20 C.F.R. § 404.1520

At step two, a claimant must show a severe impairment that significantly limits the ability to perform basic work activities.

Dean v. Commissioner of Social Security · filed 2021-06-02(c)

At step two of the disability analysis, the ALJ must determine whether the plaintiff has a severe impairment that significantly limits 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.”

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.

Winter v. Commissioner of Social Security · filed 2021-06-09(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).

At step two, a claimant must show that medically determinable impairments significantly limit the ability to perform basic work activities.

Bentley v. Commissioner of Social Security · filed 2021-06-11(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).

Section 404.1520(c) requires the ALJ at step two to determine whether a medically determinable impairment is severe because it significantly limits basic work activities.

Afton v. Commissioner of Social Security · filed 2021-06-15(c)

“At step two of the sequential evaluation process, the ALJ must determine whether the claimant has a severe impairment that significantly limits his or her physical or mental ability to do basic work activities.” Henderson v. Comm’r of Soc. Sec., No. 18-cv-00072, 2019 WL 3237343, 2019 U.S. Dist. LEXIS 119834, *8 (W.D.N.Y. July 18, 2019), citing 20 C.F.R. §§ 404.1520(c), 416.920(c) (internal citation omitted). It is the claimant’s burden at Step Two to establish that he has a medically determinable impairment and that the impairment is severe. ... “[T]he standard for a finding of severity under Step Two of the sequential analysis is de minimis and is intended only to screen out the very weakest cases.” ... Contrary to the Commissioner’s position, the ALJ did not determine whether Claimant’s hypertension, diabetes mellitus, or coronary artery disease were severe under the regulations. ... Upon remand, the ALJ shall properly consider all the evidence of record; formulate a new Step Two severity determination, including whether Claimant’s hypertension, diabetes mellitus, and coronary artery disease are severe; consider both severe and non-severe impairments when formulating Claimant’s RFC; weigh the significance, if any, of Claimant’s death certificate; and further develop the record if it is deemed incomplete.

Section 404.1520(c) requires the Commissioner at step two to find an impairment nonsevere only when it has no more than a minimal effect on the claimant’s ability to work.

Graham v. Kijakazi · filed 2021-06-22(c)

At this step, the Commissioner considers the severity of the claimant’s impairment. 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii). If the claimant suffers from “any impairment or combination of impairments which significantly limits [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). ... Here, the ALJ is applying the incorrect standard at step two: that since Plaintiff’s mental health impairments were not work preclusive, they are not severe. The correct standard is “[a]n 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, 80 F.3d at 1290. As such, the ALJ will readdress his step two determination regarding Plaintiff’s mental health impairments at step two.

Section 404.1520(c) requires the ALJ to treat an impairment as severe only when it significantly limits the claimant’s physical or mental ability to perform basic work activities.

Weeks v. Saul · filed 2021-06-30(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). ... Plaintiff has not met her burden in demonstrating her impairments are severe nor that the ALJ harmfully erred in finding the impairments non-severe.

Section 404.1520 requires an ALJ to classify impairments as severe or non-severe at step two, and a severe impairment is one that significantly limits the ability to perform basic work activities.

(SS) Martinez v. Commissioner of Social Security · filed 2021-07-02(c)

Under step two, the ALJ is to classify any impairments as either “severe” or “non–severe.” See 20 C.F.R. § 404.1520. 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 two assessment is a “de minimus screening to dispose of groundless claims.” Edlund v. Massanari, 253 F. 3d 1152, 1158 (9th Cir. 2001). Here, the ALJ identified pla intiff’s migraines as non-severe, reasoning that they had been treated with over-the-counter medications only. (AT 26.) ... Thus, the ALJ did not take into consideration plaintiff’s migraines beyond step two. (Id.) ... Given the plain error on the ‘no-prescription’ finding and the lack of articulation on the latter medical records, the case must be remanded to the ALJ for further consideration of plaintiff’s migraine issue.

Section 404.1520 requires disability claims to be evaluated through a sequential five-step process, including deciding at step two whether the claimant has a severe impairment.

Marjama v. Commissioner Social Security Administration · filed 2021-07-08(c)

The Commissioner has established a five-step process for determining whether a person is disabled. Bowen v. Yuckert, 482 U.S. 137, 140 (1987); 20 C.F.R. §§ 404.1520, 416.920. ... At step two, the Commissioner determines whether the claimant has a “medically severe impairment or combination of impairments.” Yuckert, 482 U.S. at 140–41; 20 C.F.R. §§ 404.1520(c), 416.920(c). A severe impairment is one “which significantly limits [the claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1520(c) & 416.920(c). ... As such, the Court finds that the ALJ harmfully erred by failing to include Plaintiff’s migraines among her severe impairments at step two.

Section 404.1520(c) requires the Commissioner to treat an impairment as severe when it significantly limits a claimant’s physical or mental ability to do basic work activities.

Rodriguez v. Kijakazi · filed 2021-07-12(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). ... The medical records indicate on multiple occasions that Plaintiff’s hypertension was stable and well-controlled. Tr. 335, 338, 466. Plaintiff reported at an appointment that her lightheadedness resolved with a decreased dosage of her medication. Tr. 354. Plaintiff cites to her self-report, and does not cite to objective evidence of her hypertension causing limitations that were not accounted for in the RFC. ECF No. 17 at 4-6. As such, Plaintiff has not demonstrated the ALJ harmfully erred at step two by finding hypertension is a non-severe impairment.

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.

Melton v. Commissioner of Social Security · filed 2021-07-13(c)

At step two, a claimant must make a threshold showing that his or her medically determinable impairments significantly limit his or 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).

At step two, an impairment is severe only if it significantly limits the claimant’s ability to perform basic work activities, and the claimant’s burden is easy to meet but not toothless.

Reijo v. Kijakazi · filed 2021-07-14(a)(4)(ii), (c)

At the second step of the analysis, the SSA considers “the medical severity of [a claimant’s] impairment(s).” 20 C.F.R. § 404.1520(a)(4)(ii). ... An impairment is not severe if it does not significantly limit a claimant’s physical or mental ability to do basic work activities. See id. at 707; 20 C.F.R. § 404.1520(c). The severity showing “is not an onerous requirement for the claimant to meet, but it is also not a toothless standard.”

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 at step two.

Gaddis v. Commissioner of Social Security · filed 2021-07-19(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.

Section 404.1520(c) requires an ALJ at step two to determine whether an impairment or combination of impairments is severe, meaning it significantly limits basic work activities.

Paris v. Social Security Administration · filed 2021-07-20(c)

At step two of the sequential evaluation process, the ALJ must determine whether the claimant has a medically determinable impairment that is “severe” or a combination of impairments that is “severe.” 20 CFR § 404.1520(c). An impairment or combination of impairments is “severe” within the meaning of the Regulations if it significantly limits a claimant’s physical or mental ability to perform basic work activities; conversely, an impairment is not severe if it does not significantly limit a claimant’s physical or mental ability to do basic work activities. Id.; 20 CFR §§404.1521(a), 416.920(c), 416.921(a).

Section 404.1520(c) treats an impairment as severe only if it significantly limits the claimant’s ability to perform basic work activities; step two is a de minimis screening device.

Anderson v. Commissioner of Social Security Administration · filed 2021-07-27(c)

The Ninth Circuit has characterized the step-two severity requirement as a “de minimis screening device” designed to weed out “groundless claims.” Smolen v. Chater, 80 F.3d 1273, 1290 (9th Cir. 1996). An impairment is not severe if it does not significantly limit the claimant’s ability to do basic work activities. 20 C.F.R. § 404.1520(c). “Basic work activities are ‘abilities and aptitudes necessary to do most jobs, including, for example, walking, standing, sitting, lifting, pushing, pulling, reaching, carrying or handling.’” Smolen, 80 F.3d at 1273 (citation omitted). Only if the evidence establishes a “slight abnormality” that has “no more than a minimal effect on [an individual’s] ability to work” should the inquiry end at step two.

Section 404.1520(c) requires an impairment to significantly affect a claimant’s ability to perform work-related activities to be considered severe at step two.

Turner v. Kijakazi (CONSENT) · filed 2021-07-30(c)

An impairment is severe if it significantly affects a claimant’s ability to perform work-related activities, irrespective of age, education, and work experience. See 20 C.F.R. §§ 404.1520(c), 404.1521(a); Bridges v. Bowen, 815 F.2d 622, 625 (11th Cir. 1987). ... Here, substantial evidence supports the ALJ’s finding that Plaintiff’s chronic pain syndrome, sleep apnea, spinal cord disease, memory impairment, vision problems, and tremor were not severe. ... Upon review here, the Court finds that, regardless of how the ALJ phrased her findings, she applied the correct legal standard. She determined that Plaintiff’s conditions did not and do not inhibit her ability to perform basic work activities for a continuous period of 12 months (in either the past or the future), and substantial evidence supports that determination.

At step two, § 404.1520 requires the analysis to proceed when an impairment significantly limits basic work activities; if the impairment does not satisfy that severity threshold, the claimant is not disabled.

Tabayoyon v. Kijakazi · filed 2021-07-30(a)(4)(ii), (c)

If the claimant is not engaged in substantial gainful activity, the analysis proceeds to step two. At this step, the Commissioner considers the severity of the claimant’s impairment. 20 C.F.R. § 404.1520(a)(4)(ii). 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). 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).

Section 404.1520(a)(4) requires the ALJ at step two to assess the medical severity of the claimant’s impairments and determine whether a severe impairment or combination of impairments satisfies the duration requirement.

Groomes v. Social Security Administration · filed 2021-08-04(a)(4)

At step two, the ALJ must “consider the medical severity of [the claimant’s] impairment(s). If [the claimant] do[es] not have 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, we will find that [the claimant is] not disabled.” 20 C.F.R. § 404.1520(a)(4); id. § 416.920(a)(4).

Section 404.1520(c) treats an impairment as severe when it limits an individual’s ability to perform basic work activities.

Dane v. Commissioner, SSA · filed 2021-08-10(c)

Under the regulations, an impairment or combination of impairments is “severe” when it meets the threshold of limiting an individual’s ability to perform basic work activities. 20 C.F.R. §§ 404.1520(c), 416.920(c).

Section 404.1520(c) requires the claimant at step two to show a severe impairment that significantly limits the ability to perform basic work activities, and the court applied that standard to headaches.

Szymkowiak v. Commissioner of Social Security · filed 2021-08-12(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.); see 20 C.F.R. §§ 404.1520(c), 416.920(c). ... Review of the evidence indicates that Plaintiff met the de minimis standard for Step Two for headaches to be deemed a severe impairment. ... This case is remanded for the ALJ to reconsider the Step Two analysis and to incorporate headaches in the subsequent steps of the analysis.

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.

Blue v. Commissioner of Social Security · filed 2021-08-17(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).

Section 404.1520(c) permits rejecting a disability claim at step two only when the claimant has no impairment or combination of impairments that significantly limits basic work activities.

Latta v. Commissioner of Social Security · filed 2020-08-20(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). ... Here, there is substantial evidence in the record that Latta suffers from bulimia nervosa. ... But the ALJ failed to explain why he did not consider Latta’s bulimia to be severe. Even worse, the ALJ never even mentioned bulimia nervosa in his step two analysis. ... Thus, this Court agrees with Latta that the ALJ erred at step two. ... Thus, this Court finds that although the ALJ erred at step two, the error was harmless.

Section 404.1520(a)(4)(2) requires the Commissioner to consider the medical severity of the claimant’s impairments at step two of the sequential evaluation.

Lozada v. Commissioner of Social Security · filed 2020-09-04(a)(4)(2)

At step two of the sequential evaluation, the Commissioner “consider[s] the medical severity of [the claimant’s] impairment(s).” 20 C.F.R. § 404.1520(a)(4)(2). If the Commissioner fails to consider an impairment at step two, the error may be harmless if the Commissioner continues through the remaining steps and considers the impairment that was omitted at step two.

Section 404.1520(c) requires the ALJ to determine at step two whether an impairment or combination of impairments is severe; if it is not severe, the disability analysis ends with a finding of not disabled.

Walter v. Commissioner of Social Security · filed 2020-09-04(c)

At step one, the ALJ must determine whether the claimant is engaged in substantial gainful work activity. See 20 C.F.R. § 404.1520(b). If so, the claimant is not disabled. If not, the ALJ proceeds to step two and determines whether the claimant has an impairment, or combination of impairments, that is “severe” within the meaning of the Act, meaning that it imposes significant restrictions on the claimant’s ability to perform basic work activities. 20 C.F.R. § 404.1520(c). If the claimant does not have a severe impairment or combination of impairments, the analysis concludes with a finding of “not disabled.” If the claimant does, the ALJ continues to step three. ... Accordingly, the ALJ did not commit reversible error in declining to find that Plaintiff’s GERD, status post fracture of the right clavicle, and chronic back pain were severe impairments.

At step two, § 404.1520(c) requires determining whether an impairment or combination significantly limits the claimant’s ability to perform basic work activities, without considering age, education, or work experience.

Medved v. Saul · filed 2020-09-29(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). At step two, the claimant must show he has an impairment or combination of impairments that significantly limits his ability to work in most jobs. See Bowen v. Yuckert, 482 U.S. 137, 146 (1987) (quoting 20 C.F.R. §§ 404.1520(c), 404.1521(b)). To rise to the level of “severe,” the impairment must have lasted or be expected to last for a continuous period of at least 12 months. See 20 C.F.R. § 404.1509. A claimant’s “age, education, and work experience” are not relevant to the step two inquiry. See 20 C.F.R. § 404.1520(c). Instead, “medical evidence alone is evaluated in order to assess the effects of the impairment(s) on ability to do basic work activities.” SSR 85-28, 1985 WL 56856, at *4 (S.S.A. 1985). 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, 482 U.S. at 153. 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.

Section 404.1520(c) treats an impairment as severe only when it significantly limits basic work activities; an impairment causing no more than a minimal effect is not severe.

Bruegeman v. Saul · filed 2021-03-01(c)

To be considered ‘severe’ at step two of the sequential analysis, an impairment must significantly limit an individual’s ability to perform basic work activities. 20 C.F.R. §§ 404.1520(c), 416.920(c); see also Smolen v. Chater, 80 F.3d 1273, 1290 (9th Cir.1996). An impairment that is ‘not severe’ must be a slight abnormality (or a combination of slight abnormalities) that has no more than a minimal effect on the ability to do basic work activities. S.S.R. 85-28, available at 1985 WL 56856, at *3.

At step two, § 404.1520(a)(4)(ii) requires the Commissioner to determine whether the claimant’s impairment or combination of impairments is severe, applying a de minimis threshold that excludes only slight abnormalities with no more than a minimal effect on the ability to work.

Bruton v. Saul · filed 2021-03-29(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).1 “[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). Nonetheless, “[t]he claimant [still] carries the initial burden of proving a disability.” Burch v. Barnhart, 400 F.3d 676, 679 (9th Cir. 2005).

Section 404.1520(a)(4) requires the ALJ at step two to assess the medical severity of the claimant’s impairments and find no disability if there is no severe impairment or severe combination meeting the duration requirement.

Groomes v. Social Security Administration · filed 2021-07-27(a)(4)

At step two, the ALJ must “consider the medical severity of [the claimant’s] impairment(s). If [the claimant] do[es] not have 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, we will find that [the claimant is] not disabled.” 20 C.F.R. § 404.1520(a)(4); id. § 416.920(a)(4).

Section 404.1520 requires a step-two severity assessment and requires the ALJ to account for limitations from all impairments, including those found non-severe, when formulating the RFC.

Lesoing v. Commissioner of Social Security · filed 2021-11-05(a)(4)(ii), (c), (e)

At step two, the “medical severity” of a claimant’s impairments is considered. 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); Social Security Ruling (SSR) 96-3p, 1996 WL 374181, at *1. ... The ALJ must consider all limitations and restrictions when formulating the RFC, even those stemming from impairments that are not “severe.” See Buck v. Berryhill, 869 F.3d 1040, 1049 (2017); 20 C.F.R. § 404.1520(e).

At step two, an impairment need not be found severe, but the ALJ must still consider evidence of non-severe impairments when formulating the claimant’s RFC.

Garcia v. Commissioner of Social Security · filed 2022-01-27(a)(4)(ii)

Prior to formulating a claimant’s RFC, the ALJ considers the medical severity of a claimant’s impairments. 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii). ... While an ALJ need not determine that every impairment is severe, an ALJ must consider all the record evidence, including evidence of non-severe impairments, in making the RFC determination. ... Based on the ALJ’s acknowledgment and review of Plaintiff’s mental health history, substantial evidence supports the ALJ’s decision to not include mental limitations in Plaintiff’s RFC.

Under the sequential evaluation, functional limitations from impairments found non-severe at step two must still be considered at steps three, four, and five, including in the RFC assessment.

BEARY v. COMMISSIONER OF SOCIAL SECURITY · filed 2022-01-28(a)(4)(ii)

The Court agrees, and Plaintiff is correct that her “[f]unctional limitations caused by all impairments, whether found to be severe or non-severe at [S]tep [T]wo, must be taken into consideration at steps three, four and five of the sequential evaluation.” ... On remand, the ALJ shall revisit the RFC assessment and discuss whether or not additional limitations should be included based on the evidence in the record concerning Plaintiff’s OSA, neck/cervical strain, and bilateral carpal tunnel syndrome, even if such impairments are “non-severe” at Step Two.

At step two, the regulation requires the ALJ to determine whether an impairment is severe, and the sequential evaluation should continue when the impairment's effect on basic work activities cannot be clearly determined; the ALJ must also consider non-severe impairments when assessing residual functional capacity.

Khadivi v. Kijakazi · filed 2022-09-09(a)(4)(ii), (c), (e)

At step two, which is at issue in this matter, the ALJ determines whether the individual has an impairment or combination of impairments that is “severe.” Id. § 404.1520(a)(4)(ii), (c).3 An impairment or combination of impairments is considered “severe” if it “significantly limits [an individual’s] physical or mental ability to do basic work activities.” ... At a minimum, the record presents contradictory evidence of whether Plaintiff’s migraines are severe. Thus, the ALJ could not “determine clearly” the effect of Plaintiff’s migraines and should have continued the sequential evaluation process related thereto. ... By concluding the analysis of Plaintiff’s migraines at step two, the ALJ failed to comply with SSR 85-28, and thus, committed legal error requiring reversal and remand.

Section 404.1520 requires the ALJ to consider relevant evidence when evaluating impairment severity and to account for nonsevere impairments in later steps.

Trent v. SSA · filed 2021-01-19(a)(3)

The problem is, nowhere in the ALJ’s decision does he consider Trent’s non-severe depression and anxiety during later steps, as required by SSA regulations.

Section 404.1520(c) requires an ALJ at step two to evaluate all of a claimant’s impairments, including those deemed severe and non-severe.

Williams v. Commissioner Social Security Administration · filed 2020-06-11(c)

At step two, an ALJ must evaluate all of a claimant’s impairments, both severe and non-severe. 20 C.F.R. §§ 404.1520(c), 916.920(c). ... Thus, for the reasons explained above, the ALJ did not err in assessing Plaintiff’s PTSD, depressive disorder, or costochondritis at step two.

Section 404.1520 requires the Commissioner to assess whether a claimant has a severe impairment at step two, but an erroneous non-severity finding is harmless when the analysis continues and all impairments are considered in the residual functional capacity.

Murphy v. Commissioner Social Security Administration · filed 2025-01-15(a)(4)(ii), (c)

At step two, the ALJ determines “whether the claimant had severe impairments during the period for which he seeks disability benefits.” ... An impairment is severe “if it ‘significantly limits’ an individual’s ‘ability to do basic work activities.’” ... Step two errors are harmless so long as the ALJ found at least one severe medically determinable impairment, the sequential process proceeded to step three, and the ALJ included limitations due to all the medically determinable impairments, severe and non-severe, in formulating the claimant's residual functional capacity. ... Thus, even if the ALJ erroneously finds that particular impairments are non-severe at step two, the error is harmless so long as the ALJ considers all of the claimant's severe and non-severe impairments at subsequent steps of the analysis. ... Because step two was resolved in Plaintiff’s favor, and because the ALJ continued with the sequential analysis, any error at step two was harmless.

Under § 404.1520, an ALJ’s failure to identify an impairment at step two can be harmless when the ALJ considers its effects later in the sequential evaluation.

Bright v. Kijakazi · filed 2022-07-11(c)

The ALJ’s continuation of the sequential analysis, during which she considered the symptom of frequent urination, also rendered any error at step two harmless.

An ALJ’s failure to identify an impairment at step two is not reversible error when the ALJ identifies other severe impairments and considers the omitted impairment at later steps.

Zeler v. Commissioner of Social Security · filed 2023-03-10(a)(4)(ii)

Based on the circumstances of the present case, the Court disagrees with Claimant’s argument that the ALJ’s failure to expressly consider Claimant’s cervical spine impairment at step two of the sequential evaluation process constitutes reversible legal error. Although the ALJ did not identify Claimant’s cervical spine as a medically determinable impairment at step two, as indicated above, the ALJ did identify several other “severe impairments,” including myalgia, spondylosis of the spine with radiculopathy, and fibromyalgia. Tr. 23. Consequently, the ALJ proceeded with the subsequent steps of the five step sequential evaluation process, where he specifically considered the findings of Claimant’s January 2020 cervical spine MRI (Tr. 32), and her visit to Dr. Hsu in June 2020 (Tr. 33) in the context of a thorough review of the record evidence between her termination of employment in 2016 and the date of the ALJ’s decision. See Tr. 28–33.

A step-two impairment classification error is harmless when the claimant identifies no resulting functional limitations omitted from the later analysis.

Griffith v. Kijakazi · filed 2023-03-20(a)(4)(ii)

Therefore, because Griffith does not point to any functional limitations related to the emphysema and Chiari malformation, other than the headaches and cognitive issues recognized, any error related to the Chiari malformation itself would be harmless.

At step two, misclassifying an impairment does not require remand when the ALJ finds another severe impairment and still analyzes the claimant’s functional limitations.

ROBINSON · filed 2025-11-25(a)(4)(ii)

In the instant matter, the misclassification as a symptom rather than standalone diagnosis did not deprive Plaintiff of any functional analysis. The ALJ still found Step Two in Plaintiff’s favor, making any deficiencies in his chronic fatigue analysis irrelevant and does not, on its own, warrant remand.

An error in identifying an impairment as severe at step two is harmless when the ALJ finds other severe impairments and continues the sequential evaluation.

Murray v. Commissioner Social Security Administration · filed 2017-01-04(a)(4)(ii)

Here, the ALJ resolved step two in Plaintiffs favor, finding other severe impairments and continuing with the sequential evaluation. ... In short, even if the ALJ erred in failing to identify depression and anxiety as severe, the error is harmless.

Section 404.1520’s step-two screening does not require remand for an omitted impairment when the claimant advances beyond step two and the ALJ considers the impairment in assessing residual functional capacity.

Winchel v. Commissioner of Social Security · filed 2020-07-24(a)(4)(ii)

Step two was decided in Plaintiff’s favor following two hearings, sending Plaintiff for additional testing, and taking the testimony of a psychological expert. Additionally, the ALJ addressed the somatization disorder diagnosis when discussing the RFC determination. Therefore, Plaintiff could not have been prejudiced as any alleged error is harmless and cannot be a basis for remand.

An error at step two is harmless when the ALJ proceeds to later steps rather than denying benefits at step two.

Palmer v. Social Security Administration · filed 2024-03-07(c)

Regardless, any error committed by the ALJ at this step is harmless, as he proceeded through steps three and four, suggesting that Plaintiff’s benefits could not properly be denied at step two.

At step two, failing to classify an impairment as severe is harmless when the ALJ finds other severe impairments and proceeds to step three.

Faiz v. Commissioner of Social Security · filed 2024-03-11(a)(4)(ii)

With this standard in mind, even if the ALJ should have characterized Plaintiff’s mental impairments as severe, any error is harmless because the ALJ characterized other impairments – degenerative disc disease, fibromyalgia, migraines, and obesity – as severe.

A failure to classify an impairment as severe at step two is harmless when the ALJ considers its limitations at step four.

(SS)Schmitzer v. Commissioner of Social Security · filed 2024-03-12(c)

Because the ALJ considered Plaintiff’s fatigue limitation at step four, any error resulting from the non-inclusion of MCAS at step two is harmless.

An error in classifying an impairment at step two is harmless when the claimant passes that step and the sequential analysis continues.

Lomax v. Commissioner Social Security Administration · filed 2024-04-16(a)(4)(ii)

Because step two was resolved in plaintiff’s favor, and because the ALJ continued with the sequential analysis, any error at step two was harmless.

An ALJ’s failure to identify an impairment as severe at Step Two does not require reversal if the ALJ continues the sequential analysis and properly evaluates all impairments.

Spielberg v. SSA · filed 2011-10-18(e)

Even if the ALJ erred by omitting fibromyalgia as a severe impairment at Step Two, the error does not require reversal as long as it did not prejudice the outcome. ... Therefore, if the ALJ found any severe impairment at Step Two, continued through the sequential analysis, and properly evaluated all impairments for purposes of the disability determination, the decision will not be reversed.

Section 404.1520 requires the ALJ to assess impairment severity at step two; failing to identify an additional severe impairment is harmless when the ALJ proceeds to later steps and considers all impairments.

Besso v. Commissioner of Social Security · filed 2020-03-17(a)(4)(ii)

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). ... Any error in failing to find that Plaintiff suffers from additional severe mental health impairments would be harmless.

An ALJ’s failure to designate an impairment as severe at step two may be harmless if the ALJ considers its functional limitations in the remaining steps.

Freeborn v. Colvin · filed 2020-11-10(c)

Failure to designate an impairment as severe at step two may be harmless if the ALJ incorporates the functional limitations from that impairment in the remaining steps of the evaluation. ... Accordingly, the Court finds the ALJ’s error for failing to include fibromyalgia in step two is harmless.

An ALJ’s failure to identify additional severe impairments at step two is harmless when the ALJ finds at least one severe impairment and continues the evaluation.

Cresap v. Social Security Administration · filed 2022-09-02(a)(4)(ii)

Because the ALJ found Plaintiff had severe impairments at step two and proceeded to the subsequent steps of his analysis, any failure in identifying additional severe impairments does not constitute reversible error.

An ALJ’s failure to classify chronic pain as a medically determinable impairment at step two is harmless when the ALJ considers the pain at later steps and the claimant shows no prejudice.

Wilson v. Comissioner of Social Security · filed 2024-02-01(a)(4)(ii)

But, even beyond the rules of logic, Plaintiff’s argument ignores the fact that the record, as thoroughly explicated by Judge Harvey, shows that the ALJ did, indeed, consider the evidence at issue at steps four and five. ... Plaintiff’s argument that she was prejudiced because the ALJ did not consider her chronic pain after step two is therefore unpersuasive.

Under § 404.1520, omitting an impairment at step two is harmless when the ALJ finds another severe impairment, continues the evaluation, and considers the omitted condition’s functional limits.

FREDMAN v. COMMISSIONER OF SOCIAL SECURITY · filed 2025-07-31(a)(4)(ii)

Here, the ALJ found that Plaintiff had severe impairments during the relevant period in step two and continued to step three, rendering any deficiency at step two harmless.

When an ALJ finds at least one severe impairment and continues the sequential evaluation, an error in classifying another impairment at step two is harmless if the ALJ considers it at later steps.

Saxey v. Bisignano · filed 2025-09-15(a)(4)

Under these circumstances, where the ALJ proceeded beyond step two and adequately considered Mr. S.’s knee impairment at subsequent steps, any error at step two was harmless.

Section 404.1520(a)(4)(ii) requires an impairment to be medically determinable before it can be treated as severe.

Muniz v. Commissioner of Social Security · filed 2020-03-23(a)(4)(ii)

But the ALJ provided specific and valid reasons which are supported by the record for discounting the VA’s rating when he determined the vast majority of impairments the VA considered in its disability rating were either not medically determinable or were effectively controlled with medication. See 20 C.F.R. § 404.1520(a)(4)(ii) (an “impairment” must be “medically determinable” to be “severe”); see also Rebensdorf v. Berryhill, 773 F. Appx 874, 877 (9th Cir. 2019) (it is appropriate for an ALJ to assign little weight to a VA rating if the claimant’s symptoms are controlled with medication).

At step two, § 404.1520(a)(4)(ii) requires a claimant to show a medically determinable impairment that significantly limits the claimant’s physical or mental ability to do basic work activities.

Mendoza-Arias v. Commissioner Social Security Administration · filed 2019-09-27(a)(4)(ii)

The ALJ did not err at step two by failing to find a severe, medically determinable cognitive impairment. At step two, Plaintiff carries the burden of showing that she has a medically determinable impairment that “significantly limits [her] physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1520(a)(4)(ii), 404.1520(c); see also Burch v. Barnhart, 400 F.3d 676, 679 (9th Cir. 2005).

Section 404.1520(a)(4)(ii) requires the ALJ at step two to consider whether alleged impairments are medically determinable, and a general severe-impairment finding may encompass a related diagnosis.

Huffstetler v. Social Security Administration, Commissioner of · filed 2019-09-30(a)(4)(ii)

At step two, the ALJ is required to consider whether Plaintiff’s alleged impairments constitute “medically determinable” impairments. See 20 C.F.R. §§§ 404.1508; 416.920(a)(4)(ii); 404.1520(a)(4)(ii). ... Accordingly, the Court finds that the ALJ’s determination that Plaintiff’s peripheral neuropathy constituted a severe impairment appropriately encompassed her consideration of Plaintiff’s carpal tunnel syndrome as a medically determinable impairment at step two.

Section 404.1520 requires an ALJ to consider the medical severity of a claimant’s impairments at step two, and an impairment is severe when it significantly limits the claimant’s physical or mental ability to do basic work activities.

BECKER v. COMMISSIONER OF SOCIAL SECURITY · filed 2019-10-01(a)(4)(ii), (c)

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). The severe impairment “must have lasted or must be expected to last for a continuous period of at least twelve months.” 20 C.F.R. § 404.1509. 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).

At step two, § 404.1520(a)(4)(ii) is a de minimis screening test for severity, and finding an impairment severe does not establish limitations in every basic work activity.

DICIANO v. COMMISSIONER OF SOCIAL SECURITY · filed 2019-12-09(a)(4)(ii)

The limitations of a severe impairment must be supported by record evidence, and simply because an impairment is deemed “severe” at step two does not compel the finding that the impairment causes limitations in every basic work activity. See McCrea v. Comm’r of Soc. Sec., 370 F.3d 357, 360–61 (3d Cir. 2004) (citing 20 C.F.R. § 404.1520(a)(4)(ii)) (explaining that at step two, the ALJ has to “consider the medical severity of a claimant’s impairment(s),” and that the “severity test at step two is a ‘de minimis screening device to dispose of groundless claims.’”).

Section 404.1520(c) defines a severe impairment as one that significantly limits a claimant’s physical or mental ability to do basic work activities.

Mucilli v. Commissioner, Social Security Administration · filed 2019-12-16(c)

An impairment is “severe” if it “significantly limits [a claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c)[; see also 20 C.F.R. § 416.920(c)]. ... Thus, the failure to find a particular impairment severe at step two is not reversible error when the ALJ finds that at least one other impairment is severe. Here, the ALJ found six other impairments severe. ... In the instant case, the ALJ found three other impairments to be severe. Tr. 17. Thus, the ALJ found that Plaintiff could not conclusively be denied benefits at step two and proceeded to steps three and four of her analysis. Thus, Plaintiff’s argument that the ALJ erred at step two “fails as a matter of law.” Allman, 813 F.3d at 1330.

At step two, an impairment is severe when it significantly limits the claimant's physical or mental ability to perform basic work activities.

Brood v. Commissioner Social Security Administration · filed 2019-12-20(c)

The ALJ considers the severity of the claimant's impairment(s) at step two. 20 C.F.R. § 404.1520(a)(4)(ii). A severe impairment is one which significantly limits the claimant's physical or mental ability to do basic work activities. 20 C.F.R. § 404.1520(c).

Section 404.1520(c) defines a severe impairment as one that significantly limits a claimant’s physical or mental ability to perform basic work activities.

(SS) Swahn v. Commissioner of Social Security · filed 2020-01-16(c)

Under step 2, the ALJ is to classify any impairments as either “severe” or “non–severe.” ... 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). ... However, the ALJ discussed these conditions when he formulated and justified Plaintiff’s RFC. (See AT 24–29.) Therefore, any failure to classify these conditions at step 2 was harmless. Lewis, 498 F.3d at 911.

At step two, an impairment is severe only if it significantly limits a claimant’s physical or mental ability to do basic work activities.

Sullivan v. Commissioner of Social Security Administration · filed 2020-01-07(c)

An impairment is “severe” if it “significantly limits [the claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1520(c), 416.920(c).

Section 404.1520(c) treats an impairment as severe at step two when it significantly limits a claimant’s physical or mental ability to perform basic work activities.

(SS) Alva v. Commissioner of Social Security · filed 2020-01-22(c)

An impairment or combination of impairments is deemed to be severe at step two if it “significantly limits [plaintiff’s] physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1520(c), 404.1521(a). ... Here, the RFC included no mental limitations. ... Plaintiff has not shown that she had greater mental limitations than the mild variety found by the ALJ, a finding supported by Dr. Colsky’s opinion and other cited evidence, including normal mental status findings and plaintiff’s emphasis on physical limitations in her Function Report. Mild mental impairment is generally consistent with unskilled work. ... Thus, given that plaintiff was found nondisabled based on her ability to perform unskilled jobs, any error in failing to include mild mental limitations in the RFC is harmless.

Section 404.1520(c) requires an impairment or combination of impairments to significantly limit a claimant’s physical or mental ability to do basic work activities to be considered severe at step two.

MEDINA v. COMMISSIONER OF SOCIAL SECURITY · filed 2020-01-23(c)

Under step two, the ALJ determines whether the claimant suffers from a severe impairment or combination of impairments that meets the duration requirement found in §§ 404.1509 and 416.909. 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii). An impairment or a combination of impairments is not severe when medical and other evidence establishes only a slight abnormality or combination of abnormalities that would have a minimal effect on an individual’s ability to work. 20 C.F.R. §§ 404.1521, 416.921; Social Security Rules (“SSR”) 85-28, 96-3p, 96-4p. An impairment or a combination of impairments is severe when it significantly limits the claimant’s “physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1520(c), 416.920(c).

At step two, an impairment is severe when it significantly limits a claimant's ability to perform basic work activities.

Lorusso v. Berryhill · filed 2020-02-19(c)

An impairment is “severe” if it “significantly limits [the plaintiff’s] ability to do basic work activities.” 20 C.F.R. § 404.1520(c).

At step two, § 404.1520(a)(4)(ii) requires determining whether an impairment or combination is severe, meaning it significantly limits the claimant’s physical or mental ability to perform basic work activities.

Campbell v. Berryhill · filed 2020-02-28(a)(4)(ii)

The second step requires the Commissioner to determine whether the claimant's impairment or combination of impairments are "severe." 20 C.F.R. § 404.1520(a)(4)(ii), (c) and § 416.920(a)(4)(ii), (c); Yuckert, 482 U.S. at 140-41. An impairment is severe if it significantly limits the claimant's physical or mental ability to do basic work activities. Id. If the claimant has an impairment(s) that is severe, the Commissioner proceeds to step three. ... Therefore, the ALJ did not err in concluding Plaintiff's mental health impairments were not severe at step two.

At step two, § 404.1520(c) treats an impairment as severe only when it significantly limits the claimant’s ability to perform basic work activities.

Swanson v. Commissioner of Social Security · filed 2020-03-16(c)

At step two in the sequential evaluation, the ALJ must determine whether a claimant has a medically severe impairment or combination of impairments. 20 C.F.R. § 404.1520(a)(4)(ii). ... To be severe, an impairment must significantly limit a claimant’s ability to perform basic work activities. 20 C.F.R. §§ 404.1520(c), 404.1522(a); Edlund, 253 F.3d at 1159. ... When arguing on appeal that the ALJ failed to include a severe impairment at step two, a claimant cannot simply point “to a host of diagnoses scattered throughout the medical record.”

At step two, an impairment is severe only if it significantly limits a claimant’s physical or mental ability to perform basic work activities; a medically determinable impairment alone is insufficient.

Justice v. Commissioner of Social Security · filed 2020-03-19(c)

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). ... Thus, there is no reasonable basis to conclude that a knee impairment that may have been medically determinable would have been a severe impairment “which significantly limits [Plaintiff's] physical or mental ability to do basic work activities” or otherwise impacts the residual functional capacity finding. 20 C.F.R. § 404.1520(c).

At step two, the regulation requires the ALJ to determine whether the claimant has a medically determinable impairment.

Williams v. Social Security Administration · filed 2020-03-23(a)(4)(ii)

At step two, an ALJ must consider whether a claimant’s impairment is a medically determinable impairment. 20 C.F.R. § 404.1520(a)(4)(ii).

Section 404.1520 requires the ALJ to follow the sequential disability evaluation, including deciding at step two whether an alleged impairment is medically determinable and severe.

Allerton v. Social Security Administration, Commissioner of · filed 2020-03-24(a)(4)(ii)

At step two, the ALJ is required to consider whether Plaintiff’s alleged impairments constitute “medically determinable” impairments. See 20 C.F.R. §§ 404.1508; 416.920(a)(4)(ii); 404.1520(a)(4)(ii). ... Ultimately, the Court finds that the ALJ’s step two decision that Plaintiff’s carpal tunnel syndrome was not a severe impairment is not supported by substantial evidence, and Plaintiff satisfied her de minimis hurdle at this stage of the disability determination.

Section 404.1520 requires the ALJ at step two to consider whether the claimant’s alleged impairments are medically determinable.

Horne v. Social Security Administration, Commissioner of (PLR2) · filed 2020-03-31(a)(4)(ii)

At step two, the ALJ is required to consider whether Plaintiff’s alleged impairments constitute “medically determinable” impairments. See 20 C.F.R. §§§ 404.1508; 416.920(a)(4)(ii); 404.1520(a)(4)(ii).

At step two, an ALJ must consider whether the claimant has a medically determinable impairment based on medically acceptable clinical and laboratory diagnostic techniques.

Durbin v. Commissioner of Social Security · filed 2020-05-27(a)(4)(ii)

At Step Two, an ALJ must consider whether a claimant’s impairment constitutes a “medically determinable impairment,” i.e., an impairment that results from anatomical, physiological, or psychological abnormalities that can be shown by medically acceptable clinical and laboratory diagnostic techniques. 20 C.F.R. §§ 404.1521, 404.1505, 404.1520(a)(4)(ii).

At step two, § 404.1520(a)(4)(ii) requires determining whether the claimant has a severe medically determinable impairment or combination of impairments.

Vargas v. Saul · filed 2020-09-14(a)(4)(ii)

At step two, the ALJ determines if the claimant has a severe medically determinable impairment or combination of impairments. 20 C.F.R. § 404.1520(a)(4)(ii). To satisfy the severity requirement, the claimant must prove the impairment by providing objective medical evidence; the claimant’s own statement of symptoms alone will not suffice. See 20 C.F.R. § 416.921. An impairment is considered “severe” if a claimant’s physical or mental ability to complete basic work activities are significantly limited. Id. § 404.1520. Basic work activities include the “abilities and aptitudes necessary to do most jobs,” such as walking, sitting, lifting, speaking, remembering simple instructions, using judgment, and adapting to changes in a routine work setting. See 20 C.F.R. § 404.1522.

Section 404.1520(a)(4)(ii) requires the ALJ to determine at step two whether the claimant has a severe medically determinable impairment, with the inquiry ending if none is found.

Jackson v. Commissioner of Social Security Administration · filed 2020-11-17(a)(4)(ii)

At step two, the ALJ determines whether the claimant has a “severe” medically determinable physical or mental impairment. Id. § 404.1520(a)(4)(ii). If not, the claimant is not disabled, and the inquiry ends. ... The Court agrees with Jackson that the ALJ erred when considering her fibromyalgia at step two of the disability determination. ... The Court therefore concludes that the ALJ committed legal error at step two of the disability determination. Jackson’s fibromyalgia should have been included in the disability determination process as a severe medically determinable impairment.

At step two, the ALJ must determine the claimant’s medically determinable impairments and assess whether each is severe.

Torres v. Commissioner of Social Security · filed 2021-03-03(a)(4)(ii)

At step two, the ALJ must determine the claimant’s MDIs and assess whether each is severe. 20 C.F.R. § 404.1520(a)(4)(ii); see Social Security Rule (“SSR”) 16-3p, 2017 WL 5180304, at *11, 2014 SSR LEXIS 4, at *28–29 (“At step 2 of the sequential evaluation process, we determine whether an individual has a severe medically determinable physical or mental impairment or combination of impairments that has lasted or can be expected to last for a continuous period of at least 12 months or end in death.”). However, because “[s]tep two is merely a threshold determination[,] … [i]t 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). Thus, errors at step two are generally harmless if the ALJ proceeds to step three, because in determining the claimant’s RFC, the ALJ must consider the functional limitations caused by all of the claimant’s impairments, whether severe or not.

Section 404.1520(a)(4)(ii) requires the ALJ at Step Two to consider whether the claimant's alleged impairments are medically determinable.

Kilgore v. Social Security Administration, Commissioner of · filed 2021-03-11(a)(4)(ii)

At Step Two, the ALJ is required to consider whether Plaintiff’s alleged impairments constitute “medically determinable” impairments. See 20 C.F.R. §§ 404.1508; 416.920(a)(4)(ii); 404.1520(a)(4)(ii).

Section 404.1520 requires an ALJ at step two to determine whether a claimant has a severe medically determinable impairment, meaning one that significantly limits the claimant's physical or mental ability to do basic work activities.

Koch v. Commissioner of Social Security · filed 2021-11-08(a)(4)(iii) & (c)

At step two of the sequential evaluation, the ALJ must determine if a claimant has a “severe medically determinable physical or mental impairment.” 20 C.F.R. § 404.1520, § 416.920. ... A medically determinable impairment is one which results from “anatomical, physiological, or psychological abnormalities that can be shown by medically acceptable clinical and laboratory diagnostic techniques[.]” Social Security Ruling (“SSR”) 16-3p, 2017 WL 5180304, at *3. A medically determinable impairment is considered “severe” if it “significantly limits [a claimant’s] physical or mental ability to do basic work activities. . . .” 20 C.F.R. §§ 404.1520(a)(4)(iii) & (c), 416.920(a)(4)(iii) & (c). ... The ALJ lacked substantial evidence to find the record clearly established Plaintiff did not have a medically severe impairment. Thus, the ALJ committed harmful error by ending the sequential evaluation at step two.

At step two, the ALJ must consider whether the claimant's alleged impairments are medically determinable.

Rieder v. Commissioner of Social Security · filed 2021-12-13(a)(4)(ii)

At step two, the ALJ must consider whether Plaintiff's alleged impairments constitute “medically determinable” impairments. See 20 C.F.R. § 404.1520(a)(4)(ii).

At step two, § 404.1520 requires a severe medically determinable impairment meeting the duration requirement, or a severe combination of impairments meeting it; otherwise, the claimant is not disabled.

Glass v. Commissioner of Social Security · filed 2022-03-31(4)(ii)

The second step of the disability analysis is to determine whether the claimant has a severe “medically determinable” impairment. 20 C.F.R. § 404.1520(4)(ii). “If [the claimant] do[es] not have a severe medically determinable physical or mental impairment that meets the duration requirement in [20 C.F.R.] § 404.1509, or a combination of impairments that is severe and meets the duration requirement, we will find that [the claimant is] not disabled.” Id. ... Thus, the ALJ had substantial evidence to find that neither test for fibromyalgia had been met. ... Magistrate Judge Myers’ finding affirming the ALJ’s decision is without clear error and not contrary to law. ... The Social Security Administration’s decision is affirmed.

At step two, § 404.1520(a)(4)(ii) requires the ALJ to determine whether an impairment is medically determinable and whether it is severe.

FORD v. COMMISSIONER OF SOCIAL SECURITY · filed 2022-04-20(a)(4)(ii)

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), 416.920(a)(4)(ii); SSR 85-28, 1985 WL 56856. ... The ALJ did not err at Step Two and his conclusion that mental health was non-medically determinable was supported by substantial evidence.

At step two of the sequential evaluation, the ALJ must determine whether the claimant has a medically determinable impairment.

Donovan v. Commissioner of Social Security · filed 2022-06-30(a)(4)(ii)

At step two, an ALJ must consider whether a claimant’s impairment constitutes a “medically determinable impairment,” i.e., an impairment that results from anatomical, physiological, or psychological abnormalities that can be shown by medically acceptable clinical and laboratory diagnostic techniques. 20 C.F.R. §§ 404.1521, 404.1505, 404.1520(a)(4)(ii).

At step two, a claimant must establish a severe medically determinable impairment; if no medically determinable impairment is established, the ALJ ends the sequential evaluation and finds the claimant not disabled.

Vaglica v. Commissioner of Social Security · filed 2022-09-26(a)(4)(ii)

Step two of the sequential process required Plaintiff to prove that he had a severe medically determinable impairment. 20 C.F.R. § 404.1520(a)(4)(ii). Before addressing the issue of severity, the ALJ had to first determine whether Plaintiff had a medically determinable impairment at all. 20 C.F.R. § 404.1521. Because ALJ Crawley found that “[t]hrough the date last insured, there were no medical signs or laboratory findings to substantiate the existence of a medically determinable impairment,” he ended his analysis and found that Plaintiff was not disabled. (Tr. 12, 15.)

At step two, § 404.1520(c) requires an impairment to be medically determinable and severe; an impairment is not severe when it does not significantly limit basic work activities.

Popov v. Commissioner Social Security Administration · filed 2022-09-28(c)

At step two, the ALJ determines whether the claimant has an impairment that is both medically determinable and severe. 20 C.F.R. § 404.1520(c). ... An impairment is “not severe” if it does not “significantly limit” a claimant’s ability to conduct basic work activities. 20 C.F.R. §§ 404.1520(c), 416.920(c); see also Sullivan v. Zebley, 493 U.S. 521, 525 (1990). ... On this record, plaintiff did not meet her burden, the ALJ did not err in failing to find, that she had a major neurocognitive disorder that constituted a severe impairment at step two.

Section 404.1520 requires an ALJ at step two to determine whether a claimant has a severe, medically determinable impairment, and one such impairment moves the evaluation to the next step.

KORNETZ v. COMMISSIONER OF SOCIAL SECURITY · filed 2023-03-27(a)(4)(ii), (c)

At step two of the five-step evaluation, an ALJ must determine whether a claimant has a severe, medically determinable impairment. 20 C.F.R. §§ 404.1520(a)(4)(ii), (c). A showing of just one such impairment propels the evaluation to the next step. Id. At this early point in an ALJ’s evaluation, the bar for a claimant is not set especially high. McCrea v. Comm’r of Soc. Sec., 370 F.3d 357, 360 (3d Cir. 2004). Only “groundless claims” ought to be denied at step two. Newell v. Comm’r of Soc. Sec., 347 F.3d 541, 546 (3d Cir. 2003).

At step two, § 404.1520 requires a claimant to show a severe medically determinable impairment that can be expected to result in death or last for at least twelve months, and defines severe as significantly limiting the claimant's ability to perform basic work activities.

Helbling v. Commissioner Social Security Administration · filed 2023-08-30(a)(4)(ii), (c)

At step two of the sequential evaluation, the claimant has the burden to show that she has a severe medically determinable impairment that can be expected to result in death or last for a continuous period of at least twelve months. ... Further, an ALJ will find an impairment to be “severe” only if it “significantly limits [a claimant’s] physical or mental ability to do basic work activities.”

At step two, § 404.1520(c) requires the Commissioner to determine whether an impairment or combination of impairments is medically determinable and severe, with severity meaning that it significantly limits basic work activities.

McCafferty v. Commissioner Social Security Administration · filed 2023-12-11(c)

At step two, the ALJ determines whether the claimant has an impairment, or combination of impairments, that is both medically determinable and severe. 20 C.F.R. § 404.1520(c). An impairment is medically determinable if it is diagnosed by an acceptable medical source and based upon acceptable medical evidence. 20 C.F.R. § 404.1520(c). An impairment is severe if it significantly limits the claimant's ability to do basic work activities. 20 C.F.R. § 404.1520(c). ... Because the ALJ continued with the sequential evaluation process, “[u]nder well-established case law, any alleged error at step two was harmless.”

Section 404.1520(a)(4)(ii) requires an ALJ at step two to consider whether a claimant's alleged impairments are medically determinable.

Walker v. Commissioner of Social Security · filed 2024-07-31(a)(4)(ii)

At the second step, an ALJ must consider whether a claimant’s alleged impairments are “medically determinable.” 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii).

At step two, § 404.1520(a)(4)(ii) requires an ALJ to determine whether an impairment is medically determinable and, if so, its severity.

TRELOAR v. KIJAKAZI · filed 2024-11-27(a)(4)(ii)

At step two, the ALJ is required to determine if an impairment is medically determinable and if so, its severity. Id. at §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii). ... Unlike the Commissioner’s assertion, Plaintiff provided a clinical evaluation and an opinion from an acceptable source establishing that Plaintiff’s left wrist impairment was medically determinable.

At step two, a claimant must establish a medically determinable impairment before its severity is evaluated.

K.J. v. Bisignano · filed 2025-11-28(a)(4)(ii)

Before addressing the severity of an impairment, Plaintiff must first establish the existence of the impairment.

At Step 2, a claimant must prove a medically determinable impairment; evidence of an anatomical or physiological abnormality alone is insufficient.

Fields v. Andrew Saul, Commissioner, Social Security Administration · filed 2019-09-27(a)(4)(ii)

In sum, Step 2 requires proof of a medically determinable impairment, not just proof of an anatomical or physiological abnormality, and that is all that Fields has produced.

Section 404.1520(b) precludes a finding of disability when a claimant engages in substantial gainful activity, regardless of the severity of the claimant’s impairments.

Herbert C. FOWLER, Plaintiff-Appellant, v. Otis R. BOWEN, Secretary of Health and Human Services, Defendant-Appellee · filed 1989-06-06(b)

If plaintiff actually engaged in substantial gainful activity, he could not be found disabled, regardless of the severity of his impairments.

Section 404.1520(b) bars child’s insurance benefits when a claimant engaged in substantial gainful activity before age 22, regardless of medical findings.

Dinkel v. Secretary of Health & Human Services · filed 1990-02-09(b)

If a claimant was working and engaging in substantial gainful activity before the age of 22, claimant will not be found to be eligible for child’s insurance benefits regardless of medical findings. 20 C.F.R. § 404.1520(b).

Section 404.1520(b) begins the sequential disability analysis by asking whether the claimant is presently working.

Burden v. Shirley S. Chater, Commissioner of Social Security, 1 · filed 1996-03-15(b)

The ALJ correctly followed the analysis which the Social Security regulations prescribe in ascertaining that (1) Burden was not presently working; (2) Burden was severely impaired; (3) the impairment was not equivalent to an impairment listed in the Social Security regulations; and (4) Burden could not perform his past work. 20 C.F.R. § 404.1520(b)-(e).

Section 404.1520(b) precludes a finding of disability when a claimant is engaging in substantial gainful activity.

Ronald M. TYRA, Plaintiff-Appellant, v. SECRETARY OF HEALTH & HUMAN SERVICES, Defendant-Appellee · filed 1990-02-23(b)

The regulations preclude a finding of disability, regardless of impairment, if a claimant is engaging in substantial gainful activity. 20 C.F.R. § 404.1520(b) (1989).

Section 404.1520(b) requires a claimant engaged in substantial gainful activity to be found not disabled at the first step of the disability evaluation.

WRIGHT, Joya, Appellant, v. SULLIVAN, Louis, Secretary of Health and Human Services · filed 1990-04-09(b)

We conclude that her satisfactory performance of substantial, remunerative, 1 non-sheltered work on an on call basis, without special accommodations, constituted substantial gainful activity within the meaning of the Social Security Act. Thus, as an individual to be disabled under Title II of the Social Security Act must be prevented from performing any substantial gainful activity by reason of a medically determinable impairment, see 42 U.S.C. Sec. 423(d)(1)(A), her actual employment barred her from benefits for the period in dispute prior to August 1, 1987, regardless of her mental condition. Id.; 20 C.F.R. Sec. 404.1520(b) (1989).

Section 404.1520(b) treats substantial gainful activity as barring disability benefits, including when the work occurs after an earlier disability determination.

Perry BRITTON, Appellant, v. Louis W. SULLIVAN, Secretary of Department of Health and Human Services, Appellee · filed 1990-07-11(b)

We are not persuaded, however, that we are limited to examining evidence of fraud only during ... despite an earlier determination of disability. ... 20 C.F.R. § 404.1520(b) (1989). Therefore, we concentrate upon Britton’s activities rather than upon his physical condition.

Section 404.1520(b) provides that a claimant engaged in substantial gainful activity cannot be found disabled, regardless of age, education, prior work activity, or physical or mental impairment.

James C. COOPER, Appellant, v. SECRETARY OF HEALTH AND HUMAN SERVICES, Louis W. Sullivan, M.D., Appellee · filed 1990-11-27(b)

The regulations provide that if a claimant is engaged in substantial gainful activity, then there can be no finding of disability, regardless of the claimant’s age, education, prior work activity and even if the claimant is in fact physically or mentally impaired.

Section 404.1520(b) makes a claimant ineligible for disability benefits during a period in which the claimant engages in substantial gainful activity, regardless of the claimant’s medical condition.

Berry v. Sullivan · filed 1990-05-11(b)

An individual who engages in “substantial gainful activity” during the period of claimed disability is not eligible for benefits, regardless of the nature of the individual’s medical condition.

Section 404.1520(b) requires finding that a claimant who is working and engaging in substantial gainful activity is not disabled, regardless of the claimant’s medical condition, age, education, or work experience.

Lavada J. Nettles v. Louis W. Sullivan, Secretary of Health & Human Services · filed 1992-02-11(b)

If you are working and the work you are doing is substantial gainful activity, we will find that you are not disabled regardless of your medical condition or your age, education, and work experience.

Section 404.1520(b) categorizes a claimant as not disabled once the ALJ determines that the claimant is engaged in substantial gainful activity.

Nance v. Louis W. Sullivan, Secretary of Health and Human Services · filed 1992-02-19(b)

The regulation as a whole provides that a claimant's earnings may show that he or she has engaged in substantial gainful activity. Once an ALJ has determined that a claimant is currently engaged in substantial gainful activity, the claimant is then categorized as not disabled. 20 C.F.R. § 404.1520(b). Thus, a finding that the claimant has engaged in substantial gainful activity automatically results in a determination that the claimant is not entitled to disability benefits.

Section 404.1520(b) provides that a claimant is not considered disabled, regardless of medical condition, while performing substantial gainful activity.

Hill v. The Department of Human Services, Louis Sullivan, Secretary · filed 1992-11-25(b)

A claimant will not be considered disabled regardless of his medical condition if he is performing substantial gainful activity.

At step one, § 404.1520(b) requires a finding of not disabled when a claimant is doing substantial gainful activity, regardless of medical condition, age, education, or work experience.

Rollins v. Shalala · filed 1994-07-01(b)

The regulation defining step one, 20 C.F.R. § 404.1520(b), could not be more clear on this point. It apprises claimants that: ... In other words, once the ALJ determined that plaintiff was engaged in substantial gainful activity as of December 31, 1985, he properly concluded that plaintiff was “not disabled” for social security purposes. There was no need for any further assessment of plaintiff’s medical condition.

Section 404.1520 requires the disability claim to proceed through a five-step sequential evaluation, beginning with whether the claimant is engaged in substantial gainful activity.

Orozco v. Secretary of Health & Human Services · filed 1993-09-08(a)

In an effort to achieve uniformity of decisions, the Secretary has promulgated regulations which contain, inter alia, a five-step sequential disability evaluation process. ... Applying step one of this process, the ALJ found that Plaintiff has engaged in daily activities analogous to work and he engages in these activities four to six hours per day every day or every other day and earns $900 to $2,400 per month doing so. ... The ALJ therefore held that Plaintiff was “not disabled.”

Section 404.1520(b) provides that a claimant engaged in substantial gainful activity is not disabled regardless of medical findings.

Greenspan v. Shalala · filed 1994-11-21(b)

(1) An individual who is working and engaging in substantial gainful activity will not be found disabled regardless of medical findings.

Section 404.1520 requires a claimant who is engaged in substantial gainful activity to be found not disabled regardless of the claimant’s medical condition.

Douglas R. MILLER, Plaintiff-Appellant, v. SECRETARY OF HEALTH AND HUMAN SERVICES, Defendant-Appellee · filed 1988-01-20(a)

When a claimant is working, and the work he does constitutes substantial gainful activity, he must be found not disabled regardless of his medical condition. 20 C.F. R. § 404.1520(a), (b).

Section 404.1520(b) requires the Commissioner to determine at the first step whether a claimant is engaged in substantial gainful activity, which precludes disability if the work is substantial gainful activity.

Pippins v. Callahan · filed 1997-05-30(b)

The first step, and the only one relevant here, requires the ALJ to determine whether the claimant engaged in substantial gainful activity during the relevant time period. As the regulation says, “If you are working and the work you are doing is substantial gainful activity, we will find that you are not disabled regardless of your medical condition or your age, education, and work experience.” 20 C.F.R. §§ 404.1520(b), 416.920(b). ... In short, the ALJ’s decision was based on an inference: If a claimant has an expensive drug and alcohol habit, he must be engaged in substantial gainful activity to fund it. This inference is impermissible.

Section 404.1520(b) requires a finding of not disabled at the work-activity step when a claimant is performing substantial gainful activity, regardless of the claimant's medical condition.

Brando v. Chater · filed 1997-05-23(b)

As provided in 20 C.F.R. § 404.1520(b) (1996), if a claimant is working and the work is a substantial gainful activity the ALJ will find that the claimant is not disabled regardless of the claimant’s medical condition.

At step one, § 404.1520(b) treats a person currently engaged in substantial gainful activity as not disabled.

Willis v. Callahan · filed 1997-10-06(b)

A person who is presently working at a job which qualifies as substantial gainful activity is not disabled. 20 C.F.R. § 404.1520(b).

Section 404.1520(b) requires a claimant, at the first step of the disability analysis, to demonstrate that the claimant is not engaged in substantial gainful activity.

Cerrone v. Shalala · filed 1998-05-07(b)

The claimant must first demonstrate that he is not engaged in any substantial gainful activity. 20 C.F.R. § 404.1520(b) (1997).

At the first step, a claimant who is performing substantial gainful activity is not disabled, so the remaining disability factors need not be considered.

Dierks v. Apfel · filed 1999-09-16(b)

The ALJ’s determination in this case stopped at the first step; that is, the only inquiry required was whether the claimant was working and performing substantial gainful activity during a claimed period of disability, regardless of the claimant’s medical condition, age, education, and work experience. 20 C.F.R. § 404.1520(b).

Section 404.1520(b) treats a claimant as not disabled when the claimant is engaging in substantial gainful activity, and the Court accepted the Agency’s interpretation that this applies when the impairment no longer prevents such activity within 12 months after onset.

Barnhart v. Walton · filed 2002-03-27(b)

Acting pursuant to statutory rulemaking authority, 42 U. S. C. §§ 405(a) (Title II), 1383(d)(1) (Title XVI), it has promulgated formal regulations that state that a claimant is not disabled “regardless of [his] medical condition,” if he is doing “substantial gainful activity.” 20 CFR § 404.1520(b) (2001). And the Agency has interpreted this regulation to mean that the claimant is not disabled if “within 12 months after the onset of an impairment ... the impairment no longer prevents substantial gainful activity.” 65 Fed. Reg. 42774 (2000). Courts grant an agency’s interpretation of its own regulations considerable legal leeway. Auer v. Robbins, 519 U. S. 452, 461 (1997); Udall v. Tallman, 380 U. S. 1, 16-17 (1965). And no one here denies that the Agency has properly interpreted its own regulation.

Section 404.1520(a) makes substantial gainful activity a step-one bar to disability benefits; when the claimant's work is neither substantial nor gainful, the Commissioner must proceed to the next step.

Weiland v. Barnhart · filed 2002-12-23(a)

Under Social Security regulations, “substantial gainful activity” is work that is both substantial and gainful. If a claimant performs substantial gainful activity during an alleged period of disability, the claimant is disqualified from receiving DI benefits. 20 C.F.R. § 404.1520(a) (“If you are doing substantial gainful activity, we will determine that you are not disabled.”) ... Because Weiland’s work activity at the livestock operation and the hatchery was neither substantial nor gainful, the Commissioner should have proceeded to the second step of the five-step analysis.

At step one, § 404.1520(b) directs the ALJ to find a claimant not disabled if the claimant is engaged in substantial gainful activity.

Myers v. Barnhart · filed 2002-11-27(b)

A five-step sequential process is utilized by the ALJ to determine whether a claimant qualifies for disability benefits. ... In this five-step process, the ALJ considers: ... 1) whether the claimant is currently engaged in substantial gainful activity, as an individual who is working and engaging in substantial gainful activity will not be found disabled, regardless of the medical findings; ... There is no dispute that Myers did not engage in substantial gainful activity during the relevant period in question, thereby, meeting the first step of the sequential process.

Section 404.1520(a) provides that, at the first step of the disability analysis, a claimant is not disabled if he was doing substantial gainful activity.

Reddinger v. Commissioner of Social Security · filed 2003-05-20(a)

Under the first step of the analysis, a claimant is not disabled if he was doing substantial gainful activity. 20 C.F.R. § 404.1520(a).

Section 404.1520(i)(5) treats a person who is working and performing substantial gainful activity as not disabled, regardless of medical condition, age, education, or work experience; “working” means holding a job in the labor market.

Gentle v. Jo Anne B. Barnhart, Commissioner of Social Security · filed 2005-12-07(i)(5)

Granted, there is tension between these cases and a regulation (which the cases do not discuss) that states that “if you are working and the work you are doing is substantial gainful activity, we will find that you are not disabled regardless of your medical condition or your age, education, and work experience.” 20 C.F.R. §§ 404.1520(i)(5), 416.920(i)(5). The regulation is not strictly applicable here, because Gentle is ■ no longer working; her work in the household is not “substantial gainful activity” within the meaning of the regulation, in which “working” signifies holding a job in the labor market. But the regulation implies that someone engaged in “substantial gainful activity,” regardless of circumstances, is not disabled. In the case of the indulgent employer, the work may not be “substantial gainful activity”; but in the case of the desperate employee, it would be. The regulation may simply reflect a commonsense presumption that to work implies a capacity to continue working, and the presumption fails if the applicant is no longer working.

Section 404.1520(a)(4)(i) requires a finding that a claimant is not disabled at step one when her work activity constitutes substantial gainful activity.

Kangail v. Jo Anne B. Barnhart, Commissioner of Social Security · filed 2006-07-14(a)(4)(i)

It is true that if she was gainfully employed between then and the , date of the final hearing on her application for benefits (February 2003), she is not disabled.

At the first step, an ALJ determines whether the claimant is engaged in substantial gainful activity; if so, the claimant is not disabled.

Leyva v. Commissioner of Social Security · filed 2010-05-11(a)(i)

The regulations set forth a five-step process to determine if a claimant is disabled and, thus, eligible for benefits. First, the ALJ must determine whether the claimant is engaged in substantial gainful activity. 20 C.F.R. § 404.1520(a)(i), (b). If so, the claimant is not disabled.

Section 404.1520(b) provides that a claimant who is working and performing substantial gainful activity is not disabled at step one of the sequential evaluation.

Paz v. A. Duda & Sons, Inc. · filed 2010-10-13(b)

This was error because causation is not part of step one of the five-step evaluation; rather, questions regarding causation pertain to an employee’s entitlement to workers’ compensation benefits, and conflation of the two concepts does not illustrate to this court that the appropriate legal standard was used in determining Claimant’s entitlement to benefits. ... Step one concerns only whether the claimant is “doing substantial gainful activity”; the Social Security regulations specify that “[i]f you are working and the work you are doing is substantial gainful activity, we will find that you are not disabled.” 20 C.F.R. § 404.1520(b) (1992).

Section 404.1520(b) provides that a claimant engaged in substantial gainful employment is found not disabled at the first step of the sequential evaluation.

POSKO v. Astrue · filed 2010-12-21(b)

1. If the claimant currently is engaged in substantial gainful employment, he will be found “not disabled.”

Subsection (b) requires the Commissioner to determine at step one whether a claimant is engaged in substantial gainful activity, ending the inquiry with a finding of not disabled if so.

Fort v. Astrue · filed 2012-03-12(b)

At Step One, the Commissioner determines whether the claimant is currently engaged in substantial gainful activity. 20 C.F.R. § 404.1520(b). Substantial gainful activity is work that involves doing significant and productive physical or mental duties that are done, or intended to be done, for pay or profit. 20 C.F.R. § 404.1510. If the claimant is engaged in substantial gainful activity, he or she is found not disabled, regardless of medical condition, age, education, or work experience, and the inquiry ends; if not, the inquiry proceeds to Step Two.

Section 404.1520(a)(4)(i) requires a finding of not disabled when the claimant is doing work that constitutes substantial gainful activity.

Stringer v. Astrue · filed 2012-03-22(a)(4)(i)

Even if Stringer had bipolar disorder before the age of 22, he has not shown that the ALJ should thus have concluded that he was disabled. The ALJ’s finding that Stringer performed work before the age of 22 that constituted substantial gainful activity was sufficient to conclude that he was not disabled. See 20 C.F.R. § 404.1520(a)(4)(i) (“If . . . the work you are doing is substantial gainful activity, we will find that you are not disabled . . . .”).

Subsection (b) requires the ALJ to determine at step one whether the claimant is engaged in substantial gainful activity; continued work at that level precludes disability for that period.

Brown v. Colvin · filed 2015-03-11(b)

A claimant who is performing substantial gainful activity is not disabled regardless of medical condition, age, education, or work experience. 20 C.F.R. § 404.1520(b). Thus even if plaintiffs impairments commenced- earlier, the fact that he -nevertheless continued to work precludes a finding of disability for any period of time prior to the date he actually stopped working.

Section 404.1520 establishes a five-step disability evaluation, and at step one the SSA determines whether the claimant engages in substantial gainful activity; failure to show its absence ends the sequential analysis and results in denial of benefits.

Rubinson v. Commissioner of Social Security · filed 2015-03-25(b)

Ordinarily, the SSA reviews claims of disability in accordance with the sequential five-step process set forth in 20 C.F.R. § 404.1520. ... In step one, the SSA determines whether the claimant engages in “substantial gainful activity.” 20 C.F.R. § 404.1520(b); ... Consequently, a failure to meet this burden, automatically results in the denial of benefits.

Section 404.1520(b) requires the Commissioner to deny disability benefits at step one when the claimant is engaged in substantial gainful activity.

Cintrón-Rivera v. Colvin · filed 2015-09-11(b)

The regulations under the Act establish a series of hurdles that an applicant must surmount before establishing eligibility for benefits. 20 C.F.R. § 404.1520. If a claimant’s work activity qualifies as "substantial gainful activity,” then the Commissioner will find under step one of the evaluation process that the claimant is not disabled.

Section 404.1520 makes a finding of not disabled automatic when the claimant is doing substantial gainful activity, but that rule does not apply to periods after such work ended.

Cutter v. Colvin · filed 2016-12-14(a)(4)(i) (b)

Title 20 C.F.R. § 404.1520, cited by the Commissioner, is not to the contrary. It states only that a finding of “not disabled” is automatic “[i]f you are doing substantial gainful activity,” 20 C.F.R. § 404.1520(a)(4)(i) (emphasis added), and that “[i]f you are working and the work you are doing is substantial gainful activity, we will find that you are not disabled,” id. § 404.1520(b) (emphasis added). These circumstances did not pertain to Cutter after October 8, 2011, and through the time his claim was adjudicated.

At step one of the disability analysis, a person who is actually engaged in substantial gainful activity is not disabled, regardless of the severity of the physical or mental challenges.

Lambert v. Berryhill · filed 2018-07-19(a)

Consider, for example, the first step in the five-step analysis of disability. No matter how severe the physical or mental challenges might be, if the person is actually working (“substantial gainful activity”), the person is not disabled. 20 C.F.R. §§ 404.1520(a), 416.920(a).

Section 404.1520(b) requires a finding of no disability when a claimant is engaged in substantial gainful activity, regardless of the claimant's medical condition or vocational factors.

Sullivan v. Social Security Administration, Commissioner of · filed 2022-01-10(b)

Moreover, the ALJ noted that despite Plaintiff’s alleged onset date of March 13, 2018, Plaintiff reported on June 29, 2018 that he was returning to full-time employment with the Tennessee Department of Transportation (AR 715), a scenario that inherently precludes a finding of disability. See 20 C.F.R. § 404.1520(b) (“If you are working and the work you are doing is substantial gainful activity, we will find that you are not disabled regardless of your medical condition or your age, education, and work experience.”).

Section 404.1520(b) provides that a claimant who engages in substantial gainful activity after filing for benefits cannot be found disabled, regardless of medical condition.

Stamp v. Commissioner of Social Security Administration · filed 2022-05-02(b)

If a claimant has engaged in substantial gainful activity since filing for benefits, then claimant cannot be found to be disabled regardless of her medical condition. 20 C.F.R. §§ 404.1520(b), 416.920(b).

Section 404.1520(a)(4)(i) requires a disability claimant to show that the claimant is not engaged in substantial gainful activity.

Pruitt v. Social Security Administration, Commissioner · filed 2023-01-17(a)(4)(i)

In order to qualify for disability benefits, a claimant must show that he is not engaged in “substantial gainful activity.” 20 C.F.R. § 404.1520(a)(4)(i). Here, the administrative law judge found that Pruitt was not engaged in substantial gainful activity—she agreed with Pruitt that his 2018 work attempt had been “unsuccessful.” However, she later discussed his work attempt as one of several facts that weighed against crediting Dr. Fleming’s opinion that Pruitt had a neurocognitive disorder that caused difficulty remembering instructions. That was not improper, because Pruitt quit work in 2018 due to physical pain—not mental limitations.

A claimant who is engaged in substantial gainful activity cannot be found disabled, regardless of medical condition, age, education, or work experience.

Williams v. Commissioner of Social Security · filed 2023-09-07(b)

It follows that a claimant who is engaged in SGA cannot be found disabled, no matter what his medical condition, age, education, or work experience. 20 C.F.R. § 404.1520(b).

Section 404.1520(b) treats a person who engages in substantial gainful activity as not disabled.

Patton v. Bowen · filed 1988-01-28(b)

The first issue to be reviewed in this case is whether during the period of disability determined to have begun in April 1980 the plaintiff was able to engage in gainful work activity, rendering him not “disabled” under the Act. See 20 C.F.R. § 404.1520(b). ... Since the record indicates that plaintiff is operating a business on his premises and since the plaintiff has not offered substantial evidence to rebut or explain the evidence against him, this court must find that the plaintiff has been engaging in gainful work activity since the period of disability was first determined in 1980.

Section 404.1520(b) bars benefits during periods of substantial gainful activity, but eligibility can resume when that activity ends.

Powell v. Heckler · filed 1985-10-18(b)

Substantial gainful activity clearly does bar benefits under the statute regardless of any actual disability of the claimant. But it bars such benefits only for such periods of activity.

Section 404.1520(b) treats a claimant who performs substantial gainful activity as not disabled, regardless of whether the claimant’s medical condition has improved.

Wonica v. Secretary of the Department of Health & Human Services · filed 1991-09-19(b)

The regulations promulgated by the Secretary pursuant to the 1967 amendments make clear that an ongoing medical condition is not regarded as an appropriate counterbalance to the presumption.

Subsection (b) bars a finding of disability when a claimant engages in substantial gainful activity, even if the claimant has an impairment.

Comstock v. Chater · filed 1996-08-05(b)

If a claimant engages in substantial gainful activity, there can be no finding of disability, even if the claimant does in fact have an impairment.

The disability inquiry may end when the claimant’s work establishes substantial gainful activity.

Poulin v. Heckler · filed 1984-09-07(c)

This fact was enough to properly end the AU’s inquiry at that point. 20 C.F.R. § 404.1520(c).

Section 404.1520 requires denying disability benefits when a claimant is doing substantial gainful activity.

Tom KING, Appellant, v. Shirley S. CHATER, Appellee · filed 1995-12-21

The relevant regulations state that if a person “[is] doing substantial gainful activity,” the person is not eligible for disability benefits. See 20 C.F.R. § 404.1520(a); see also 20 C.F.R. § 404.1520(b).

Section 404.1520(b) provides that a claimant engaged in substantial gainful activity is found not disabled at the first step of the disability evaluation.

TAYLOR v. COMMISSIONER OF SOCIAL SECURITY · filed 2019-08-02(b)

1. If the claimant currently is engaged in substantial gainful employment, he will be found “not disabled.”

At step two, the regulation requires determining whether the claimant has a severe impairment significantly limiting basic work activities, and an omitted severity finding is harmless only when all medically determinable impairments are considered in the RFC.

Bass v. Berryhill · filed 2020-03-31(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). ... Where the ALJ finds at least one severe impairment at step two, and properly considers all medically determinable impairments at step four, failing to find that any specific impairment is severe is harmless error. ... However, if an ALJ does not consider all medically determinable impairments when assessing a claimant’s RFC, then an error at step two is not harmless. ... For the reasons stated above, the court finds that the ALJ erred in failing to find that Bass’s diabetes and back pain are severe impairments. Those errors are not harmless because the ALJ did not consider them as required in assessing Bass’s RFC. Any error the ALJ committed with respect to the other impairments is harmless, as Bass did not identify corresponding errors in the ALJ’s RFC. On remand, the ALJ shall revisit the step two analysis and make findings consistent with this order.

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.

Hoy v. Astrue · filed 2010-08-12(c)

But whether a condition or injury is a severe impairment does not turn on whether it can be improved; an impairment, or combination of impairments, is severe if it significantly limits the claimant’s physical or mental ability to perform basic work activities.

At step two, a claim may be denied only when the medical evidence clearly establishes that the claimant’s impairments have no more than a minimal effect on the ability to perform basic work activities; otherwise, the sequential evaluation must continue.

Lopez-Navarro v. Barnhart · filed 2002-06-11(c)

Step two of the sequential evaluation process involves a determination of whether the claimant has a severe impairment or combination of impairments. ... If you do not have any impairment of combination of impairments which significantly limits your physical or mental ability to do basic work activities, we will find that you do not have a severe impairment and are, therefore, not disabled. We will not consider your age, education, and work experience. ... Thus, SSR 85-28 allows the Commissioner to decide that an impairment “is ‘not severe’ only where the medical evidence clearly establishes that an ailment or injury has a minimal or non-serious effect on the claimant’s ability to perform work-related activities.” ... Because a claim can be denied at step two only when the evidence is clear, and because the ALJ rejected uncontroverted medical evidence to the contrary, the determination must be reversed based on an error of law.

Section 404.1520(c) treats a mental impairment as severe when it limits the claimant’s ability to perform basic work activities.

Maloney v. Massanari · filed 2002-06-28(c)

A severe mental impairment limits the claimant’s ability to do basic work activities. 20 C.F.R. §§ 404.1520(c), 416.920(c) (2001). Maloney never sought or received mental health treatment, nor did she report mental health impairment upon application for DIB and SSI. In fact, when Maloney submitted to mental health examination at the request of the state, the doctor failed to find any evidence of mental impairment which would preclude her from performing simple work activities. This report was confirmed by two additional doctors upon review. Therefore, Maloney’s claim that the ALJ overlooked evidence of her mental impairment lacks merit.

The second step requires a claimant to have a severe impairment that significantly limits the claimant’s physical or mental ability to do basic work activities.

Brown v. Secretary of Health and Human Services · filed 1990-06-26(c)

The second step requires the plaintiff to prove a severe impairment “which significantly limits [his] physical or mental ability to do basic work activities.” 20 C. F. R. § 404.1520(c).

Section 404.1520(c) treats an impairment as severe when it significantly limits the claimant’s physical or mental ability to perform basic work activities; without a severe impairment, the claimant is considered not disabled.

Wrona v. Sullivan · filed 1991-06-18(c)

Second, does the claimant have a severe impairment? The Department defines “severe impairment” as “any impairment or combination of impairments which would significantly limit your physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c). If the claimant does not have a severe impairment he is automatically considered not to be disabled.

Section 404.1520(c) ends the disability inquiry at step two when a claimant's impairment or combination of impairments is not severe enough to limit basic work activities.

Berryman v. Louis W. Sullivan, M.D., Secretary of Health and Human Services · filed 1992-03-04(c)

The Secretary has established a five-step sequential evaluation process to determine if a claimant is disabled. ... (2) A person who does not have an impairment or combination of impairments severe enough to limit the ability to do basic work activities is not disabled. ... The step two severity determination is based on medical factors alone, and does not include consideration of vocational factors such as age, education, and work experience. ... Unless the claimant makes a de minimis showing of medical severity, the evaluation process ends and the claimant is determined not disabled. ... In the instant case, the ALJ ended the disability inquiry at step two by finding that plaintiff's impairment or combination of impairments was not "severe."

Section 404.1520(a) requires a disability claimant to have a severe impairment.

Gwathney v. Chater · filed 1997-01-14(a)

To be disabled, a claimant must have a severe impairment. 20 C.F.R. § 404.1520(a) (1996).

Section 404.1520(a) requires a claimant to have a severe impairment to qualify as disabled for Social Security disability benefits.

Gwathney, Ss v. Chater · filed 1997-01-14(a)

To be disabled, a claimant must have a severe impairment. 20 C.F.R. § 404.1520(a) (1996).

At step two, a claimant must have an impairment or combination of impairments that significantly limits the ability to perform basic work activities.

Turner v. Callahan · filed 1998-02-05(c)

To meet his burden at step two, plaintiff must show that he suffers from 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), 416.920(c); see also Bowen v. Yuckert, 482 U.S. 137, 146 & n.5 (1987).

Section 404.1520(c) requires a claimant at step two to show an impairment or combination of impairments that significantly limits the physical or mental ability to perform basic work activities.

Turner v. Kenneth S. Apfel, Commissioner of Social Security Administration · filed 1998-02-05(c)

To meet his burden at step two, plaintiff must show that he suffers from 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), 416.920(c); see also Bowen v. Yuckert, 482 U.S. 137, 146 & n. 5 (1987).

Section 404.1520 treats an impairment as severe only when it significantly limits a claimant’s physical or mental ability to perform basic work activities.

Vick v. Commissioner of the Social Security Administration · filed 1999-07-02

A severe impairment is one that “significantly limits your physical or mental ability to do basic work activities.” ... An impairment is not severe when it has “no more than a minimal effect on [claimant’s] physical or mental abilityfies) to perform basic work activities.” ... The ALJ correctly determined that the medical record does not support a finding of severe impairment or combination of impairments. ... Thus, because claimant’s testimony is not completely credible and the medical evidence fails to substantiate her claim of severe impairment or combination of impairments, the ALJ’s severity determination is consistent with the weight of the evidence.

Section 404.1520 requires the Commissioner to determine at step two whether an impairment is severe, and a non-severe finding ends the disability evaluation; the step-two standard must be applied to the claimant's impairments and their combined effect on basic work activities.

Bagley v. SSA · filed 1999-08-10(a), (c)

At step two of the evaluation process the Commissioner must determine if the individual has an impairment and if that impairment is severe. See 20 C.F.R. §404.1520(c). ... A severe impairment is a mental or physical condition, either resulting in death or continuing for at least twelve consecutive months, that significantly limits an individual's physical or mental ability to perform basic work activities. See 20 C.F.R. §404.1520(c). ... Thus, at step two, the ALJ must consider the combined effect of all of the claimant's impairments even if these impairments taken alone would not be considered severe. See 20 C.F.R. §404.1523. ... Nonetheless, the validity of the step two regulation depends upon how it is applied. See Yuckert, 482 U.S. 158 (O'Connor, J., concurring); McDonald, 795 F.2d at 1124-25; Social Security Ruling 85-28. In this case considering all of the medical evidence indicating that Bagley's impairments effected her basic work activities, it is obvious to the court that the ALJ improperly applied the step two regulation in his evaluation. Even without considering any potential mental impairments13 that Bagley may have had, the combination of her physical impairments alone over the relevant time period suggest more than a de minimus effect on her ability to do basic work activities at step two. Thus, the Commissioner's finding that Bagley's impairments are not severe is not supported by substantial evidence.

At step two, § 404.1520(c) requires a claimant to present medical evidence showing a severe impairment before the disability claim can proceed.

Graham v. Apfel · filed 1999-09-01(c)

To satisfy step two, the plaintiff must present medical evidence demonstrating that he suffers from a severe impairment.

Section 404.1520(c) treats an impairment as non-severe when it does not significantly limit the claimant's physical or mental ability to perform basic work activities, including for the required duration.

Eaker v. Apfel · filed 2000-07-11(c)

Further, Social Security regulations state that there is no disability if "you do not have 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) (1999). Basic work activities are those that are required for most jobs, such as walking, standing, sitting; the capacity to see, hear, speak, understand, carry out and remember simple instructions; and the ability to use judgment. Id. at § 404.1521. ... Each condition was, however, episodic . The ALJ conducted an extensive inquiry into the nature and degree of each ailment and correctly concluded that none of these conditions, either singularly or cumulatively, significantly limited Eaker's physical or mental ability to do basic work activities for a period of twelve months or more.