20 C.F.R. § 404.1520
Evaluation of disability in adults: the cases that interpreted this section
33,077 citing cases reviewed of 71,843 in the citation index: 6,452 interpreted the section (annotated below), 26,625 cited it only in passing. Cases filed after 2026-06-25 may not have been reviewed yet.
Have a situation under 20 C.F.R. § 404.1520?
These notes show how courts have ruled. Ask about your specific facts and see which of these rulings apply, with citations you can check.
Sequential evaluation and stopping rules
Section 404.1520 requires the Commissioner to use a five-step evaluation when determining whether a claimant meets a listed impairment.
Dunahoo v. Kenneth S. Apfel, Commissioner, Social Security Administration · filed 2001-02-26(a)
In determining whether Dunahoo has met the listing for rheumatoid arthritis, the Commissioner must engage in a five step evaluation.Read the full opinion on CourtListener →
At the past-work step, a claimant is not disabled if the claimant can perform either the specific work previously done or the same type of work as generally performed in the national economy.
Lowe v. Apfel · filed 2000-09-25(e)
Where the claimant has the residual functional capacity to do either the specific work previously done or the same type of work as it is generally performed in the national economy, the claimant is found not to be disabled. See Jones v. Chater, 86 F.3d 823, 826 (8th Cir. 1996); see also 20 C.F.R. § 404.1520(e), § 416.920(e).Read the full opinion on CourtListener →
If an impairment meets or equals a listed impairment, the claimant is found disabled without considering age, education, or work experience.
Credle v. Apfel · filed 2001-02-14(d)
“If you have an impairments) which ... is listed in appendix 1 or is equal to a listed impairment(s), we will find you disabled without considering your age, education, and work experience.”Read the full opinion on CourtListener →
Severe impairment and duration at step two
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, but finding at least one severe impairment does not itself establish functional limitations or require matching RFC restrictions; it requires the ALJ to continue through the five-step evaluation.
Hie v. Commissioner of Social Security · filed 2021-09-07(c)
As defined by the Social Security regulations, a “severe” impairment is “any impairment or combination of impairments which significantly limits [a claimant’s] physical or mental ability to do basic work activities.” § 404.1520(c). Courts, however, liberally construe the phrase “significantly limits” in favor of claimants. ... But a finding that a claimant has at least one severe impairment does not mean that a claimant has limitations. Instead, it means that the ALJ must proceed with the five-step sequential evaluation process.Read the full opinion on CourtListener →
At step two, an impairment is severe when it significantly limits a claimant’s physical or mental ability to perform basic work activities, and a finding of any one severe impairment requires proceeding to step three.
Maddox v. Commissioner of the Social Security Administration · filed 2021-11-10(c)
A severe impairment is defined by the regulations as “any impairment or combination of impairments which significantly limits your physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c). Plaintiff bears the burden of demonstrating that she has a severe impairment. ... A finding of a single severe impairment at step two of the sequential evaluation is enough to ensure that the factfinder will progress to step three. ... The ALJ made no express finding as to any upper extremity and cervical ailments, except finding degenerative disc disease, arachnoid cyst, and chronic pain syndrome as severe. (Tr. 14). ... Substantial evidence supports the ALJ’s consideration of Plaintiff’s ailments; if it was any error in not making express findings as to Plaintiff’s upper extremity and cervical, it was harmless error as the ALJ provided discussion related to the RFC determination concerning the upper extremity and cervical/neck.Read the full opinion on CourtListener →
At step two, an impairment is severe if it significantly limits a claimant’s physical or mental ability to perform basic work activities, and the threshold is only a de minimis hurdle requiring more than a minimal effect.
Abbott v. Commissioner of Social Security · filed 2021-12-15(c)
“The regulations define a ‘severe’ impairment as ‘any impairment or combination of impairments which significantly limits your physical or mental ability to do basic work activities.’” Griffeth v. Comm’r of Soc. Sec., 217 F. App'x 425, 428 (6th Cir. 2007) (quoting 20 C.F.R. § 404.1520(c)). ... “At step two ‘significant’ is liberally construed in favor of the claimant.” ... “Thus, “[t]o establish a ‘severe’ impairment at step two of the sequential evaluation process, [a] plaintiff must make only a ‘de minimis’ showing,” namely, a claimant “need only show that an impairment would have more than a minimal effect on her ability to do basic work activities.” ... The undersigned concludes that the ALJ’s finding that Abbott did not suffer from a “severe” impairment at step two of the sequential evaluation process is not supported by substantial evidence.Read the full opinion on CourtListener →
At step two, the regulation requires a claimant to show that an impairment or combination of impairments significantly limits the ability to perform basic work activities; without a severe impairment, the claimant is not disabled.
Fortune v. Commissioner of Social Security · filed 2021-12-29(c)
At step two, he concluded that Plaintiff’s conditions did not meet the Social Security Administration’s definition of severe, either together or separately. To survive step two, a claimant must demonstrate that she has an “impairment or combination of impairments which significantly limits [her] physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c). If the claimant does not have a severe impairment, she is not disabled regardless of any other factors or considerations. Id.Read the full opinion on CourtListener →
At step two, § 404.1520 requires a medically determinable impairment or combination of impairments to be severe before the disability inquiry continues.
Turk v. Kijakazi (CONSENT) · filed 2022-03-07(c)
At step 2, an ALJ must determine whether a claimant has a medically determinable impairment that is severe or a combination of impairments that are severe. 20 C.F.R. § 404.1520(c).Read the full opinion on CourtListener →
At Step Two, § 404.1520(c) treats an impairment as severe when it significantly limits basic work abilities and bars considering age, education, or work experience.
Jenkins v. Commissioner of Social Security · filed 2022-03-23(c)
Finally, in finding that plaintiff’s mental impairments were not severe, the ALJ noted that plaintiff “evidently returned to work.” (Tr. 20). However, “work experience” should not be considered in determining whether an impairment is severe at Step Two of the sequential evaluation process. 20 C.F.R. § 404.1520(c) (“If you do not have any impairment or 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.”) (emphasis added).Read the full opinion on CourtListener →
Section 404.1520(c) requires a claimant to have a severe impairment—one that significantly limits the ability to perform basic work activities—to proceed past step two.
Walker v. Commissioner of Social Security Administration · filed 2022-04-28(c)
The Act defines “disability” as the “inability to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment which can be expected to result in death or which has lasted or can be expected to last for a continuous period of not less than 12 months.” 42 U.S.C. § 423(d)(1)(A). The Social Security regulations interpret § 423(d)(1)(A) to require the existence of a “severe” impairment — that is, “any impairment or combination of impairments which significantly limits [the claimant’s] ability to do basic work activities.” 20 C.F.R. § 404.1520(c).Read the full opinion on CourtListener →
At step two, § 404.1520(a)(4)(ii) requires the claimant to show a severe medically determinable impairment or combination of impairments meeting the duration requirement; otherwise, the claimant is not disabled.
Simpson v. Kijakazi · filed 2022-07-14(a)(4)(ii)
Contrary to Plaintiff’s argument that the Commissioner bears the burden at step two, it is a claimant’s burden at that step to show that his impairments are severe. To carry that burden, a claimant must demonstrate that his impairments: (1) are medically determinable; (2) are severe, meaning that they significantly limit his physical and mental ability to perform basic work activities; and (3) lasted for at least twelve consecutive months.Read the full opinion on CourtListener →
Section 404.1520(a)(4)(ii) requires a claimant at step two to have a severe medically determinable impairment, or severe combination of impairments, satisfying the duration requirement.
Heath v. Commissioner of Social Security · filed 2022-08-19(a)(4)(ii)
At the second step in the sequential evaluation process, a claimant must demonstrate she suffers from a “severe medically determinable physical or mental impairment that meets the duration requirement . . . or a combination of impairments that is severe and meets the duration requirement . . .” 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii); Social Security Ruling 16-3p, 2017 WL 5180304, at *11 (Oct. 25, 2017); Higgs v. Bowen, 880 F.2d 860, 863 (6th Cir. 1988) (per curiam).Read the full opinion on CourtListener →
Section 404.1520(c) treats an impairment as severe only when it significantly limits a claimant's ability to perform basic work activities, and a claimant without a severe impairment is not disabled.
Vozzella v. Saul · filed 2022-09-28(c)
Severe impairment is defined as "any impairment or combination of impairments which significantly limits your physical or mental ability to do basic work activities." 20 C.F.R. § 404.1520(c) (2022). If the ALJ finds that the claimant does not have a "severe impairment," then the claimant is not disabled. Id.Read the full opinion on CourtListener →
At step two, § 404.1520 requires severity and duration to be analyzed separately: severity asks whether the impairment is more than de minimis, while duration is evaluated separately.
Gibson v. Saul · filed 2022-09-30(a)(4)(ii)
At step two of the analysis, the ALJ must consider an impairment’s severity. See 20 C.F.R. § 404.1520(a)(4)(ii). ... An impairment is ‘severe’ where it “significantly limits [a claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520. ... In short, “[a]lthough whether an impairment is severe and whether an impairment meets the duration requirement are both addressed at step two in the evaluation process, these are separate questions that require separate analyses.” ... By so reasoning, the ALJ conflated the requirement of severity with the requirement of duration, i.e., she interpreted the regulation to require that the limitation had to be severe for at least 12 months. The ALJ thus erroneously found that Plaintiff’s impairment was not severe because of its duration, rather than considering whether it was more than de minimis in terms of severity and then separately evaluating its actual or expected duration.Read the full opinion on CourtListener →
At step two, § 404.1520(a)(4)(ii) requires an ALJ to consider whether a claimant has a severe physical or mental impairment (or combination of impairments) that meets the duration requirement.
Atencio v. Social Security Administration · filed 2023-02-17(a)(4)(ii)
At step two, an ALJ must consider whether a DIB claimant has a severe physical or mental impairment (or combination of impairments) that meets the duration requirement. 20 CFR. § 404.1520(a)(4)(ii). The ALJ’s failure at step two to consider Mr. Atencio’s GI disorders and whether they significantly limited his physical ability to do basic work activities, was error. Id; 20 CFR §§ 404.1521, 404.1522.Read the full opinion on CourtListener →
Section 404.1520 treats step two as a threshold inquiry and directs a finding of not disabled when the claimant lacks a severe impairment that meets the duration requirement.
Jensen v. Kijakazi · filed 2023-05-05(a)(4)(ii)
The ALJ evaluated Jensen’s claim for DIB under the mandatory five-step sequential analysis. See 20 C.F.R. §404.1520(a)(4). ... The ALJ therefore found Jensen was not disabled. See 20 C.F.R. §404.1520(c) (a claimant is not disabled if she has no severe impairment). ... Even if an impairment is found to be “severe” at step two, the impairment must also meet the duration requirement set forth at 20 C.F.R. §404.1509 before proceeding to subsequent steps. See 20 C.F.R. §404.1520(a)(4)(ii) (“At the second step, we consider the medical severity of your impairment(s). If you do not have a severe medically determinable physical or mental impairment that meets the duration requirement, . . . we will find that you are not disabled.”). ... The ALJ’s determination with respect to step two was supported by substantial evidence and will not be disturbed by the Court.Read the full opinion on CourtListener →
At step two, an impairment is severe only if it significantly limits basic work activities and satisfies the required duration.
Dixon v. Commissioner of Social Security · filed 2023-07-21(c), (a)(4)(ii)
In general, at step two of the disability analysis, the ALJ determines whether the plaintiff has an impairment, or combination of impairments, that is “severe” within the meaning of the regulations, in that it “significantly limits” plaintiffs ability to perform basic work activities. 20 C.F.R. §§ 404.1520(c), 416.920(c). ... In addition, to be severe, the impairment must satisfy a durational requirement. See id. §§ 404.1509, 404.1520(a)(4)(ii), 416.909, 416.920(a)(4)(ii). ... Therefore, although the record does not contain a medical source opinion pertaining to the severity of Plaintiffs impairments, the ALJ’s step two determination was proper and supported by substantial evidence.Read the full opinion on CourtListener →
Section 404.1520(c) treats an impairment as severe when it significantly limits a claimant’s physical or mental ability to perform basic work activities.
Barth v. Commissioner of Social Security · filed 2023-08-21(c)
At step two of the sequential evaluation process, Plaintiff bears the burden of proving the existence of a severe, medically determinable impairment that meets the twelve-month durational requirement. ... A severe impairment is defined as “any impairment or combination of impairments which significantly limits your physical or mental ability to do basic work activities,” 20 C.F.R. §§ 404.1520(c), 416.920(c), and which lasts or can be expected to last “for a continuous period of not less than 12 months,” 20 C.F.R. §§ 404.1509, 416.909.Read the full opinion on CourtListener →
Section 404.1520(c) requires a claimant at step two to show that her medically determinable impairments significantly limit her ability to perform basic work activities.
Villarreal v. O'Malley · filed 2023-09-27(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, 482 U.S. at 145; 20 C.F.R. § 404.1520(c).Read the full opinion on CourtListener →
Section 404.1520(a)(4)(ii) requires the claimant to establish a severe impairment at step two; an impairment is severe when it significantly limits basic work-related activities for at least twelve months.
Zimmermann v. O'Malley · filed 2024-08-19(a)(4)(ii)
At Step Two of the five-step sequential-evaluation process by which ALJs evaluate disability claims, it is the claimant’s burden to prove her impairments are severe. Castile v. Astrue, 617 F.3d 923, 926 (7th Cir. 2010); 20 C.F.R. §§ 404.1512, 404.1520(a)(4)(ii), 404.1521. An impairment is severe if, for twelve months, it significantly limits one’s ability to perform basic work-related activities like walking and understanding simple instructions. 20 C.F.R. §§ 404.1520(a)(4)(ii), 404.1522; Social Security Ruling (“SSR”) 85-28. On the other hand, an impairment is nonsevere if the “medical evidence establishe[s] only a slight abnormality or combination of slight abnormalities which would have no more than a minimal effect on an individual’s ability to work.”Read the full opinion on CourtListener →
Section 404.1520(c) treats an impairment as severe only when it significantly limits a claimant’s physical or mental ability to do basic work activities.
Stevenson v. O'Malley · filed 2024-08-19(c)
At step two of the sequential process, the ALJ determines whether the claimant suffers from a “severe” impairment, i.e., one that significantly limits her physical or mental ability to do basic work activities. This involves a two-step process: 1) determining whether the claimant has a medically determinable impairment and 2), if so, determining whether the impairment is severe.Read the full opinion on CourtListener →
At step two, an impairment is severe when it significantly limits a claimant’s physical or mental ability to perform basic work tasks.
Berna v. Social Security Administration · filed 2024-09-03(c)
First, the ALJ omitted limitations related to Claimant’s mental impairments. A severe impairment is defined as one which significantly limits the physical or mental ability to perform basic work tasks. 20 C.F.R. §404.1520(c); 20 C.F.R. §404.1522. In the AC’s remand orders, it instructed the ALJ to reevaluate Claimant’s mental disorders. In the current decision, the ALJ determined once again that Claimant’s mental impairments were not severe. (Tr. 2123). However, these findings are inconsistent with the facts.Read the full opinion on CourtListener →
Section 404.1520(a)(4)(ii) permits an ALJ to find a claimant not disabled at step two when the claimant lacks a severe impairment; the court treated an impairment failing the 12-month durational requirement as non-severe for this step.
Delay v. Kijakazi · filed 2024-09-10(a)(4)(ii)
An ALJ may discount impairments at step two of the sequential analysis by finding that an impairment is non-severe because it has not met the 12-month durational requirement. 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii). But “[s]tep two is merely a threshold determination meant to screen out weak claims.” Buck v. Berryhill, 869 F.3d 1040, 1048 (9th Cir. 2017) (citation omitted). Thus, step two “is not meant to identify the impairments that should be taken into account when determining the RFC.” Id. at 1048–49. Because the ALJ must consider even non-severe impairments in assessing the RFC, the RFC should be “exactly the same regardless of whether certain impairments are considered ‘severe’ or not.” Id. at 1049. So even if an ALJ errs in finding an impairment non-severe at step two, such error is harmless if the ALJ discusses the limitations of the impairment at step four of the analysis. Lewis v. Astrue, 498 F.3d 909, 911 (9th Cir. 2007). ... Here, the ALJ found that Plaintiff’s edema was non-severe at step two because it did not meet the 12-month durational requirement. ECF No. 12-1 at 37. ... Thus, one rational interpretation from the record as a whole is that Plaintiff’s edema was “sporadic.” See Burch, 400 F.3d at 679. The Court therefore will uphold such finding. See Batson, 359 F.3d at 1193.Read the full opinion on CourtListener →
Section 404.1520 requires the Commissioner to find a claimant not disabled at Step Two unless the claimant has a severe impairment or combination of impairments that meets the duration requirement, with severity requiring a significant limitation on basic work activities.
Bohannon v. O'Malley · filed 2024-09-18(a)(4)(ii), (c)
At Step Two, the Commissioner must determine whether the claimant has a “severe medically determinable physical or mental impairment that meets the [12-month] duration requirement in § 404.1509, or a combination of impairments that is severe and meets the duration requirement....” See 20 C.F.R. §§ 404.1509, 416.909, 404.1520(a)(4)(ii), 416.920(a)(4)(ii). ... To be a “severe impairment,” an impairment must “significantly limit[ ] [the claimant's] physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1520(c), 416.920(c). ... Applying this standard, the record contains substantial evidence to support the ALJ’s determination that Plaintiff’s impairments were not severe between during the specified period. ... Therefore, the Court finds the Commissioner’s findings at Step Two are supported by substantial evidence.Read the full opinion on CourtListener →
Section 404.1520 requires a claimant at step two to show that an impairment is severe, meaning that it significantly limits basic work activities, and meets the duration requirement, or benefits are denied.
Srite · filed 2025-11-13(a)(4)(ii), (c)
Step Two involves a determination of whether the claimant has an impairment or combination of impairments which is “severe” and meets the duration requirement. 20 C.F.R. §§ 404.1520(a)(4)(ii); 416.920(a)(4)(ii). If not, benefits are denied. Id. A “severe” impairment significantly limits a claimant’s ability to perform basic work activities. 20 C.F.R. §§ 404.1520(c); 416.920(c).Read the full opinion on CourtListener →
At step two, § 404.1520(c) treats an impairment as nonsevere when it does not significantly limit a claimant's physical or mental ability to perform basic work activities.
Peterson · filed 2025-12-29(c)
An impairment is not severe if it does not significantly limit a claimant’s “physical or mental ability to do basic work activities.” Id. §§ 404.1520(c), 416.920(c); see also Kirby v. Astrue, 500 F.3d 705, 707 (8th Cir. 2007) (“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.”) (Citing Bowen, 482 U.S. at 153 (O’Connor, J. concurring)). ... Based on the foregoing, I find that the ALJ properly determined that Claimant’s IBS and GERD were nonsevere impairments. Claimant did not meet her burden to establish that her IBS and GERD were severe impairments.Read the full opinion on CourtListener →
At step two, an impairment is severe when it significantly limits a claimant's physical or mental ability to do basic work activities, and failing to label an additional condition severe is not reversible error once another severe impairment is found.
Moore · filed 2026-02-17(c)
Further, at step two of the sequential evaluation, a plaintiff must show that he suffers from a “severe impairment” in order to warrant a finding of disability. ... A “severe impairment” is defined as an 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). ... “Once the ALJ determines that a claimant suffers from a severe impairment, the fact that the ALJ failed to classify a separate condition as a severe impairment does not constitute reversible error.”Read the full opinion on CourtListener →
Section 404.1520(c) requires the sequential disability evaluation to continue past step two when a claimant has a severe impairment.
Canales-Rivera v. Secretary of Health and Human Services · filed 1992-05-12(c)
Because she suffered from another, demonstrably severe, impairment, however, the ALJ was constrained to proceed with the sequential analysis, considering at all times the combined effect of the non-severe back ailment and the severe allergic condition.Read the full opinion on CourtListener →
At step two, a mental impairment that has more than a minimal impact on the ability to work meets the severity threshold.
Dotson v. Kijakazi · filed 2022-01-19(c)
This unanimity of expert opinion of the existence and limiting impact of mental/social impairments, while not necessarily indicating Dotson is disabled, certainly meets the de minimus standard for a severe impairment.Read the full opinion on CourtListener →
Section 404.1520(c) treats an impairment as severe when it significantly limits a claimant’s physical or mental ability to do basic work activities.
Barrett v. Colvin · filed 2025-01-09(c)
At step two of the sequential process, the ALJ determines whether the ... claimant suffers from a “severe” impairment, i.e., one that significantly limits her ... physical or mental ability to do basic work activities.Read the full opinion on CourtListener →
Section 404.1520(c) directs a finding of no disability at step two when the claimant has no impairment or combination of impairments that significantly limits basic work activities.
Williams v. Halter · filed 2001-03-16(c)
Second, if a claimant does not have any impairment or combination of impairments which significantly limit her physical or mental ability to do basic work activities, then she does not have a severe impairment and is not disabled. 20 C.F.R. § 404.1520(c).Read the full opinion on CourtListener →
At step two, an impairment is severe if it significantly limits a claimant’s ability to perform basic work activities; symptoms that are more than slight or trivial satisfy this threshold.
Craig A. Smith, II v. Commissioner of Social Security · filed 2024-03-06(c)
For these reasons, the ALJ’s conclusion at step two of the analysis that Smith did not have any severe impairment is not ... supported by substantial evidence.Read the full opinion on CourtListener →
Section 404.1520(c) treats an impairment or combination of impairments as severe only if it significantly limits the claimant’s ability to do basic work activities.
Carreathers v. Kijakazi, Acting Commissioner of the Social Security Administration · filed 2024-03-21(c)
Under controlling regulations, an impairment or combination of impairments qualifies as “severe” only if it “significantly limits [a claimant’s] physical or mental ability to do basic work activities.” Id. § 404.1520(c); see also id. § 404.1522.Read the full opinion on CourtListener →
At step two, the ALJ must determine whether the claimant has a severe impairment that significantly limits the ability to do basic work activities.
Smith v. Commissioner of Social Security · filed 2024-03-21(a)(4)(ii), (c)
At step two of the sequential analysis, the ALJ must determine whether the claimant has a “severe impairment” that “significantly limits [claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1520(a)(4)(ii), (c).Read the full opinion on CourtListener →
At step two, an ALJ may find an impairment nonsevere when the record supports a finding that it does not significantly limit basic work activities.
Thompson v. Commissioner of Social Security · filed 2024-04-18(c)
In this case, the ALJ reasonably concluded that Plaintiff’s depression was nonsevere in light of her own statements, her daily activities, the absence of medical treatment, and the apparent ability of Plaintiff to manage her symptoms without medical intervention.Read the full opinion on CourtListener →
At step two, the claimant must show a severe impairment; mild functional limitations do not meet that standard.
Hearn v. Kilolo Kijakazi, Acting Commissioner, Social Security Administration · filed 2022-09-01(a)(4)(ii)
At the first three steps, the claimant must prove that (1) he is not engaged in substantial gainful activity; (2) he has a severe impairment; and (3) the impairment meets or equals a listed impairment. 20 C.F.R. § 404.1520(a)(4)(i)-(iii). ... Mild functional limitations do not meet the Step Two standard for a severe medically determinable impairment.Read the full opinion on CourtListener →
Severe impairment duration requirement
At step two, § 404.1520 treats an impairment as severe only when it significantly limits basic work activities; the condition must also meet the twelve-month duration requirement.
Medley v. Commissioner of Social Security · filed 2019-09-03(a)(4)(ii), (c)
Even if Medley’s claimed neuropathy is considered a medically determinable impairment, it nevertheless does not rise to the level of a severe impairment. A severe impairment is one that significantly limits a claimant’s physical or mental ability to perform basic work activities and has lasted or is expected to last for a continuous period of at least twelve months. 20 C.F.R. §§ 404.1520(a)(4)(ii), (c) and 404.1509; §§ 416.920(a)(4)(ii), (c) and 416.909. There is no evidence in the record showing that the condition meets the twelve-month durational requirement. Nor is there any objective medical evidence indicating that the condition resulted in any significant functional limitations. The ALJ did not err in his Step 2 analysis of Medley’s claimed neuropathy.Read the full opinion on CourtListener →
At step two, a severe impairment meets the duration requirement and significantly limits the claimant’s ability to perform basic work activities.
Harris v. Kijakazi · filed 2021-11-03(a)(4)(ii)
The ALJ’s analysis of Dr. Hyer’s opinion is particularly troubling because a major basis for the ALJ finding the opinion unpersuasive is because “the alleged impairments [would not] last longer than 12 months[]” (Doc. 13, PageID. 78), a position that is untenable in light of the ALJ’s step 2 finding that Plaintiff’s “major joint dysfunction of the left shoulder and arm; a back disorder; and obesity” are severe impairments, that is, impairments that meet the duration requirement and significantly limit his ability to perform basic work activities.Read the full opinion on CourtListener →
The section requires an impairment to be more than a slight abnormality with only a minimal effect on the ability to work to qualify as severe.
Sweeney v. Astrue · filed 2011-06-20(c)
In Stone, the Fifth Circuit concluded that a proper construction of the regulation is that “an impairment can be considered as not severe only if it is a slight abnormality having such minimal effect on the individual that it would not be expected to interfere with the individual’s ability to work, irrespective of age, education or work experience.” ... The court agrees with Commissioner that the analysis of the ALJ is consistent with Stone, and that the wording of the ALJ’s opinion makes clear that the ALJ correctly applied the Stone standard.Read the full opinion on CourtListener →
Section 404.1520(c) permits a finding of non-severity on medical evidence alone only when the impairment is so slight that no person who has it would be disabled.
Hundrieser v. Heckler · filed 1984-03-19(c)
Properly applied, 20 C.F.R. § 404.1520(c) is a threshold test invoked at the option of the Secretary. It is, however, a test which the Secretary and not the claimant must meet. ... In other words, by making out a prima facie case of disability through showing an inability to do past work due to “an impairment” the claimant necessarily satisfies the “severe impairment” requirement of 20 C.F.R. § 404.-1520(c).Read the full opinion on CourtListener →
Section 404.1520(c) requires an impairment to significantly limit basic work activities and satisfy the duration requirement to qualify as severe.
Poteat v. Shalala · filed 1995-01-20(c)
Plaintiff also challenges the ALJ’s finding that his pneumonia and congestive heart failure were not “severe” within the meaning of 20 C.F.R. § 404.1520(c). ... The court finds that substantial evidence supports the ALJ’s finding that the pneumonia and congestive heart failure were transitory impairments that were resolved within 12 months and thus did not meet the duration test for disability.Read the full opinion on CourtListener →
Severe impairment threshold
Section 404.1520(c) requires a claimant to show at step two that a severe impairment significantly limits basic work activities; age, education, and work history are not considered at that stage.
Bell v. Barnhart · filed 2002-08-22(c)
The “severity regulation” applied at step two of the evaluation process states that the claimant must have a severe impairment or combination of impairments which significantly limits claimant’s physical or mental ability to do basic work activities. 20 C.F.R. § 404.1520(c). Otherwise, claimant does not have a severe impairment and is not disabled. Age, education, and work history are not taken into consideration at this stage. 20 C.F.R. § 404.1520(c). ... Based on the above discussion, the court finds that the Commissioner properly applied the rules and regulations governing step two of the disability determination process and had substantial evidence to support her determination that plaintiff did not have a severe impairment or combination of impairments prior to June 30, 1993.Read the full opinion on CourtListener →
Section 404.1520 requires the ALJ to determine at step two whether an impairment significantly limits work activities and at step four whether it prevents performance of past work, based on the claimant's residual functional capacity and the demands of past work.
Ramos v. SSA · filed 2002-04-30(c), (e)
At the fourth step, a claimant bears the burden of showing that he is no longer able to perform his previous work because of his impairments. ... The ALJ must determine whether the claimant's impairment prevents him from performing his past work based on the claimant's residual functional capacity and the demands of the claimant's past work. ... At the second step of the sequential evaluation process, the ALJ must determine whether the claimant has a severe impairment, meaning an impairment or a combination of impairments that significantly limits his ability to do work activities. 20 C.F.R. § 404.1520(c). ... Therefore, the record supports the ALJ's conclusion that Ramos did not have a severe limitation caused by a somatoform disorder either alone or in combination with his other impairments.Read the full opinion on CourtListener →
Section 404.1520 requires a claimant to establish an impairment meeting the applicable duration requirement, and it treats an impairment as severe when it significantly limits the claimant’s ability to perform basic work activities.
Cottrill v. Apfel · filed 2000-06-27(a), (c)
Before a claimant can be found disabled 'under Social Security regulations, he or she must first establish the existence of a “severe” impairment which is expected to “result in death” or has lasted or is expected to last “for a continuous period of not less than 12 months.” 20 C.F.R. § 404.1505(a) and § 404.1520(a). To be “severe,” an impairment must significantly limit a claimant’s physical or mental ability to do basic work activities. 20 C.F.R. § 404.1520(c).Read the full opinion on CourtListener →
Subsection (d) requires the ALJ at step four to determine whether the claimant retains the residual functional capacity to perform past relevant work.
Fargnoli v. Larry G. Massanari, Commissioner, Social Security Administration · filed 2001-04-11(d)
Step four requires the ALJ to consider whether the claimant retains the residual functional capacity to perform her past relevant work. 20 C.F.R. § 404.1520(d). ... In this case, the ALJ undertook the five-step sequential evaluation in determining that Fargnoli was not disabled. ... The ALJ erred, Fargnoli contends, at step four in determining that he retained the residual functional capacity to do light work. We agree.Read the full opinion on CourtListener →
At step two, § 404.1520(c) requires an impairment to significantly limit basic work activities to be severe; an impairment having only a minimal effect is not severe.
Chapman v. Barnhart · filed 2002-03-07(c)
Step 2 of the requisite sequential analysis requires a determination of whether the claimant has a “severe” impairment or impairments. A disability claimant can be considered as not suffering from a severe impairment only if the impairment is a slight abnormality having only a minimal effect on a person’s ability to perform the full range of work-related activities. ... The Court finds that the ALJ did not err when he determined that Plaintiffs hand impairment was not “severe.” ... Therefore, the Court finds that substantial evidence supports the ALJ’s determination that Plaintiffs hand impairment was not “severe.”Read the full opinion on CourtListener →
At step two, the claimant must establish a severe medical impairment or combination of impairments.
Vaughan v. Massanari · filed 2001-10-02(c)
Because Vaughan’s medical records failed to establish a severe medical impairment or combination of impairments, as required at step two, substantial evidence supports the ALJ’s finding that she was not disabled.Read the full opinion on CourtListener →
At step two, the claimant bears the burden of showing a severe impairment, which must significantly limit basic work activities; denial is proper only for no more than a slight abnormality with a minimal effect on the ability to work.
Cullinane v. SSA · filed 2003-01-09(c)
At the second step of the analysis, the claimant bears the burden of showing that she had a medically severe impairment. See 20 C.F.R. § 404.1520(c); Bowen v . Yuckert, 482 U.S. 1 3 7 , 146 n.5 (1987). ... At step two, an impairment is severe if it “significantly limits [the claimant’s] physical or mental ability to do basic work activities.” § 404.1420(c). ... The step two requirement is intended only to screen out meritless claims. See McDonald v . Sec’y of Health & Human Servs., 795 F.2d 1118, 1124 (1st Cir. 1986). ... Therefore, a claim may be denied at step two only if the medical evidence establishes nothing more than a slight abnormality that “would have no more than a minimal effect on an individual’s ability to work.” Barrientos v . Sec’y of Health & Human Servs., 820 F.2d 1 , 2 (1st Cir. 1987) (internal quotation omitted).Read the full opinion on CourtListener →
Section 404.1520(c) requires the Commissioner to determine whether a claimant has a severe impairment at step two, and a claimant who fails to show a severe impairment is ineligible for disability benefits.
Walker v. Commissioner of Social Security · filed 2003-02-04(c)
In step two, the Commissioner must determine whether the claimant is suffering from a severe impairment. 20 C.F.R. § 404.1520(c). If the claimant fails to show that his impairments are “severe,” he is ineligible for disability benefits.Read the full opinion on CourtListener →
At step two, a claimant must have a severe impairment that meets the required duration period.
Bennett v. Barnhart · filed 2003-02-25(c)
In order for a claimant to be found “disabled” for purposes of disability benefits, he must have an impairment(s) that is severe and that meets the required dura-tional period. 20 C.F.R. § 404.1520(a) (1999).Read the full opinion on CourtListener →
Section 404.1520(a)(4)(ii) requires the ALJ to determine at step two whether the claimant is suffering from a severe impairment.
Mays v. Comm Social Security · filed 2003-10-27(a)(4)(ii)
As mentioned above, step two of the five-step sequential evaluation process requires the ALJ to determine whether the claimant is suffering from a severe impairment.Read the full opinion on CourtListener →
Section 404.1520(c) requires the Commissioner to identify every impairment that significantly limits a claimant’s ability to perform basic work activities as a severe impairment at step two.
Ingram v. Barnhart · filed 2003-08-04(c)
At step two of the five-step sequential process, the Commissioner was required to identify Ingram’s “severe impairments.” ... The Commissioner erred by excluding Dr. Washburn’s diagnosis of depression and Dr. Reade’s diagnosis of a panic disorder from his step-two analysis of Ingram’s “severe impairments” without providing specific, legitimate reasons supported by substantial evidence in the record.Read the full opinion on CourtListener →
Section 404.1520(c) screens out claimants who lack a severe impairment or combination of impairments that significantly limits their ability to perform basic work activities.
Smith v. Barnhart · filed 2003-11-18(c)
The second step of the Social Security Administration’s five-step disability evaluation screens out claimants without a “severe impairment” or “combination of impairments” that significantly limits the claimant’s “physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c).Read the full opinion on CourtListener →
Section 404.1520(c) requires the ALJ at step two to determine whether the claimant has a medically severe impairment or combination of impairments.
Cainglit v. Barnhart · filed 2003-12-17(c)
At step two the ALJ must determine whether the claimant has a medically severe impairment or combination of impairments. 20 C.F.R. §§ 404.1520(c), 416.920(c). An impairment is considered “not severe” if it does not significantly limit a claimant’s physical and mental ability to do basic work activities. 20 C.F.R. §§ 404.1521(a), 416.921(a).Read the full opinion on CourtListener →
Section 404.1520 requires disability claims to be evaluated through a five-step sequence, with the evaluation ending at step two when the impairment is not severe.
Dixon v. Jo Anne B. Barnhart · filed 2003-12-22
A five-step sequential analysis is used to determine disability under the Act. The Commissioner of Social Security must evaluate: (1) whether the claimant is presently engaged in a substantial gainful activity; (2) whether the claimant has a severe impairment that significantly limits the claimant's physical or mental ability to perform basic work activities; (3) whether the claimant has an impairment that meets or equals a presumptively disabling impairment listed in the regulations; (4) whether the claimant has the residual functional capacity to perform his or her past relevant work; and (5) if the claimant cannot perform the past work, the burden shifts to the Commissioner to prove that there are other jobs in the national economy that the claimant can perform. Simmons, 264 F.3d at 754-55; 20 C.F.R. § 404.1520 (2003). The sequential analysis can be discontinued at step two "when an impairment or combination of impairments would have no more than a minimal effect on the claimant's ability to work." Simmons, 264 F.3d at 755. The issue here is whether there was substantial evidence on the record as a whole that Dixon's impairments had "no more than a minimal effect" on his ability to work as of December 1991, twelve years ago.Read the full opinion on CourtListener →
At step two, the regulation requires a claimant to show that a medically determinable impairment or combination of impairments significantly limits the ability to do basic work activities, based on medical factors rather than vocational factors.
Parris v. Barnhart · filed 2004-05-26(c)
At step two, the claimant bears the burden to demonstrate an impairment or combination of impairments that significantly limits his ability to do basic work activities. 1 See Bowen v. Yuckert , 482 U.S. 137, 146 n.5 (1987). The step two severity determination “is based on medical factors alone, and . . . does not include consideration of such vocational factors as age, education, and work experience.” Williams , 844 F.2d at 750; 20 C.F.R. § 404.1520(c).Read the full opinion on CourtListener →
Section 404.1520(a)'s sequential evaluation requires a claim to proceed past step two unless the impairment is only a slight abnormality with no more than a minimal effect on the claimant's ability to work.
Jakubowski v. Commissioner Social Security · filed 2005-04-12(a)
The Commissioner may deny an applicant’s claim for failure to establish the existence of a “severe impairment” at step two of the sequential framework. But step two should rarely be the stage at which an applicant’s claim is rejected. “The step-two inquiry is a de minimis screening device to dispose of groundless claims[,]” Newell v. Commissioner of Social Security, 347 F.3d 541, 546 (3d Cir. 2003) (citations omitted), and “because step two is to be rarely utilized as basis for the denial of benefits, its invocation is certain to raise a judicial eyebrow.” McCrea v. Commissioner of Social Security, 370 F.3d 357, 361 (3d Cir. 2004) (citation omitted). “An impairment or combination of impairments can be found ‘not severe’ only if the evidence establishes a slight abnormality or a combination of slight abnormalities which have ‘no more than a minimal effect on an individual’s ability to work.’” Newell, 347 F.3d at 546 (quoting Social Security Ruling 85-28, 1985 SSR LEXIS 19, at *6-7). “Only those claimants with slight abnormalities that do not significantly limit any ‘basic work activity’ can be denied benefits at step two.” Id. (quoting Bowen v. Yuckert, 482 U.S. 137, 158 (1987) (O’Connor, J., concurring)). “If the evidence presented by the claimant presents more than a ‘slight abnormality,’ the step-two requirement of ‘severe’ is met, and the sequential evaluation process should continue.” Id. (citation omitted). “Reasonable doubts on severity are to be resolved in favor of the claimant.” Id. at 547. ... Based on the evidence in the record, particularly the evidence from Dr. Carran’s 2002 treatment of Appellant, we find that the District Court erred in denying Appellant’s claim at step two of the sequential evaluation. We will therefore reverse the order of the District Court and remand with instructions to remand the matter to the Commissioner for further proceedings consistent with this opinion.Read the full opinion on CourtListener →
At step two, the regulation requires the ALJ to determine whether an impairment, alone or with others, significantly limits the claimant’s ability to perform basic work activities.
Wind v. Jo Anne B. Barnhart · filed 2005-06-02(a)(4)(ii), (c)
At the second step of the sequential-disability determination, the ALJ must “consider the medical severity of [the claimant’s] impairments.” ... In doing so, the ALJ must determine whether the impairments, alone or in combination, “significantly limit” the claimant’s “physical or mental ability to do basic work skills.” ... However, as the ALJ explained in his decision, the record contains no evidence showing that Wind’s obesity affected her ability to perform medium work-related activities.Read the full opinion on CourtListener →
At step two, a claimant must show a medically severe impairment or combination of impairments that significantly limits the ability to perform basic work activities.
Jones v. Barnhart · filed 2005-12-23(a)(4)(ii)
At step two, the claimant must prove that she has a medically severe impairment or combination of impairments that significantly limits her ability to do basic work activities. 20 C.F.R. §§ 404.1520(a)(4)(ii), 404.1521(a).Read the full opinion on CourtListener →
Section 404.1520 requires disability claims to be evaluated through a five-step sequential process, with step two serving as a threshold screening inquiry that the claimant must satisfy with sufficient evidence.
Sanchez v. Comm Social Security · filed 2006-06-29
Mrs. Sanchez also alleges the ALJ erred in denying her claim at step two of the five-step sequential evaluation process required pursuant to 20 C.F.R. § 404.1520. The step-two inquiry, which is intended as a screening device, was not applied in error here. See, e.g., Newell, 347 F.3d at 546. Here again, it was Mrs. Sanchez’s burden to introduce evidence sufficient to satisfy the threshold requirements of step two, and the record evidence shows she did not satisfy that burden. See, e.g., Plummer, 186 F.3d at 428.Read the full opinion on CourtListener →
Section 404.1520(c) requires determining from the record whether a claimant has a medically severe impairment or combination of impairments at step two.
Jordan v. Barnhart · filed 2006-12-15(c)
The ALJ’s step-two task is to determine, based on the record, whether the claimant has a medically severe impairment or combination of impairments. 20 C.F.R. § 404.1520(c).Read the full opinion on CourtListener →
Section 404.1520(c) requires a claimant to show that a medically determinable impairment is severe; a diagnosis alone is insufficient at step two.
Petersen v. Barnhart · filed 2006-12-20(c)
A diagnosis of MS alone cannot satisfy the step two inquiry. Petersen must show also show her medically discernable impairments are severe. 20 C.F.R. § 404.1520(c).Read the full opinion on CourtListener →
At step two, § 404.1520(c) requires an impairment or combination of impairments that significantly limits a claimant’s physical or mental ability to perform basic work activities.
Taylor v. Barnhart · filed 2007-02-21(c)
At step two, the ALJ must determine whether a claimant, who is not currently performing substantial gainful work, is suffering from a severe impairment. If the claimant fails to show that her impairments are “severe,” she is ineligible for disability benefits. ... The Regulations provide that a “severe” impairment is an “impairment or combination of impairments which significantly limits your physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520. ... On this record, the court finds that the Commissioner’s decision is supported by substantial evidence.Read the full opinion on CourtListener →
Section 404.1520 treats an impairment as severe when it significantly limits the claimant’s physical or mental ability to perform basic work activities.
Cop v. Commissioner of Social Security · filed 2007-04-04
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. Basic work activities include “abilities and aptitudes necessary to do most jobs.” Newell v. Comm’r of Soc. Security, 347 F.3d 541, 546 (3d Cir. 2003) (internal quotation marks and citations omitted). We have explained that the claimant’s burden is to show that the impairment has more than a minimal effect on his or her ability to work. See id. (internal citations omitted).Read the full opinion on CourtListener →
Section 404.1520(c) treats an impairment as non-severe when it does not significantly limit the claimant’s ability to perform basic work activities, making step two a minimal screening threshold.
Kinney v. Commissioner of Social Security · filed 2007-07-06(c)
At step two, the ALJ determines whether the claimant has a medically severe impairment. Id. An impairment is not severe if it does not “significantly limit [a claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c). ... The claimant’s burden at step two is “not an exacting one.” ... This step should be “rarely utilized” to deny benefits. ... Rather, “[t]he step two inquiry is a de minimis screening device to dispose of groundless claims.” ... An individual should be denied benefits at step two only if the impairment he presents is a “slight abnormality” that has “no more than a minimal effect on [his] ability to work.” Id. Any doubt should be resolved in the claimant’s favor.Read the full opinion on CourtListener →
Subsection (c) requires the ALJ at step two to determine whether the claimant has a severe impairment or combination of impairments that significantly limits basic work activities; an impairment causing more than a minimal effect is severe.
Padilla v. Astrue · filed 2008-02-21(c)
The Commissioner has promulgated regulations establishing a five-step sequential evaluation process for the ALJ to follow in a disability case. 20 C.F.R. §§ 404.1520, 416.920. ... If not, in the Second Step, the ALJ must determine whether the claimant has a severe impairment or combination of impairments significantly limiting her from performing basic work activities. 20 C.F.R. §§ 404.1520(c), 416.920(c). ... The Step Two inquiry is “a de minimis screening device to dispose of groundless claims.” ... A severe impairment or combination of impairments within the meaning of Step Two exists when there is more than a minimal effect on an individual’s ability to do basic work activities. ... If a claimant meets his burden of demonstrating he suffers from an impairment affecting his ability to perform basic work activities, “the ALJ must find that the impairment is ‘severe’ and move to the next step in the SSA’s five-step process.”Read the full opinion on CourtListener →
Section 404.1520(c) requires the ALJ at step two to determine whether the claimant has a severe impairment, and a non-severe finding must be properly articulated and supported by substantial evidence.
Harris v. Astrue · filed 2008-02-29(c)
At step two of the sequential evaluation the ALJ must determine whether the claimant has a severe impairment. 20 C.F.R. § 404.1520(c). The burden at this step is on the claimant. ... [s]tep two is a threshold inquiry. It allows only claims based on the most trivial impairments to be rejected. ... An impairment is not severe only if the abnormality is so slight and its effect so minimal that it would clearly not be expected to interfere with the individual’s ability to work, irrespective of age, education or work experience. Claimant need show only that her impairment is not so slight and its effect is not so minimal. ... It is not for the reviewing court to say that a plaintiffs impairment is or is not trivial, only that the ALJ must properly justify his finding on that issue, and the ALJ’s findings must be supported by substantial evidence. ... The ALJ failed to properly articulate and justify his findings here.Read the full opinion on CourtListener →
Section 404.1520(c) requires an impairment to significantly limit a claimant’s physical or mental ability to do basic work activities to be considered severe at step two.
Giordano v. Astrue · filed 2008-12-04(c)
The ALJ and Appeals Council did not err in finding any alleged mental-impairment not severe. Giordano failed to meet her burden of proving that her alleged mental impairments “significantly limit[] [her] physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c) (2007).Read the full opinion on CourtListener →
Section 404.1520(c) requires the ALJ at Step Two to determine whether the claimant has a severe impairment or combination of impairments that significantly limits basic work activities.
Jimenez v. Astrue · filed 2009-02-23(c)
The Commissioner has promulgated regulations establishing a five-step sequential evaluation process for the ALJ to follow in a disability case. 20 C.F.R. §§ 404,1520, 416.920. In the First Step, the ALJ must determine whether the claimant is currently engaged in substantial gainful activity. 20 C.F.R. §§ 404.1520(b), 416.920(b). If not, in the Second Step, the ALJ must determine whether the claimant has a severe impairment or combination of impairments significantly limiting him from performing basic work activities. 20 C.F.R. §§ 404.1520(c), 416.920(c). If so, in the Third Step, the ALJ must determine whether the claimant has an impairment or combination of impairments that meets or equals the requirements of the Listing of Impairments (“Listing”), 20 C.F.R. Part 404, Subpart P, App. 1. 20 C.F.R. §§ 404.1520(d), 416.920(d). If not, in the Fourth Step, the ALJ must determine whether the claimant has sufficient residual functional capacity despite the impairment or various limitations to perform his past work. 20 C.F.R. §§ 404.1520(f), 416.920(f). If not, in Step Five, the burden shifts to the Commissioner to show the claimant can perform other work that exists in significant numbers in the national economy. 20 C.F.R. §§ 404.1520(g), 416.920(g).Read the full opinion on CourtListener →
At step two of the sequential disability evaluation, an ALJ must expressly consider whether a documented impairment is severe; silence about it is not a finding that it is non-severe.
Rupard v. Astrue · filed 2009-06-16(a)(4)(ii), (c)
After reviewing the entire record, we find that the ALJ’s failure to make a finding concerning the severity of Plaintiffs hand impairment requires that the case be remanded for further proceedings. ... There is no question that the ALJ did not expressly consider Plaintiffs alleged hand impairment at step two. The ALJ made no finding one way or the other concerning Plaintiffs hand impairment. This silence cannot be interpreted as a determination that Plaintiffs hand impairment is not “severe,” especially considering the fact that the ALJ expressly determined that Plaintiffs depression and drug and alcohol abuse are non-severe impairments.Read the full opinion on CourtListener →
At step two, the regulations require only one severe impairment to avoid denial of benefits and require the ALJ to proceed to the next step.
Dray v. Astrue · filed 2009-11-17(c), (a)(4)(ii)
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), 416.920(c). A claimant must make only a de minimis showing for her claim to advance beyond step two of the analysis. ... The reason is grounded in the Commissioner’s regulations describing step two, which state: “If you do not have a severe medically determinable physical or mental impairment . . . or a combination of impairments that is severe . . ., we will find that you are not disabled.” 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii) (emphasis added). By their plain terms, the regulations require a claimant to show only “a severe” impairment—that is, one severe impairment—in order to avoid a denial of benefits at step two. As long as the ALJ finds one severe impairment, the ALJ may not deny benefits at step two but must proceed to the next step.Read the full opinion on CourtListener →
At step two, § 404.1520(a)(4)(ii) requires the Commissioner to determine whether the claimant has a severe impairment, applying a de minimis threshold intended to screen out only totally groundless claims.
Nejat v. Commissioner of Social Securit · filed 2009-12-22(a)(4)(ii)
At step two, the Commissioner must determine whether the claimant has a severe impairment. See 20 C.F.R. § 404.1520(a)(4)(ii). This circuit construes the step two severity regulation as a “de minimis hurdle,” Rogers, 486 F.3d at 243 n.2 (internal quotation marks and citation omitted), intended to “screen out totally groundless claims.” Farris v. Sec’y of Health & Human Servs., 773 F.2d 85, 89 (6th Cir. 1985). Thus, if an impairment has “more than a minimal effect” on the claimant’s ability to do basic work activities, the ALJ must treat it as “severe.”Read the full opinion on CourtListener →
At step two, an impairment is severe when it significantly limits a claimant's physical or mental ability to perform basic work activities.
Bakewell v. Commissioner of Social Security Administration · filed 2010-01-04(c)
At step two of the sequential process for evaluating disability, 20 C.F.R. § 404.1520(a)(4)(ii), the ALJ concluded that Bakewell’s migraines were not a severe impairment. ... Accordingly, there is no substantial evidence supporting the ALJ’s position that Bakewell’s migraines do not “significantly limit[] [her] physical or mental ability to do basic work activities,” 20 C.F.R. § 404.1520(c), as the ALJ’s conclusion was based upon the erroneous factual finding that Bakewell’s migraines are under control.Read the full opinion on CourtListener →
At step two, a claimant must show that an impairment significantly limits the ability to perform basic work activities.
Halton v. Astrue · filed 2010-03-15(a)(4)(ii)
Under Step Two of the Commissioner's five-step evaluation process, a claimant has the burden of establishing that her impairment significantly limits her ability to perform basic work activities, that is, more than minimally impacts her ability to work.Read the full opinion on CourtListener →
At step two, § 404.1520 requires evaluating whether an impairment or combination is severe and meets the duration requirement; a severe impairment significantly limits basic work activities.
Norman v. Astrue · filed 2010-03-01(a)(4)(ii), (c)
At step two, the Commissioner considers whether a claimant has an impairment or combination of impairments that is severe and that meets the duration requirement. 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii). The Social Security Association has determined that a “severe impairment” is an impairment or combination of impairments that “significantly limit a claimant’s physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1520(c), 416.920(c).Read the full opinion on CourtListener →
At step two, a claimant is not disabled if she lacks a severe impairment that significantly limits her physical or mental ability to perform basic work activities.
Thelosen v. Commissioner of Social Security · filed 2010-06-17(c)
If the claimant is found not to have a severe impairment which significantly limits his or her physical or mental ability to do basic work activity, a finding of not disabled is directed. If there is a severe impairment, proceed to Step 3. ... After considering the medical evidence, the consultative reports, and the hearing testimony, the ALJ determined that the evidence did not support a finding, at step two of the sequential evaluation, that TheLosen had a severe impairment at a time that would qualify her to receive DIB or DAC benefits.Read the full opinion on CourtListener →
At step two of the disability evaluation, the claimant must establish a severe medically determinable physical or mental impairment.
Carrelli v. Comm'r of Social Security · filed 2010-07-23(a)(4)(ii)
To make a determination as to disability, an ALJ undertakes a five-step sequential evaluation mandated by regulation. Wilson v. Comm’r of Soc. Sec., 378 F.3d 541, 548 (6th Cir. 2004). First, the claimant must demonstrate that she has not engaged in substantial gainful activity during the claimed period of disability. 20 C.F.R. § 404.1520(a)(4)(i). Second, the claimant must show that she suffers from a severe medically determinable physical or mental impairment. § 404.1520(a)(4)(ii). ... At step two, Carrelli must show that she suffers from a severe medically determinable physical or mental impairment. 20 C.F.R. § 404.1520(a)(4)(ii). An impairment is not considered severe when it “does not significantly limit [one’s] physical or mental ability to do basic work activities.” § 404.1521(a). ... In the final analysis, we conclude that substantial evidence supported the ALJ’s conclusion that Carrelli does not suffer from a severe mental impairment.Read the full opinion on CourtListener →
At step two, § 404.1520(c) requires determining whether a claimant has a medically determinable impairment or combination of impairments that is severe.
Eovaldi v. Astrue · filed 2010-07-27(c)
At Step 2, the ALJ considers whether the claimant has a medically determinable impairment or combination of impairments that are severe. 20 C.F.R. § 404.1520(c). Severity is determined by whether the impairment or combination of impairments significantly limits the claimant’s ability to perform basic work activities; an impairment or combination of impairments is not severe when evidence establishes only a slight abnormality that would have only a minimal effect on the claimant’s ability to work. 20 C.F.R. § 404.1521; Social Security Ruling (“SSR”) 85-28, 1985 WL 56856 (S.S.A. 1985); SSR 96-3p, 1996 WL 374181 (S.S.A. July 2, 1996); SSR 96-4p, 1996 WL 374187 (S.S.A. July 2, 1996). ... The court fails to find evidence that the above-listed ailments could be considered severe enough to significantly limit Plaintiffs ability to perform basic work activities, and Plaintiff fails to guide the court to any records in support of his assertion. Accordingly, the court overrules Plaintiffs argument on this point.Read the full opinion on CourtListener →
At step two, an ALJ need find only one medically determinable severe impairment to satisfy the step-two requirement and proceed to the next step; failing to classify additional impairments as severe is not grounds for reversal.
Parise v. Astrue · filed 2010-11-30(a)(4)(ii)
At step two of the five-step sequential evaluation process, the ALJ determines whether the claimant has a medically determinable severe impairment or impairments. See 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii); see also Wall, 561 F.3d at 1052. An impairment is severe if it significantly limits a claimant’s physical or mental ability to perform basic work activities. See 20 C.F.R. §§ 404.1521, 416.921; see also Wall, 561 F.3d at 1052. Once an ALJ determines that the claimant suffers from one or more medically determinable severe impairments, he moves to the next step in the sequential evaluation process. ... Because the ALJ found that Ms. Parise had two medically determinable severe impairments, his failure to find her back, hip, and leg problems were severe impairments, is not grounds for reversal.Read the full opinion on CourtListener →
At step two, the Commissioner must determine whether the claimant has a medically severe impairment or combination of impairments; an impairment is severe if it limits the claimant’s ability to perform basic work activities.
Costa v. Astrue · filed 2010-09-30(c)
A severe impairment is one that limits a plaintiffs ability to perform basic work activities. 20 C.F.R. §§ 404.1520(c), 416.920(c).Read the full opinion on CourtListener →
At step two of the sequential evaluation, the ALJ must identify the claimant’s severe impairments.
Ramirez v. Astrue · filed 2011-03-29(a)(4)(ii)
At step two of the sequential evaluation process, an ALJ is tasked with identifying a claimant’s “severe” impairments. 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(h).Read the full opinion on CourtListener →
At step two, an impairment or combination of impairments is severe only if it significantly limits the claimant’s physical or mental ability to do basic work skills.
Williams v. Asture · filed 2011-03-03(c)
The claimant bears the burden of proving that she has a severe impairment or combination of impairments to demonstrate a qualifying disability. See Moore v. Barnhart, 405 F.3d 1208, 1211 (11th Cir. 2005) (holding that the regulations place “a very heavy burden” on the claimant to demonstrate a qualifying disability); Phillips v. Barnhart, 357 F.3d 1232, 1237 (11th Cir. 2004) (noting that the second step of the analysis requires the ALJ to consider the severity of the claimant’s impairments alone and in combination). Impairments, alone or in combination, are severe if they “‘significantly limit’ the claimant’s ‘physical or mental ability to do basic work skills.’” Phillips, 357 F.3d at 1237 (quoting 20 C.F.R. § 404.1520(c)). ... Moreover, because substantial evidence supports the ALJ’s finding that Williams did not have a severe psychotic disorder, such evidence also supports the ALJ’s decision not to consider her psychotic disorder in combination with her other impairments.Read the full opinion on CourtListener →
Section 404.1520(c) requires an impairment to significantly limit a claimant’s physical or mental ability to do basic work activities for the impairment to be considered severe at Step Two.
Gray v. Commissioner of Social Security · filed 2011-05-11(c)
We conclude that the ALJ did not apply an incorrect legal standard with regard to Step Two. The ALJ simply used the language of the regulations in stating that Gray’s impairments did not “significantly limit” her ability to perform basic work activities. See 20 C.F.R § 404.1520(c) (stating that, if the applicant does not have an impairment that “significantly limits [her] physical or mental ability to do basic work activities,” no severe impairment will be found); § 404.1521(a) (“An impairment . . . is not severe if it does not significantly limit [an applicant’s] physical or mental ability to do basic work activities.”).Read the full opinion on CourtListener →
Section 404.1520(c) treats an impairment as severe when it significantly limits a claimant’s physical or mental ability to perform basic work activities, and only the most trivial impairments may be rejected at step two.
Kuhl v. Commissioner of Social Security · filed 2011-10-14(c)
An impairment is “severe” if it “significantly limits [a] claimant’s physical or mental ability to do basic work activities.” Crayton v. Callahan, 120 F.3d 1217, 1219 (11th Cir. 1997); 20 C.F.R. §§ 404.1520(c), 416.920(c). “Basic work activities” include: physical functions such as walking, standing, sitting, lifting, pulling, reaching, carrying or handling; capacities for seeing, hearing and speaking; understanding, carrying out and remembering simple instructions; use of judgment; responding appropriately to supervision, coworkers and usual work situations; and dealing with changes in a routine work setting. 20 C.F.R. §§ 404.1521(b), 416.921(b). “An impairment can be considered as not severe only if it is a slight abnormality which has such a minimal effect on the individual that it would not be expected to interfere with the individual’s ability to work, irrespective of age, education, or work experience.” McCruter v. Bowen, 791 F.2d 1544, 1546 (11th Cir. 1986). The claimant’s “burden at step two is mild” and “allows only claims based on the most trivial impairments to be rejected.”Read the full opinion on CourtListener →
At step two, the regulation requires determining whether the claimant has a severe impairment or combination of impairments.
Galarza v. Astrue · filed 2011-10-24(a)(4)(ii)
The ALJ’s statements regarding the conflicting medical opinions, Galarza’s sporadic treatment history, and inconsistencies in Galarza’s testimony regarding his pain provide a specific and legitimate basis to determine that Galarza does not have a severe impairment under step two of the five step sequential process. See 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii) (2010).Read the full opinion on CourtListener →
At step two, § 404.1520(a)(4)(ii) requires determining whether the claimant has a severe impairment; conflicting medical opinions, sporadic treatment, and inconsistent pain testimony can support a finding that the claimant does not.
Galarza v. Astrue · filed 2011-10-24(a)(4)(ii)
The ALJ’s statements regarding the conflicting medical opinions, Galarza’s sporadic treatment history, and inconsistencies in Galarza’s testimony regarding his pain provide a specific and legitimate basis to determine that Galarza does not have a severe impairment under step two of the five step sequential process. See 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii) (2010). The ALJ correctly applied the law and his decision was supported by substantial evidence. See Thomas v. Barnhart, 278 F.3d 947, 957 (9th Cir. 2002).Read the full opinion on CourtListener →
Section 404.1520(a)(4)(ii) requires a claimant to establish at least one severe impairment at step two to avoid a finding of not disabled and proceed to the later steps.
Burk v. Astrue · filed 2012-08-06(a)(4)(ii)
At step two, a claimant is required to show that she has at least one severe impairment to avoid a finding of “not disabled” and proceed to the other steps in the sequential process. See 20 C.F.R. § 404.1520(a)(4)(ii) (“If you do not have a severe medically determinable physical or mental impairment . . . or a combination of impairments that is severe . . . , we will find that you are not disabled.” (emphasis added)); cf. Lax, 489 F.3d at 1084 (“If a determination can be made at any of the steps that a claimant . . . is not disabled, evaluation under subsequent steps is not necessary.” (quotation omitted)). Here, Ms. Burk met her burden at step two as the ALJ determined that she had three severe impairments. He was therefore obligated to continue to the next step of the sequential process and he did so.Read the full opinion on CourtListener →
At step two, § 404.1520(c) requires deciding whether the claimant’s impairment or combination of impairments is severe, meaning it significantly limits basic work activities.
Balaguer v. Astrue · filed 2012-07-31(c)
At the second step of the sequential evaluation analysis, the hearing officer is required to determine whether the claimant’s impairment or combination of impairments is severe, meaning that the impairments significantly limit the claimant’s physical or mental ability to do basic work activities.Read the full opinion on CourtListener →
At step two, a medically diagnosed impairment is severe only when evidence shows that it significantly limits the claimant’s physical or mental ability to perform basic work activities.
Grady v. Astrue · filed 2012-09-28(c)
It is not enough for Plaintiff to be diagnosed with certain impairments: Plaintiff must provide evidence that these impairments “significantly limit[] [his] physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c).Read the full opinion on CourtListener →
Section 404.1520(c) requires a claimant to have a severe impairment or combination of impairments that significantly limits the ability to perform basic work activities to pass step two of the disability evaluation.
Guardado v. Astrue · filed 2013-02-14(c)
The second step of the Social Security Administration’s five-step disability evaluation screens out claimants who do not have a “severe impairment” or “combination of impairments” that significantly limits the claimant’s “physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c). ... The administrative law judge (“ALJ”) determined that Guardado did not establish a severe impairment or combination of impairments present for at least twelve months. This conclusion is supported by substantial evidence.Read the full opinion on CourtListener →
Section 404.1520(a)(4)(ii) requires the ALJ to determine at step two whether the claimant has a severe impairment, and any severe impairment is enough to satisfy that step.
Sanchez v. Commissioner of Social Security · filed 2013-02-08(a)(4)(ii)
At step two, the ALJ must make a “threshold inquiry” as to the medical severity of the claimant’s impairments. McDaniel v. Bowen, 800 F.2d 1026, 1031 (11th Cir. 1986); see 20 C.F.R. §§ 404.1520(a)(4)(ii), (c), 404.1520a(a), 404.1523, 416.920(a)(4)(ii), (c), 416.920a(a), 416.923. “[T]he finding of any severe impairment, whether or not it qualifies as a disability and whether or not it results from a single severe impairment or a combination of impairments that together qualify as severe, is enough to satisfy the requirement of step two.”Read the full opinion on CourtListener →
Section 404.1520 requires a five-step sequential inquiry for disability claims, including a step-two determination of whether the claimant has a severe medical impairment.
Perez v. Commissioner Social Security · filed 2013-03-27(c)
Under this framework, the Commissioner inquires whether the applicant: (1) is engaged in a substantial gainful activity; (2) has a “severe” medical impairment; (3) suffers from an impairment that is listed in the regulation‟s appendix; (4) can still perform past relevant work; and (5) can perform any other work existing in significant numbers in the national economy. See id. (citing 20 C.F.R. § 404.1520). ... We agree with the District Court, however, that if the ALJ erred by not explicitly applying the de minimis standard at step two, such error was harmless because the record is devoid of evidence that Appellant suffered from any disability prior to June 30, 1988.Read the full opinion on CourtListener →
At step two, § 404.1520(c) requires a medically determinable impairment to significantly limit a claimant’s physical or mental ability to do basic work activities.
Maiorano v. Astrue · filed 2013-03-13(c)
The severe impairment standard at step two of the analysis requires evidence that a claimant’s medically determinable impairment “significantly limits [her] physical or mental ability to do basic work activities”. 20 C.F.R. § 404.1520(c).Read the full opinion on CourtListener →
At step two, an impairment is severe only if it significantly limits the claimant’s physical or mental ability to perform basic work activities.
Smith v. Astrue · filed 2013-07-05(c)
Rather, a claimant is required to show that his diagnosis “significantly limit[s] his physical or mental ability to do basic work activities.” Foley, 349 Fed.Appx. at 808 (citing 20 C.F.R. §§ 404.1520(c), 404.1521(a)).Read the full opinion on CourtListener →
Section 404.1520(a)(4)(ii) requires the adjudicator to determine at step two whether the claimant has a severe impairment or combination of impairments.
Smith v. Commissioner of Social Security · filed 2013-09-11(a)(4)(ii)
At this step, the ALJ must make a “threshold inquiry” as to the medical severity of the claimant’s impairments. ... In addition, an impairment is not severe if it does not significantly limit the claimant’s ability to do basic work activities, which are defined as “the abilities and aptitudes necessary to do most jobs.” ... We conclude that substantial evidence supports the ALJ’s decision that Smith is not mentally retarded because she presented no evidence that her IQ limited her ability to do basic work activities.Read the full opinion on CourtListener →
Section 404.1520(c) makes step two a threshold inquiry: an impairment is severe when it significantly limits basic work activities, and a step-two error is harmless when the ALJ considers the impairment later in the sequential process.
Gray v. Commissioner of Social Security · filed 2013-12-30(c)
Step two is a threshold inquiry that “allows only claims based on the most trivial impairments to be rejected.” ... To show a “severe” impairment, a claimant must show “any impairment or combination of impairments which significantly limits [her] physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1520(c), 416.920(c); see id. §§ 404.1521(b), 416.921(b) (defining the ability to perform basic work activities as “the abilities and aptitudes necessary to do most jobs,” examples of which including walking, standing, sitting, and responding appropriately to usual work situations). ... If any impairment or combination of impairments is qualifies as “severe,” step two is satisfied and the claim advances to step three. ... Here, we need not consider whether substantial evidence supports the ALJ’s conclusion at step two -- that Gray’s cervical spine impairment was not a severe impairment -- because even if there was error, it would be harmless. In assessing Gray’s RFC, the ALJ found that Gray had severe impairments and that the step two test was satisfied, and then specifically considered and discussed the symptoms that Gray alleged stemmed from a cervical spine impairment elsewhere in the five-step sequential process. ... The ALJ thus performed the analysis that would have been required had he determined a cervical spine impairment was severe at step two. ... Accordingly, even if the ALJ erred at step two, any error was harmless.Read the full opinion on CourtListener →
The regulation requires a severe medically determinable impairment as a threshold for disability benefits; once at least one impairment meets that threshold, the ALJ proceeds to assess residual functional capacity using all relevant evidence about the claimant's impairments and related symptoms.
Dimter v. Commissioner Social Security · filed 2024-12-05(a)(4)(ii)
A “severe medically determinable” impairment is a threshold requirement for obtaining disability benefits. 20 C.F.R. § 404.1520(a)(4)(ii). But if at least one impairment meets that threshold, the ALJ proceeds to evaluate the claimant’s “residual functional capacity” in light of “all the relevant evidence in [the] case record” regarding the claimant’s “impairment(s), and any related symptoms.” § 404.1545.Read the full opinion on CourtListener →
Section 404.1520(a)(4)(ii) requires the ALJ to assess the medical severity of a claimant’s impairments at step two; failure to classify one impairment as severe is harmless when the ALJ finds another severe impairment and proceeds to the next step.
Michel v. Commissioner of Social Security · filed 2024-12-06(a)(4)(ii)
At step two, the ALJ must consider the medical severity of a claimant’s impairments. 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii). ... To the extent Plaintiff seeks remand because the ALJ’s failed to classify her knee impairments as severe, any such error is harmless. The ALJ found that Plaintiff had other severe impairments and properly proceeded to step three of the sequential analysis (Tr. 106).Read the full opinion on CourtListener →
Section 404.1520(c) requires an impairment to significantly limit basic work activities to qualify as severe.
Berryman v. Massanari · filed 2001-08-01(c)
The second part of the Listing, therefore, imposes a less stringent requirement than that imposed by 20 C.F.R. § 404.1520(c), which sets forth the five-step sequential process by which a disability claim is evaluated. Section 404.1520(c) defines “severe impairment” to require that the impairment or combination of impairments significantly limit the claimant’s physical or mental ability to do basic work activities. Listing 12.05C only requires a “more than slight or minimal” limitation.Read the full opinion on CourtListener →
Step-two harmless-error rule
Section 404.1520(c) treats an impairment as severe at step two only when it significantly limits the claimant’s physical or mental ability to perform basic work activities.
Sawyer v. Colvin · filed 2014-02-03(c)
A severe impairment is one that “significantly limits [a claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1520(c), 416.920(c). A non-severe impairment is defined as one that “does not significantly limit [a claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1521(a), 416.921(a). A severe impairment “must result from anatomical, physiological, or psychological abnormalities which can be shown by medically acceptable clinical and laboratory diagnostic techniques. A physical or mental impairment must be established by medical evidence consisting of signs, symptoms, and laboratory findings, not only by your statement of symptoms[.]” 20 C.F.R. §§ 404.1508, 416.908. It is the claimant’s burden to prove that she suffers from a medically-severe impairment.Read the full opinion on CourtListener →
Section 404.1520(c) treats an impairment as severe when it significantly limits a claimant’s physical or mental ability to perform basic work activities.
Morris v. Colvin · filed 2014-02-26(c)
A “severe” impairment is one that significantly limits a claimant’s physical or mental ability to do basic work activities. 20 C.F.R. §§ 404.1520(c), 416.920(c).Read the full opinion on CourtListener →
At step two, an impairment is severe if it significantly limits a claimant’s physical or mental ability to do basic work activities; it may be found not severe only when the evidence shows a slight abnormality with no more than a minimal effect on ability to work.
Russell v. Colvin · filed 2014-03-27(c)
At step two, the claimant must present evidence of at least one impairment that “significantly limits [a claimant’s] physical or mental ability to do basic work activities.” ... “An impairment may be found not severe only if the evidence establishes a slight abnormality that has no more than a minimal effect on an individual’s ability to work.” ... The ALJ’s finding that Ms. Russell’s mental limitations were not severe was not harmless, as argued by the Commissioner. Had Dr. Hughey’s identification of “marked” mental limitations been recognized as establishing depression as a severe impairment at step two, and subsequently in determining Ms. Russell’s RFC, the VE testified such limitations would have precluded employment at all jobs. AR 77-78.Read the full opinion on CourtListener →
At step two, a claimant must establish a severe impairment or combination of impairments that significantly limits the claimant’s physical or mental ability to perform basic work.
Woodmancy v. Colvin · filed 2014-09-02(a)(4)(ii)
Woodmancy contends that Administrative Law Judge (“ALJ”) Elizabeth W. Koennecke erred at step two of the disability analysis, see 20 C.F.R. § 404.1520(a)(4)(ii), in finding that between June 15, 2009, and January 27, 2011, the period at issue, Woodmancy was severely impaired by substance abuse, depression, and facet anthropathy, but not by anemia, sleep apnea, and chronic pancreatitis. A claimant has the burden of establishing that she has a “severe impairment,” which is “any impairment or combination of impairments which significantly limits [her] physical or mental ability to do basic work.” 20 C.F.R. § 416.920(c); see Green-Younger v. Barnhart, 335 F.3d 99, 106 (2d Cir. 2003). ... For the reasons set forth in the district court’s thorough opinion, see Woodmancy v. Colvin, No. 5:12-CV-991 GLS, 2013 WL 5567553, at *2 (N.D.N.Y. Oct. 9, 2013), we conclude that substantial evidence supports the agency determination that Woodmancy did not carry her burden of demonstrating that these conditions were severe impairments.Read the full opinion on CourtListener →
Section 404.1520 requires a step-two determination of whether the claimant has a medically determinable impairment that is severe, meaning it significantly limits or is expected to significantly limit basic work-related activities for twelve consecutive months.
López-González v. Commissioner of Social Security · filed 2014-09-19(a)(4)(ii), (c)
Step two demands a determination of two things: (1) whether a claimant has a medically determinable impairment or combination of impairments, and (2) whether the impairments or combination of impairments is severe, that is, that significantly limits or is expected to significantly limit the ability to perform basic work-related activities for twelve consecutive months.Read the full opinion on CourtListener →
At step two, § 404.1520(c) treats an impairment as severe only if it significantly limits the claimant’s ability to perform work activities; when it imposes no vocational restriction, further RFC analysis is unnecessary.
Mendez v. Colvin · filed 2014-10-21(c)
As for Mr. Mendez’s obesity, the ALJ recognized that Mr. Mendez was “an obese individual.” Id. at 23. She determined, however, that his obesity was not a severe impairment because it “did not require treatment or result in vocationally relevant limitations.” Id.; see also 20 C.F.R. §§ 404.1520(c), 416.920(c) (requiring that an impairment or combination of impairments significantly limit the claimant’s ability to do work activities). Mr. Mendez correctly contends that the ALJ still was required to consider the combined effects of his obesity and other impairments, see Wells v. Colvin, 727 F.3d 1061, 1065 (10th Cir. 2013), but the ALJ’s finding that his obesity posed no vocational limitations obviated the need for further analysis of Mr. Mendez’s obesity in assessing his RFC, see id. at 1065 n.3 (explaining that an ALJ’s finding at step two that an impairment poses no restriction to the claimant’s work activities obviates the need for further analysis at step four); see also Burch v. Barnhart, 400 F.3d 676, 683-84 (9th Cir. 2005) (holding that obesity without attending functional limitations was adequately considered by ALJ even though it was not expressly incorporated into RFC).Read the full opinion on CourtListener →
At step two, a claimant must show that an impairment or combination of impairments significantly limits the ability to do basic work; the court upheld the finding that Woodmancy’s anemia, sleep apnea, and chronic pancreatitis were not severe impairments.
Woodmancy v. Colvin · filed 2014-09-02(a)(4)(ii)
Woodmancy contends that Administrative Law Judge (“ALJ”) Elizabeth W. Koennecke erred at step two of the disability analysis, see 20 C.F.R. § 404.1520(a)(4)(ii), in finding that between June 15, 2009, and January 27, 2011, the period at issue, Woodmancy was severely impaired by substance abuse, depression, and facet anthropathy, but not by anemia, sleep apnea, and chronic pancreatitis. ... Woodmancy argues that her anemia, sleep apnea, and chronic pancreatitis were severe impairments because they required ongoing treatment and caused her functional limitations, pain, and fatigue. For the reasons set forth in the district court’s thorough opinion, see Woodmancy v. Colvin, No. 5:12-CV-991 GLS, 2013 WL 5567553, at *2 (N.D.N.Y. Oct. 9, 2013), we conclude that substantial evidence supports the agency determination that Woodmancy did not carry her burden of demonstrating that these conditions were severe impairments.Read the full opinion on CourtListener →
At step two, an impairment is severe only if it significantly limits a claimant’s physical or mental ability to do basic work activities.
Brown v. Colvin · filed 2015-02-11(c)
Contrary to Brown’s contention, the ALJ did not err at step two of the sequential evaluation when the ALJ did not identify pes planus (flat foot), regional pain syndrome, and foot and ankle pain among Brown’s severe impairments. There was no evidence that pes planus significantly limited Brown’s ability to do basic work activities. See 20 C.F.R. § 404.1520(c) (defining “severe impairment” as “any impairment or combination of impairments which significantly limits [one’s] physical or mental ability to do basic work activities”).Read the full opinion on CourtListener →
Section 404.1520(c) treats an impairment as severe only when it significantly limits a claimant’s physical or mental ability to perform basic work activities.
Brown v. Colvin · filed 2015-02-11(c)
Contrary to Brown’s contention, the ALJ did not err at step two of the sequential evaluation when the ALJ did not identify pes planus (flat foot), regional pain syndrome, and foot and ankle pain among Brown’s severe impairments. There was no evidence that pes planus significantly limited Brown’s ability to do basic work activities. See 20 C.F.R. § 404.1520(c) (defining “severe impairment” as “any impairment or combination of impairments which significantly limits [one’s] physical or mental ability to do basic work activities”).Read the full opinion on CourtListener →
At step two, § 404.1520(c) treats an impairment as severe only if it significantly limits a claimant’s ability to perform basic work activities.
Wilhelm v. Commissioner of Social Security Administration · filed 2015-03-13(c)
Substantial evidence supports the Administrative Law Judge’s (ALJ) determination that Wilhelm’s foot condition was not a severe impairment. Considering the medical evidence, including the lack of any significant treatment records for Wilhelm’s foot after 2006, the ALJ reasonably inferred that Wilhelm’s foot impairment did not significantly limit her ability to do basic work activities. 20 C.F.R. § 404.1520(c); Molina, 674 F.3d at 1111 (“Even when the evidence is susceptible to more than one rational interpretation, we must uphold the ALJ’s findings if they are supported by inferences reasonably drawn from the record.”).Read the full opinion on CourtListener →
At step two, an impairment is severe if it significantly limits the claimant’s physical or mental ability to perform basic work activities; otherwise, the claim is denied.
Rascoe v. Commissioner of Social Security · filed 2015-05-07(c)
The second inquiry is whether the claimant has a “severe impairment,” meaning an “impairment or combination of impairments which significantly limits [her] physical or mental ability to do basic work activities[.]” 20 C.F.R. § 404.1520(c). If not, the claimant is considered not disabled and the application for benefits is denied.Read the full opinion on CourtListener →
At step two, the claimant must establish a severe medically determinable impairment and bears the burden of production and proof.
Bowers v. Colvin · filed 2015-10-08(a)(4)(ii)
This appeal concerns the ALJ’s determination at step two of that procedure, under which Bowers was required to show “a severe medically determinable physical or mental impairment . . . or a combination of impairments that is severe.” 20 C.F.R. § 404.1520(a)(4)(ii). Significant for purposes of our analysis, the claimant bears the burden of production and proof to show that he suffers from a severe medically determinable impairment.Read the full opinion on CourtListener →
At step two, § 404.1520(a)(4)(ii) requires only one severe medically determinable impairment, or one severe impairment in combination with others, to avoid denial of benefits and proceed to the next step.
Allman v. Colvin · filed 2016-02-23(a)(4)(ii)
The reason is grounded in the Commissioner’s regulation describing step two, which states: “If you do not have a severe medically determinable physical or mental impairment . . . or a combination of impairments that is severe . . . , we will find that you are not disabled.” 20 C.F.R. § 404.1520(a)(4)(ii) (emphasis added). By its plain terms, the regulation requires a claimant to show only “a severe” impairment—that is, one severe impairment—to avoid a denial of benefits at step two. Id. (emphasis added). As long as the ALJ finds one severe impairment, the ALJ may not deny benefits at step two but must proceed to the next step.Read the full opinion on CourtListener →
At step two, the claimant must have a severe impairment to proceed through the sequential evaluation.
Marovich v. Colvin · filed 2016-03-24(a)(4)(ii)
However, the ALJ did specifically consider that impairment3 and determined that, based on the evidence before him, any impairment was too mild to be considered severe.Read the full opinion on CourtListener →
Section 404.1520(a) establishes a five-step disability analysis, including a Step Two determination whether the claimant has a severe medically determinable impairment or combination of impairments.
Therrien v. SSA · filed 2017-04-21(a)
At Step Two, the ALJ must determine whether the claimant has a medically determinable impairment or a combination of impairments that is severe. § 404.1520(a)(4)(ii). The severity requirement is a threshold test “designed to do no more than screen out groundless claims.” ... Nevertheless, to be severe within the meaning of the regulations, the impairment or combination of impairments must significantly limit the claimant’s “physical or mental ability to do basic work activities.” § 404.1520(c). Errors at Step Two are harmless as long as the ALJ found at least one severe impairment, continued on with the sequential analysis, and considered the effect of all impairments on the claimant’s functional capacity. See Fortin v. Colvin, No. 3:16-cv-30019-KAR, 2017 WL 1217117, at *10 (D. Mass. Mar. 31, 2017).Read the full opinion on CourtListener →
At step two, § 404.1520(a)(4)(ii) requires the ALJ to determine whether the claimant has a severe impairment or combination of impairments; after finding one, the ALJ proceeds to step three.
Barrett v. Commissioner of Social Security · filed 2017-09-14(a)(4)(ii)
At step two of the sequential evaluation process, the ALJ must determine whether the claimant has an impairment, or combination of impairments, that is severe. 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii). “An impairment is considered ‘severe’ if it significantly limits a claimant’s ability to do work-related activities.” Miller v. Colvin, No. 2:13–cv–31251, 2015 WL 917772, at *11 (N.D. W. Va. Mar. 3, 2015) (citing 20 C.F.R. §§ 404.1520(a), 416921(a); SSR 96–3p, 1996 WL 374181, at *1 (July 2, 1996)). If the ALJ determines that the claimant suffers from one severe impairment, or combination of impairments, the ALJ must proceed to the third step of the evaluation process. Miller, 2015 WL 917772, at *11. Because the ALJ determined that Plaintiff suffers from two severe mental impairments (affective and anxiety disorders), the ALJ properly proceeded to step three of the sequential evaluation process.3 R. 22–23.Read the full opinion on CourtListener →
Section 404.1520(a)(4)(ii) ends the sequential evaluation at step two when the claimant lacks a severe impairment or combination of impairments that significantly limits basic work activities.
Steele v. Colvin · filed 2017-09-28(a)(4)(ii)
At step two, if the claimant does not have a severe impairment or combination of impairments that significantly limits the claimant from performing basic work activities, the claim is denied. See 20 C.F.R. §§ 404.1520(a)(4)(ii) & (c), 404.1521. After evaluating all medical records and Steele’s testimony, the ALJ found that Steele’s medically determinable impairment of scoliosis was not severe within the meaning of the regulations at any time on or before her DLI of December 31, 2010. (Tr. 22-25). That finding ended the sequential evaluation and, thus, the ALJ found that Steele was not disabled within the meaning of the Act during the period at issue, which was December 1, 2005 through her DLI of December 31, 2010. (Tr. 25).Read the full opinion on CourtListener →
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.
Garcia v. Nancy Berryhill, Acting Cmsnr · filed 2017-11-30(c)
The regulations define a severe impairment as “any impairment or combination of impairments which significantly limits [one’s] physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c). This court considers a “slight abnormality” to be non-severe wherever it has “such minimal effect on that individual that it would not be expected to interfere with the individual’s ability to work.”Read the full opinion on CourtListener →
Section 404.1520 requires evaluation of impairment severity at step two and ends the sequential evaluation with a finding of not disabled when the claimant has no severe impairment.
Gorman v. Berryhill · filed 2017-11-30(a)(4)(ii)
To establish a severe mental impairment, the claimant must furnish objective medical and other evidence proving that her mental impairments resulted in either repeated episodes of decompensation or extended duration, or in more than a mild limitation of daily living, social functioning, and concentration, persistence, or pace. 20 C.F.R. § 404.1520(a)(d)(1). If a claimant has no severe impairments, the sequential evaluation process terminates at step two and the claimant is found not disabled. 20 C.F.R. § 404.1520(a)(4)(ii).Read the full opinion on CourtListener →
At step two, the sequential evaluation determines whether a claimant’s impairments are severe; if a claimant has no severe impairments, the process ends and the claimant is found not disabled.
Fain v. Berryhill · filed 2018-03-01(a)(4)(ii)
The ALJ evaluates whether the claimant’s impairments are severe at the second step of the sequential evaluation process. 20 C.F.R. § 404.1520(a)(4)(ii). ... If a claimant has no severe impairments, the sequential evaluation process terminates at step two and the claimant is found not disabled. 20 C.F.R. § 404.1520(a)(4)(ii).Read the full opinion on CourtListener →
Section 404.1520(c) treats an impairment as severe when it significantly limits a claimant’s physical or mental ability to perform basic work activities.
Christofferson v. Berryhill · filed 2018-03-06(c)
These records relate back to the pre-decision era and provide a clear explanation for Ms. Christofferson’s chronic pain. Supported by pre-decision records, as well as those following in close proximity over the next several months, the diagnoses by Drs. Bassing and Dietrich show Ms. Christofferson’s impairment “significantly limits [her] physical and mental ability to do basic work activities.” 20 CFR § 404.1520(c). The longitudinal medical records support the conclusion Ms. Christofferson’s fibromyalgia has lasted longer than 12 months. 20 CFR § 404.1509. Her fibromyalgia constitutes a severe impairment. 20 CFR § 404.1521.Read the full opinion on CourtListener →
Section 404.1520(a)(4)(ii) and (c) require the ALJ at Step Two to assess the severity of impairments, with a severe impairment being one that significantly limits the claimant’s ability to perform basic work activities.
Thompson · filed 2018-03-07(a)(4)(ii), (c)
Step Two of the sequential evaluation requires the ALJ to “consider the medical severity of [a claimant’s] impairment(s).” 20 C.F.R. § 404.1520(a)(4)(ii). The claimant bears the burden at this step to show that she has a severe impairment. See Bowen v. Yuckert, 482 U.S. 137, 146 n.5 (1987). A severe impairment is one that “significantly limits [a clatmant’s] physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c). ... The mere presence or diagnosis of a condition is insufficient to meet Thompson’s burden at Step Two; rather, she must show how it significantly limits her ability to do basic work activities. See 20 C.F.R. § 404.1520(c); Bowen, 482 US. at 146 n.5; see also Higgs v. Bowen, 880 F.2d 860, 863 (6th Cir. 1988) (noting that “[t]he mere diagnosis of [an impairment], of course, says nothing about the severity of the condition’’); Washington v. Astrue, 698 F. Supp. 2d 562, 580 (D.S.C. 2010) (“Plaintiffs medical records establish the existence of her impairment, but the current record contains no evidence of how it significantly limits her physical or mental ability to do basic work activities.”).Read the full opinion on CourtListener →
At step two, a claimant is not disabled if the claimant lacks a severe impairment or combination of impairments.
Davenport v. Colvin · filed 2018-03-07(c)
Step two considers whether the plaintiff has a medically determinable impairment that is severe, or a combination of impairments that is severe as defined by the pertinent regulations. 20 CFR § 404.1520(c). A plaintiff who does not have an impairment that is severe is not disabled. ... The court also finds in that regard that the ALJ did not err when he determined on this record that the evidence did not show that the plaintiff suffered from a severe impairment. See e.g., Teague, 151 F. Supp. 3d at 226.Read the full opinion on CourtListener →
Section 404.1520(c) treats an impairment as severe at step two only when it significantly limits the claimant’s physical or mental ability to do basic work activities.
Topoulos v. Colvin · filed 2018-03-16(c)
The second inquiry is whether the claimant has a “severe impairment,” meaning an “impairment or combination of impairments which significantly limits [her] physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1520(c), 416.920(c). ... This court finds that the ALJ’s determination that Topoulos’ mental impairments are not severe is supported by substantial evidence.Read the full opinion on CourtListener →
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.
Lujan v. Berryhill · filed 2018-03-31(c)
A severe impairment is one that "significantly limits" a claimant's "physical or mental ability to do basic work activities."Read the full opinion on CourtListener →
Section 404.1520(c) directs the Commissioner not to consider a claimant’s age, education, or work experience when determining whether the claimant has a severe impairment at step two, and the court held that the provision was effective August 24, 2012.
Fabian v. Nancy Berryhill, Acting Cmsnr · filed 2018-06-05(c)
Fabian also argues that the Commissioner erroneously applied the incorrect federal regulation, because 20 C.F.R. § 404.1520(c)—preventing consideration of education and work experience at step two of the disability analysis—was not effective until March 2017. She contends that these regulations are not retroactive, so the Commissioner’s decision violated her constitutional right to Due Process. But this regulation became effective August 24, 2012; so Fabian’s argument is unavailing. See 20 C.F.R. § 404.1520(c).Read the full opinion on CourtListener →
Section 404.1520(a)(4)(ii) requires a step-two determination of whether the claimant has a severe impairment or combination of impairments that significantly limits basic work activities; an error in classifying an impairment at that step is harmless when the evaluation proceeds to later steps.
Kiely v. Berryhill · filed 2018-07-25(a)(4)(ii)
As discussed supra, the ALJ must determine whether the claimant has a severe impairment or combination of impairments that limits her ability to perform basic work activities. See 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii). ... Finally, it is important to note that the ALJ’s alleged error in not finding Kiely’s osteoarthritis and back pain as severe impairments is harmless. Had the ALJ denied Kiely’s claim for benefits at step two, the ALJ’s impairment determination could be reviewed. However, at step two, the ALJ “concluded that [she] could not be denied benefits conclusively . . . and proceeded to the next step of the evaluation sequence[,]” rendering any step two challenge moot.Read the full opinion on CourtListener →
Section 404.1520(a)(4)(ii) and (c) require treating an impairment as severe only when it significantly limits the claimant’s ability to perform basic work activities; a slight abnormality that does not do so is not severe.
Hobbs v. Berryhill · filed 2018-08-21(a)(4)(ii), (c)
At step two, the ALJ must determine “whether the claimant has an impairment or combination of impairments that significantly limits the claimant’s ability to perform basic work activities.” Page v. Astrue, 484 F.3d 1040, 1043 (8th Cir. 2007); accord 20 C.F.R. §§ 404.1520(a)(4)(ii), 404.1521, 416.920(a)(4)(ii). If an impairment only amounts to a “slight abnormality that would not significantly limit the claimant’s physical or mental ability to do basic work activities,” then the impairment is “not severe.” Kirby v. Astrue, 500 F.3d 705, 707 (8th Cir. 2007).Read the full opinion on CourtListener →
At step two, § 404.1520 requires an impairment or combination of impairments to significantly limit basic work activities; a slight abnormality that does not do so is not severe.
Hocking v. Berryhill · filed 2018-08-28(a)(4)(ii)
At step two, the ALJ must determine “whether the claimant has an impairment or combination of impairments that significantly limits the claimant’s ability to perform basic work activities.” ... If an impairment only amounts to a “slight abnormality that would not significantly limit the claimant’s physical or mental ability to do basic work activities,” then the impairment is “not severe.”Read the full opinion on CourtListener →
At step two, an impairment is severe when it significantly limits a claimant’s physical or mental ability to do basic work activities; an erroneous finding that one impairment is non-severe is harmless when the evaluation proceeds past step two based on other severe impairments and the impairment’s effects are considered in the RFC.
Moffitt v. Nancy A. Berryhill, Acting Commissioner, Social Security Administration · filed 2018-09-05(c)
First of all, if the ALJ erred in determining that Moffitt’s CTS was not a severe impairment, that error would have been harmless because the ALJ found two other impairments to be severe, continued the sequential evaluation past step two, and considered the effects of her CTS when formulating her RFC.Read the full opinion on CourtListener →
Section 404.1520 requires disability claims to be evaluated through a five-step sequence, including a step-two finding that the claimant has a severe impairment or combination of impairments.
Moorer v. Berryhill · filed 2018-09-11(c)
The Social Security regulations provide a five-step sequential evaluation process for determining if a claimant has proven his disability. 20 C.F.R. §§ 404.1520, 416.920. The claimant must first prove that he or she has not engaged in substantial gainful activity. The second step requires the claimant to prove that he or she has a severe impairment or combination of impairments. ... The ALJ determined that Plaintiff’s CRPS did not cause significant functional limitations that would significantly limit his ability to perform basic work activities and, thus, that the condition was non-severe. Having carefully reviewed the record, the Court agrees that substantial evidence supports the ALJ’s finding that Plaintiff’s CRPS is non-severe and that the ALJ did not err in failing to evaluate Plaintiff’s CRPS under SSR 03-2p.Read the full opinion on CourtListener →
At step two, an impairment is severe only if it significantly limits the claimant’s physical or mental ability to do basic work activities.
York v. Berryhill · filed 2018-11-14(c)
“A severe impairment is an impairment or combination of impairments that ‘significantly limits [one’s] physical or mental ability to do basic work activities.’” Id. (quoting 20 C.F.R. § 404.1520(c)); see also SSR 96-3P, 1996 WL 374181 (July 2, 1996). ... “Reviewing the medical records and Virginia’s hearing testimony, the court finds that there is substantial evidence to support the ALJ’s non-severity finding as to sleep apnea.” ... “The record refers generally to a previous diagnosis of obstructive sleep apnea, (A.R. 530, 579, 1162, 1253), but lacks any objective evidence that the condition limits Virginia’s ability to work in any way, let alone significantly, see 20 C.F.R. § 404.1520(c); see also Colson, 120 F. Supp. 3d at 788.”Read the full opinion on CourtListener →
At step two, § 404.1520(c) treats an impairment as severe when it significantly limits basic work activities; a slight abnormality with no more than minimal effect is not severe.
Wheatman v. Colvin · filed 2018-11-27(c)
At step two, the ALJ must determine whether the claimant has an impairment or combination of impairments that significantly limits his ability to perform basic work-related activities for 12 consecutive months. 20 C.F.R. §§ 404.1521 et seq., 416.909. A severe impairment is one that “significantly limits [the claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c). It is not severe if evidence establishes only a “slight abnormality or a combination of slight abnormalities which would have no more than a minimal effect on an individual's ability to work.” ... Because the ALJ adequately supported his conclusion that Wheatman did not suffer an impairment or combination of impairments that significantly limited his ability to perform basic work-related activities for 12 consecutive months prior to his applying for DIB, the Court affirms the ALJ’s decision.Read the full opinion on CourtListener →
At Step Two, the regulation requires a claimant to have a severe medically determinable impairment, or combination of impairments, that satisfies the duration requirement.
Tarr v. Nancy A. Berryhill, Acting Commissioner, Social Security Administration · filed 2019-03-04(a)(4)(ii)
At Step Two, the ALJ must determine whether the claimant has “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.” § 404.1520(a)(4)(ii).Read the full opinion on CourtListener →
At step two, identifying at least one severe impairment satisfies the severity-screening requirement when the ALJ considers all of the claimant’s functional limitations in assessing the RFC, so omitting additional impairments from the severe-impairment list can be harmless.
Lopardo v. Berryhill · filed 2019-03-20(c)
Because step two's "severity requirement is . . . a de minimus policy, designed to do no more than screen out groundless claims," McDonald v. Sec'y of Health & Human Servs., 795 F.2d 1118, 1124 (1st Cir. 1986), the ALJ's finding that Plaintiff had other severe impairments is all that step two required as long as the ALJ considered all of Plaintiff's functional limitations in crafting the RFC (A.R. at 21).Read the full opinion on CourtListener →
At Step Two, § 404.1520 requires the ALJ to determine whether the claimant has a severe medically determinable impairment, or severe combination of impairments, that meets the duration requirement.
Tarr v. Nancy A. Berryhill, Acting Commissioner, Social Security Administration · filed 2019-03-04(a)(4)(ii)
At Step Two, the ALJ must determine whether the claimant has “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.” § 404.1520(a)(4)(ii).Read the full opinion on CourtListener →
Section 404.1520(c) requires a claimant to show an impairment that significantly limits the ability to do basic work activities; once any severe impairment is found, the sequential evaluation proceeds and failure to label additional impairments severe is harmless.
Harman v. Saul · filed 2019-03-28(c)
Indeed, it must “significantly limit[]” an individual’s “ability to do basic work activities[.]” 20 C.F.R. §§ 404.1520(c), 416.920(c) (emphasis added). ... Accordingly, since the ALJ determined that Plaintiff suffered from a severe impairment at step two and then proceeded beyond step two in the sequential analysis, any error in failing to find that Plaintiff suffered from other severe impairments is rendered harmless and provides no basis for remand.Read the full opinion on CourtListener →
At step two, an impairment is severe only if it significantly limits a claimant’s ability to do basic work activities, and finding any one severe impairment is enough to proceed.
Harman v. Saul · filed 2019-03-28(c)
Indeed, it must “significantly limit[]” an individual’s “ability to do basic work activities[.]” 20 C.F.R. §§ 404.1520(c), 416.920(c) (emphasis added). ... At step two the ALJ must determine if the claimant has any severe impairment. This step acts as a filter; if no severe impairment is shown the claim is denied, but the finding of any severe impairment, whether or not it qualifies as a disability and whether or not it results from a single severe impairment or a combination of impairments that together qualify as severe, is enough to satisfy the requirement of step two.Read the full opinion on CourtListener →
At step two, the ALJ must determine whether the claimant has a severe impairment that significantly limits basic work activities; omitting an impairment is not reversible error if the ALJ considers it in the later steps of the sequential evaluation.
Winder v. Berryhill · filed 2019-03-29(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." ... It is settled - and the Plaintiff does not contest this rule of law in her objection - that failure to find every impairment at issue severe at Step Two is not reversible error if the ALJ incorporates those impairments in the later steps of the sequential analysis. ... Because the ALJ addressed the impairments at issue in his Step Two analysis at Steps Four and Five, their omission from his Step Two analysis is of no moment.Read the full opinion on CourtListener →
Section 404.1520(c) requires the ALJ at step two to determine whether the claimant has a severe medically determinable impairment or combination of impairments; the claimant need only show a significant limitation in basic work activities, not satisfy a listing.
Hughes v. Berryhill · filed 2019-03-30(c)
At step two, the ALJ must decide whether the claimant has a medically determinable impairment that is severe or a combination of impairments that are severe. 20 CFR § 404.1520(c). ... However, at step two, Ms. Hughes need not show that she met the criteria for Listing 12.04, she must only show that the medically determinable impairment significantly limited her physical or mental ability to perform basic work activities. ... The court finds the ALJ erred in determining whether Ms. Hughes’ mental impairments were a severe impairment.Read the full opinion on CourtListener →
Section 404.1520(c) requires the ALJ at step two to determine whether the claimant has a medically determinable impairment or combination of impairments that is severe, meaning it significantly limits the ability to perform basic work activities.
Miller v. Berryhill · filed 2019-03-31(c)
At step two, the ALJ must decide whether the claimant has a medically determinable impairment that is severe or a combination of impairments that are severe. 20 CFR § 404.1520(c). ... Thus, a severe impairment is one which significantly limits a claimant’s physical or mental ability to do basic work activities. ... The court finds the ALJ did not err in identifying claimant’s severe impairments at step two.Read the full opinion on CourtListener →
At step two, § 404.1520 requires the ALJ to determine whether the claimant has a severe impairment, and objective evidence showing more than minimal limitations means the ALJ may not end the disability analysis there.
Gress v. Berryhill · filed 2019-06-07(a)(4)(ii)
At step two, the ALJ must determine whether the claimant has any impairments, singly or in combination, that qualify as severe under the regulations. 20 C.F.R. §§ 404.1520(a)(4)(ii) and 416.920(a)(4)(ii). ... Because there is objective evidence in the record suggesting that Plaintiff’s impairments significantly limited his ability to perform certain basic work activities, the ALJ erred by finding that Plaintiff did not have any severe impairments and ending his analysis at step two.Read the full opinion on CourtListener →
At step two, the ALJ proceeds with the disability evaluation when the claimant has at least one severe impairment; failing to identify additional severe impairments is harmless when the evaluation continues.
Laskey v. Berryhill · filed 2019-06-14(a)(4)(ii)
However, the ALJ found that Laskey had two severe impairments and thus proceeded to the remaining steps of the sequential evaluation for disability. Eleventh Circuit case law is pellucid that, so long as the ALJ finds at least one severe impairment at Step Two, any failure to find additional severe impairments is at most harmless error. ... Thus, Laskey’s first claim of reversible error10 is OVERRULED.Read the full opinion on CourtListener →
Section 404.1520(c) requires a claimant to have an impairment or combination of impairments that significantly limits basic work activities to proceed beyond step two.
MOREAU v. COMMISSIONER OF SOCIAL SECURITY · filed 2019-06-25(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. ... 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.” ... At step two, ALJ Merrill properly considered the entire medical record in finding that Plaintiff did not have an impairment or combination of impairments that significantly limited his ability to perform basic work-related activities for twelve consecutive months through the date last insured. ... Because the ALJ determined at step two that the Plaintiff was not disabled, she correctly did not proceed to the other steps of the disability test. 20 C.F.R. §§ 404.1520(a)(4), 416.920(a)(4).Read the full opinion on CourtListener →
At step two, § 404.1520(c) ends the sequential evaluation with a finding of not disabled when the claimant does not have a severe impairment.
Lorenzo v. Commissioner of Social Security · filed 2019-07-18(c)
Once an ALJ concludes that “a condition is not severe[,]” the ALJ reaches a finding that the “plaintiff is not disabled, and the [ALJ’s] inquiry stops at the second level of the five-step sequential evaluation process.” Rosario v. Apfel, No. 97 CV 5759, 1999 WL 294727, at *5 (E.D.N.Y. Mar. 19, 1999) (citing 20 C.F.R. § 404.1520(c)); ... The Court finds no error with the ALJ’s conclusion in this case.Read the full opinion on CourtListener →
At step two, § 404.1520(c) requires a claimant to show a severe impairment that significantly limits basic work activities; failure to explicitly classify an impairment as severe may be harmless when the analysis continues and the impairment is considered later.
Chuderski v. Commissioner of Social Security · filed 2019-07-23(c)
It is the claimant’s burden to show at step two that she has a “severe” impairment or combination of impairments, meaning an impairment or combination of impairments that “significantly limits [her] physical or mental ability to do basic work activities,” 20 C.F.R. § 404.1520(c); see 20 C.F.R. § 404.1522, “for a continuous period of at least 12 months,” 20 C.F.R. § 404.1509. ... Importantly, the ALJ’s omission of an impairment at step two does not in and of itself require remand and may be deemed harmless error. ... Applied here, even if the ALJ erred in failing to explicitly consider and find Plaintiff’s Hashimoto’s thyroiditis severe, the error was harmless for several reasons.Read the full opinion on CourtListener →
Section 404.1520(c) treats an impairment as severe only if it significantly limits a claimant’s ability to perform basic work activities.
Kathriner v. Saul · filed 2019-07-25(c)
At step two of the sequential evaluation, the issue is whether the claimant suffers from at least one “severe” medically determinable impairment. ... An impairment is “severe” if it “significantly limits [a claimant’s] physical or mental ability to do basic work activities.” ... However, “a showing of the mere presence of a condition is not sufficient.” ... At most, Plaintiff has shown the mere presence of a condition, which is not sufficient under step two.Read the full opinion on CourtListener →
Section 404.1520(c) treats an impairment as severe when it significantly limits a claimant’s physical or mental ability to do basic work activities.
Nove v. Commissioner Social Security Administration · filed 2019-07-28(c)
A severe impairment is one that significantly limits the claimant’s physical or mental ability to do basic work activities. 20 C.F.R. §§ 404.1520(c), 416.920(c).Read the full opinion on CourtListener →
Section 404.1520 requires the ALJ to determine whether an impairment significantly limits basic work activities and whether it satisfies the step-two duration requirement of lasting or being expected to last at least 12 months.
Moody v. Berryhill · filed 2019-07-29(c), (a)(4)(ii)
According to agency regulations, an impairment is severe if it “significantly limits your physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1520(c), 416.920(c). ... As part of the severity analysis, the ALJ must determine whether the impairment has or is expected to last for a continuous period of at least 12 months. 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii), 416.909, 404.1509. ... Although the ALJ failed to apply the standard required by the Fifth Circuit for a non-severe impairment, the failure to apply the standard in this case resulted in harmless error.Read the full opinion on CourtListener →
At step two, § 404.1520(c) requires the ALJ to determine whether the claimant has a severe impairment that significantly limits her ability to perform basic work activities.
Donahue v. Commissioner of Social Security · filed 2019-08-02(c)
At step two of the disability-evaluation process, the ALJ must determine whether the claimant suffers from a “severe” impairment, i.e., one that significantly limits her physical or mental ability to do basic work activities. 20 C.F.R. §§ 404.1520(c), 416.920(c).Read the full opinion on CourtListener →
At step two, § 404.1520 requires a claimant to show a medically determinable impairment that significantly limits the ability to perform basic work activities; the court applied that standard in upholding the finding that the plaintiff's neck pain and mitral valve prolapse were non-severe.
Isbell v. Social Security Administration, Commissioner · filed 2019-07-30(a)(4)(ii)
At step two of the sequential evaluation, the ALJ determined whether Plaintiff had a severe impairment, defined as an impairment significantly limiting the claimant’s abilities to do basic work activities. 20 C.F.R. §404.1520(a)(4)(ii), (c), 404,1521(a). However, Plaintiff’s neck pain and mitral valve prolapse were found to be non-severe. ... Plaintiff has not demonstrated that these conditions were severe impairments.Read the full opinion on CourtListener →
Notes 2251–2400 of 6,452, oldest cases first.
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