20 C.F.R. § 404.1520

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

Harshbarger v. Commissioner of Social Security · filed 2020-12-15(c)

It is the claimant’s burden to show at step two that he has a “severe impairment,” meaning an impairment that “significantly limits [his] physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1520(c), 416.920(c); Meadors v. Astrue, 370 F. App’x 179, 182 (2d Cir. 2010); see Bowen v. Yuckert, 482 U.S. 137, 146 n.5 (1987) (“It is not unreasonable to require the claimant, who is in a better position to provide information about his own medical condition, to do so.”).

Section 404.1520(a)(4)(ii) requires a claimant at step two to have a severe medically determinable impairment, or a severe combination of impairments, that meets the duration requirement.

Wiggins v. Commissioner of Social Security · filed 2021-01-11(a)(4)(ii)

At the second step in the sequential evaluation process a claimant must demonstrate he 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).

Section 404.1520(c) requires a claimant at step two to show that a medically determinable impairment significantly limits the ability to perform basic work activities.

Patton v. Commissioner of Social Security · filed 2021-01-15(c)

At step two, a claimant must make a threshold showing her medically determinabl e impairments significantly limit her ability to perform basic work activities. See Bowen v. Yuckert, 482 U.S. 137, 145 (1987); 20 C.F.R. § 404.1520(c).

Section 404.1520(c) requires a claimant to make a threshold showing of a medically determinable impairment that is severe before proceeding through the sequential disability evaluation.

(SS) Norma A. Garcia v. Commissioner of Social Security · filed 2021-01-22(c)

A claimant must make a “threshold showing” that (1) she has a medically determinable impairment or combination of impairments and (2) the impairment or combination of impairments is severe. Id. at 146-47; see also 20 C.F.R. § 404.1520(c).

At step two, § 404.1520(c) requires a medically determinable severe impairment or combination of severe impairments; one severe impairment satisfies step two, and failure to identify additional severe impairments is harmless if all impairments are considered throughout the sequential evaluation.

Jones v. Commissioner of Social Security · filed 2021-01-29(c)

Finally, even if the ALJ erred by not finding the Claimant’s CTS to be severe, the error would be harmless. At step two, the ALJ must determine whether the claimant has a medically determinable impairment that is severe or a combination of impairments that are severe. 20 C.F.R. § 404.1520(c). “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.” Jamison v. Bowen, 814 F.2d 585, 588 (11th Cir. 1987) (citations omitted). Therefore, the finding of a single severe impairment satisfies step two. See id. The failure to find additional severe impairments is harmless error if the ALJ considers all the claimant’s impairments – severe and non-severe – in combination throughout the rest of the sequential evaluation process. See, e.g., Freeman v. Comm’r, Soc. Sec. Admin., 593 F. App’x 911, 914-915 (11th Cir. 2014); Tuggerson-Brown v. Comm’r of Soc. Sec., 572 F. App’x 949, 951-52 (11th Cir. 2014).

Section 404.1520(a)(4)(ii) requires the Commissioner to determine at step two whether a claimant has a severe impairment or combination of impairments that significantly limits basic work activities.

Ard v. Commissioner of Social Security · filed 2021-02-05(a)(4)(ii)

Step two addresses whether the claimant has 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(a)(4)(ii), 416.920(a)(4)(ii).

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

Vesneske v. Commissioner of Social Security · filed 2021-02-10(c)

As for impairments consideration at step two, Plaintiff bears the burden of establishing that he has a severe impairment, “which is ‘any impairment or combination of impairments which significantly limits [the claimant’s] ability to do basic work,’” Miller v. Berryhill, No. 16CV6467, 2017 U.S. Dist. LEXIS 153578, at *20 (W.D.N.Y. Sept. 20, 2017) (Telesca, J.); see 20 C.F.R. §§ 404.1520(c), 416.920(c).

Section 404.1520(a)(4)(ii) requires only one severe impairment to avoid denial at step two; the ALJ must proceed to the next step when at least one severe impairment is found.

Wheeler v. Social Security Administration · filed 2021-02-12(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). . . . 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. Thus, the failure to find a particular impairment severe at step two is not reversible error when the ALJ finds that at least one other impairment is severe.

Section 404.1520(c) makes step two a threshold inquiry into whether the claimant has a severe impairment, meaning an impairment that is more than a slight abnormality with more than a minimal effect on basic work activities.

(SS) Jones v. Commissioner of Social Security · filed 2021-02-17(c)

At step two of the sequential evaluation, the ALJ determines which of claimant’s alleged impairments are “severe” within the meaning of 20 C.F.R. § 404.1520(c). “An impairment is not severe if it is merely ‘a slight abnormality (or combination of slight abnormalities) that has no more than a minimal effect on the ability to do basic work activities.’” Webb v. Barnhart, 433 F.3d 683, 686 (9th Cir. 2005) (quoting Social Security Ruling (“SSR”) 96–3p (1996)). The step-two severity determination is “merely a threshold determination of whether the claimant is able to perform his past work. Thus, a finding that a claimant is severe at step two only raises a prima facie case of a disability.” Hoopai v. Astrue, 499 F.3d 1071, 1076 (9th Cir. 2007). ... The ALJ’s step-two analysis in this case is deficient because the ALJ failed to mention fibromyalgia, lupus, and sacro-iliac joint dysfunction. However, because the ALJ found that plaintiff had at least one severe impairment, plaintiff was not prejudiced by any arguable step two error.

At step two, a claimant must show a severe medically determinable impairment or combination of impairments that meets the duration requirement.

Pyanowski v. Commissioner of Social Security · filed 2021-02-25(a)(4)(ii)

At the second step in the sequential evaluation process a claimant must demonstrate he 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).

Section 404.1520(c) requires a claimant at step two to show that a medically determinable impairment significantly limits the ability to perform basic work activities.

DeGraff v. Commissioner of Social Security · filed 2021-03-02(c)

At step two, a claimant must make a threshold showing that her medically determinable impairments significantly limit her ability to perform basic work activities. See Bowen v. Yuckert, 482 U.S. 137, 145 (1987); 20 C.F.R. § 404.1520(c). ... Substantial evidence thus supports the ALJ’s finding that sinusitis did not significantly limit Plaintiff’s ability to perform basic work activities.

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

Borawski v. Commissioner of Social Security · filed 2021-03-03(c)

At step two of the sequential evaluation, an ALJ must determine whether a claimant has a “severe” impairment. See 20 C.F.R. §§ 404.1520(a)(40)(ii). To determine if a claimant has a severe impairment, the ALJ must find that an impairment, or combination of impairments, significantly limits the claimant's physical or mental ability to do “basic work activities.” See 20 C.F.R. § 404.1520(c). ... When the ALJ considers all of a claimant’s impairments in the remaining steps of the disability determination, the failure to find additional severe impairments at Step Two does “not constitute reversible error.”

An impairment is severe at step two when it significantly limits a claimant’s physical or mental ability to perform basic work activities.

Woods v. Berryhill · filed 2021-03-05(c)

Rather, an impairment is severe if it “significantly limits physical or mental abilities to do basic work activities.” 20 C.F.R. § 404.1520(c). ... At a minimum, the ALJ erred in determining that Woods’s severe impairments did not include his left shoulder and left foot injuries. That error is harmless, however, because she found that Woods suffered from other severe impairments and proceeded onto the next steps of the sequential evaluation.

Section 404.1520(c) requires the ALJ at step two to determine whether the claimant has any severe impairments.

Pearson v. Commissioner of Social Security · filed 2021-03-04(c)

At step two, the ALJ must determine if the claimant suffers from any impairments that are “severe.” 20 C.F.R. § 404.1520(c).

At step two, § 404.1520 requires deciding whether the claimant has a severe impairment that has lasted or is expected to last at least twelve months, with severity measured by significant limits on basic work activities.

DeBeaulieu v. Commissioner of Social Security · filed 2021-03-08(a)(4)(ii), (c)

At step two of the sequential evaluation process, the ALJ must determine whether the claimant has a medically determinable impairment or combination of impairments that is “severe” and has lasted or is expected to last for at least twelve months. 20 C.F.R. §§ 404.1505(a), 404.1520(a)(4)(ii), (c); Barnhart v. Walton, 535 U.S. 212, 216 (2002). An impairment or combination of impairments is “severe” if it “significantly limits [the claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c).

Section 404.1520(c) requires the ALJ to determine whether a claimant has a medically determinable impairment that significantly limits the ability to perform basic work activities, while § 404.1520(a)(4) places the burden of proof for the first four disability-determination steps on the claimant.

Vicario v. Commissioner of Social Security · filed 2021-03-09(c), (a)(4)

As stated, Discussion, supra, at 7, at step two the ALJ must determine whether the claimant has a medically determinable impairment or combination of impairments that is “severe,” meaning limiting his mental or physical ability to perform basic work activity. 20 C.F.R. § 404.1520(c) and § 416.920(c). ... Nor was the ALJ required to contact Plaintiff’s treating sources to obtain more information regarding whether Plaintiff’s symptoms meet SSR 12-2p’s criteria for fibromyalgia because the ALJ specifically states she considered the medical evidence of record and failed to find the criteria met. Plaintiff does not point to sufficient evidence establishing otherwise, as is his burden. 20 C.F.R. §§ 404.1520(a)(4) and 416.920(a)(4) (providing the burden of proof is on the applicant for the first four steps, with the Commissioner bearing the burden of proof on the final step); Burgess, 537 F.3d at 128 (same). Furthermore, because ALJ Jones’s determination that Plaintiff’s fibromyalgia is not a severe impairment is supported by substantial evidence in the record, there were no limiting effects posed by Plaintiff’s fibromyalgia that the ALJ was required to consider.

At step two, § 404.1520(a)(4)(ii) asks whether the claimant has a severe impairment or combination of impairments that significantly limits the ability to do basic work activities.

Lopez v. Commissioner of Social Security · filed 2021-03-10(a)(4)(ii)

Step two addresses whether the claimant has 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(a)(4)(ii).

At step two, § 404.1520 requires determining whether the claimant has a severe impairment; the impairment must significantly limit basic work activities and be severe for at least 12 consecutive months.

Parish v. Social Security Administration, Commissioner · filed 2021-03-12(a)(4)(ii)

At Step Two of the sequential evaluation, the ALJ determines whether a claimant has 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). A claimant bears the burden to establish these conditions significantly limit her ability to perform basic work functions. 20 C.F.R. §§ 404.1520(a), (c), 404.1521(a); Bridges v. Bowen, 815 F.2d 622, 625-26 (11th Cir. 1987) (recognizing an impairment cannot be severe if it has only a minimal impact). Examples of basic work activities include physical functions such as walking, standing, sitting, lifting, pushing, pulling, reaching, carrying, and handling. See 20 C.F.R. §§ 404.1521(b)(1), 416.921(b)(1). Further, to be considered a severe impairment at step two, an impairment also must be severe for at least 12 consecutive months. See 20 C.F.R. §§ 404.1505(a), 404.1509, 404.1520(a)(4)(ii), 416.905(a), 416.909, 416.920(a)(4)(ii); Barnhart v. Walton, 535 U.S. 212, 217 (2002).

At step two, a finding of disability requires a severe medically determinable physical or mental impairment, or combination of impairments, that meets the duration requirement.

Vooge v. Saul · filed 2021-03-18(a)(4)(ii)

A finding of disability requires a severe medically determinable physical or mental impairment (or combination of impairments) that meets the duration requirement. 20 C.F.R. § 404.1520(a)(4)(ii).

At step two, § 404.1520(c) requires a claimant to show that her medically determinable impairments significantly limit her ability to perform basic work activities.

Zavery v. Commissioner of Social Security · filed 2021-03-19(c)

At step two, a claimant must make a threshold showing that her medically determinable impairments significantly limit her ability to perform basic work activities. See Bowen v. Yuckert, 482 U.S. 137, 145 (1987); 20 C.F.R. § 404.1520(c).

Step two is a threshold screen for whether an impairment significantly limits basic work activities; all impairments, including non-severe ones, must nevertheless be considered in determining the claimant’s RFC.

Hymes v. Commissioner of Social Security · filed 2021-03-22(c)

Step two is merely a threshold determination meant to screen out weak claims. It is not meant to identify the impairments that should be taken into account when determining the RFC. In fact, “[i]n assessing RFC, the adjudicator must consider limitations and restrictions imposed by all of an individual’s impairments, even those that are not ‘severe.’” The RFC therefore should be exactly the same regardless of whether certain impairments are considered “severe” or not.

Section 404.1520(c) requires the ALJ at step two to decide whether an impairment significantly limits the claimant’s physical or mental ability to perform basic work activities.

McMillan v. O'Malley · filed 2021-03-30(c)

At step two of the sequential process, the ALJ must determine whether claimant suffers from a “severe” impairment, i.e., one that significantly limits her physical or mental ability to do basic work activities. 20 C.F.R. §§ 404.1520(c), 416.920(c). ... However, as the case is being remanded to reconsider the medical opinion evidence, the ALJ is also instructed to perform the five-step analysis anew, including considering whether Plaintiff’s hepatitis C and depression are now severe medically determinable impairments and to assess any additional limitations caused by the impairments.

At step two, § 404.1520(a)(4)(ii) requires a determination whether the claimant has a severe impairment, which § 404.1520(c) defines as an impairment that significantly limits the ability to do basic work activities; finding an impairment severe does not by itself require a corresponding RFC restriction.

Herren v. Saul · filed 2021-03-30(a)(4)(ii), (c)

At step two, a claimant is not disabled unless the ALJ finds that the claimant has a severe impairment. See 20 C.F.R. § 404.1520(a)(4)(ii). The regulations define a severe impairment as “any impairment or combination of impairments which significantly limits [a claimant’s] physical or mental ability to do basic work activities.” Id. § 404.1520(c). ... The “prevailing rule,” however, is that an ALJ does not err solely because he finds an impairment “severe” at step two but does not attribute any limitation to that impairment in assessing the claimant’s RFC.

Section 404.1520(c) makes step two a threshold inquiry into whether the claimant has a severe impairment or combination of impairments; an omission is harmless when the impairment's limitations are considered in the RFC at step four.

(SS) Stivers v. Commissioner of Social Security · filed 2021-03-30(c)

At step two of the five-step sequential evaluation, the ALJ is required to determine whether a plaintiff has a “severe” medical impairment or combination of impairments. 20 C.F.R. §§ 404.1520(c), 416.920(c). “Step two is merely a threshold determination meant to screen out weak claims.” ... Any error in failing to include an impairment at step two is harmless if the ALJ considered any limitations imposed by the impairment in the RFC determination at step four. ... Even assuming arguendo that the ALJ erred in finding Plaintiff’s depression and anxiety not severe at step two, any such error is harmless because the ALJ considered and discussed Plaintiff’s mental condition in the RFC at step four of the sequential evaluation.

Section 404.1520(c) treats an impairment as severe only if it significantly limits a claimant’s physical or mental ability to do basic work activities; slight abnormalities with minimal effects are not severe.

Koengeter v. Saul · filed 2021-03-30(c)

A disability finding requires that the claimant have a “severe impairment,” which the regulations explain is an “impairment or combination of impairments which significantly limits [the claimant’s] physical or mental ability to do basic work activities. . . .” 20 C.F.R. § 404.1520(c). The claimant must prove the impairment by providing relevant evidence. See 20 C.F.R. § 404.1512(a). Objective medical evidence includes “medical signs, laboratory findings, or both.” 20 C.F.R. §§ 404.1513(a)(1), 404.1502(f). An impairment is not severe if clearly established objective medical evidence shows only slight abnormalities that minimally affect a claimant’s ability to do basic work activities. Webb, 433 F.3d at 687; Smolen, 80 F.3d at 1290.

At step two, § 404.1520(c) requires a claimant to show that her medically determinable impairments significantly limit her ability to perform basic work activities.

Brauer v. Commissioner of Social Security · filed 2021-04-12(c)

At step two, a claimant must make a threshold showing that her medically determinable impairments significantly limit her ability to perform basic work activities. See Bowen v. Yuckert, 482 U.S. 137, 145 (1987); 20 C.F.R. § 404.1520(c).

At step two, the regulation requires an impairment to meet the duration requirement and significantly limit a claimant’s ability to perform basic work activities.

Engel v. Commissioner Social Security Administration · filed 2021-04-22(a)(4)(ii), (c)

At step two, the ALJ must determine if the claimant has a medically determinable impairment that meets the durational requirements and “significantly limits [the claimant's] physical or mental ability to do basic work activities . . .” 20 C.F.R. §§ 404.1520(a)(4) Gi), 404.1520(c).

Section 404.1520(c) requires a severe medically determinable impairment, or a combination of severe impairments, at step two; one severe impairment is enough to satisfy that step.

Clowdus v. Commissioner of Social Security · filed 2021-05-12(c)

At step two, the ALJ must determine whether the claimant has a medically determinable impairment that is severe or a combination of impairments that are severe. 20 C.F.R. § 404.1520(c). “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.” ... Thus, the finding of a single severe impairment satisfies step two. ... First, as Claimant apparently concedes, the ALJ found that Claimant suffered from several severe impairments which satisfies step two.

At step two, the regulation requires the ALJ to determine whether the claimant has a severe impairment or combination of impairments that significantly limits the ability to perform basic work activities.

OESER v. COMMISSIONER OF SOCIAL SECURITY · filed 2021-05-18(c)

At step two, the ALJ decides whether the plaintiff has a “severe impairment” or combination of impairments that “significantly limits [the plaintiff’s] physical or mental ability to do basic work activities[.]” 20 C.F.R. § 404.1520(c). If the plaintiff does not have a severe impairment or combination of impairments, then the inquiry ends because the plaintiff is not disabled. Otherwise, the ALJ proceeds to step three. ... Although the ALJ recited that “[a]n impairment or combination of impairments is ‘not severe’ when medical and other evidence establish only a slight abnormality or a combination of slight abnormalities that would have no more than a minimal effect on an individual’s ability to work[,]” R. 19 (citing 20 C.F.R. § 404.1522; SSR 85-28 and 16-3p), the ALJ did not actually apply this de minimis screening standard when discounting Dr. Arnold’s opinions and finding Plaintiff’s impairments to be non-severe at step two. ... In light of this evidence, the Court cannot agree that the ALJ applied the proper de minimis standard at step two of the sequential evaluation process in finding that Plaintiff’s claim is “groundless” and that her claim to disability benefits should be denied at step two. Moreover, this Court cannot find that this error at step two was harmless where, as a result, the ALJ failed to fully consider Plaintiff’s allegations of disability. ... For all these reasons, the ALJ’s denial of benefits at step two warrants remand in this case.

Section 404.1520(c) requires a claimant to have at least one severe, medically determinable impairment or combination at step two; once that threshold is met, the evaluation proceeds to step three.

MASTROCESARE v. SAUL · filed 2021-06-15(c)

At the second step, claimants must prove they suffer from at least one severe, medically determinable impairment or combination of impairments, otherwise the inquiry immediately ends with a finding that they are “ineligible for disability benefits.” 20 C.F.R. § 404.1520(c). Because claimants who prove they suffer from even one qualifying impairment at step two continue to step three, an ALJ’s failure to label any secondary impairment “severe” is not an error that requires remand.

Section 404.1520(c) governs step two and requires determining whether a medically determinable impairment significantly limits basic work activities before proceeding.

Mireles v. Kijakazi · filed 2021-06-16(c)

At step two of the sequential process, the ALJ must determine whether the claimant suffers from a “severe” impairment, i.e., one that significantly limits the individual’s physical or mental ability to do basic work activities. This involves a two-step process: 1) determining whether a claimant has a medically determinable impairment and 2), if so, determining whether that impairment is severe.

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

Walsh v. Commissioner of Social Security · filed 2021-06-16(c)

A severe impairment is one that “significantly limits [a claimant’s] physical or mental ability to do basic work activities.” Id. §§ 404.1520(c), 416.920(c).

At step two, the ALJ must determine whether the claimant has a severe impairment that significantly limits physical or mental abilities to do basic work activities.

Bowers v. Commissioner of Social Security · filed 2021-06-21(c)

At step two, the ALJ must determine whether the claimant has a severe impairment that significantly limits a claimant’s physical or mental abilities to do basic work activities. 20 C.F.R. § 404.1520(c).

At step two, an impairment is severe if it significantly limits basic work abilities; the claimant need only make a de minimis showing, and the impairment need not be severe for the entirety of the twelve-month duration period.

Copeland v. Berryhill · filed 2021-06-28(c)

At step two of the disability analysis, the ALJ considers whether the claimant has a medically determinable impairment or combination of impairments that is severe.” ... “A “severe impairment” is one that “significantly limits [the claimant's] physical or mental ability to do basic work activities.” ... “An impairment is “not severe” only if it does not impose any interference on the ability to perform work activities. ... “Therefore, the step-two showing requires Plaintiff only to make a “de minimis showing.” ... “For an impairment to be severe, it must last for twelve months and be severe, but does not need to be severe for the entirety of those twelve months.” ... “The ALJ’s imposition of the durational requirement on the severity of the impairment is the incorrect legal standard.”

Section 404.1520(c) requires the ALJ at step two to determine whether the claimant has a severe impairment that significantly limits the claimant’s physical or mental ability to perform basic work activities.

Cargill v. Saul · filed 2021-06-28(c)

As described above, at Step Two, the ALJ must determine whether the claimant has a severe impairment that significantly limits his or her physical or mental abilities to do basic work activities. 20 C.F.R. § 404.1520(c).

At step two, an ALJ must determine whether the claimant has at least one severe medically determinable impairment or combination of impairments.

Myhres v. Commissioner of Social Security · filed 2021-06-29(a)(4)(ii)

At step two, an ALJ must determine whether a claimant has at least one severe medically determinable impairment or combination of impairments. 20 C.F.R. § 404.1520(a)(4)(ii).

Section 404.1520(c) requires the ALJ at step two to decide whether a medically determinable impairment or combination of impairments is severe, meaning it significantly limits the claimant's ability to perform basic work activities; an impairment is not severe only when it causes no interference with work activities.

Latiolais v. Berryhill · filed 2021-06-29(c)

“At step two of the disability analysis, the ALJ considers whether the claimant has a medically determinable impairment or combination of impairments that is severe.” Foster, 2011 WL 5509475, at *11 (citing 20 C.F.R. §§ 404.1520(c), 416.920(c)). “A “severe impairment” is one that “significantly limits [the claimant's] physical or mental ability to do basic work activities.” Id. (citing § 404.1520(c)). An impairment is “not severe” only if it does not impose any interference on the ability to perform work activities. Stone v. Heckler, 752 F.2d 1099, 1101 (5th Cir. 1985).6 Therefore, the step-two showing requires Plaintiff to make only a “de minimis showing.”

At step two, a claimant need only have at least one severe impairment; finding another impairment non-severe is harmless when the ALJ considers it at later steps.

Williams v. Social Security Administration, Commissioner · filed 2021-07-01(a)(4)(ii)

The Eleventh Circuit has held that “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.” ... An ALJ does not err when, in determining a claimant’s impairment (or lack thereof) to be non-severe and the omission is harmless, the record demonstrates the ALJ considered and discussed them at subsequent steps in the analysis.

At step two, § 404.1520(c) requires a claimant to have a severe impairment, meaning one that significantly limits the ability to perform basic work activities.

Wright v. Commissioner of Security Security · filed 2021-07-26(c)

The regulations establish that claimants must have a “severe impairment” in order to be found disabled. 20 C.F.R. § 404.1520(c). A severe impairment is a condition “which significantly limits [an individual’s] physical or mental ability to do basic work activities.” Id. “An impairment is severe when it causes more than minimal functional limitations.”

A severe impairment significantly limits a claimant’s physical or mental ability to perform basic work activities and must meet the applicable duration requirement.

Bender v. Commissioner of Social Security · filed 2021-08-03(c)

At step two of the five-step analysis set forth in 20 C.F.R. §404.1520(a)(4), the ALJ must determine whether the claimant has a severe impairment. 20 C.F.R. §404.1520(a)(4)(ii). A severe impairment is “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.” 42 U.S.C. §423(d)(1)(A). ... The court agrees with the conclusion of the magistrate judge that the ALJ’s decision not to classify plaintiff’s headaches as a severe impairment was supported by substantial evidence.

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; at step two, only the most trivial impairments may be rejected as non-severe.

Synowicz v. Kijakazi · filed 2021-08-12(c)

The regulations define a severe impairment as “any impairment or combination of impairments which significantly limits [a claimant’s] physical or mental ability to do basic work activities.” Jd. § 404.1520(c). The ALJ’s step two determination is “‘a de minimis screening for groundless claims.” Meuser v. Colvin, 838 F.3d 905, 910 (7th Cir. 2016) Gnternal quotation and citation omitted). An impairment is only “not severe” if it is “a slight abnormality” that has “no more than a minimal effect on the ability to do basic work activities.” Jd. (internal quotation and citation omitted). Thus, only “claims based on the most trivial impairments” should be rejected as non-severe. McDaniel v. Bowen, 800 F.2d 1026, 1031 (11th Cir. 1986).

At step two, omitting an impairment is harmless if the ALJ finds at least one severe impairment and continues the sequential analysis.

TAYLOR-HARMON v. COMMISSIONER OF SOCIAL SECURITY · filed 2024-04-16(a)(4)(ii)

It is well established that any omission of an impairment at Step Two is harmless error, provided that the ALJ determines that the claimant has at least one severe impairment and continues onto the subsequent steps of the sequential analysis.

At step two, the regulations require only one severe impairment; once the ALJ finds one, the claimant cannot be denied at that step and the ALJ must proceed, so failure to find another impairment severe is not reversible error.

Blair v. Commissioner, Social Security Administration · filed 2021-03-31(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)[; see also 20 C.F.R. § 416.920(c)]. ... 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. Thus, the failure to find a particular impairment severe at step two is not reversible error when the ALJ finds that at least one other impairment is severe.

At step two, § 404.1520 requires an ALJ to determine whether the claimant has a medically severe impairment or combination of impairments, treating an impairment as severe when it significantly limits basic work abilities.

Lahti v. Saul · filed 2021-03-31

At step two, the ALJ determines if the claimant has a medically “severe” impairment or combination of impairments. 20 C.F.R. § 404.1520. To satisfy the severity requirement, the claimant must prove the impairment by providing objective medical evidence; the claimant’s own statement of symptoms alone will not suffice. See 20 C.F.R. § 416.921. An impairment is considered “severe” if a claimant’s physical or mental ability to complete basic work activities are significantly limited. Id., § 404.1520.

Section 404.1520 requires the ALJ at step two to determine whether the claimant has a severe impairment, meaning one that significantly limits the ability to perform basic work functions.

MINOR v. COMMISSIONER OF SOCIAL SECURITY · filed 2021-03-31(a)(4)(ii), (c)

At step two of the sequential evaluation process, the ALJ is required to consider whether the claimant has a severe medically determinable impairment that meets the 12-month durational requirement of the Act. 20 C.F.R. § 404.1520(a)(4)(ii). A “severe” impairment is one that significantly limits a claimant’s physical or mental ability to perform basic work functions. 20 C.F.R. § 404.1520(c). ... The ALJ’s decision that Minor’s obesity is non-severe is supported by various portions of the record. ... Therefore, while the ALJ may have only specifically referred to Minor’s obesity once or twice, he fully considered the impacts Minor’s body-mass index and weight had on her ability to perform work and provided a reasonable basis for finding Minor did not suffer additional functional limitations because of her weight.

At step two, § 404.1520(c) requires determining whether a claimant has a severe impairment that significantly limits her physical or mental ability to perform basic work activities.

Kosier v. Commissioner of Social Security · filed 2021-03-31(c)

At step two, the ALJ must determine whether the claimant has a severe impairment that significantly limits her physical or mental abilities to do basic work activities.

Section 404.1520(c) requires the ALJ at step two to determine whether a claimant has a severe impairment or combination of impairments; an impairment is not severe only when it has no more than a minimal effect on the ability to work.

Taylor v. Saul · filed 2020-04-16(c)

Under step two of the sequential evaluation process, the ALJ must determine whether the claimant suffers from a severe impairment or combination of impairments. 20 C.F.R 404.1520(c); 416.920. At the step two inquiry, “the ALJ must consider the combined effect of all of the claimant’s impairments on her ability to function, without regard to whether each alone was sufficiently severe.” ... The Social Security Act defines a “severe” impairment as one “which significantly limits [a claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c). “An impairment or combination of impairments may be found ‘not severe only if the evidence establishes a slight abnormality that has no more than a minimal effect on an individual’s ability to work.’” ... The step two “inquiry is a de minimis screening device [used] to dispose of groundless claims.”

Section 404.1520(c) requires the ALJ at Step Two to find an impairment severe when it has more than a minimal effect on the claimant’s ability to perform basic work activities and then proceed to the next step.

Averbach v. Astrue · filed 2010-08-06(c)

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. ... Here, properly crediting Dr. Vicary’s opinions, it is clear plaintiff has a severe mental impairment, and the ALJ’s decision to the contrary is not supported by substantial evidence.

At Step Two, § 404.1520(c) requires finding a severe impairment when it has more than a minimal effect on the claimant’s ability to perform basic work activities.

Averbach v. Astrue · filed 2010-08-06(c)

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). ... 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.

Section 404.1520(c) requires the Commissioner to determine whether a claimant has a severe impairment or combination of impairments that significantly limits the ability to perform basic work activities before proceeding to the next step.

Abed v. Astrue · filed 2010-08-24(c)

That determination is governed by the “severity regulation,” which provides: ... 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. ... §§ 404.1520(c), 416.920(c). If the claimant does not have a severe impairment or combination of impairments, the disability claim is denied. If the impairment is severe, the evaluation proceeds to the third ... step. ... The ALJ’s failure to make any severity findings at all about the effect of these impairments, either singly or in combination with the impairments found to be severe, was legal error.

Section 404.1520's five-step evaluation treats step two as a threshold filter: finding any severe impairment is enough to continue to the next steps, so failure to classify additional impairments as severe may be harmless.

Medina v. Social Security Administration · filed 2016-01-06(a)(4)

Step two of the test merely “acts as a filter.” ... In other words, “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 proceed with the rest of the five-step analysis. ... Thus, even if Medina’s other conditions should have been categorized as severe impairments, any error was harmless because the ALJ determined that her obesity and “thyroid cancer status post total thyroidectomy” were severe impairments, allowing him to move onto step three of the test.

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 a Step Two classification error is harmless when resulting limitations are accounted for later.

Cotton v. Astrue · filed 2010-04-02(c)

Cotton maintains that fibromyalgia, diagnosed by her treating physicians, must be accepted as a “severe” impairment. 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). An ALJ must consider all of the evidence at Step Two to determine whether a medically determinable impairment significantly limits the claimant’s ability to perform basic work activities. Id. § 404.1520(a); Bowen v. Yuckert, 482 U.S. 137, 145 (1987). ... In any event, the ALJ did conclude that Cotton should be limited to light work due to the possibility that she might have fibromyalgia. For this reason, any error in failing to include fibromyalgia as a severe impairment is harmless. See Lewis v. Astrue, 498 F.3d 909, 911 (9th Cir. 2007) (holding that when an ALJ accounts for resulting limitations later in the sequential evaluation process, any error in finding the impairment non-severe at Step Two is harmless).

Section 404.1520(c) permits an ALJ to reject a claimant’s allegation of disabling pain when the decision addresses the allegation, states the reason for rejecting it, and is supported by the record.

Mercado-Pumares v. Commissioner of Social Security · filed 2003-09-30(c)

An ALJ in a social security disability case may reject the claimant’s claim of disabling pain if he affirmatively addresses the claim in his decision, specifies the reason for rejecting it, and his conclusion is supported by the record, 20 C.F.R. 404.1520(c).

The regulation requires an ALJ to consider the claimant's impairments in combination, without regard to whether any single impairment would be disabling.

Speed v. Commissioner of Social Security · filed 2022-03-08(a)(4)(ii)

The ALJ needed to consider the combination of all impairments without regard to whether any single impairment would be disabling, 20 C.F.R. § 404.1520(a)(4)(ii) (id. at 19). ... Although the ALJ did not specify which limitations compelled the opinion of an expert, this is consideration in combination of all of Plaintiff’s impairments.

At step two, the ALJ must assess the medical severity of the claimant's impairments, including whether a combination of impairments is severe.

Allen v. Astrue · filed 2011-12-29(a)(4)(ii)

Under 20 C.F.R. § 404.1520(a)(4)(ii), the ALJ is required to consider “the medical severity” of the claimant’s impairments and this includes whether a claimant has a combination of impairments that is severe.

Section 404.1520(a) requires the ALJ to consider the combined effect of all of a claimant’s impairments when determining the claimant’s ability to work.

Remick v. SSA · filed 2011-10-21(a)

In determining whether a claimant is disabled, an ALJ must consider “the combined effect of all of a claimant’s impairments.” McDonald v . Sec’y of Health & Human Servs., 795 F.2d 1118, 1126 (1st Cir. 1986) (citing 42 U.S.C. § 423(d)(2)(C)); see also 20 C.F.R. § 404.1520(a). It is “simply a matter of common sense that various physical, mental, and psychological defects, each non-severe in and of itself, might, in combination, in some cases, make it impossible for a claimant to work.” McDonald, 795 F.2d at 1127. Thus, in assessing a claimant’s ability to work, the ALJ should not disregard individual, non-severe impairments where the claimant’s collective impairments are severe.

Section 404.1520 establishes a five-step sequential process for deciding disability claims, including evaluation of listed impairments at step three and available work at step five.

Jones v. Comm Social Security · filed 2004-02-10(a), (c), (d), (e), and (f)

The Social Security Administration has promulgated a five-step evaluation process to determine whether an individual is disabled. See 20 C.F.R. § 404.1520; see generally Plummer, 186 F.3d at 428. In step one, the Commissioner decides whether the claimant is currently engaging in substantial gainful activity. If so, the claimant is not eligible for disability benefits. 20 C.F.R. § 404.1520(a). In step two, the Commissioner determines whether the claimant is suffering from a severe impairment. If the impairment is not “severe,” the claimant is not eligible for disability benefits. 20 C.F.R. § 404.1520(c). In step three, the Commissioner evaluates whether the evidence establishes that the claimant suffers from a listed impairment. If so, the claimant is automatically eligible for benefits. If the claimant does not suffer from a listed impairment or its equivalent, however, the Commissioner proceeds to the next step. 20 C.F.R. § 404.1520(d). In step four, the Commissioner reviews whether the claimant retains the “residual functional capacity” to perform his past relevant work. If so, the claimant is not eligible for disability benefits. 20 C.F.R. § 404.1520(e). Finally, in step five the Commissioner considers whether work exists in significant numbers in the national economy that the claimant can perform given his medical impairments, age, education, past work experience, and “residual functional capacity.” If so, the claimant is not eligible for benefits. 20 C.F.R. § 404.1520(f). In this final step, “the burden of production shifts to the Commissioner, who must demonstrate the claimant is capable of performing other available work in order to deny a claim of disability.” Plummer, 186 F.3d at 428.

Section 404.1520(c) requires a claimant to show that an impairment or combination of impairments significantly limits the abilities and aptitudes necessary to do most jobs.

Alicea v. Rhode Island Department of Human Services, 03-3144 (2004) · filed 2004-02-18(c)

The severity regulation requires the claimant to show that he has an `impairment or combination of impairments which significantly limits' `the abilities and aptitudes necessary to do most jobs.' 20 C.F.R. § 404.1520 (c), 404.1521(b) (1986).

At the fifth step, the Commissioner bears the burden to show that a claimant who cannot perform past relevant work can adjust to other work existing in significant numbers in the national economy.

Delgado v. Barnhart · filed 2004-02-19(a)(4)(v)

As previously noted, the Commissioner bears the burden of proof at the fifth step of the administrative disability determination prescribed by 20 C.F.R. § 404.1520.

Section 404.1520 requires an ALJ to consider the entire record, including evidence supporting the claimant’s disability claim, rather than selectively relying on favorable evidence.

Sutherland v. Barnhart · filed 2004-06-23

The ALJ must consider the entire record in accordance with his duty under 20 C.F.R. 404.1520(3). It is not proper for the ALJ to simply pick and choose from the transcript only such evidence that supports his determination, without affording consideration to evidence supporting the plaintiffs claims. It is grounds for remand for the ALJ to ignore parts of the record that are probative of the claimant’s disability claim.

Section 404.1520(d) provides that a claimant is eligible for benefits when her impairment meets or equals an impairment in the Listing of Impairments.

Barnett v. Jo Anne B. Barnhart, Commissioner of Social Security · filed 2004-08-25(d)

Under a theory of presumptive disability, a claimant is eligible for benefits if she has an impairment that meets or equals an impairment found in the Listing of Impairments. 20 C.F.R. § 404.1520(d); 20 C.F.R. Pt. 404, Subpt. P, App. 1. The listings specify the criteria for impairments that are considered presumptively disabling. 20 C.F.R. § 404.1525(a).

Section 404.1520(d) requires the adjudicator to determine whether severe impairments, considered in combination, meet or equal a listed impairment.

Segal v. Barnhart · filed 2004-10-29(d)

Since the ALJ found Plaintiffs chronic ulcerative colitis, spastic colon and migraines to be severe, he was required to determine whether these impairments meet or equal a listed impairment in Appendix 1, Subpart P, Regulations No. 4 (20 C.F.R. § 404.1520(d)). ... This court finds that the ALJ erred by failing to find Plaintiff suffered from impairments of listing severity. The ALJ must take into consideration all impairments in combination, when determining whether they equal a listing.

Section 404.1520 establishes a five-step sequential evaluation process, under which a claimant who can perform previous work is found not disabled at step four without assessing whether that work exists in significant numbers in the national economy.

Barnhart v. Thomas · filed 2003-11-12(e)

As the above description shows, step four can result in a determination of no disability without inquiry into whether the claimant’s previous work exists in the national economy; the regulations explicitly reserve inquiry into the national economy for step five. Thus, the SSA has made it perfectly clear that it does not interpret the clause “which exists in the national economy” in § 423(d)(2)(A) as applying to “previous work.”

Section 404.1520 requires a five-step sequential analysis to determine disability, moving from current employment and severity through listed impairments and past work to other work in the national economy.

Lusk v. Commissioner of Social Security · filed 2004-08-06(b)-(f)

A five-part sequential analysis is used to evaluate disability claims, which includes the following inquiries: (1) Is the claimant presently employed? If so, the claim is disallowed; if not, the inquiry proceeds to step two; (2) Is the claimant’s impairment “severe?” If not, the claim is disallowed; if so, the inquiry proceeds to step 3; (3) Does the impairment meet or exceed one of a list of specific impairments? If so, the claimant is automatically disabled; if not, the inquiry moves to step four; (4) Is the claimant able to perform his or her past relevant work experience? If so, the claim is denied, and if not, the inquiry moves to step five; (5) Is the claimant able to perform any other work in the national economy? If so, the claim is denied, and if not, the claimant is allowed disability benefits.

Section 404.1520 uses a five-step disability evaluation, and at step five the Commissioner must show that the claimant can perform other work existing in significant numbers in the national economy.

Donatelli v. Comm Social Security · filed 2005-04-15(a)(4)(v)

Pursuant to regulations promulgated by the SSA, a five-step evaluation process governs the determination of whether a person meets these criteria and is therefore disabled and entitled to benefits. See 20 C.F.R. § 404.1520; see also Jones v. Barnhart, 364 F.3d 501, 503 (3d Cir. 2004) (explaining the manner in which an ALJ should apply the five-step evaluation process). ... Lastly, in step five, the question is whether jobs exist in sufficient numbers in the national economy that the claimant can perform given the claimant’s medical impairments, age, education, past work experience, and residual functional capacity. If these jobs exist, the claimant is not eligible for benefits. § 404.1520(a)(4)(v). At this ultimate step, the burden shifts from the claimant to the Commissioner, whereby the Commissioner must show that the claimant is capable of performing other available work that exists in the national economy. ... This appeal arises from the ALJ’s determination at step five. ... The ALJ’s decision in this regard is supported by substantial evidence. See Jones, 364 F.3d at 503.

Section 404.1520(a)(4) requires the Commissioner to stop the sequential evaluation once it finds a claimant disabled or not disabled at a step.

Pritchard v. Jo Anne B. Barnhart · filed 2005-07-19(a)(4)

Pritchard’s argument that the ALJ erred in stopping the first step of the five step analysis is also without merit. Section 404.1520 explicitly provides that if “we find that you are disabled or not disabled at a step, we make our determination or decision and we do not go on to the next step.” Id. § 404.1520(a)(4). In this case, the ALJ found at step one that Pritchard had engaged in substantial gainful activity and therefore was not disabled during the relevant period. Following the explicit command of the Regulations, the ALJ then properly terminated its evaluation at that point.

At the fourth step, the claimant must prove that she cannot perform her past relevant work; if she can still perform it, she is not disabled and the disability analysis need not proceed to step five.

Carmack v. Barnhart · filed 2005-08-31(e), (a)(4)(iv)

If the claimant does not show that she is “disabled” under the third step, the fourth step requires the claimant to prove that she is incapable of performing work that she has done in the past. 20 C.F.R. § 404.1520(e). ... Under the fourth step, claimants who can still perform their past relevant work are deemed not disabled regardless of whether they have a meritorious argument on the fifth step.

At the fifth step, the Commissioner must show that significant numbers of jobs exist that the claimant can perform, after which the burden shifts back to the claimant to rebut that showing.

Palomo v. Barnhart · filed 2005-11-18(f)

Under the fifth-step of the evaluation process, the Commission bears the burden of showing that there exists work in significant numbers in the national economy that the claimant can perform. Once such jobs are identified, the burden shifts back to the claimant to rebut this finding.

Section 404.1520(a)(4)(v) requires considering whether a claimant who cannot return to past work can perform other work available in the national economy.

Walker v. Barnhart · filed 2005-12-09(a)(4)(v)

While all concur that Walker cannot return to his previous work as a bus driver, the standard is whether he also cannot perform other work in the national economy. 20 C.F.R. § 404.1520(a)(4)(v).

At step five, the Commissioner must show that jobs exist in the national economy that the claimant can perform; a finding that the claimant can perform sedentary work alone is insufficient.

Smith v. Barnhart · filed 2005-12-29(g)

Specifically, notwithstanding a finding that plaintiff could perform sedentary work, if the Commissioner has not demonstrated that jobs exist in the national economy that plaintiff could perform, a finding of “not disabled” is not supported by substantial evidence.

Section 404.1520 requires the ALJ to use a five-step sequential evaluation, including deciding at step four whether the claimant’s residual functional capacity permits performance of past relevant work.

Brown v. Barnhart · filed 2006-01-23(a)(4)(iv)

To arrive at a determination as to disability, the ALJ must undertake the five-step sequential evaluation embodied in 20 C.F.R. § 404.1520. This process requires that the ALJ first determine whether the claimant is presently engaged in substantial gainful activity. 20 C.F.R. § 404.1520(b). If so, a finding of “no disability” is made. If the claimant is not engaged in such activity, then, the ALJ must proceed to the second step of the sequential evaluation. ... This step requires that the ALJ determine whether the claimant has the “residual functional capacity” to perform past relevant work. 20 C.F.R. § 404.1520(a)(4)(iv). ... The ALJ must then compare the RFC to the demands of the previous employment to determine whether the claimant is still capable of performing that kind of work. If so, the ALJ will conclude that the claimant is not disabled.

At step four, the ALJ must determine whether the claimant retains the residual functional capacity to perform her past relevant work.

Smith v. Commissioner of Social Security · filed 2006-05-01(a)(4)(iv) and (f)

If a claimant does not suffer from a listed impairment or its equivalent, the analysis proceeds to steps four and five. In the former, the ALJ is required to consider whether the claimant retains the residual functional capacity to perform her past work. 20 C.F.R. § 404.1520(a)(4)(iv) and (f). ... After determining that Smith had the residual functional capacity to perform light work, the ALJ reviewed the demands of Smith’s relevant past work to determine whether she could still meet those demands. 20 C.F.R. §§ 404.1520(a)(4)(iv) and (f), 404.1567(b).

Section 404.1520(a) requires the ALJ to consider the combined effect of all of a claimant’s impairments throughout the sequential disability determination.

Forni v. SSA · filed 2006-10-17(a)

In determining whether a claimant is disabled, an ALJ must consider “the combined effect of all of a claimant’s impairments.” McDonald, 795 F.2d at 1126 (citing 42 U.S.C. § 423(d)(2)(C)); see also 20 C.F.R. § 404.1520(a).

Section 404.1520(a) requires the ALJ to consider the combined effect of all of a claimant’s impairments, including impairments that are non-severe individually when the impairments collectively are severe.

Remick v. SSA · filed 2011-10-21(a)

In determining whether a claimant is disabled, an ALJ must consider “the combined effect of all of a claimant’s impairments.” McDonald v . Sec’y of Health & Human Servs., 795 F.2d 1118, 1126 (1st Cir. 1986) (citing 42 U.S.C. § 423(d)(2)(C)); see also 20 C.F.R. § 404.1520(a). It is “simply a matter of common sense that various physical, mental, and psychological defects, each non-severe in and of itself, might in combination, in some cases, make it impossible for a claimant to work.” McDonald, 795 F.2d at 1127. Thus, in assessing a claimant’s ability to work, the ALJ should not disregard individual, non-severe impairments where the claimant’s collective impairments are severe. ... Here, the record does not support Remick’s assertion that the ALJ failed to consider the combined effect of his multiple impairments. ... I conclude that the ALJ’s analysis sufficiently took into account the combined effect of Remick’s impairments and is supported by substantial evidence.

Section 404.1520(c) requires the ALJ to evaluate the combined impact of a claimant’s impairments on her ability to work, without separately apportioning pain among them.

Leigh Ayn D. Laurey v. Commissioner of Social Security · filed 2015-12-01(c)

Moreover, Laurey provides no authority for the proposition that the ALJ was required explicitly to apportion Laurey’s pain among her severe impairments before evaluating the pain’s intensity, persistence and limiting effects. To the contrary, the ALJ is required to evaluate the “combined impact” of a claimant’s impairments on her ability to work. See 20 C.F.R. §§ 404.1520(c), 404.1523.

Section 404.1520(c) requires consideration of the cumulative effect of a claimant’s impairments when determining whether the impairments are severe enough to affect the ability to work.

MATTIS v. SAUL · filed 2020-06-18(c)

The ALJ must analyze the cumulative effect of all the claimant’s impairments in determining whether he is capable of performing work and is not disabled. See Beeks v. Comm'r of Soc. Sec., 424 F. App’x 163, 164 (3d Cir. 2011) (not precedential) (citing Plummer, 186 F.3d at 428). See also 20 C.F.R. §§ 404.1520(c), 416.920(c), 404.1523(c), 416.923(c), 404.1545(a), 416.945(a). In the present case, the ALJ’s decision shows that, throughout the sequential analysis, he considered the cumulative effect of the severe and non-severe impairments that plaintiff presented.

Section 404.1520(e) requires the ALJ to consider the combined, cumulative, or synergistic effects of all impairments when assessing a claimant’s residual functional capacity.

Klugh v. Commissioner of Social Security · filed 2023-05-05(e)

The ALJ determined Claimant did not have an impairment or combination of impairments equaling the severity of one of the listed impairments at step three, but the ALJ did not consider the “cumulative, compounding, or synergistic effect” of all impairments in combination when assessing the RFC, as required pursuant to 20 C.F.R. 404.1520(e), 404.1545, and SSR 96-8p.

At step three, an ALJ must meaningfully consider obesity alone and in combination with other impairments when evaluating disability.

Diaz v. Commissioner of Social Security · filed 2009-08-12(d)

Hence, an ALJ must meaningfully consider the effect of a claimant’s obesity, individually and in combination with her impairments, on her workplace function at step three and at every subsequent step.

Section 404.1520 requires disability evaluators to consider the combined effect of a claimant’s impairments.

Sims, Linda P. v. Barnhart, Jo Anne B. · filed 2002-10-04

Before closing, we make one final observation about disability evaluations carried out by ALJs. We remind ALJs that they must not narrowly confine their review to isolated impairments when the record shows that the impairments have some “combined effect.” See 20 C.F.R. §§ 404.1520, 416.920. Here we are persuaded that the ALJ considered the combined effect of Sims’s impairments because he ensured that the VE took into account all of Sims’s impairments when determining whether jobs existed in Indiana that Sims could perform. The ALJ’s evaluation in this case was therefore acceptable, though we urge the SSA in the future to carefully examine the issue of disability in light of a claimant’s total impairments.

Section 404.1520 requires consideration of the combined effects of a claimant’s impairments during the disability evaluation.

Reid v. Berryhill · filed 2020-09-28(g)

“SSA regulations and case law mandate that the ALJ consider the combined effect of a claimant’s impairments at each step of the sequential analysis.” Snow v. Barnhart, No. 05-cv-11878-RGS, 2006 WL 3437400, at *6 (D. Mass. Nov. 29, 2006) (citing 20 C.F.R. § 404.1520(g)). ... Accordingly, the ALJ adequately considered Reid’s combined impairments.

Section 404.1520(c) allows the severity of a claimant’s impairments to be assessed in combination.

Brown v. Kijakazi · filed 2022-04-18(c)

A plaintiff can have a marked or extreme limitation as the result of a single listed disorder or a combination of disorders. 20 CFR 404.1520(c).

At the fifth step, a claimant is disabled if unable to perform other work; if able to do other work, the Commissioner must establish that a significant number of jobs exist that the claimant can do.

Lounsburry v. Barnhart · filed 2006-11-06(f)(1)

Step 5: Is the claimant able to do any other work? If not, then the claimant is “disabled” and therefore entitled to disability insurance benefits. See 20 C.F.R. § 404.1520(f)(1). If the claimant is able to do other work, then the Commissioner must establish that there are a significant number of jobs in the national economy that claimant can do. There are two ways for the Commissioner to meet the burden of showing that there is other work in “significant numbers” in the national economy that claimant can do: (1) by the testimony of a vocational expert, or (2) by reference to the Medical-Vocational Guidelines at 20 C.F.R. pt. 404, subpt. P, app. 2. If the Commissioner meets this burden, the claimant is “not disabled” and therefore not entitled to disability insurance benefits. See 20 C.F.R. §§ 404.1520(f), 404.1562. If the Commissioner cannot meet this burden, then the claimant is “disabled” and therefore entitled to disability benefits.

Section 404.1520 requires disability claims to be evaluated through a five-step sequential process, with the Commissioner bearing the burden at step five to show that the claimant can perform other work.

Reliford v. Barnhart · filed 2006-08-02(a)

In determining whether a claimant is disabled, Social Security regulations outline a five-step sequential process. 20 C.F.R. § 404.1520(a)-(f). ... Therefore, the Commissioner failed to carry her burden at step five of showing the plaintiff could perform other work.

Section 404.1520 establishes a five-step sequential inquiry for determining disability, and the inquiry ends when the claimant is found not disabled at any step.

David v. Barnhart · filed 2006-08-14

Social Security regulations provide a five-step sequential inquiry to determine whether a claimant is disabled. ... 20 C.F.R. §§ 404.1520; 416.920. If the ALJ determines that the claimant is not disabled at any step of the five-step inquiry, the inquiry ends without proceeding to the next step. Id.

Section 404.1520 requires an ALJ to apply a five-step disability analysis, including determining at step five whether the claimant can perform a significant number of jobs in the national economy.

JANEZICH v. Barnhart · filed 2006-09-27

In determining whether a claimant is disabled, an ALJ must employ a now-familiar five-part test, considering whether: ... (5) the claimant is unable to perform any other work existing in significant numbers in the national economy. ... However, in determining whether a person meets the Act’s definition of disability — -which includes in its definition that a person be disabled for a continuous period of twelve months — the ALJ was required to apply the five-step analysis described above. The ALJ, however, improperly ignored the evidence and misapplied the law as to step five of the analysis.

Section 404.1520 sets out a five-step disability inquiry; at step five, the Commissioner must show that the claimant can perform other work in the national economy.

Barber v. Barnhart · filed 2006-11-08(a)

In determining whether a claimant is disabled, Social Security regulations outline a five-step sequential process. 20 C.F.R. § 404.1520(a)-(f). The Commissioner must determine in sequence: ... (5) whether the claimant is capable of performing any work in the national economy. ... The court concludes that substantial evidence does not support the ALJ’s decision not to credit the opinions of the plaintiffs treating psychiatrist or those of the Commissioner’s consulting psychiatrists. Based upon these opinions and the testimony of the VE, the Commissioner failed to carry her burden at step five of showing the plaintiff could perform other work.

Section 404.1520(a) requires the Commissioner to determine disability through a five-step sequential analysis.

Frobes v. Barnhart · filed 2006-11-20(a)

To make this determination, the Commissioner must employ a five step sequential analysis. 20 C.F.R. §§ 404.1520(a)-(f); 416.920(a)-(f). Under this process, the ALJ must inquire, in the following order: (1) whether the claimant is engaged in substantial gainful employment; (2) whether the claimant has a severe impairment; (3) whether the claimant’s impairment meets or equals a listed impairment; (4) whether he can perform past relevant work; and (5) whether the claimant is capable of performing any work in the national economy.

Section 404.1520 uses a five-step sequential evaluation, with step one asking whether the claimant engaged in substantial gainful activity during the alleged disability period; engagement in such activity means the claimant is not disabled.

Surgeon v. Commissioner of Social Security · filed 2006-06-21(b)

A five-step sequential analysis is used to evaluate disability claims. ... At the first step of this analysis, the Commissioner evaluates the claimant’s work activity and determines whether the claimant has been engaged in “substantial gainful activity” during the period of alleged disability. ... If the claimant has been engaged in such activity, then he is not disabled.

Section 404.1520 requires the ALJ to use a five-step sequential evaluation of disability, with the burden shifting to the Commissioner at step five to show that the claimant can perform other work existing in significant numbers in the national economy.

Banks v. Barnhart · filed 2006-06-13(b), (c), (d), (f), (g)

Regulations promulgated by the Commissioner establish a five-step sequential evaluation process to be followed by the ALJ 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, 20 C.F.R. § 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 his limitations to perform his past work. 20 C.F.R. §§ 404.1520(f), 416.920(f). If not, in the Fifth Step, 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).

Section 404.1520 requires disability claims to be evaluated through a five-step sequence covering work activity, impairment severity, listed impairments, past work, and other work considering vocational factors.

Woods v. Barnhart · filed 2006-09-05(b), (c), (d), (e), and (f)

“An ALJ must engage in a five-step sequential inquiry to determine whether the claimant is capable of performing “substantial gainful activity,” or is, in fact, disabled: ... 1. An individual who is working and engaging in substantial gainful activity will not be found disabled regardless of the medical findings. ... 2. An individual who does not have a “severe impairment” will not be found to be disabled. ... 3. An individual who “meets or equals a listed impairment in Appendix 1” of the regulations will be considered disabled without consideration of vocational factors. ... 4. If an individual is capable of performing the work he has done in the past, a finding of “not disabled” must be made. ... 5. If an individual’s impairment precludes performance of his past work, then other factors, including age, education, past work experience, and residual functional capacity must be considered to determine if any work can be performed. ... A finding that a claimant is disabled or is not disabled at any point in the five-step review is conclusive and terminates the analysis.”

Section 404.1520(a)(4) requires disability claims to be evaluated through a five-step sequential analysis.

Miller v. Astrue · filed 2008-03-05(a)(4)

Regulations of the Commissioner set forth a five-step analysis that must be used in evaluating a disability claim. ... It is clear from the record that the ALJ applied the correct legal standards, performing the five-step analysis and giving the appropriate weight to the opinions and reports of the various medical professionals.

Section 404.1520 requires an administrative law judge to evaluate disability claims using a five-step sequential analysis.

Singleton v. Astrue · filed 2008-03-31

In determining whether a person is disabled, the Regulations require the A.L.J. to perform a sequential five-step analysis. 20 C.F.R. §§ 404.1520, 416.920.

Section 404.1520 requires an ALJ to evaluate disability claims through a sequential process, including determining whether the claimant can perform past work and, if not, whether the Commissioner proves that other work exists in the national economy.

Costa v. Astrue · filed 2008-07-17(f)

In evaluating a disability claim, an ALJ is required to follow the sequential step analysis prescribed by 20 C.F.R. § 404.1520. The ALJ must first determine whether a claimant was gainfully employed prior to the onset of the disabling condition. The ALJ must then determine whether the claimant suffers from a severe impairment limiting her ability to work. If the impairment is the same as, or equal in its effect to, an impairment (or combination of impairments) listed in Appendix 1 of Subpart P of the regulations, the claimant is presumptively deemed disabled. If the impairment is not covered by Appendix 1, the fourth step of the analysis requires that the claimant prove that her disability is sufficiently serious to preclude a return to her former occupation. ... Only if she meets that burden is the Commissioner at the fifth step obligated to prove that there are other jobs in the national economy that she could nonetheless perform.

Section 404.1520(a)(4)(iii) treats medical conditions meeting the listed-impairment requirements as totally disabling without inquiry into labor-market conditions.

Bauer, Christine v. Astrue, Michael · filed 2008-07-08(a)(4)(iii)

This is implicit in the concept of listed impairments—medical conditions that are deemed totally disabling without inquiry into labor-market conditions. 20 C.F.R. § 404.1520(a)(4)(iii); 20 C.F.R. pt. 404, subpt. P; Barnett v. Barnhart, 381 F.3d 664, 668 (7th Cir. 2004).

Section 404.1520(a)(4) establishes a five-step disability-evaluation framework and ends the inquiry once the Commissioner finds a claimant disabled or not disabled at a step.

Hayes v. Astrue · filed 2008-02-25(a)(4)

A five-step regulatory framework governs the evaluation of disability in general. See 20 C.F.R. § 404.1520; see also Bowen v. Yuckert, 482 U.S. 137, 140-42, 107 S.Ct. 2287, 96 L.Ed.2d 119 (1987) (describing the five-step process); Fastner v. Barnhart, 324 F.3d 981, 983-84 (8th Cir.2003). If the Commissioner finds that a claimant is disabled or not disabled at any step, a decision is made and the next step is not reached. 20 C.F.R. § 404.1520(a)(4).

At the second step of the sequential evaluation, the claimant's alleged impairment must be severe.

Guinn v. Commissioner of Social Security · filed 2008-04-11

The second step of the sequential inquiry used to establish whether a claimant is “disabled” is to determine whether the alleged impairment is severe.

Section 404.1520 requires an ALJ to determine disability through a five-step sequential process and stop the review when disability or non-disability is established at an earlier step.

Eskridge v. Astrue · filed 2008-08-07(a)(4)

To determine disability, the ALJ uses a five-step sequential analysis. ... If a finding of disability or non-disability can be made at any point in the sequential process, the ALJ will not review the claim further. 20 C.F.R. § 404.1520(a)(4).

Section 404.1520(c) requires only a de minimus showing for an impairment to be severe at step two; once any severe impairment is found, failure to classify another impairment as severe does not by itself require reversal.

Hill v. Astrue · filed 2008-08-12(c)

A determination that an impairment is “severe” at step two requires only a de minimus showing. ... This error does not require reversal, however. Once the ALJ finds that the claimant has any severe impairment, he has satisfied the analysis for purposes of step two. His failure to find that additional alleged impairments are also severe is not in itself cause for reversal.

At step five, after a claimant shows a severe impairment preventing past relevant work, the burden shifts to the Social Security Administration to show that the claimant can perform other work in the national economy considering the claimant's vocational factors.

Jordan v. Astrue · filed 2008-08-06(g)

Once the claimant has established he has a severe impairment which prevents him from performing his past relevant work, the burden at step five shifts to the Social Security Administration to establish the claimant is capable of engaging in any other work in the national economy, considering his age, education and work experience.

At step two, § 404.1520(c) provides that a claimant is not disabled if no impairment or combination of impairments significantly limits the claimant’s ability to do basic work activities.

Palomo v. Commissioner of Social Security · filed 2008-09-29(c)

If a claimant has no “impairment or combination of impairments which significantly limits [his] physical or mental ability to do basic work activities,” SSA will find that he “do[es] not have a severe impairment and [he is], therefore, not disabled.”

At step four, the Commissioner determines whether, despite a claimant’s severe impairments, the claimant retains the residual functional capacity to perform past relevant work.

Garrett v. Commissioner of Social Security · filed 2008-04-17(e)

At step four, the Commissioner determines whether, despite her severe impairments, the claimant retains the RFC to perform her past relevant work.

At Step Four, a claimant who can perform past relevant work is not disabled, so the evaluation need not proceed to Step Five.

Mullan v. Astrue · filed 2008-08-08(a)(4)(iv)

The Administrative Law Judge (“ALJ”) applied the five-step sequential analysis mandated by 20 C.F.R. § 404.1520. ... At Step Four, the ALJ properly found that Mullan retained the residual functional capacity to perform his past relevant work as a chemical dependency counselor. Because Step Five is required only where a claimant cannot perform his past relevant work, the ALJ properly decided not to proceed to this step.

At step five, § 404.1520(f)(1) requires the Commissioner to show that significant numbers of jobs exist that the claimant can perform; if that burden is unmet, the claimant is disabled.

Wright v. Astrue · filed 2008-07-25(f)(1)

The Social Security Regulations set out a five-step sequential process for determining whether a claimant is disabled within the meaning of the Social Security Act. 20 C.F.R. § 404.1520. ... Step 5. Is the claimant able to do any other work? If not, then the claimant is “disabled” and therefore entitled to disability insurance benefits. See 20 C.F.R. § 404.1520(f)(1). If the claimant is able to do other work, then the Commissioner must establish that there are a significant number of jobs in the national economy that claimant can do. There are two ways for the Commissioner to meet the burden of showing that there is other work in “significant numbers” in the national economy that claimant can do: (1) by the testimony of a vocational expert, or (2) by reference to the Medical-Vocational Guidelines at 20 C.F.R. pt. 404, subpt. P, app. 2. If the Commissioner meets this burden, the claimant is “not disabled” and therefore not entitled to disability insurance benefits. See 20 C.F.R. §§ 404.1520(f), 404.1562. If the Commissioner cannot meet this burden, then the claimant is “disabled” and therefore entitled to disability benefits. ... For all of these reasons, we must remand this action to the ALJ to reconsider the evidence in a manner consistent with this Order, and to re-assess under step five whether the Commission met its burden to prove that Plaintiff was capable of working in jobs that existed in significant numbers in the national economy from January 12, 2005, when he filed his Application, through September 19, 2006.

Section 404.1520 requires an ALJ to evaluate disability claims in five sequential steps, moving from substantial gainful activity and severity to listings, past work, and, if necessary, other work in the national economy.

Best v. Astrue · filed 2008-08-11(b), (c), (d), (f), (g)

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. § 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).

Section 404.1520(a)(4) sets out the five-step process for an initial disability determination, including assessing substantial gainful activity, impairment severity, listed impairments, past relevant work, and other work.

Delph v. Astrue · filed 2008-08-15(a)(4)

This sequential analysis for cessation of benefits includes the five steps to be followed in an initial disability determination. See 20 C.F.R. §§ 404.1520(a)(4), 416.920(a)(4); Smith v. Shalala, 987 F.2d 1371, 1373 (8th Cir. 1993) (the five-step process for making the initial disability evaluation is: (1) whether claimant is engaged in substantial gainful activity, (2) whether claimant has a severe impairment, (3) whether the impairment meets or equals the severity of a listed impairment, (4) whether claimant has the residual functional capacity to perform past relevant work activity, and (5) if claimant is unable to do past work, whether claimant can perform other work).

Section 404.1520 sets out a five-step disability evaluation process, and an omission at step two is harmless when the ALJ proceeds through later steps and considers the claimant’s cumulative medically-supported symptoms.

Reed-Goss v. Astrue · filed 2008-08-25

Reed-Goss contends that the ALJ committed legal error in his application of the five-step disability evaluation process set forth in 20 C.F.R. § 404.1520. ... Where the ALJ fails to discuss the severity of all of a claimant’s impairments at step two, there is a danger that his analysis at steps three through five might be inaccurate. ... In this case, however, the ALJ proceeded to steps three through five and considered the cumulative effect of Reed-Goss’ medically-supported symptoms; thus, any error was harmless.

Section 404.1520 requires disability claims to be evaluated through a five-step sequential process, with the claimant bearing the burden through past relevant work and the Commissioner bearing the burden at the final step.

McGee v. Astrue · filed 2008-09-05

The Commissioner uses a five-step sequential analysis to determine whether a claimant is disabled. 20 C.F.R. §§ 404.1520, 416.920. A claimant must prove: first, that she has not engaged in substantial gainful activity; second, that she has a medically determinable severe impairment, as that term is defined in the regulations; third, she may prove her impairment meets or equals a presumptively disabling impairment listed in the regulations; if so, the claimant is presumed to be disabled, and no further analysis is needed. If not, the analysis proceeds to a fourth step. Here, the claimant must prove her impairment prevents her from performing her past relevant work; and fifth, if the claimant carries her burden to this point, the Commissioner has the opportunity (and burden) to prove there are other jobs the claimant can perform.

Section 404.1520 establishes a five-step sequential process for determining disability, requiring the ALJ to consider work activity, impairment severity, listed-impairment equivalence, past relevant work, and other national-economy work in that order.

Henning v. Astrue · filed 2008-09-23(a)

To make this determination, one must employ a five step sequential analysis. 20 C.F.R. §§ 404.1520(a)-(f). Under this process, the ALJ must inquire, in the following order: (1) whether the claimant is engaged in substantial gainful employment; (2) whether the claimant has a severe impairment; (3) whether the claimant’s impairment meets or equals a listed impairment; (4) whether the claimant can perform past relevant work; and (5) whether the claimant is capable of performing any work in the national economy.

Section 404.1520(a)(3) requires the ALJ to consider all evidence in the case record when determining whether a claimant is disabled.

Carpenter v. Astrue · filed 2008-08-25(a)(3)

This is error because the regulations require the ALJ to “consider all evidence in [the] case record when [he] makes a determination or decision whether [claimant is] disabled,” 20 C.F.R. §§ 404.1520(a)(3), 416.920(a)(3), and this court requires the ALJ to discuss “the significantly probative evidence he rejects[,]” Clifton, 79 F.3d at 1010.

At step four, the ALJ must determine whether the claimant's impairments prevent her from performing her past relevant work.

McAuliffe v. Barnhart · filed 2008-07-25(a)(4)(IV)

At step four of the sequential evaluation process, the ALJ must determine whether a claimant’s impairments prevent her from doing her past relevant work. 20 C.F.R. §§ 404.1520(a)(4)(IV), 416. 920(a)(4)(IV).

At step four, if an applicant’s impairment does not meet or equal a listed impairment and the applicant can perform past relevant work, the applicant is not disabled.

Carnes v. Commissioner of the Social Security Administration · filed 2008-08-19(e)

If an applicant’s impairment does not meet or equal a listed impairment and the finding that the applicant can perform past relevant work is uncontested, then the applicant is not disabled. 20 C.F.R. §§ 404.1520(e) and 404.1520(f).

Section 404.1520 requires consideration of all evidence in the record and a five-step sequential evaluation to determine whether a claimant is disabled.

Sosa v. Commissioner of Social Security · filed 2008-04-16(a)

In making a determination as to whether a claimant is disabled, all of the evidence in the record must be considered. 20 C.F.R. § 404.1520(a). A five-step sequential evaluation process must be applied to every case in making a final determination as to whether a claimant is disabled. 20 C.F.R. § 404.1520.

Section 404.1520 requires a five-step disability determination covering substantial gainful activity, severity, listed impairments, past work, and other work, with the claimant bearing the burden through step four and the Commissioner at step five.

Walterich v. Astrue · filed 2008-09-18(b)-(f)

The federal regulations set forth a five-step analysis that the Commissioner must follow in determining eligibility for disability insurance benefits. 20 C.F.R. §§ 404.1520, 416.920. ... The first step is to determine whether the applicant is engaged in substantial gainful activity. 20 C.F.R. §§ 404.1520(b), 416.920(b). If the individual is engaged in such activity the inquiry ceases and the individual cannot be eligible for disability benefits. ... The next step is to determine whether the applicant has a severe impairment, which significantly limits his physical or mental ability to do basic work activities, as defined in the regulations. 20 C.F.R. §§ 404.1520(c), 416.920(c). Absent an impairment, the applicant is not eligible for disability benefits. ... Third, if there is an impairment and the impairment, or an equivalent, is listed in Appendix 1 of the regulations and meets the duration requirement, the individual is deemed disabled, regardless of the applicant’s age, education or work experience, 20 C.F.R. §§ 404.1520(d), 416.920(d), as, in such case, there is a presumption that an applicant with such an impairment is unable to perform substantial gainful activity. ... However, as a fourth step, if the impairment or its equivalent is not listed in Appendix 1, the Commissioner must then consider the applicant’s “residual functional capacity” and the demands of any past work. 20 C.F.R. §§ 404.1520(e), 416.920(e). If the applicant can still perform work he has done in the past, the applicant will be denied disability benefits. ... Finally, if the applicant is unable to perform any past work, the Commissioner will consider the individual’s “residual functional capacity,” age, education and past work experience in order to determine whether the applicant can perform any alternative employment. 20 C.F.R. §§ 404.1520(f), 416.920(f). ... The applicant bears the burden of proof as to the first four steps, while the Commissioner bears the burden of proof on the final step relating to other employment.

Section 404.1520 uses a five-step sequential evaluation to determine disability, including severity, listed impairments, residual functional capacity and past work, and other work.

Tommie Kemp, Jr. v. Astrue · filed 2009-01-26

The Social Security regulations set forth the following five-step “sequential evaluation” process to determine whether a claimant is disabled: (1) the disability examiner determines whether the claimant is engaged in “substantial gainful activity”; (2) if not, the examiner decides whether the claimant’s condition or impairment is “severe,” i.e., whether it significantly limits claimant’s physical or mental ability to do basic work activities; (3) if so, the examiner decides whether the claimant’s impairment meets or equals the severity of the specified impairments in the Listing of Impairments (“Listing”), thereby precluding any gainful work activity; (4) if the claimant has a severe impairment that does not meet or equal the severity of an impairment in the Listing, the examiner assesses a claimant’s “residual functional capacity,” which measures whether a claimant can perform past relevant work despite the impairment; and (5) if the claimant is unable to do past relevant work, the examiner determines whether, in light of residual functioning capacity, age, education, and work experience, the claimant can perform other work. Crayton v. Callahan, 120 F.3d 1217, 1219 (11th Cir. 1997); 20 C.F.R. §§ 404.1520 (c)-(f), 416.920(c)-(f).

Section 404.1520 requires disability claims to be evaluated through a five-step sequential process, including substantial gainful activity, severity, residual functional capacity and past work, and other work.

Smith v. Commissioner of Social Security · filed 2009-02-05(b), (c), (e), (f)

To determine whether a claimant is disabled within the meaning of the Social Security Act, the ALJ proceeds through a five-step sequential evaluation. ... At step one, the ALJ must determine whether the claimant is engaged in substantial gainful work activity. See 20 CFR § 404.1520(b). If so, the claimant is not disabled. If not, the ALJ proceeds to step two, and determines whether the claimant has an impairment, or combination of impairments, that is “severe,” e.g., that imposes significant restrictions on the claimant’s ability to perform basic work activities. 20 CFR § 404.1520(c). If not, the analysis concludes with a finding of “not disabled.” If so, the ALJ continues to step three. ... If not, analysis proceeds to step four, and the ALJ determines the claimant’s residual functional capacity (“RFC”), which is the ability to perform physical or metal work activities on a sustained basis notwithstanding limitations for the collective impairments. See 20 CFR § 404.1520(e), (f). ... Based on the foregoing, I believe the ALJ applied the proper procedure and that his decision is supported by substantial evidence.

Section 404.1520 establishes a five-step sequential disability evaluation: after the claimant proceeds through the first four steps, the Commissioner must use the claimant’s residual functional capacity and vocational factors at step five to determine whether the claimant can perform other work.

Addison White, Jr. v. Commissioner of Social Security · filed 2009-02-24(b), (c), (d), (e), (f)

A social security disability determination is made in accordance with the five-step sequential analysis set forth in 20 C.F.R. § 404.1520: First, [White] must demonstrate that [he] is not currently engaged in substantial gainful employment at the time of the disability application. 20 C.F.R. § 404.1520(b). Second, [White] must show that [he] suffers from a severe impairment. 20 C.F.R. § 404.1520(c). Third, if [White] is not engaged in substantial gainful employment and has a severe impairment which is expected to last for at least twelve months, which meets or equals a listed impairment, [he] will be considered disabled without regard to age, education, and work experience. 20 C.F.R. § 404.1520(d). Fourth, if the Commissioner cannot make a determination of disability based on medical evaluations and current work activity and [White] has a severe impairment, the Commissioner will then review [White’s] residual functional capacity (RFC) and relevant past work to determine if [he] can do past work; if so, [he] is not disabled. 20 C.F.R. § 404.1520(e). ... The ALJ determined that the first four parts did not entitle [White] to disability benefits, so this case turns on the fifth: if [White’s] impairment prevents [him] from doing past work, the Commissioner will consider [his] RFC, age, education and past work experience to determine if [he] can perform other work. If [he] cannot perform other work, the Commissioner will find [him] disabled. 20 C.F.R. § 404.1520(f). The Commissioner has the burden of proof only on “the fifth step, proving that there is work available in the economy that the claimant can perform.”

Section 404.1520 requires the Commissioner to use a five-step sequential analysis, including consideration of residual functional capacity and past or alternative work.

Corson v. Astrue · filed 2009-03-04(b)-(f)

The federal regulations set forth a five-step analysis that the Commissioner must follow in determining eligibility for disability insurance benefits. 20 C.F.R. §§ 404.1520 and 416.920.

Section 404.1520 applies to disability insurance applications; § 416.920 applies to SSI disability claims.

Colbert v. Chater · filed 1995-07-24

Section 404.1520 applies to applications for disability insurance, while § 416.920 concerns claims for SSI disability benefits.

Section 404.1520(d) requires an impairment to produce functional limitations, not merely be severe, to support a finding of disability.

Helm v. Commissioner of Social Security Administration · filed 2011-01-04(d)

A claimant must do more than show that she is severely impaired. To support a finding of disability, the impairment must result in functional limitations. See 20 C.F.R. §§ 404.1520(d)-(f); Higgs. v. Bowen, 880 F.2d 860, 863 (6th Cir. 1988).

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

McPherson v. Astrue · filed 2009-03-02(c)

The assessment of whether a claimant has severe impairments is the second step of the sequential five-step analysis of disability claims provided for in 20 C.F.R. §§ 404.1520, 416.920. Severe impairments are impairments which, singly or in combination, “significantly limit[ ] [a claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1520(c); 404.920(c).

Section 404.1520(a)(3) requires the ALJ to consider all relevant evidence, including personal and anecdotal testimony by witnesses, when determining whether a claimant is disabled.

Vella v. Astrue · filed 2009-07-07(a)(3)

In determining the existence of a disability, the ALJ should consider all relevant evidence, including personal and anecdotal testimony by witnesses.

Section 404.1520(a)(3) requires the SSA to consider all evidence in a claimant’s case record when deciding whether the claimant is disabled.

Gage v. U.S. Social Security Administration, Acting Commissioner · filed 2018-10-31(a)(3)

The SSA provides that it “will consider all evidence in [a claimant’s] case record when [it] make[s] a determination or decision whether [the claimant is] disabled.”

Subsection (a)(3) requires the ALJ to consider the entire record when determining a claimant's residual functional capacity and whether the claimant is disabled.

Adamczyk v. Berryhill · filed 2019-02-12(a)(3)

In making these determinations, the ALJ is required to consider the entire record. 20 C.F.R. § 404.1520(a)(3).

Section 404.1520 establishes the sequential evaluation process, including the Step 2 severity inquiry and continuation through later steps when at least one severe impairment is found.

Norris v. Commissioner of Social Security · filed 2020-03-06

Moreover, errors at Step 2 of the sequential analysis will not necessarily require reversal, if the ALJ finds at least one “severe” impairment and therefore continues with the remaining steps in the sequential process. That is because in determining a plaintiff's residual functional capacity and ability to work later in the sequential process, the ALJ must consider even the impairments found not to be “severe” at Step 2. See Maziarz v. Secretary of Health and Human Servs., 837 F.2d 240, 244 (6th Cir. 1987); 20 C.F.R. § 404.1520.

Section 404.1520(e) requires a separate step-four assessment of a claimant's residual functional capacity; a step-two finding that an impairment is severe does not itself establish an RFC limitation.

Sagastume v. Social Security Administration · filed 2021-10-26(e)

A finding that an impairment is severe at step two, however, “is not determinative of the claimant’s RFC and cannot substitute for a proper step-four analysis.” Johnson v. Berryhill, 679 F. App’x 682, 686–87 (10th Cir. 2017) (unpublished) (citing Oldham v. Astrue, 509 F.3d 1254, 1257 (10th Cir. 2007)). It is well-established that step two findings do not equate to an RFC limitation because the showing required at step two is “de minimis” and “does not account for the ALJ’s assessment, at step four, of a claimant’s ability to work at a given exertional level.” Id. (citing 20 C.F.R. § 404.1520(e)).

Section 404.1520 requires the Commissioner to evaluate disability claims through a five-step sequential process, ending the evaluation when disability or nondisability can be found at a step.

Hall v. Commissioner of Social Security · filed 2019-10-10(a)(4)

To determine whether a claimant has a disability within the meaning of the Act, the Commissioner follows the five-step sequential evaluation process outlined in the regulations. 20 C.F.R. § 404.1520; see Kirby v. Astrue, 500 F.3d 705, 707 (8th Cir. 2007). Each of these steps may be dispositive in a claimant’s case. See 20 C.F.R. § 1520(a)(4) (“If we can find that you are disabled or not disabled at a step, we make our determination or decision and we do not go on to the next step. If we cannot find that you are disabled or not disabled at a step, we go on to the next step.”).

Section 404.1520 requires the Commissioner to use a five-step sequential process to determine whether a claimant is disabled.

Alcantara v. Astrue · filed 2009-10-21

In determining whether a claimant is disabled, the Commissioner is required to apply the five-step sequential process set forth in 20 C.F.R. § 404.1520.

Section 404.1520 requires disability claims to be evaluated through a five-step sequential analysis addressing substantial gainful activity, severe impairment, listed impairments, past relevant work, and work available in the national economy.

Ulloa v. Astrue · filed 2009-04-09(a)-(f)

To make this determination, one must employ a five step sequential analysis. 20 C.F.R. §§ 404.1520(a)-(f). Under this process, the ALJ must inquire, in the following order: (1) whether the claimant is engaged in substantial gainful employment; (2) whether the claimant has a severe impairment; (3) whether the claimant’s impairment meets or equals a listed impairment; (4) whether the claimant can perform past relevant work; and (5) whether the claimant is capable of performing any work in the national economy.

Section 404.1520(a)(4) requires the Commissioner to evaluate disability claims through a five-step sequence, beginning by deciding whether the claimant is engaged in substantial gainful activity.

Patterson v. Colvin · filed 2014-06-06(a)(4)

Regulations issued pursuant to the Social Security Act set forth a five-step process that the Commissioner must use in evaluating a disability claim. ... First, the Commissioner must determine whether the claimant is currently engaged in any “substantial gainful activity.” 20 C.F.R. § 404.1520(a)(4)®.

Section 404.1520 requires the Commissioner to use a five-step sequential analysis to determine whether a person is disabled.

Bentzen v. Astrue · filed 2014-06-13(a)(4)

In determining whether a person is disabled, the Commissioner is required to perform a five-step sequential analysis.

Once a claimant shows she cannot perform her former occupation, the Secretary must prove she can perform other work.

Evelyn ADORNO, Appellant, v. Donna SHALALA, Secretary of Health and Human Services, Appellee · filed 1994-11-09(f)(1)

Adorno thus had the initial burden of proving that she could not pursue her former occupation. Once a claimant establishes her inability to pursue her former occupation, the burden shifts to the Secretary to prove that she retains the capacity to pursue less demanding work.

At Step 5, § 404.1520(g) places the burden on the Commissioner to show that a claimant can perform work other than past relevant work.

DOTEN v. SOCIAL SECURITY ADMINISTRATION COMMISSIONER · filed 2019-07-24(g)

The ALJ reached Step 5 of the sequential evaluation process, at which stage the burden of proof shifts to the commissioner to show that a claimant can perform work other than his past relevant work. 20 C.F.R. § 404.1520(g); Bowen v. Yuckert, 482 U.S. 137, 146 n.5 (1987); Goodermote, 690 F.2d at 7.

At Step 5 of the sequential evaluation, the burden shifts to the Commissioner to show that a claimant can perform work other than past relevant work.

MCFARLAND v. SOCIAL SECURITY ADMINISTRATION COMMISSIONER · filed 2019-06-28(g)

The ALJ reached Step 5 of the sequential evaluation process, at which stage the burden of proof shifts to the commissioner to show that a claimant can perform work other than his past relevant work. 20 C.F.R. § 404.1520(g); Bowen v. Yuckert, 482 U.S. 137, 146 n.5 (1987); Goodermote, 690 F.2d at 7.

Section 404.1520 requires disability claims to be evaluated through a sequential process: substantial gainful activity, severe impairment, listed impairment, residual functional capacity and past relevant work, and other work in the national economy, with the burden shifting to the agency at step five.

Boehm v. Commissioner of Social Security · filed 2009-05-06

In making a disability determination, the ALJ must perform the sequential evaluation outlined in 20 C.F.R. § 404.1520. First the claimant must not be engaged in substantial gainful activity after the date the disability began. Second the claimant must provide evidence of a severe impairment. Third, the claimant must show that the impairment meets or equals an impairment in Appendix 1 of the Regulations. If the claimant fails to provide sufficient evidence to accomplish step three, the analysis proceeds to step four. In step four, the ALJ must determine the claimant’s residual functional capacity, then determine if the claimant can perform his or her past relevant work. The claimant has the burden of proving the inability to perform past relevant work. If the claimant’s evidence shows an inability to perform past relevant work, the burden shifts to the ALJ in step five. The ALJ must show that there is other gainful work in the national economy which the claimant can perform. Once the ALJ identifies such work, the burden returns to the claimant to prove his or her inability to perform such work.

Section 404.1520 requires disability claims to be evaluated through a five-step sequence, and review stops when the claimant is found disabled or not disabled at any step.

Nocks v. Astrue · filed 2009-06-15(a)

Social Security Administration regulations incorporate a sequential evaluation process for determining whether a claimant is under a disability. 20 C.F.R. § 404.1520. The ALJ first considers whether the claimant is currently engaged in substantial gainful activity. If he is not, then the ALJ considers in the second step whether the claimant has a “severe impairment” that significantly limits his physical or mental ability to perform basic work activities. If the claimant suffers a severe impairment, the third inquiry is whether, based on the medical evidence, the impairment meets the criteria of an impairment ... listed in the “listing of impairments,” 20 C.F.R. pt. 404, subpt. P, app. 1 (1999), which result in a presumption of disability, or whether the claimant retains the capacity to work. If the impairment does not meet the criteria for a listed impairment, then the ALJ assesses in the fourth step whether, despite the severe impairment, the claimant has the residual functional capacity to perform his past work. If the claimant cannot perform his past work, then step five is to determine whether there is other work in the national economy that the claimant can perform. ... If the ALJ finds that a claimant is disabled or not disabled at any point in the sequence, review does not proceed to the next step. 20 C.F.R. § 404.1520(a).

At step five, when nonexertional limitations materially reduce the claimant's occupational base, the medical-vocational grid cannot alone determine disability and vocational evidence is required.

Devin v. SSA · filed 2009-05-06(a)(4)(v)

The critical issue here is whether plaintiff has nonexertional limitations which required defendant to obtain evidence from a vocational specialist, rather than just relying on the medical-vocational guidelines, to determine the availability of jobs for purposes of assessing her disability. See 20 C.F.R. § 404.1520(a)(4)(iv) & (v) (factoring RFC, age, education and past relevant work to determine whether the impairments render claimant disabled); see also 20 C.F.R. Pt. 404, Subpt. P, A p p . 2 (tables determining whether someone is disabled based on RFC, age, education and experience). ... The ALJ should not have relied simply on the grid at step 5 to determine whether jobs exist that plaintiff could perform, because the tables do not reflect an occupational base that is circumscribed by her individual restrictions. The rules require vocational evidence in these circumstances. See SSR 83-12 & 83-14. Accordingly, I recommend that this case be remanded to the ALJ for further consideration of plaintiff's RFC and the availability of jobs in the national economy considering that RFC, with the guidance and assistance of a vocational expert.

Section 404.1520 requires a five-step disability evaluation, and at Step 5 an ALJ must support reliance on the Grid when nonexertional limitations may significantly erode the occupational base, ordinarily with vocational-expert evidence.

Sherman v. SSA · filed 2016-12-08(a)(4)(v)

To decide whether a claimant is disabled for the purpose of determining eligibility for disability insurance benefits, an ALJ is required to employ a five-step process. See 20 C.F.R. § 404.1520. ... The ALJ’s first limitation, to work involving “unskilled, simple tasks of 1-3 step instructions,” Tr. 22, does not preclude reliance on the Grid. See Gurney v. Astrue, Civ. No. 09-153-B-W, 2010 WL 323912, at *2 (D. Me. Jan. 20, 2010). However, it is not self-evident that a limitation to “superficial interactions with coworkers and supervisors,” Tr. 22 (emphasis added), would only have a negligible effect on a person’s ability to perform the full range of unskilled jobs. Consequently, the ALJ committed reversible error by declining to take evidence from a VE to support her Step 5 determination.

Section 404.1520(e) requires an ALJ to assess a claimant’s residual functional capacity between steps three and four, considering all relevant medical and other evidence, including medical opinions.

Griffin v. Social Security Administration · filed 2023-05-19(e)

In determining a claimant’s RFC, an ALJ must consider all relevant medical and other evidence, including medical opinion evidence. 20 C.F.R. § 404.1520(e).

At step four, § 404.1520(e) requires determining the claimant’s residual functional capacity and the physical and mental demands of past relevant work to decide whether the claimant can still perform that work.

Blanchette v. SSA · filed 2009-06-09(e)

Here, by contrast, the ALJ did make a finding concerning claimant’s RFC. And, after considering the vocational expert’s opinion, which incorporated claimant’s description of her past relevant work, the ALJ determined that claimant’s RFC did not preclude her from performing her PRW. In other words, the ALJ in this case met his obligation to “determine the claimant’s residual functional capacity (RFC) and the physical and mental demands of the work that the claimant has done in the past.” Id. at 318 (citing 20 C.F.R. § 404.1520(e); Santiago v. Sec’y of HHS, 944 F.2d 1, 5 (1st Cir. 1991)).

Section 404.1520(a)(4)(iv) requires the adjudicator at step four to determine whether the claimant's residual functional capacity allows her to perform her past relevant work, by comparing that capacity with the demands of the past work.

Garibay v. Commissioner of Social Security · filed 2009-07-13(a)(4)(iv)

At Step 4, the ALJ must consider whether the claimant retains the RFC to perform her past relevant work. 20 C.F.R. § 404.1520(a)(4)(iv). Step four involves three substeps: ... (3) the ALJ must compare the residual functional capacity to the past relevant work to determine whether claimant has the level of capability needed to perform the past relevant work.

At step four, the Commissioner assesses a claimant’s residual functional capacity to determine whether the claimant can perform past relevant work; a claimant who retains that capacity is not disabled.

Huisman v. Astrue · filed 2010-04-21(4)(iv)

Fourth, if the claimant’s impairment is severe, but it does not meet or equal one of the presumptively disabling impairments, then the Commissioner will assess the claimant’s residual functional capacity (“RFC”) to determine the claimant’s “ability to meet the physical, mental, sensory, and other requirements” of the claimant’s past relevant work. 20 C.F.R. §§ 404.1520(4)(iv); 404.1545(4); ... If a claimant retains the RFC to perform past relevant work, then the claimant is not disabled. 20 C.F.R. § 404.1520(4)(iv). ... Because a full and complete credibility analysis is lacking, and the ALJ’s RFC assessment is not supported by the record, the court finds it would be appropriate to remand the case for further proceedings, including any necessary development of the record regarding Huisman’s work-related mental and physical limitations.

Section 404.1520(a)(4)(iv) requires the Commissioner, after determining that a claimant lacks a listed impairment, to decide whether the claimant's residual functional capacity permits performance of past work.

Hilsdorf v. Commissioner of Social Security · filed 2010-07-15(a)(4)(iv)

(4) Assuming the claimant does not have a listed impairment, the Commissioner then asks whether, despite the claimant’s severe impairment, he has the residual functional capacity to perform his past work. ... The inquiries at steps four and five follow from the Commissioner’s determination of the claimant’s residual functional capacity (“RFC”). 20 C.F.R. §§ 404.1520(a)(4)(iv)-(v). ... Because the ALJ failed to assess Plaintiffs exertional and postural abilities on a function-by-function basis, his RFC determination cannot be upheld by this court.

At step four, the ALJ must assess the claimant’s residual functional capacity and ability to return to past relevant work.

Scott v. Commissioner of Social Security · filed 2011-09-07(a)(4)(iv)

“At the fourth step, the ALJ must assess: (1) the claimant’s residual functional capacity (“RFC”); and (2) the claimant’s ability to return to her past relevant work.” Phillips, 357 F.3d at 1238 (citing 20 C.F.R. § 404.1520(a)(4)(iv)). ... We conclude that the ALJ properly considered Scott’s residual functional capacity and her ability to return to her past relevant work in assessing her eligibility for benefits.

Section 404.1520(a)'s sequential evaluation requires the ALJ at step four to determine whether a claimant can perform her past relevant work.

Nishke v. Astrue · filed 2012-06-26(a)

At step four of the sequential evaluation process, the ALJ considers whether the claimant has the capacity to do her “past relevant work.” 20 C.F.R. §§ 404.1520(a), 416.920(a).

Section 404.1520(e) requires an ALJ to determine residual functional capacity before step four using all relevant evidence and all of the claimant’s impairments, including nonsevere impairments.

Cumella v. Colvin · filed 2013-03-26(e)

Before considering step four of the evaluation process, the ALJ is required to determine a claimant’s residual functional capacity (“RFC”). 20 CFR §§ 404.1520(e) and 416.920(e). RFC is a claimant’s ability to do physical and mental work activities on a sustained basis despite any limitations from her impairments. 20 CFR §§ 404.1545(a)(1) and 416.945(a). In making this finding, the ALJ must consider all of the- claimant’s impairments, including those which are not severe. 20 CFR §§ 404.1545(e) and 416.945(e). All of the relevant medical and non-medical evidence in the record must be considered. 20 CFR §§ 404.1520(e), 404.1545, 416.920(e), and 416.945.

At step four, § 404.1520(e) requires the Commissioner to assess the claimant's residual functional capacity to determine whether the claimant can perform past relevant work.

Marintez v. Colvin · filed 2014-03-10(e)

At Step 4 of the sequential evaluation process, when determining whether a claimant can perform his or her past relevant work, the Coimnissioner is obligated to assess the claimant's RFC. See 20 C.F.R. §§ 404.1520(e) & 416.920(e).

Section 404.1520(a)(4)(iv) requires the ALJ to determine whether a claimant’s residual functional capacity permits performance of past relevant work by comparing that capacity with the physical and mental demands of the past relevant work.

Johnson v. Colvin · filed 2014-07-09(a)(4)(iv)

At step four of the sequential evaluation, the ALJ makes a determination regarding the claimant’s residual functional capacity and determines whether the claimant can perform his or her past relevant work. ... In particular, the ALJ must compare the claimant’s RFC with the physical and mental demands of the past relevant work. 20 C.F.R. §§ 404.1520(a)(4)(iv) and 416.920(a)(4)(iv). ... The ALJ’s findings with respect to RFC and the demands of the past relevant work must be based on evidence -in the record.