a threshold determination meant to screen out weak claims. ... It is not meant to identify the impairments that should be taken into account when determining the RFC.” ... “At step four, on the other hand, the [Commissioner] must look to all the evidence on record and determine more precisely how, if at all, the claimant's impairments limit her ability to work.”Read the full opinion on CourtListener →
Section 404.1520(c) requires a claimant to show that medically determinable impairments significantly limit the ability to perform basic work activities at step two.
Lane v. Commissioner of Social Security · filed 2021-04-06(c)
At step two, a claimant must make a threshold showing that her medically determinable impairments significantly limit her ability to perform basic work activities. See Bowen v. Yuckert, 482 U.S. 137, 145 (1987); 20 C.F.R. §§ 404.1520(c), 416.920(c).Read the full opinion on CourtListener →
Section 404.1520(a)(4)(ii) requires the ALJ to determine at step two whether the claimant has a medically determinable impairment that is severe.
Dandridge Bacon v. Commissioner of Social Security · filed 2021-04-27(a)(4)(ii)
At step two of the sequential evaluation, the ALJ must determine if the claimant suffers from any medically determinable impairments that are “severe.” 20 C.F.R. § 404.1520(a)(4)(ii).Read the full opinion on CourtListener →
Section 404.1520(c) requires a claimant at step two to show that medically determinable impairments significantly limit the ability to perform basic work activities.
Peterson v. Commissioner of Social Security · filed 2021-04-30(c)
At step two, a claimant must make a threshold showing that her medically determinable impairments significantly limit her ability to perform basic work activities. See Bowen v. Yuckert, 482 U.S. 137, 145 (1987); 20 C.F.R. §§ 404.1520(c), 416.920(c). “Basic work activities” refers to “the abilities and aptitudes necessary to do most jobs.” 20 C.F.R. §§ 404.1522(b), 416.922(b).Read the full opinion on CourtListener →
Section 404.1520(c) requires a claimant at step two to show that medically determinable impairments significantly limit the ability to perform basic work activities.
Graham v. Commissioner of Social Security · filed 2021-05-05(c)
Plaintiff has the burden at step two to make a threshold showing her medically determinable impairments significantly limit her ability to perform basic work activities. See Bowen v. Yuckert, 482 U.S. 137, 145 (1987); 20 C.F.R. §§ 404.1520(c), 416.920(c).Read the full opinion on CourtListener →
At step two, § 404.1520(c) treats an impairment as severe when it significantly restricts the claimant’s ability to perform basic work activities.
Delano v. Commissioner of Social Security · filed 2021-05-10(c)
In general, at step two of the disability analysis, the ALJ determines whether plaintiff has an impairment, or combination of impairments, that is “severe” within the meaning of the Act, in that it imposes significant restrictions on plaintiff’s ability to perform basic work activities. 20 C.F.R. § 404.1520(c)3. The regulations define “basic work activities” as “the abilities and aptitudes necessary to do most jobs,” including mental abilities of “[u]nderstanding, carrying out, and remembering simple instructions”; “[u]se of judgment”; “[r]esponding appropriately to supervision, co-workers and usual work situations”; and “[d]ealing with changes in a routine work setting.” Id. § 404.1522(b).Read the full opinion on CourtListener →
At step two, § 404.1520(c) requires an ALJ to determine whether an impairment significantly limits a claimant’s physical or mental ability to do basic work activities.
Bonson v. Saul · filed 2021-05-12(c)
At step two of the sequential process, the ALJ must determine whether the claimant suffers from a “severe” impairment, i.e., one that significantly limits her physical or mental ability to do basic work activities. 20 C.F.R. § 404.1520(c). ... Further, even if the ALJ should have determined that Plaintiff’s spinal impairment and adjustment disorder are severe impairments, any error would be harmless because the step was resolved in Plaintiff’s favor. ... Thus, the ALJ’s step two finding is legally sufficient.Read the full opinion on CourtListener →
Section 404.1520(c) requires a claimant at step two to show that her medically determinable impairments significantly limit her ability to perform basic work activities, with severity assessed through a de minimis screening inquiry.
Wood v. Commissioner of Social Security · filed 2021-05-13(c)
At step two, a claimant must make a threshold showing that her medically determinable impairments significantly limit her ability to perform basic work activities. See Bowen v. Yuckert, 482 U.S. 137, 145 (1987); 20 C.F.R. §§ 404.1520(c), 416.920(c). “Basic work activities” refers to “the abilities and aptitudes necessary to do most jobs.” 20 C.F.R. §§ 404.1522(b), 416.922(b). “An impairment or combination of impairments can be found ‘not severe’ only if the evidence establishes a slight abnormality that has ‘no more than a minimal effect on an individual’s ability to work.’” Smolen v. Chater, 80 F.3d 1273, 1290 (9th Cir. 1996) (quoting Social Security Ruling (SSR) 85-28). “[T]he step two inquiry is a de minimis screening device to dispose of groundless claims.” Smolen, 80 F.3d at 1290. An ALJ is also required to consider the “combined effect” of an individual’s impairments in considering severity. Id.Read the full opinion on CourtListener →
At step two, § 404.1520(c) requires the ALJ to determine whether an established impairment significantly limits the claimant’s ability to perform basic work activities.
Carter v. Commissioner of Social Security · filed 2021-05-14(c)
At step two of the sequential process, the ALJ must determine whether there is a medically determinable impairment established by objective medical evidence from an acceptable medical source. 20 C.F.R. § 404.1521. A statement of symptoms, a diagnosis, or a medical opinion does not establish the existence of an impairment. Id. After a medically determinable impairment is established, the ALJ must determine whether the impairment is “severe;” i.e., one that significantly limits his or her physical or mental ability to do basic work activities. 20 C.F.R. § 404.1520(c).Read the full opinion on CourtListener →
At step two, a claimant must show that a medically determinable impairment significantly limits the ability to perform basic work activities.
Eidson v. Commissioner of Social Security · filed 2021-05-18(c)
At step two, claimants must make a threshold showing that their medically determinable impairments significantly limit their ability to perform basic work activities. See Bowen v. Yuckert, 482 U.S. 137, 145 (1987); 20 C.F.R. §§ 404.1520(c), 416.920(c).Read the full opinion on CourtListener →
Section 404.1520(c) requires the ALJ at step two to determine whether the claimant has an impairment or combination of impairments that significantly limits the ability to perform basic work activities.
Bathgate v. Saul · filed 2021-05-18(c)
At step two of the sequential analysis, the ALJ must determine whether the claimant has “any impairment or combination of impairments which significantly limits [his] physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1520(c), 416.920(a). ... Overall, the ALJ provided sufficient reasoning for finding plaintiff’s left thumb osteoarthritis and avascular necrosis to be nonsevere by discussing plaintiff’s record surrounding these conditions. The ALJ also included limitations in plaintiff’s RFC due to her avascular necrosis. Therefore, I conclude that substantial evidence supports the ALJ’s conclusion that these conditions are nonsevere.Read the full opinion on CourtListener →
Section 404.1520(c) requires a claimant at step two to show that medically determinable impairments significantly limit the ability to perform basic work activities.
Lozano v. Commissioner of Social Security · filed 2021-05-19(c)
At step two, a claimant must make a threshold showing that his medically determinable impairments significantly limit his ability to perform basic work activities. See Bowen v. Yuckert, 482 U.S. 137, 145 (1987); 20 C.F.R. §§ 404.1520(c), 416.920(c). “Basic work activities” refers to “the abilities and aptitudes necessary to do most jobs.” 20 C.F.R. §§ 404.1522(b), 416.922(b).Read the full opinion on CourtListener →
At step two, an impairment is severe only if it significantly limits a claimant’s physical or mental ability to do basic work activities.
Sullins v. Commissioner of the Social Security Administration · filed 2021-05-27(c)
But in this case, none of the medical evidence supports any identifiable limitations caused by either of these impairments, much less limitations that would make either condition a “severe” limitation—that is, one that “significantly limits [a claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c).Read the full opinion on CourtListener →
Notes 1651–1800 of 6,452, oldest cases first.
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