20 C.F.R. § 404.1520

Section 404.1520 requires an ALJ to use a five-step process to decide disability eligibility, with the claimant bearing the burden through step four and the Commissioner bearing it at step five.

Conley v. Commissioner of Social Security · filed 2020-10-30

When considering a claimant’s eligibility for disability benefits, an ALJ must apply the standard five-step analysis: (1) is the claimant currently employed; (2) is the claimant’s impairment or combination of impairments severe; (3) do her impairments meet or exceed any of the specific impairments listed that the Secretary acknowledges to be so severe as to be conclusively disabling; (4) if the impairment has not been listed by the Secretary as conclusively disabling, given the claimant’s residual functional capacity, is the claimant unable to perform her former occupation; (5) is the claimant unable to perform any other work in the national economy given her age, education, and work experience. 20 C.F.R. § 404.1520; Young v. Sec’y of Health & Human Servs., 957 F.2d 386, 389 (7th Cir. 1992). The claimant bears the burden of proof until step five, where the burden shifts to the Commissioner to prove that the claimant can perform other work in the economy. See id.

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

Ruybal v. Commissioner of Social Security · filed 2020-03-30(f)

At the fourth step of the sequential analysis, the ALJ must determine whether the claimant can perform her past relevant work.3 20 C.F.R. §§ 404.1520(f), 404.1560(b). ... Upon review of the parties’ arguments and the ALJ’s decision, the Court concludes that substantial evidence does not support the ALJ’s finding that Plaintiff was capable of performing her past relevant work as those jobs are performed generally in the national economy. ... Absent a hearing transcript that reveals the ALJ’s questioning of the VE about Plaintiff’s ability to perform past work with an RFC for light work and a sit/stand option, there is no record evidence that supports the ALJ’s finding at step four. Accordingly, the cases on which the Commissioner relies are inapposite.

Section 404.1520(e)–(f) requires the ALJ at step four to determine whether a claimant can perform past relevant work by comparing the claimant’s RFC with that work’s physical and mental demands.

Sherwood v. Social Security, Commissioner of · filed 2024-08-09(e), (f)

At Step Four of the sequential evaluation process, the ALJ determines whether a claimant can perform his past relevant work. 42 U.S.C. § 423(d)(2)(A); 20 C.F.R. § 404.1520(e). In so doing, the ALJ examines a claimant’s RFC and compares it to the physical and mental demands of that claimant’s past relevant work. 20 C.F.R. § 404.1520(f); see also Boucher v. Apfel, 238 F.3d 419 (6th Cir. 2000). If the evidence shows that a claimant retains the RFC to perform the functional demands and job duties of a particular past relevant job as he actually performed it, the claimant is not disabled. 20 C.F.R. § 404.1560(b)(2); see also Social Security Ruling (SSR) 82-61, 1982 WL 31387, at *1 (Jan. 1, 1982).

At step five, § 404.1520(g) shifts the burden to the Commissioner to show that a claimant, considering her vocational factors and RFC, can perform jobs existing in significant numbers in the national economy.

STEUTH v. COMMISSIONER OF SOCIAL SECURITY · filed 2020-03-30(g)

Step Five: At this point, the burden shifts to the Commissioner to demonstrate that the claimant, considering her age, education, work experience, and RFC, is capable of performing jobs that exist in significant numbers in the national economy. 20 C.F.R. §§ 404.1520(g), 416.920(g); see Poulos v. Comm’r of Soc. Sec., 474 F.3d 88, 91-92 (3d Cir. 2007). If so, benefits will be denied; if not, they will be awarded.

Section 404.1520(a) requires disability claims to be evaluated through a five-step process in order, with no later steps needed once a claimant is found disabled or not disabled.

Livengood v. Social Security Administration, Commissioner of · filed 2020-03-30(a)

Pursuant to the Act, the Social Security Administration has established a five-step sequential evaluation process for determining whether an individual is disabled. Wilson v. Astrue, 602 F.3d 1136, 1139 (10th Cir. 2010); see also 20 C.F.R. § 404.1520(a). The steps are designed to be followed in order. If it is determined, at any step of the evaluation process, that the claimant is or is not disabled, further evaluation under a subsequent step is unnecessary. Barkley, 2010 WL 3001753, at *2.

Section 404.1520(a)(4) allows the disability determination to end at any step once the claimant is found disabled or not disabled.

Remelin v. Commissioner of Social Security · filed 2022-01-03(a)(4)

The ALJ was not required to proceed to steps two through five in the sequential evaluation of Plaintiff’s disability. 20 C.F.R. §§ 404.1520(a)(4), 416.920(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.”); see Cantrall v. Colvin, 540 Fed. Appx. 607, 610 n.1 (9th Cir. 2013).

The regulation requires the sequential disability evaluation to stop once the agency determines at a step that the claimant is disabled or not disabled.

Carrero-Chavez v. Commissioner of Social Security · filed 2022-03-18(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.

Section 404.1520 requires a five-step disability evaluation, and at step two a claimant must have a severe impairment that significantly limits basic work activities; failure to show one ends the inquiry.

Borgart v. Commissioner of Social Security · filed 2020-03-30(c)

The applicable regulations set forth a five-step analysis the Commissioner must follow in determining eligibility for disability benefits. 20 C.F.R. §§ 404.1520 and 416.920. See Bapp v. Bowen, 802 F.2d 601, 604 (2d Cir. 1986); Berry v. Schweiker, 675 F.2d 464 (2d Cir. 1982). If the claimant meets the criteria at any of the five steps, the inquiry ceases and the claimant is not eligible for disability benefits. 20 C.F.R. §§ 404.1520 and 416.920. ... The second step is whether the applicant has a severe impairment which significantly limits the physical or mental ability to do basic work activities, as defined in the relevant regulations. 20 C.F.R. §§ 404.1520(c) and 416.920(c). ... Given the dearth of evidence demonstrating Plaintiff’s knee impairment significantly impaired Plaintiff’s ability to perform basic work activities for at least 12 consecutive months, the ALJ did not err in failing to consider Plaintiff’s right knee impairment to be severe at step 2. The ALJ’s decision therefore is supported by substantial evidence in the record.

At step two, the ALJ evaluates the medical severity of the claimant’s impairments in the sequential disability determination.

Brooks v. Commissioner of Social Security · filed 2020-03-30(a)(4)

At step two of the five-step sequential evaluation process, the ALJ considers the “medical severity of [the claimant’s] impairments.” 20 C.F.R. § 404.1520(a)(4).

At step two, the regulation requires the ALJ to determine whether the claimant has a medically determinable impairment, or combination of impairments, that is severe.

Monter v. Commissioner of Social Security · filed 2020-04-08(c)

At step two the ALJ must determine whether the plaintiff has a medically determinable impairment that is “severe,” or a combination of impairments is “severe”. 20 C.F.R. §§ 404.1520(c), 416.920(c)2. An impairment, or combination of impairments, is “severe” if it significantly limits the plaintiff’s ability to perform basic work activities and meets the durational requirement. Id. §§ 404.1522, 416.922.

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

Elben v. Saul · filed 2020-04-15(c)

At step two of the sequential process, the ALJ must determine whether the claimant suffers from a “severe” impairment, i.e., one that significantly limits her physical or mental ability to do basic work activities. 20 C.F.R. §§ 404.1520(c), 416.920(c).

At step two, an impairment is severe when it significantly limits the claimant's ability to perform basic work activities for at least a consecutive twelve-month period, and the claimant must make a threshold showing of a medically determinable impairment or combination of impairments that is severe.

(SS) Schuler v. Commissioner of Social Security · filed 2020-05-27(c), (a)(4)(ii)

At step two of the Social Security Administration’s five-step sequential evaluation process, the claimant must make a “threshold showing” that (1) he has a medically determinable impairment or combination of impairments and (2) the impairment or combination of impairments is severe. Bowen v. Yucket, 482 U.S. 137, 146-47 (1987); see also 20 C.F.R. §§ 404.1520(c), 416.920(c). An impairment is “severe” if it significantly limits a claimant's ability to perform basic work activities for at least a consecutive twelve-month period. See 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii); SSR 96–3p, 2018 WL 3461816 (June 14, 2018).

At step two, § 404.1520(c) requires an impairment or combination of impairments that significantly limits a claimant’s ability to perform basic work activities.

McGonigal v. Saul · filed 2020-06-17(c)

Even if an inference of linkage with Plaintiff’s pre-DLI condition could be made from this evidence (R. at 46), Plaintiff has not shown how this evidence demonstrates that he had an impairment or combination of impairments during the relevant period that met the duration requirement and that significantly limited his physical or mental ability to do basic work activities. See 20 C.F.R. §§ 404.1509, 404.1520(a)(4)(ii), 404.1520(c), 404.1522(a).

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

Correa v. Saul · filed 2020-06-19(c)

To establish that a medically determinable impairment is “severe,” the claimant must show that it “significantly limits [his or her] physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c).

At step two, § 404.1520(c) requires the Commissioner to determine whether a claimant has a severe impairment that significantly limits the ability to perform basic work activities.

Cary v. Saul · filed 2020-07-28(c)

At step two of the sequential process, the ALJ must determine whether the claimant suffers from a “severe” impairment, i.e., one that significantly limits her physical or mental ability to do basic work activities. 20 C.F.R. §§ 404.1520(c), 416.920(c). ... The ALJ reasonably concluded that the medical evidence showed Plaintiff did not have mental impairments that significantly limited her ability to perform basic work activities. Tr. 20-24. ... Therefore, any error in the ALJ’s finding that Plaintiff had no severe impairments would be harmless.

Section 404.1520(c) treats an impairment as nonsevere when it does not significantly limit a claimant’s physical or mental ability to perform basic work activities.

ADRIANO v. COMMISSIONER OF SOCIAL SECURITY · filed 2020-07-31(c)

Pursuant to the Regulations, claimants are not considered to have a severe impairment if it “does not significantly limit their physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c). ... Therefore, the Court concludes the ALJ did fulfill the step-two requirement of determining whether Adriano’s fibromyalgia is a medical determinable impairment that is severe.

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

Rathbone v. Commissioner of Social Security · filed 2020-08-19(c)

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

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

(SS) Gillit v. Commissioner of Social Security · filed 2020-08-27(c)

Under the Commissioner’s regulations, an impairment or combination of impairments is deemed to be severe at step two if it “significantly limits [a claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1520(c), 404.1521(a).

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

Gebhardt v. Saul · filed 2020-08-31(c)

Step Two requires the ALJ to determine whether the claimant has a medically determinable severe impairment or combination of impairments that prove severe. A impairment proves severe if “significantly limits [the person’s] physical or mental ability to do basic work activities.” See 20 C.F.R. § 404.1520(c).

Section 404.1520(c) requires a claimant to show a medically determinable impairment or combination of impairments that is severe, meaning it significantly limits the ability to perform basic work activities; step two is a de minimis screening for groundless claims.

(SS) Guzman v. Commissioner of Social Security · filed 2020-09-18(c)

The inquiry at step two is a de minimus screening “to dispose of groundless claims.” ... 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). Thus, the burden of proof is on the claimant to establish a medically determinable severe impairment that significantly limits her physical or mental ability to do basic work activities, or the “abilities and aptitudes necessary to do most jobs.” 20 C.F.R. § 404.1521(a).

At Step Two, the regulation requires a claimant to have a severe impairment that meets the duration requirement, and defines severity as significantly limiting the ability to perform basic work activities.

Muratovic v. Saul · filed 2020-09-22(a)(4)(ii), (c)

As discussed above, at Step Two, the Commissioner must determine whether the claimant has a “severe medically determinable physical or mental impairment that meets the [twelve-month] duration requirement in § 404.1509, or a combination of impairments that is severe and meets the duration requirement . . . .” 20 C.F.R. §§ 404.1509, 404.1520(a)(4)(ii). To be a “severe impairment,” an impairment must “significantly limit[] [the claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c). ... In light of these records showing substantial improvement in Plaintiffs left shoulder impairment in a short period of time, the Court finds substantial evidence to support the ALJ’s conclusion that Plaintiff's left shoulder impairment would not significantly impact Plaintiff’s ability to perform work activities over a period of at least twelve months and thus was not a severe impairment. Therefore, the ALJ’s finding at Step Two will be affirmed.

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

(SS) Kisner v. Commissioner of Social Security · filed 2020-09-30(c)

A severe impairment is one that “significantly limits” a claimant's “physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1520(c), 416.920(c).

At step two, an impairment is severe if it affects the claimant’s ability to perform basic work activities; an impairment is not severe only when it is a slight abnormality that minimally affects work ability.

Fields v. BERRYHILL · filed 2020-09-30(c)

A “severe” impairment at step two is “one that affects an individual’s ability to perform basic work-related activities for an adult.” SSR 16-3p; 20 C.F.R. §§ 404.1520(c), § 416.920(c). Basic work activities “mean the abilities and aptitudes necessary to do most jobs,” including, with relevance to mental abilities: “[u]nderstanding, carrying out, and remembering simple instructions,” “use of judgment,” “[r]esponding appropriately to supervision, co-workers and usual work situations,” and “[d]ealing with changes in a routine work setting.” 20 C.F.R. §§ 404.1522(b), 416.922(b). The Sixth Circuit construes the step two severity regulation as a de minimis hurdle. See Higgs v. Bowen, 880 F.2d 860, 862 (6th Cir. 1988). “Under the prevailing de minimis view, an impairment can be considered not severe only if it is a slight abnormality that minimally affects work ability regardless of age, education, and experience.” Id. at 862.

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 applies that standard at step two of the disability evaluation.

(SS) Wright v. Commissioner of Social Security · filed 2020-11-23(c)

At step two of the five-step analysis, the ALJ is required to determine whether a plaintiff has a “severe” medical impairment or combination of impairments. 20 C.F.R. §§ 416.920(c). An impairment is “severe” if it “significantly limits [the claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1520(c), 416.920(c), 416.921(a). The evaluation at step two is a de minimis screening device to dispose of groundless claims.

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

Miller v. Commissioner, Social Security Administration · filed 2020-11-30(c)

At step two, the ALJ must determine whether plaintiff has a medically determinable impairment or combination of impairments that is “severe.” 20 C.F.R. § 404.1520(c). ... An impairment is “severe” if it “significantly limits” a claimant's “physical or mental ability to do basic work activities,” 20 C.F.R. § 404.1520(c), such as walking, standing, sitting, seeing, hearing, speaking, carrying out simple instructions, using judgment, responding appropriately to supervision or coping with changes in routine.

Section 404.1520(c) treats an impairment as severe only when it significantly limits a claimant’s physical or mental ability to perform basic work activities, with a de minimis threshold intended to screen out groundless claims.

Mateo-Rivera v. Commissioner of Social Security · filed 2020-12-30(c)

At step two, the Commissioner determines whether the claimant has a medically severe impairment or combination of impairments. 20 C.F.R. § 404.1520(c). A severe impairment is one that significantly limits a claimant’s physical or mental ability to perform basic work activities. See López-González v. Comm’r of Soc. Sec., 59 F. Supp. 3d 372, 378 (D.P.R. 2014) (citing 20 C.F.R. § 404.1520(c)). The step two severity requirement imposes a de minimis burden, which is designed to screen out groundless claims. McDonald v. Sec'y of Health and Human Servs., 795 F.2d 1118, 1123 (1st Cir. 1986).

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

Linder v. Commissioner of Social Security · filed 2021-01-25(c)

At step two, Plaintiff must make a threshold showing (1) she has a medically determinable impairment or combination of impairments and (2) the impairment or combination of impairments is severe. See Bowen v. Yuckert, 482 U.S. 137, 146 (1987); 20 C.F.R. § 404.1520(c), 416.920(c). ... An impairment is severe if it significantly limits the claimant’s physical or mental ability to do basic work activities. 20 C.F.R. § 404.1520(c), 404.1521(a).

Section 404.1520(c) requires a claimant to have a severe impairment; if no impairment or combination significantly limits basic work abilities, the claimant is found not to have a severe impairment and is not disabled.

(SS) Jones v. Commissioner of Social Security · filed 2021-02-04(c)

At step two, the ALJ assesses the medical severity of the claimant’s impairments. 20 C.F.R. § 404.1520(a)(4)(ii). A claimant must have a severe impairment and if there is not any impairment or combination of impairments which significantly limits the claimant’s physical or mental ability to do basic work activities, the claimant be will be found to not have a severe impairment and he or she would not be disabled. 20 C.F.R. § 404.1520(c).

Section 404.1520 requires a claimant to show at step two that an impairment or combination of impairments is severe, meaning it significantly limits the ability to perform basic work activities.

Johnson v. Saul · filed 2021-02-04(a)(4)(ii), (c)

At step two of the sequential evaluation, the claimant must demonstrate that she has an impairment or combination of impairments that is “severe.” 20 C.F.R. § 404.1520(a)(4)(ii), (c); Bowen, 482 U.S. at 146 n.5 (stating that the claimant bears the burden of showing that he has a “severe” impairment). An impairment or combination thereof is “severe” if it significantly limits the claimant’s ability to perform basic work activities. 20 C.F.R. § 404.1520(a)(4)(ii), (c).

Section 404.1520(c) requires an impairment to significantly limit a claimant’s ability to perform basic work activities to qualify as severe at step two.

Lariviere v. Saul · filed 2021-02-17(c)

As discussed above, a “severe” impairment is “one that affects an individual’s ability to perform basic work-related activities for an adult.” SSR 16-3p; 20 C.F.R. §§ 404.1520(c), 416.920(c). Basic work activities “mean the abilities and aptitudes necessary to do most jobs.” ... Here, substantial evidence supports the ALJ’s decision that Lariviere’s mental impairments, depression and anxiety, were not severe during the time frame at issue.

Section 404.1520(c) treats an impairment as severe when it significantly limits a claimant’s physical or mental ability to do basic work activities; an impairment with no more than a minimal effect on the ability to work does not satisfy step two.

Gassiraro v. Saul · filed 2021-03-05(c)

A severe impairment is defined as one which significantly limits the claimant’s physical or mental ability to do basic work activities. See Pekley v. Barnhart, 433 F.3d 575, 577 (8th Cir. 2006) (quoting 20 C.F.R. § 404.1520(c)). “Severity is not an onerous requirement for the claimant to meet but it is also not a toothless standard[.]” Kirby v. Astrue, 500 F.3d 705, 708 (8th Cir. 2007) (internal citations omitted). “If the impairment would have no more than a minimal effect on the claimant’s ability to work, then it does not satisfy the requirement of step two.” Id. (citing Page v. Astrue, 484 F.3d 1040, 1043 (8th Cir. 2007)).

At Step Two, an impairment is severe when it significantly limits the claimant’s ability to perform basic work activities.

Barber v. Saul · filed 2021-03-22(c)

To be considered severe, an impairment must significantly limit a claimant’s ability to do basic work activities. See 20 C.F.R § 404.1520(c). ... The ALJ’s determination that Barber’s mental limitations were not severe after October 14, 2014 lacks the support of substantial evidence.

At step two, § 404.1520(c) treats an impairment as severe when it significantly limits basic work abilities, and permits a non-severe finding only for a slight abnormality with no more than a minimal effect on the ability to work.

(SS) Few v. Commissioner of Social Security · filed 2021-03-23(c)

Under the Commissioner’s regulations, an impairment or combination of impairments is deemed to be severe at step two if it “significantly limits your physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1520(c), 404.1522(a). An impairment or combination of impairments may be found “not severe only if the evidence establishes a slight abnormality that has no more than a minimal effect on an individual’s ability to work.” ... Although the ALJ recited the proper “de minimis” step-two standard, it is clear that he did not apply it. ... A psychiatric impairment may be found not severe only if it is a slight abnormality with “no more than a minimal effect on an individual’s ability to work.” ... The record undeniably contains evidence that plaintiff’s depression and anxiety were more than a “slight abnormality.” ... even this evidence alone should have been found sufficient to show a level of impairment that at least meets the de minimis threshold at step two.

At step two, an impairment is severe only if it significantly limits the claimant’s ability to perform basic work activities.

Landers v. Saul · filed 2021-04-30(c)

At step two of the sequential evaluation process, Plaintiff must demonstrate that she has an impairment or combination of impairments that is “severe.” 20 C.F.R. § § 404.1520(a)(4)(ii), (c), ... “An impairment or combination thereof is ‘severe’ if it significantly limits the claimant’s ability to perform basic work activities.” ... The Court is satisfied that the ALJ used substantial evidence to support his conclusion that Plaintiff’s mental impairments are non-severe. Accordingly, remand is not warranted on this issue.

At step two, the ALJ must consider the medical severity of a claimant’s impairments and determine whether each is severe or non-severe before proceeding through the sequential analysis.

Haynes v. Commissioner of the Social Security Administration · filed 2021-05-14(a)(4)(ii)

Step Two of the sequential evaluation requires the ALJ to “consider the medical severity of [a claimant’s] impairment(s).” 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii). ... No mention is made of Plaintiff’s pelvic floor dysfunction as either a severe or non-severe impairment. ... After careful review and consideration, the Court concludes that the ALJ erred in his Step Two analysis. ... Failure to consider PFD at Step Two of the analysis has flawed the remaining steps of the sequential analysis.

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.

Phillips v. Commissioner, Social Security Administration · filed 2021-07-12(c)

At step two, the ALJ considers the “medical severity of [a claimant’s] impairments.” 20 C.F.R. § 416.920(a)(4)(ii). An impairment is severe if it “significantly limits [her] physical or mental ability to do basic work activities”. 20 C.F.R. § 404.1520(c). ... There is no dispute that the ALJ’s Decision at step two failed to specifically list “intellectual disorder” as one of Ms. Phillips’ severe or nonsevere impairments. However, in this Circuit, any error was harmless given that the ALJ determined the step-two analysis was satisfied by other severe impairments and continued with the analysis.

Section 404.1520(c) treats a claimant as not disabled at step two when the claimant lacks a severe impairment that significantly limits the ability to perform basic work activities.

Avalos v. Saul · filed 2021-08-12(c)

The step two inquiry is meant to be a de minimis screening device. ... At step two, the ALJ identifies a claimant’s severe impairments, i.e., impairments that significantly limit his or her ability to do basic work activities. ... If a claimant does not have a severe mental impairment, then he or she is not eligible for disability payments. 20 C.F.R. §§ 404.1520(c), 416.920(c).

Section 404.1520(c) makes step two a threshold inquiry requiring an impairment to significantly limit the claimant’s ability to perform basic work activities.

Robinson v. Kijakazi (CONSENT) · filed 2021-08-17(c)

An impairment or combination of impairments is “severe” if it “significantly limits [the plaintiff’s] physical or mental ability to do basic work activities”6 and persists for at least twelve consecutive months. 20 C.F.R. §§ 404.1520(c) and 416.920(c); 404.1505(a) and 416.905(a).

Section 404.1520 requires a five-step disability evaluation, and an error at step two in labeling an impairment nonsevere is harmless when the ALJ considers all impairments at later steps, including in assessing residual functional capacity.

Needham v. Commissioner of Social Security · filed 2021-03-05(c)

Even if the ALJ erred in failing to characterize plaintiff’s primary headache disorder as a severe impairment, any such error would be harmless. The ALJ found plaintiff suffers from several severe physical and mental impairments, proceeded with the remaining steps of the sequential evaluation process, and ultimately addressed all of plaintiff’s impairments in determining his residual functional capacity.

Section 404.1520(c) treats an impairment as severe when it significantly limits the claimant’s ability to perform basic work activities; once step two is satisfied, later evaluation must account for the claimant’s impairments.

Omoike v. Kijakazi · filed 2021-09-13(c)

Because of that fact, the ALJ conducts a “severity” test at step-two to screen out groundless claims. Stratton v. Bowen, 827 F.2d 1447, 1452 (11th Cir. 1987). In addition, if an impairment exists, it can only be considered “not severe” if it is a slight abnormality that has a minimal effect on the individual and would not interfere with the individual’s ability to work, Bridges v. Bowen, 815 F.2d 622, 625 (11th Cir. 1987). A severe impairment, on the other hand, is one that significantly limits a claimant’s abilities to do basic work activities. See 20 C.F.R. § 404.1520(c). For purposes of the step-two analysis, however, “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). This is because, once the ALJ proceeds beyond step two, he must consider the claimant’s entire medical condition. Burgin v. Comm’r of Soc. Sec., 420 Fed. Appx. 901, 902 (11th Cir. Mar. 30, 2011) (per curiam); see also 20 C.F.R. § 416.945(a)(2) (providing that the Commissioner considers all of the claimant’s impairments when determining the claimant’s RFC). Thus, if the ALJ considered Plaintiff’s impairment in step four, the omission of the impairment from the step-two recitation would not warrant reversal.

At step two, the ALJ considers the medical severity of a claimant’s medically determinable impairments, rather than the severity of symptoms standing alone.

Venable v. Kijakazi · filed 2021-09-17(a)(4)(ii)

Second, Plaintiff contends that the ALJ should have recognized that Plaintiff’s lupus was an impairment “that could cause her blackouts.” (Pl.’s Mem. at 14.) This argument, however, is not pertinent to step two, which asks the ALJ to “consider the medical severity of [Plaintiff’s] impairment(s)”—not the severity of Plaintiff’s symptoms. See §§ 404.1520(a)(4)(ii), 416.1520(a)(4)(ii) (emphasis added). Thus, at step two, the ALJ was tasked with determining whether Plaintiff’s impairments, such as lupus, were medically determinable and severe. If lupus “cause[s]” blackouts as Plaintiff alleges, then such blackouts are a symptom of lupus—not an impairment in of itself.

Section 404.1520(c) treats an impairment as non-severe when it does not significantly limit a claimant's mental or physical abilities to perform basic work activities.

Barrett v. Commissioner of Social Security · filed 2021-09-21(c)

At step two of the sequential evaluation, the ALJ must determine if the claimant suffers from any medically determinable impairments that are “severe.” 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii). An impairment is not considered to be “severe” if it does not “significantly limit” a claimant's mental or physical abilities to do basic work activities. 20 C.F.R. §§ 404.1520(c), 416.920(c); Social Security Ruling (“SSR”) 96-3p, 1996 WL 374181, at *1. Basic work activities are those “abilities and aptitudes necessary to do most jobs.” 20 C.F.R. §§ 404.1522(b), 416.922(b); SSR 85-28, 1985 WL 56856, at *3. An impairment is not severe if the evidence establishes only a slight abnormality that has “no more than a minimal effect on an individual[’]s ability to work.” SSR 85-28, 1985 WL 56856, at *3; Smolen v. Chater, 80 F.3d 1273, 1290 (9th Cir. 1996).

At step two, an impairment is severe only if it significantly limits the claimant’s ability to perform basic work activities and has lasted or is expected to last at least twelve months; the threshold is de minimis.

Demaris v. Kijakazi · filed 2021-09-21(c)

At step two of the sequential evaluation process, the ALJ must determine if the claimant’s impairments are severe. 20 C.F.R. §§ 404.1520(c), 416.920(c). For an impairment to be severe, the impairment must significantly limit the claimant’s ability to do basic work activities and have lasted or can be expected to last for a continuous period of not less than twelve months. Id., 42 U.S.C. §§ 423(d)(1)(A), 1382c(a)(3)(A). ... “Only those claimants with slight abnormalities that do not significantly limit any basic work activity can be denied benefits without undertaking the subsequent steps of the sequential evaluation process.” Id. (quotations omitted).

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

Spears v. Kijakazi · filed 2021-09-23(c)

At step two of the sequential-evaluation process, the ALJ “determines whether the claimant has a medically severe impairment or combination of impairments.” Bowen v. Yuckert, 482 U.S. 137, 140–41 (1987). “An impairment or combination of impairments is not severe if it does not significantly limit [the claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1522(a), 416.922(a). Conversely, 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), 416.920(c).

At step two, § 404.1520(c) requires a claimant to show that an impairment or combination of impairments significantly limits the ability to do basic work activities.

Caves v. Social Security Administration · filed 2021-09-27(c)

At step two, Claimant bears the burden of showing the existence of an impairment or combination of impairments which “significantly limits [his] physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1520(c), 416.920(c). ... In this case, the ALJ did not end the sequential evaluation at step two by finding Claimant had no severe impairments. Since the ALJ did not deny benefits at step two based upon the lack of any severe impairments, his failure to find Claimant’s impairments of carpal tunnel syndrome, facial pain, headaches, right knee pain, hand pain, depression, and anxiety as severe, does not constitute reversible error.

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

Ekstedt v. Kijakazi · filed 2021-09-28(c)

To be considered “severe” at step two of the sequential analysis, an impairment must significantly limit an individual’s ability to perform basic work activities. 20 C.F.R. §§ 404.1520(c), 416.920(c); see also Smolen v. Chater, 80 F.3d 1273, 1290 (9th Cir.1996). ... Thus, as above, despite evidence that could be considered more favorable to Plaintiff, it was reasonable for the ALJ to find Plaintiff’s back pain was not a severe impairment at step two. See Burch, 400 F.3d at 679. ... The Court finds no error at step two.

Section 404.1520 requires the ALJ at Step Two to determine whether an impairment is severe and, once any impairment is severe, to consider all impairments in the remaining steps; an erroneous Step Two severity finding is harmless if that consideration occurs later.

Rivera v. Saul · filed 2021-09-30(a)(4)(ii), (c)

At Step Two, the ALJ determines the severity of a plaintiff's impairments. See 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii); see also 20 C.F.R. §§ 404.1520(c), 416.920(c). ... An impairment is “severe” if it significantly limits an individual’s ability to perform basic work activities. ... If the ALJ finds any impairment to be severe, “the question whether the ALJ characterized any other alleged impairment as severe or not severe is of little consequence.” ... “Under the regulations, once the ALJ determines that a claimant has at least one severe impairment, the ALJ must consider all impairments, severe and non-severe, in the remaining steps.” ... Therefore, if the ALJ considers all impairments at subsequent stages of the analysis, failure to find a particular condition “severe” at Step Two, even if erroneous, constitutes harmless error.

Section 404.1520(c) requires the ALJ to determine whether an impairment significantly limits a claimant’s physical or mental ability to do basic work activities, and an error at step two may be harmless when the claimant proceeds through the analysis and the limitations are incorporated into the residual functional capacity.

Platt v. Kijakazi · filed 2021-10-08(c)

At step two of the sequential process, the ALJ must determine whether a 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). ... Even if the ALJ erred in dismissing this particular limitation, the error was harmless because step two of the analysis was resolved in Plaintiff’s favor and the ALJ accounted for Plaintiff’s physical limitations when considering her residual functional capacity. See Tr. 26 (finding Plaintiff capable of performing only light work).

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

Acevedo v. Saul · filed 2021-12-27(c)

Under the Commissioner’s regulations, an alleged impairment is “severe” only “if it significantly limits an individual’s physical or mental abilities to do basic work activities.” SSR 96-3p, 1996 WL 374181, at *1 (S.S.A. July 2, 1996); 20 C.F.R. § 404.1520(c).

Section 404.1520(a)(4)(ii) requires the ALJ at step two to determine whether the claimant has a medically determinable severe impairment, and § 404.1520(c) provides that an impairment is not severe unless it significantly limits basic work abilities.

Bussanich v. Commissioner of Social Security · filed 2022-02-02(a)(4)(ii), (c)

At step two of the sequential evaluation, the ALJ must determine if the claimant suffers from any medically determinable impairments that are “severe.” 20 C.F.R. § 404.1520(a)(4)(ii). An impairment is not considered “severe” if it does not “significantly limit” a claimant’s mental or physical abilities to do basic work activities. 20 C.F.R. § 404.1520(c); Social Security Ruling (“SSR”) 96-3p, 1996 WL 374181, at *1.

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

Hansen v. Kijakazi · filed 2022-02-09(c)

To be “severe,” a claimant’s impairment or combination of impairments must “significantly limit[]” his “physical or mental ability to do basic work activities.”

Section 404.1520(c) requires a claimant to show that she has a medically determinable impairment or combination of impairments that is severe.

Everdean v. Commissioner of Social Security · filed 2022-02-14(c)

At step two, a claimant must make a threshold showing that (1) she has a medically determinable impairment or combination of impairments and (2) the impairment or combination of impairments is severe. See Bowen v. Yuckert, 482 U.S. 137, 146 (1987); 20 C.F.R. § 404.1520(c), 416.920(c).

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

SHEPHERD v. KIJAKAZI · filed 2022-02-15(c)

At step two of the evaluation process, a plaintiff must establish a “severe impairment,” that is, an impairment or combination of impairments that significantly limits the claimant’s physical or mental ability to do basic work activities.

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.

White v. Commissioner of Social Security · filed 2022-03-08(c)

The regulations define a “severe” impairment or combination of impairments as one that significantly limits the physical or mental ability to perform basic work activities. 20 C.F.R. § 404.1520(c). ... The ALJ’s finding that plaintiff’s mental impairments were not severe is supported by substantial evidence.

Section 404.1520(c) treats an impairment as severe at Step Two when it significantly limits the claimant’s physical or mental ability to do basic work activities.

GRAVES-DOYLE v. COMMISSIONER OF SOCIAL SECURITY · filed 2022-03-22(c)

Alternatively, 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), 416.920(c).

Section 404.1520(c) requires a claimant to show that an impairment significantly limits the ability to perform basic work activities before it qualifies as severe at step two.

ANDREWS v. Berryhill · filed 2022-03-23(c)

“It is not enough for Plaintiff to be diagnosed with certain impairments: Plaintiff must provide evidence that these impairments ‘significantly limit[] [her] physical or mental ability to do basic work activities.’” Grady v. Astrue, 894 F. Supp. 2d. 131, 141 (D.Mass. 2012) (quoting 20 C.F.R. § 404.1520(c)) (first alteration original); ... Here, Plaintiff has shown no evidence that a personality disorder caused limitations beyond those the ALJ assessed.

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

Blakely v. Kijakazi · filed 2022-03-24(c)

At step two of the sequential process, the ALJ must determine whether the claimant suffers from a “severe” impairment, i.e., one that significantly limits his physical or mental ability to do basic work activities. ... Here, however, the Court need not decide whether the ALJ erred by omitting Plaintiff’s hearing impairments and OCD from the list of severe impairments at Step Two. The ALJ resolved Step Two in Plaintiff’s favor based on finding other medically determinable severe impairments.

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

(SS) Hensley v. Commissioner of Social Security · filed 2022-03-25(c)

Under the Commissioner’s regulations, an impairment or combination of impairments is deemed severe at step two if it “significantly limits your physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1520(c), 404.1522(a).

At step two, § 404.1520(a)(4)(ii) requires the ALJ to determine whether a claimant has a severe medically determinable impairment or combination of impairments; if none exists, disability benefits are denied.

Smith v. Kijakazi · filed 2022-03-25(a)(4)(ii)

At step two, the ALJ considers whether the claimant has “a severe medically determinable physical or mental impairment” or combination of such impairments that meets the regulations’ twelve-month durational requirement. 20 C.F.R. §§ 404.1509, 404.1520(a)(4)(ii). An impairment or combination of impairments is severe if it “significantly limits [the claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c). If the claimant does not have a severe impairment, disability benefits are denied. 20 C.F.R. § 404.1520(a)(4)(ii). If the ALJ determines that one or more impairments are severe, the ALJ proceeds to the next step. See id.

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

Montalvo v. Kijakazi · filed 2022-03-28(c)

At step two of the sequential process, the ALJ must determine whether the claimant suffers from a “severe” impairment, i.e., one that significantly limits his physical or mental ability to do basic work activities. 20 C.F.R. §§ 404.1520(c), 416.920(c). ... Plaintiff has not met his burden in demonstrating the ALJ harmfully erred at step two.

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

Tammy B. v. Kijakaz · filed 2022-03-29(c)

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

At step two, § 404.1520(a)(4)(ii) requires the ALJ to determine whether the claimant has a severe impairment or combination of impairments before proceeding with the disability analysis.

Aquino v. Commissioner of Social Security · filed 2022-04-04(a)(4)(ii)

At the second step of the sequential evaluation, an ALJ considers whether the claimant has at least one severe impairment or combination of impairments that meets the twelve-month durational requirement for establishing disability. See 20 C.F.R. § 404.1520(a)(4)(ii). ... Here, Plaintiff’s medical sources neither observed nor assessed any right shoulder condition that significantly limited his ability to perform basic work activities. ... Because Plaintiff has failed to show that his right shoulder condition significantly limited his ability to do basic work activity, his contention fails.

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

Anderson v. Commissioner, Social Security Administration · filed 2022-04-04(a)(4)(ii)

At step two, the ALJ determines whether the claimant’s medically determinable impairment or combination of impairments is severe. 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii).

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

Dearman v. Commissioner of Social Security · filed 2022-04-25(c)

At step two, an ALJ considers the severity of a claimant’s impairments. 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii). An impairment or combination of impairments is not severe “if it does not significantly limit [a claimant’s] physical or mental ability to do basic work activities” 20 C.F.R. §§ 404.1522(a), 416.922(a). Said a different way, a severe impairment is an impairment or combination thereof that significantly limits a claimant’s abilities to perform basic work activities. See SSR 85-28, 1985 WL 56856, *4 n.1; 20 C.F.R. §§ 404.1520(c), 404.1522(a), 416.920(c), 416.922(a).

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.

Kantner v. Saul · filed 2022-04-25(c)

At Step 2 of the sequential analysis, the ALJ determines whether a claimant has a medically severe impairment or combination of impairments. Bowen v. Yuckert, 482 U.S. 137, 140-41, 107 S.Ct. 2287, 96 L.Ed.2d 119 (1987). An impairment is considered severe if it “significantly limits an individual's physical or mental abilities to do basic work activities. 20 C.F.R. 404.1520(c). An impairment is severe if it is “something beyond ‘a slight abnormality which would have no more than a minimal effect on an individual’s ability to work.’” McCrea v. Comm'r of Soc. Sec., 370 F.3d 357, 360 (3d Cir. 2004) (quoting SSR 85-28, 1985 WL 56856 (1985)). The Court of Appeals is clear that the step-two inquiry is a de minimis screening device used to cast out meritless claims. McCrea, 370 F.3d at 360; Newell v. Comm'r of Soc. Sec., 347 F.3d 541, 546 (3d Cir. 2003). The burden is on the claimant to show that an impairment qualifies as severe. Bowen, 482 U.S. at 146; Stancavage v. Saul, 469 F.Supp.3d 311, 331 (M.D. Pa. 2020).

At step two, § 404.1520(c) treats an impairment as severe when it significantly limits a claimant’s physical or mental ability to perform basic work activities, and the evaluation continues when at least one severe impairment exists.

Williams v. Commissioner of Social Security · filed 2022-05-02(c)

At step one, the ALJ must determine whether the claimant is engaged in substantial gainful work activity. See 20 C.F.R. § 404.1520(b). If so, the claimant is not disabled. If not, the ALJ proceeds to step two and determines whether the claimant has an impairment, or combination of impairments, that is “severe” within the meaning of the Act, meaning that it imposes significant restrictions on the claimant’s ability to perform basic work activities. Id. § 404.1520(c). If the claimant does not have a severe impairment or combination of impairments meeting the durational requirements, the analysis concludes with a finding of “not disabled.” If the claimant does, the ALJ continues to step three. ... Even assuming arguendo that the ALJ erred at step two, where an ALJ proceeds past step two and considers the effects of all the claimant’s impairments through the remainder of the sequential evaluation process, any error at step two is harmless.

Section 404.1520(c) treats an impairment as non-severe when it does not significantly limit a claimant’s physical or mental ability to do basic work activities.

Schroeder v. Commissioner of Social Security · filed 2022-06-06(c)

An impairment or combination of impairments is not severe if it does not significantly limit your physical or mental ability to do basic work activities. 20 C.F.R. § 404.1522. See 20 C.F.R. § 404.1520(c) (If you do not have any impairment or combination of impairments which significantly limits your physical or mental ability to do basic work activities, we will find that you do not have a severe impairment and are, therefore, not disabled.); ... After a careful review of the record, the Court finds that ALJ correctly assessed Plaintiff’s severe impairments at step two.

At step two, § 404.1520(c) requires a severe impairment finding, but an erroneous non-severity determination is harmless when the ALJ proceeds through later steps and considers all impairments in the residual functional capacity analysis.

DICASTANADO v. KIJAKAZI, ACTING COMMISSIONER, SOCIAL SECURITY ADMINISTRATION · filed 2022-06-28(c)

At step two, the administrative law judge must determine whether the claimant has a medically determinable impairment or a combination of impairments that are severe. ... Because she moved through the later steps, “any error at Step Two would not alter the remainder of the five-step process, much less the overall outcome. And without more, [claimant] provides no valid basis for remand.” Judge Watson found in Mr. Dicastanado’s favor at step two. Thus any error is harmless even if she erroneously concluded his anxiety disorder is non-severe.

At step two, § 404.1520(c) treats an impairment as severe when it significantly restricts a claimant's ability to perform basic work activities, under a de minimis standard meant to screen out only the weakest claims.

Herod-Zak v. Commissioner of Social Security · filed 2022-07-08(c)

At step two of the disability analysis, the ALJ determines whether the claimant has an impairment, or combination of impairments, that is “severe” within the meaning of the Act, in that it imposes significant restrictions on the claimant’s ability to perform basic work activities. 20 C.F.R. § 404.1520(c). ... Step two’s “severity” requirement is de minimis and is meant only to screen out the weakest of claims.

At step two, § 404.1520(c) treats an impairment as severe only when it significantly limits a claimant’s ability to perform basic work activities; a slight abnormality with no more than a minimal effect is not severe.

Mance v. Saul · filed 2022-07-13(c)

A severe impairment is one that significantly limits the claimant’s “physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1520(c), 416.920(c). “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.” ... For these reasons, the ALJ’s step two assessment that Plaintiff’s hand tremor was not a severe impairment is supported by substantial evidence.

At step two of the sequential disability inquiry, § 404.1520(a)(4)(ii) requires a severe medically determinable impairment before the adjudicator proceeds to the remaining steps.

Ansary v. Commissioner Social Security Administration · filed 2022-07-20(a)(4)(ii)

Plaintiff contends that the ALJ improperly found that she did not suffer from “a severe medically determinable physical or mental impairment” for a continuous period of twelve months. 20 C.F.R. § 404.1520(a)(4)(ii). ... “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 S.S.R. No. 96–3(p) (1996)). ... Thus, substantial evidence supports the ALJ’s finding that plaintiff’s physical impairments were not severe during the relevant period.

At step two, the regulation requires a claimant to have a severe medically determinable impairment, meaning one that significantly limits basic work activities and lasts or is expected to last at least twelve months.

Sabalboro v. Kijakazi · filed 2022-07-21(a)(4)(ii), (c)

At step two in the sequential evaluation, the Social Security Administration (“SSA”) considers the medical severity of the claimant’s impairment. 20 C.F.R. § 404.1520(a)(4)(ii). To be found disabled, a disability claimant must have a medically determinable physical or mental impairment or combination of impairments that is severe. Id. A “medically determinable” physical impairment “must be established by objective medical evidence from an acceptable medical source.” See 20 C.F.R. § 404.1521 (2019). The SSA “will not use [a claimant’s] statement of symptoms, a diagnosis, or a medical opinion to establish the existence of an impairment(s).” Id. Once a medically determinable impairment is established, the SSA decides whether the impairment or combination of impairments is “severe.” Id. A severe impairment is one “which significantly limits your physical or mental ability to do basic work activities[.]” Id. § 404.1520(c). ... this evidence neither establishes any functional limitations nor meets the duration requirement: a severe impairment must last or be expected to last for a continuous period of at least twelve months. See 20 C.F.R. § 404.1520(a)(4)(ii).

Section 404.1520(c) requires the ALJ to find an impairment severe when it significantly limits the claimant’s physical or mental ability to perform basic work activities, but an error at step two may be harmless if the evaluation continues and the impairment is considered later.

Holden v. Kijakazi · filed 2022-07-26(c)

At step two, the ALJ must determine whether a claimant has one or more “severe” impairments; i.e., a condition that “significantly limits” his physical or mental ability to do “basic work activities.” 20 C.F.R. §§ 404.1520(c), 416.920(c). ... Upon review, the Court agrees with plaintiff that his severe alcohol use disorder likely clears the de minimis threshold for severity at step two. ... But even assuming it was error for the ALJ to conclude that plaintiff’s severe alcohol use disorder was not severe, it was a harmless one. “Courts have held that error at step two in determining the severity of impairments is harmless if the ALJ finds at least one other severe impairment and continues through the sequence of the disability analysis because the non-severe impairments can later be considered at the RFC stage.” ... Accordingly, any error at step two was harmless.

At step two, § 404.1520(a)(4)(ii) requires the decision maker to determine whether the claimant has a medically severe impairment or combination of impairments, and an omission is harmless when the evaluation proceeds and all limitations are incorporated into the residual functional capacity.

Tripodo v. Kijakazi · filed 2022-08-04(a)(4)(ii)

If the claimant is not engaged in substantial gainful activities, the decision maker proceeds to step two and determines whether the claimant has a medically severe impairment or combination of impairments. 20 C.F.R. §§ 416.920(a)(4)(ii), 404.1520(a)(4)(ii). If the claimant does not have a severe impairment or combination of impairments, the disability claim is denied. ... At step two, an ALJ may find impairments or combinations of impairments to be non-severe “if the evidence establishes a slight abnormality that has no more than a minimal effect on an individual’s ability to work.” ... Omissions at step two are harmless error if step two is decided in the claimant’s favor and the ALJ incorporates all of the claimant's limitations into the RFC.

At step two, § 404.1520(a)(4)(ii) requires the ALJ to determine whether a claimant has a severe impairment or combination of impairments.

Gass v. Commissioner of Social Security Administration · filed 2022-08-12(a)(4)(ii)

Once established, the ALJ then considers whether the impairment, individually or in combination with other impairments, is “severe” and expected to last more than twelve months. 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii). An impairment is “severe” if it “significantly limits [the claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1520(c), 416.920(c). ... Thus, because the ALJ considered all the impairments, whether severe or non-severe, in determining Plaintiff’s residual function capacity and because step two was decided in Plaintiff’s favor, the Court finds any alleged error is harmless and cannot be the basis for a remand.

At step two, § 404.1520 requires the ALJ to determine whether a claimant has a severe medically determinable impairment, meaning one that significantly limits physical or mental abilities to do basic work activities.

Ray v. Commissioner of Social Security · filed 2022-08-15(a)(4)(ii), (c)

At step two of the sequential evaluation, the ALJ determines whether the claimant has a “severe” medically determinable physical or mental impairment or combination of impairments. 20 C.F.R. § 404.1520(a)(4)(ii). An impairment or combination of impairments is deemed “severe” if it “significantly limits [the claimant’s] physical or mental abilities to do basic work activities.” 20 C.F.R. § 404.1520(c); SSR 96-3p, 1996 WL 374181, at *1 (July 2, 1996).

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.

Martin v. Commissioner of the Social Security Administration · filed 2022-08-19(c)

A severe impairment is defined by the regulations as “any impairment or combination of impairments which significantly limits your physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c).

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

Shaw v. Kijakazi · filed 2022-08-25(c)

Diagnosis of a medical condition and being prescribed medication does not necessarily establish that a medical condition is severe; rather, the condition must interfere with basic work activities. See 20 C.F.R. §§ 404.1520(c), 404.1522.

Section 404.1520(c) requires the ALJ to determine at step two whether the claimant has a severe medically determinable impairment or combination of impairments.

Boisvert v. Commissioner of Social Security · filed 2022-09-07(c)

At step two of the sequential evaluation process, the ALJ must determine whether the claimant has a medically determinable impairment that is “severe” or a combination of impairments that is “severe.” 20 C.F.R. §§ 404.1520(c), 416.920(c).

At step two, § 404.1520 requires the ALJ to assess the severity of medically determinable impairments and treats impairments that do not significantly limit basic work activities as non-severe.

Lee v. Kijakazi · filed 2022-09-12(a)(4)(ii), (c)

At step two, the ALJ considers the severity of a claimant’s medically determinable impairments. 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii). If a claimant does not have an impairment or combination of impairments that significantly limits her ability to do basic work activities, such impairment or impairments are not severe and the claimant is not disabled. 20 C.F.R. §§ 404.1520(c), 416.920(c); see Kirby v. Astrue, 500 F.3d 705, 707 (8th Cir. 2007) (“Step two of the evaluation states that a claimant is not disabled if his impairments are not ‘severe.’”).

Section 404.1520(c) requires finding an impairment non-severe when it does not significantly limit the claimant's physical or mental ability to perform basic work activities.

Conley v. Kijakazi · filed 2022-11-02(c)

If you do not have any impairment or combination of impairments which significantly limits your physical or mental ability to do basic work activities, we will find that you do not have a severe impairment and are, therefore, not disabled.

At step two, § 404.1520 requires the ALJ to determine whether a claimant has a severe medically determinable impairment, which must significantly limit physical or mental abilities to do basic work activities.

Kloster v. Commissioner of Social Security · filed 2022-11-15(a)(4)(ii), (c)

At step two, the ALJ must determine if the claimant suffers from any medically determinable impairments that are “severe.” 20 C.F.R. § 404.1520(a)(4)(ii). An impairment is not considered to be “severe” if it does not “significantly limit” a claimant’s physical or mental abilities to do basic work activities. 20 C.F.R. § 404.1520(c). ... Given the objective medical evidence and Plaintiff’s reports, the ALJ could reasonably find her lumbar degenerative disc disease not so severe as to “significantly limit” her ability to do basic work activities during the relevant period. See 20 C.F.R. § 416.920(c); SSR 96-3p.

At step two, § 404.1520(c) requires an impairment to significantly limit basic work activities and satisfy the duration requirement; an impairment with only a minimal effect is not severe.

Washel v. Kijakazi · filed 2022-12-12(c)

a finding of “severe” requires the ALJ to evaluate the entire record to determine whether this impairment caused more than a “minimal effect” on Plaintiff’s ability to work for the requisite twelve-month durational period. § 404.1520(c). ... Therefore, the undersigned finds that the ALJ did not err when he found that Plaintiff’s bladder impairment was not a severe impairment on the basis that it had no more than a minimal effect on her functional capabilities for the twelve-month durational period. (R. at 18.)

Section 404.1520(c) requires an impairment to have more than a minimal effect on a claimant's ability to work to qualify as severe at step two.

Larson v. Commissioner of Social Security Administration · filed 2022-12-20(c)

At step two of the sequential evaluation process, the ALJ must determine whether Plaintiff suffers from a severe impairment or combination of impairments. Smolen v. Chater, 80 F.3d 1273, 1290–91 (9th Cir. 1996). This is a de minimis screening instrument used to dispose of meritless claims. Id. at 1291. “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.” Webb v.Barnhart, 433 F.3d 683, 686 (9th Cir. 2005) (internal quotation marks omitted); see 20 C.F.R. § 404.1520(c).

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

Snelling v. Commissioner of Social Security · filed 2022-12-21(a)(4)(ii)

At step two of the sequential evaluation process, the ALJ must determine if the claimant suffers from any medically determinable impairments that are “severe.” 20 C.F.R. § 404.1520(a)(4)(ii). An impairment is not considered to be “severe” if it does not “significantly limit” a claimant’s mental or physical abilities to do basic work activities. 20 C.F.R. § 416.920(c); Social Security Ruling (“SSR”) 96-3p. ... In this case, the ALJ found that Plaintiff’s migraine headaches do not “create any significant limitation in her ability to perform basic work activities.” AR 2054. ... Plaintiff’s record shows she reported about her worsening migraines, but they do not indicate that they were so severe as to “significantly limit” her abilities to do basic work activities. 20 C.F.R. § 416.920(c); SSR 96-3p; AR 2510-12, 2519-21. Without further showing how her migraines could have more than minimally affected her ability to work, Plaintiff has not met her burden in showing the ALJ erred at step two. Accordingly, the Court rejects Plaintiff’s argument.

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

Hunt v. Saul · filed 2022-12-21(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.’ ... However, Plaintiff has failed to explain – and the burden is his – how the inability to walk far, or lift anything heavy, significantly limits his ability to do basic work activities necessary for most jobs. ... Without more from Plaintiff, it appears the evidence of record supports the determinations of the ALJ, the Appeals Council, and the SSA, that Plaintiff’s impairments are non-severe.

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

VALENTIN v. SOCIAL SECURITY COMMISSIONER · filed 2023-01-05(c)

impairments which significantly limits [the applicant’s] physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c). ... In sum, the ALJ appropriately cited evidence that would allow a reasonable person to make the determination that the knee pain did not affect Mr. Valentin’s ability to perform basic work activities during the insured period and, thus, was not a severe impairment.

Section 404.1520(c) considers an impairment severe only if it significantly limits a claimant’s physical or mental ability to do basic work activities.

Ross v. Kijakazi · filed 2023-01-06(c)

At step two of the five-step sequential analysis, the ALJ must assess the medical severity of a claimant’s impairments. 20 C.F.R. § 404.1520(a)(4)(ii); Webb v. Barnhart, 433 F.3d 683, 686 (9th Cir. 2005). ... An impairment or combination of impairments is considered “severe” if it “significantly limits [a claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c).

Section 404.1520(c) requires a step-two determination whether a claimant has a medically severe impairment or combination of impairments, and a severe combination satisfies the regulation’s de minimis screening requirement.

(SS) Carlos v. Commissioner of Social Security · filed 2023-02-09(c)

Here, the ALJ determined Plaintiff had a severe combination of impairments. This appears to satisfy the “de minimis screening” purpose of the step two analysis. ... Furthermore, even if the ALJ erred at step two by not including Plaintiff’s “chronic diarrhea” in the list of severe combination of impairments, Plaintiff has not met her burden of establishing that such error was not harmless.

Under subsection (c), an impairment is severe only when it significantly limits a claimant’s physical or mental ability to perform basic work activities; mild limitations alone do not automatically meet that threshold.

BARNETT v. COMMISSIONER OF SOCIAL SECURITY · filed 2023-02-21(c)

Plaintiff has cited no authority, see generally id., to support his apparent assertion that mild limitations in two of the broad functional areas establishes that such limitations “significantly limit[] [the plaintiff’s] physical or mental ability to do basic work activities[.]” 20 C.F.R. § 404.1520(c). Notably, this Court has previously upheld an ALJ’s finding that a claimant’s mental impairments were non-severe and properly denied benefits at step two where the claimant had no more than mild limitations in the four functional areas.

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

Ross v. Commissioner of the Social Security Administration · filed 2022-11-28(c)

A severe impairment is defined by the regulations as “any impairment or combination of impairments which significantly limits your physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c). ... The severe impairment inquiry “is a de minimis screening device to dispose of groundless claims.”

At step two, the SSA finds that a claimant does not have a severe impairment when no impairment or combination of impairments significantly limits the claimant's physical or mental ability to perform basic work activities.

Voss v. Kijakazi · filed 2023-01-26(c)

At step two, “if [a claimant] do[es] not have any impairment or combination of impairments which significantly limits [his] physical or mental ability to do basic work activities, [the SSA] will find that [the claimant] do[es] not have a severe impairment and [is], therefore, not disabled.” 20 C.F.R. § 404.1520(c). ... Here, the ALJ supported his step-two determination with substantial evidence. ... In sum, the Court is satisfied that the ALJ’s step-two conclusions were supported by substantial evidence.

Section 404.1520(c) requires the ALJ at step two to assess whether an impairment or combination of impairments significantly limits a claimant’s physical or mental ability to do basic work activities.

Runions v. Kijakazi · filed 2023-03-17(c)

Step two assesses whether the claimant has a medically severe impairment or combination of impairments that significantly limit the claimant’s physical or mental ability to do basic work activities. ... The ALJ’s finding that Plaintiff’s epilepsy did not constitute a medically determinable impairment is supported by neither sufficient explanation nor substantial evidence. The ALJ erred at step two of the sequential evaluation.

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.

Corbitt v. Kijakazi (CONSENT) · filed 2023-03-29(c)

An impairment or combination of impairments is “severe” if it “significantly limits [the plaintiff’s] physical or mental ability to do basic work activities”8 and persists for at least twelve consecutive months. 20 C.F.R. §§ 404.1520(c) and 416.920(c); 404.1505(a) and 416.905(a).

At step two, the ALJ determines whether a claimant has an impairment and whether it is severe, with severity requiring a significant limitation on basic work activities.

Jensen v. Commissioner Social Security Administration · filed 2023-03-29(a)(4)(ii)

At step two of the sequential evaluation process, the ALJ determines whether the claimant has one or more impairments (or combination of impairments) based on review of the medical record, and then determines whether these impairments are “severe.” See 20 C.F.R. §§ 404.1520(a)(4)(ii), 404.1521. An impairment is severe if it “significantly limits your physical or mental ability to do basic work activities.” See 20 C.F.R. § 404.1520(c). ... The Court concludes that the ALJ erred at step two by rejecting fibromyalgia as a medically determinable impairment without explanation.

At step two, § 404.1520(c) requires deciding whether an impairment is medically determinable and severe; severity means it significantly limits basic work abilities.

Cozad v. Commissioner Social Security Administration · filed 2023-05-12(c)

At step two, an ALJ determines whether the claimant has an impairment that is both medically determinable and severe. An impairment is severe if it “significantly limit[s]” the claimant’s ability to do basic work activities, which are defined as “abilities and aptitudes necessary to do most jobs.” 20 C.F.R. §§ 404.1520(c), 416.920(c).

Section 404.1520(c) requires the ALJ at Step Two to determine whether an impairment or combination significantly limits the claimant’s ability to perform basic work activities; an impairment may be found non-severe only if it has no more than a minimal effect.

Baig v. Kijakazi · filed 2023-05-26(c)

Step Two directs the ALJ to determine whether the claimant has a severe impairment or combination of impairments that significantly limit her ability to work. See 20 C.F.R. § 404.1520(c). ... Plaintiff first argues that the ALJ erred at Step Two in failing to include headaches and autonomic neuropathy as severe impairments. ... However, the Court cannot find the error harmless because it is not clear that the ALJ included limitations arising from these impairments in the RFC. ... Generally, “Step Two is merely a threshold determination meant to screen out weak claims.” ... The ALJ may find an impairment 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.”

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

Padilla v. Social Security Administration · filed 2023-08-09(c)

At step two of the Commissioner’s five-step analysis, this requires the ALJ “to determine whether the mental impairment is ‘severe’ or ‘not severe.’” Id. To be “severe,” an impairment or combination of impairments must “significantly limit[] [a claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1520(c), 416.920(c).

At step two, § 404.1520(c) treats an impairment as severe unless it has only a minimal effect that would not be expected to interfere with the claimant’s ability to work; the claimant need only make a de minimis showing.

Melton v. Commissioner of Social Security · filed 2023-09-11(c)

As to the severity of the plaintiff’s headache disorder, an impairment can be considered as not severe “only if it is a slight abnormality [having] such minimal effect on the individual that it would not be expected to interfere with the individual’s ability to work, irrespective of age, education or work experience.” Stone v. Heckler, 752 F.2d 1099, 1101 (5th Cir. 1985). To establish the severity of an impairment at step two, a claimant must make a de minimis showing. Salmond v. Berryhill, 892 F.3d 812, 817 (5th Cir. 2018).

At Step Two, § 404.1520(c) treats an impairment as non-severe when it does not significantly limit a claimant’s physical or mental ability to perform basic work activities.

Elizabeth L. v. Kijakazi · filed 2023-08-08(c)

Second, if a claimant does not have any impairment or combination of impairments which significantly limit her physical or mental ability to do basic work activities, then she does not have a severe impairment and is not disabled. 20 C.F.R. § 404.1520(c). ... It was not error for the ALJ to find that this evidence did not support the presence of significant limitations in Plaintiff’s ability to work. See 20 C.F.R. § 404.1520(c).

At step two, § 404.1520(a)(4)(ii) requires the ALJ to consider the combined severity of a claimant’s medically determinable physical and mental impairments and treats an impairment as severe when it significantly limits basic work abilities for at least twelve months.

Jones v. Social Security Administration, Commissioner · filed 2023-09-25(a)(4)(ii)

The second step of the sequential disability evaluation requires the ALJ to consider the combined severity of the claimant’s medically determinable physical and mental impairments. 20 C.F.R. § 404.1520(a)(4)(ii). A medically determinable impairment is severe if it significantly limits a claimant’s physical or mental abilities to do basic work activities and lasts at least twelve months. See id.

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

Giuliano v. Commissioner of Social Security · filed 2023-09-25(c)

If not, then at step two, the ALJ evaluates whether the claimant has a “severe impairment” — that is, an impairment or combination of impairments that “significantly limits” his “physical or mental ability to do basic work activities.” Id. § 404.1520(a)(4)(ii), (c).

Section 404.1520(c) treats an impairment as severe when it significantly limits a claimant’s physical or mental ability to do basic work activities, meaning it must have more than a minimal effect on the ability to work.

Schoen v. Kijakazi · filed 2023-09-27(c)

At step two, the ALJ determines whether the claimant suffers from a “severe” impairment, i.e., one that significantly limits her physical or mental ability to do basic work activities. This involves a two-step process: 1) determining whether the claimant has a medically determinable impairment, and 2) if so, determining whether the impairment is severe. To be severe, the medical evidence must establish that the impairment would have more than a minimal effect on the claimant’s ability to work.

Section 404.1520 treats step two as a threshold inquiry: finding one severe impairment allows the disability analysis to continue to step three.

NAGELMAKER v. KIJAKAZI · filed 2023-09-27(a)(4)(ii), (c)

A step two determination turns on whether any of the claimant's medical conditions constitute a "severe medically determinable physical or mental impairment." 20 C.F.R. § 404.1520(a)(4)(ii), (c); Moore v. Colvin, 743 F.3d 1118, 1121 (7th Cir. 2014). As with all the steps in the analysis (except for the fifth and final), the claimant bears the burden of proof at step two. Martinez v. Kijakazi, 71 F.4th 1076, 1079 (7th Cir. 2023). Step two is regarded as a threshold determination; if the ALJ finds any condition meets this hurdle with even one severe impairment, the analysis continues to step three. 20 C.F.R. § 404.1520(a)(4), (4)(ii).

Section 404.1520 requires an ALJ at step two to determine whether a claimant has a medically determinable impairment and assess its severity before proceeding to later steps.

MORENO v. Commissioner of the Social Security Administration · filed 2023-10-11(a)(4)(ii), (c)

The second step in the five-step evaluation process requires ALJs to consider “the medical severity of [claimants’] impairment(s).” 20 C.F.R. § 404.1520(a)(4)(ii). A prerequisite to this consideration is deciding whether claimants have a “medically determinable physical or mental impairment,” because claimants are deemed nondisabled if they cannot prove that an impairment is medically determinable. Id. § 404.1520(c). If ALJs determine that one or more severe medically determinable impairments are present, they then move on to subsequent steps in the evaluation process. See id. § 404.1520(a)(4).

Section 404.1520(c) uses a significant limitation on the ability to perform basic work activities as the severity standard at Step Two.

Daniels v. Commissioner of Social Security · filed 2023-10-12(c)

A “severe” impairment is defined as, “any impairment or combination of impairments which significantly limits [a claimant’s] physical or mental ability to do basic work activities,” 20 CFR §404.1520(c), and which meets the 12-month durational requirement.

Section 404.1520(a)(4)(ii) makes step two a threshold inquiry into whether a claimant has a medically determinable impairment, and failure to classify an impairment as severe is generally harmless if the evaluation proceeds.

Berenger v. Commissioner Social Security Administration · filed 2023-10-30(a)(4)(ii)

At step two, the ALJ determines what “medically determinable physical or mental impairments” a claimant has. 20 C.F.R. § 404.1520(a)(4)(ii). However, “[s]tep two is merely a threshold determination meant to screen out weak claims.” Buck v. Berryhill, 869 F.3d 1040, 1048 (9th Cir. 2017). If the sequential analysis proceeds beyond step two, meaning that it has been resolved in the claimant’s favor, the failure to classify an impairment as severe will generally be harmless.

Section 404.1520(a)(4)(ii) directs the ALJ at step two to determine what medically determinable physical or mental impairments a claimant has.

Pence v. Commissioner Social Security Administration · filed 2023-10-31(a)(4)(ii)

At step two, the ALJ determines what “medically determinable physical or mental impairments” a claimant has. 20 C.F.R. § 404.1520(a)(4)(ii). However, “[s]tep two is merely a threshold determination meant to screen out weak claims.” Buck v. Berryhill, 869 F.3d 1040, 1048 (9th Cir. 2017). If the sequential analysis proceeds beyond step two, meaning that it has been resolved in the claimant’s favor, the failure to classify an impairment as severe will generally be harmless. Id. at 1049.

Section 404.1520(c) requires a claimant to show that an impairment significantly limits the ability to perform basic work activities to establish severity at step two; a diagnosis alone is insufficient.

GUNN v. KIJAKAZI · filed 2023-12-05(c)

A medical diagnosis is insufficient to establish severity at step two; Plaintiff also must present evidence that a limitation significantly limited his ability to do basic work activities. Salles v. Comm’r of Soc. Sec., 229 F. App’x 140, 145 (3d Cir. 2007) (citing 20 C.F.R. §§ 404.1520(c), 404.1521(a); Ramirez v. Barnhart, 372 F.3d 546, 551 (3d Cir. 2004)).

At step two, the regulation requires determining whether the claimant has a severe medically determinable impairment or combination of impairments that significantly limits basic work activities.

Wilkinson v. Commissioner of Social Security · filed 2023-12-06(a)(4)(ii)

At step two, the ALJ must determine if the claimant has a medically determinable impairment or combination of impairments that are severe, such that they would significantly limit the claimant’s ability to perform basic work activities. See Smolen v. Chater, 80 F.3d 1273, 1289–90 (9th Cir. 1996) (citation omitted); 20 C.F.R. § 404.1520(a)(4)(ii).

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

(SS) Morrison v. Commissioner of Social Security · filed 2024-01-02(c)

At step two of the sequential evaluation, the ALJ determines which of claimant’s alleged impairments are “severe” within the meaning of 20 C.F.R. § 404.1520(c). A severe impairment is one that “significantly limits” a claimant’s “physical or mental ability to do basic work activities.”

At step two, § 404.1520(a)(4)(ii) requires the ALJ to determine whether a claimant has a severe medically determinable impairment or combination of impairments; this is a de minimis threshold inquiry.

Mills v. Commissioner Social Security Administration · filed 2024-01-04(a)(4)(ii)

At step two, the ALJ determines whether a claimant’s medically determinable impairment or combination of impairments is severe. 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii). “An impairment or combination of impairments is not severe if it does not significantly limit [a claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1522, 416.922. ... The foregoing establishes that the ALJ erred in finding Plaintiff’s mental health conditions nonsevere. ... As stated above, step two is a de minimis screening device used to dispose of groundless claims. Yuckert, 482 U.S. at 153-54. Plaintiff’s depression, anxiety, and PTSD clear this threshold.

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

Cooper v. Social Security Administration · filed 2024-01-12(c)

At step two, Plaintiff bears the burden of showing the existence of an impairment or combination of impairments which “significantly limits [his] physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c); 20 C.F.R. § 416.920(c).

Section 404.1520(c) treats an impairment as severe when it significantly limits a claimant's ability to perform basic work activities.

Crace v. Social Security Administration · filed 2024-02-13(c)

A “severe” impairment significantly limits a claimant’s ability to perform basic work activities. 20 C.F.R. §§ 404.1520(c); 416.920(c).

Section 404.1520(c) requires a step-two finding of severity when an impairment significantly limits a claimant’s physical or mental ability to perform basic work activities; an error in labeling an impairment non-severe is harmless unless it affects the later residual-functional-capacity assessment.

Merritt v. Commissioner of Social Security · filed 2024-02-20(c)

The second step requires the ALJ to determine whether the claimant has a medically determinable impairment, or 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). An impairment or combination of impairments is “severe” within the meaning of the Social Security Act if it significantly limits an individual’s physical or mental ability to perform basic work activities. 20 C.F.R. §§ 404.1520(c), 416.920(c).

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.

Craft v. Commissioner of Social Security · filed 2024-02-21(c)

The regulations define “severe impairment” as “any impairment or combination of impairments which significantly limits your physical or mental ability to do basic work activities,” 20 C.F.R. §§ 404.1520(c), 416.920(c), and which lasts or can be expected to last “for a continuous period of not less than 12 months,” 20 C.F.R. §§ 404.1509, 416.909.

An impairment is severe when it significantly limits an individual's physical or mental abilities to perform basic work activities.

DeCamacho v. Social Security · filed 2024-02-20(c)

An alleged impairment will be considered severe only when “’it significantly limits an individual’s physical or mental abilities to do basic work activities.’” Clark v. Saul, 444 F. Supp.3d 607, 622 (S.D.N.Y. 2020) (quoting SSR 96-3P, 1996 WL 374181, at *1 (July 2, 1996)); see also 20 C.F.R. §§ 404.1520(c), 416.920(c).

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

Cordero-Rivera v. Commissioner of Social Security · filed 2024-05-29(c)

A claimant must meet the burden of proof that the impairment “significantly limits [a claimant’s] physical or mental ability to do basic work activities.” Cookson v. Colvin, 111 F. Supp. 3d 142, 150–51 (D.R.I. 2015)(citing 20 C.F.R. § 404.1520(c)).

At step two, § 404.1520(c) treats an impairment as non-severe only if it does not significantly limit the claimant’s ability to do basic work activities.

(SS) McCormick v. Commissioner of Social Security · filed 2024-06-27(c)

“[A]n impairment is not severe if it does not significantly limit [the claimant’s] . . . ability to do basic work activities.” Id. at 1290 (citing 20 C.F.R. §§ 404.1520(c) & 404.1521(a)).

Section 404.1520(c) treats an impairment as severe when it significantly limits the claimant’s ability to perform basic work activities; after finding an impairment severe, the ALJ must explain its significant work-related limitations in the RFC or reconcile the finding.

Brown v. Commissioner of Social Security · filed 2024-07-12(c)

By definition and as the ALJ noted, severe impairments “significantly limit the ability to perform basic work activities as required by SSR 85-28.” (Tr. 16); see 20 C.F.R. § 404.1520(c). ... Because the ALJ found migraine headaches a severe impairment at step two, he needed to articulate what significant limitations to work activity were caused by this impairment, or state that this impairment was non-severe.

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

Olivares v. Commissioner of Social Security · filed 2024-07-12(c)

By definition and as the ALJ noted, severe impairments “significantly limit the ability to perform basic work activities as required by SSR 85-28.” (Tr. 16); see 20 C.F.R. § 404.1520(c). “[B]eyond the second step, the ALJ must consider the entirety of the claimant’s limitations, regardless of whether they are individually disabling.” Griffin v. Comm’r of Soc. Sec., 560 F. App’x 837, 841-842 (11th Cir. 2014) (internal citations omitted). ... Here, the ALJ considered the entirety of Plaintiff’s limitations, including his alleged mental impairments. The ALJ thoroughly considered the medical and other evidence of record that related to his alleged mental impairments. After consideration of the evidence of record, the ALJ assessed Plaintiff’s RFC and limited him to light work with additional limitations and to jobs that have simple routine tasks and instruction and a reasoning level 1 or 2. (Tr. 22, 27). Substantial evidence supports the ALJ’s RFC assessment.

At step two, § 404.1520(a)(4)(ii) requires a claimant to show a severe medically determinable physical or mental impairment, or a severe combination of impairments, that satisfies the duration requirement.

Nealy v. Commissioner of Social Security · filed 2024-07-15(a)(4)(ii)

At the second step in the sequential evaluation process a claimant must demonstrate she suffers from a “severe medically determinable physical or mental impairment that meets the duration requirement . . . or a combination of impairments that is severe and meets the duration requirement . . .” 20 C.F.R. § 404.1520(a)(4)(ii); SSR 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) treats an impairment as severe when it significantly limits a claimant’s physical or mental ability to perform basic work activities.

Abraham v. Commissioner of Social Security Administration · filed 2024-07-23(c)

A severe impairment is one that “significantly limits” a claimant’s physical or mental condition to perform basic work activities.

At step two, § 404.1520(c) treats an impairment as non-severe when it does not significantly limit a claimant’s ability to perform basic work activities.

(SS) Zahourek v. Commissioner of Social Security · filed 2024-08-27(c)

“‘[a]n impairment is not severe if it does not significantly limit [the claimant’s] . . . ability to do basic work activities.’” Smolen, 80 F.3d at 1290 (citing 20 C.F.R. §§ 404.1520(c) & 404.1521(a)). ... Alternatively, if an ALJ errs at step two, that error is harmless if the ALJ considers the impairment at issue in the RFC analysis. Lewis v. Astrue, 498 F.3d 909, 911 (9th Cir. 2007). ... The ALJ specifically stated that he considered all Plaintiff’s impairments, severe and non-severe, in his analysis. (AR 13) (“I considered all the claimant’s medically determinable impairments, including those that were non-severe, when assessing the claimant’s residual functional capacity.”). Therefore, Plaintiff has not demonstrated harmful error.

Section 404.1520(c) treats an impairment as nonsevere when it does not significantly limit a claimant’s physical or mental ability to do basic work activities.

Mallon v. Commissioner of Social Security · filed 2024-09-16(c)

Although the ALJ did not specifically discuss the physical impairments in his later discussion, substantial evidence does support his conclusion that those impairments, being nonsevere, did not “significantly limit[] [her] physical or mental ability to do basic work activities,” see 20 C.F.R. § 404.1520(c).

Section 404.1520(c) requires an ALJ to determine at step two whether an impairment is severe, but a non-severity finding does not require remand when the ALJ considered the impairment in the RFC.

Asato v. O'Malley · filed 2024-09-24(c)

Step 2. Is the claimant’s impairment severe? If not, then the claimant is “not disabled” and is not entitled to disability insurance benefits. If the claimant’s impairment is severe, then the claimant’s case cannot be resolved at step two and the evaluation proceeds to step three. See 20 C.F.R. § 404.1520(c). ... This step “is not meant to identify the impairments that should be taken into account when determining the RFC” when an ALJ must consider all of a plaintiff’s impairment whether severe or non-severe. Mercado, 2017 WL 4029222, at *5. (citation omitted). If an ALJ fails to credit a non-severe impairment when determining a plaintiff’s RFC, then the failure may not be harmless. Id. at 6. But when the ALJ takes all impairments into account when determining the RFC, then there is no harm to Plaintiff. Id. (citation omitted). ... The Court finds Plaintiff fails to establish harmful error warranting remand based on the ALJ’s decision that her knee impairment was non-severe.

Section 404.1520(c) requires the Commissioner at step two to determine whether an impairment or combination of impairments is medically determinable and severe, with severity meaning that it significantly limits the claimant's ability to do basic work activities.

Matthews v. Commissioner Social Security Administration · filed 2024-10-09(c)

At step two, the ALJ determines whether the claimant has an impairment, or combination of impairments, that is both medically determinable and severe. 20 C.F.R. § 404.1520(c). An impairment is medically determinable if it is diagnosed by an acceptable medical source and based upon acceptable medical evidence. 20 C.F.R. § 404.1520(c). An impairment is severe if it significantly limits the claimant’s ability to do basic work activities. 20 C.F.R. § 404.1520(c). The step two threshold is low; the Ninth Circuit describes it as a “de minimus screening device to dispose of groundless claims.”

At step two, § 404.1520(c) requires a claimant to establish a severe impairment; if the claimant cannot do so, the ALJ may terminate the disability evaluation and find the claimant not disabled.

Brown v. Commissioner of Social Security · filed 2024-11-07(c)

Because there is no objective medical evidence in the record showing that Brown suffered from a severe medically determinable impairment on or before her June 30, 2015 date last insured, Brown failed to meet her burden of proving that she had a severe impairment prior to the expiration of her insured status. Thus, the ALJ did not err in finding that Brown was not disabled at step two of her disability evaluation and was permitted to terminate her evaluation there. See Dowey v. Comm’r of Soc. Sec., No. 5:17CV2489, 2018 WL 7681369, at *3 (N.D. Ohio Dec. 21, 2018) (citations omitted), report and recommendation adopted sub nom. Dowey v. Berryhill, No. 5:17CV2489, 2019 WL 580570 (N.D. Ohio Feb. 12, 2019).

Section 404.1520(c) makes step two a screening inquiry, so failure to classify an additional impairment as severe is not consequential when the ALJ considers all impairments in the remaining steps.

Ballou v. SSA · filed 2024-11-15(c)

She argues that the ALJ ... erred “by finding that Plaintiff’s Raynaud’s disease is not a severe impairment, as contemplated under 20 C.F.R. §§ 404.1520(c), 416.920(c), especially in view of her finding that Plaintiff retains the capacity to perform medium work.” ... In essence, the severity determination is merely a screening tool that is satisfied once any severe condition has been found. ... Ms. Ballou may not agree with the conclusions the ALJ reached about her limitations, but there is no question that the ALJ fully considered her Raynaud’s disease in the RFC determination.

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

(SS) Nichols v. Commissioner of Social Security · filed 2024-12-20(c)

“[A]n impairment is not severe if it does not significantly limit [the claimant’s] . . . ability to do basic work activities.” Id. at 1290 (citing 20 C.F.R. §§ 404.1520(c) & 404.1521(a)).

Section 404.1520(c) treats an impairment as severe at step two when it more than minimally affects the claimant's ability to perform basic work activities.

Patrick v. Social Security Administration Commissioner · filed 2025-01-03(c)

Further, a medically determinable impairment is “severe” if it more than minimally affects the claimant’s ability to perform basic work activities. 20 C.F.R. § 404.1520(c). ... There was no reversible error at step two.

Section 404.1520(c) treats an impairment as severe when it significantly limits an individual's ability to perform work functions or activities, and requires evidence of its limitation on basic work activities at step two.

Tirico v. Commissioner Social Security Administration · filed 2025-01-21(c)

At step two, the ALJ determines “whether the claimant had severe impairments during the period for which he seeks disability benefits.” ... A severe impairment is any impairment or condition that “significantly limits” an individual’s “ability to perform work functions or activities.” 20 C.F.R. § 404.1520(c). ... Typically, that comes in the form of symptom testimony or medical evidence showing how a claimant’s medically determinable impairments limit his ability to do “basic work activities.” 20 C.F.R. § 404.1520(c). ... The ALJ therefore reached the reasonable conclusion, supported by substantial evidence, that Plaintiff’s impairments were not severe during the relevant period.

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

Wilson v. Commissioner of Social Security · filed 2025-01-29(c)

At Step Two, an impairment or combination of impairments is deemed “severe” if it significantly limits a claimant’s ability to perform basic work activities. 20 C.F.R. § 404.1520(c); see Miller v. Berryhill, No. 16-CV-06467 (MAT), 2017 WL 4173357, at *7 (W.D.N.Y. Sept. 20, 2017).

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.

Blackstock v. Commissioner of Social Security · filed 2025-02-14(c)

The regulations define “severe impairment” as “any impairment or combination of impairments which significantly limits your physical or mental ability to do basic work activities,” 20 C.F.R. §§ 404.1520(c), 416.920(c), and which lasts or can be expected to last “for a continuous period of not less than 12 months,” 20 C.F.R. §§ 404.1509, 416.909.

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

Oviedo-Lopez v. Kijakazi · filed 2025-02-19(c)

A severe impairment is one “which significantly limits [the] physical or mental ability to do basic work activities[.]” Id. § 404.1520(c). ... Rather, evaluating the severity of her mental impairments for purposes of her disability claims depends on the degree of functional limitation resulting from the mental impairment on the claimant’s ability to work.

At step two, § 404.1520 requires an ALJ to determine whether a claimant has a medically determinable impairment and whether that impairment is severe.

GONZALEZ v. COMMISSIONER OF SOCIAL SECURITY · filed 2025-02-20(a)(4)(ii), (c)

At step two of the sequential evaluation, an ALJ must determine whether a claimant has a medically determinable impairment and whether that impairment is severe.

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

Mansfield v. Commissioner of Social Security Administration · filed 2025-02-24(c)

An impairment is severe if it “significantly limits [an individual’s] physical or mental ability to do basic work activities.” Taylor v. Astrue, 661 F. Supp. 2d 1184, 1191 (E.D. Wash. 2009) (citing 20 C.F.R. §§ 404.1520(c) and 4160920(c)). ... As such, the ALJ’s severity determination of Plaintiff’s depression was supported by substantial evidence and Plaintiff’s argument on the matter should be denied.

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

Byers v. Commissioner of Social Security · filed 2025-02-20(c)

As noted above, at Step Two of the sequential evaluation process, an ALJ must determine whether a claimant’s medically determinable impairment is a “severe” impairment. See 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 do basic work activities[.]” 20 C.F.R. § 404.1520(c).

Section 404.1520(c) treats an impairment as severe only when it significantly limits basic work activities; a step-two error is harmless when the ALJ considers the impairment's effects at later steps and in the RFC.

Waltz v. O'Malley · filed 2025-03-05(c)

An impairment is severe if it is “something beyond ‘a slight abnormality which would have no more than a minimal effect on an individual's ability to work.’ ” ... If a claimant has no impairment or combination of impairments which significantly limits her physical or mental abilities to perform basic work activities, the claimant will be found “not disabled” and the evaluation process ends at step two, McCrea at 360 (emphasis added). If the claimant has any medically determinable impairment that is severe, the evaluation process continues. ... At the outset, we note that substantial evidence supported the ALJ’s finding that Waltz’s Hashimoto’s disease was non-severe. ... Further, although the ALJ’s discussion of Waltz’s non-severe impairments is brief and cursory, the ALJ did state that, despite finding Waltz’s hypothyroidism to be non-severe, he considered all the plaintiff’s severe and non-severe impairments when formulating the RFC. (Tr. 28). Indeed, in the RFC assessment, the ALJ acknowledged that Waltz alleged he was disabled by a combination of impairments, including Hashimoto’s disease. (Tr. 31). Thus, any error at Step 2 would be harmless.

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.

Rucci v. Commissioner of Social Security · filed 2025-03-11(c)

At step two, an impairment is severe if it “significantly limits [the claimant’s] physical or mental ability to do basic work activities,” 20 C.F.R. § 404.1520(c), whereas an impairment is “[n]on-severe . . . if it does not significantly limit [the claimant’s] physical or mental ability to do basic work activities,” or “the abilities and aptitudes necessary to do most jobs” such as walking, standing, sitting, and lifting, id. § 404.1522(a)–(b)(1).

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

Willoughby v. Commissioner of Social Security Administration · filed 2025-03-17(a)(4)(ii)

At Step Two of the sequential evaluation process, the SSA considers the medical severity of the claimant’s impairments. 20 C.F.R. § 404.1520(a)(4)(ii).

At Step Two, the regulation requires an impairment or combination of impairments to be severe and meet the duration requirement; a severe impairment significantly limits a claimant's ability to perform basic work activities.

Brizzee v. Social Security Administration · filed 2025-03-19(a)(4)(ii), (c)

Step Two involves a determination of whether the claimant has an impairment or combination of impairments which is “severe” and meets the duration requirement. 20 C.F.R. § 404.1520(a)(4)(ii). A “severe” impairment significantly limits a claimant’s ability to perform basic work activities. 20 C.F.R. § 404.1520(c).

Section 404.1520(c) treats an impairment as severe when it significantly limits a claimant's physical or mental ability to do basic work activities.

(SS) Thompson v. Commissioner of Social Security · filed 2025-03-20(c)

To qualify for benefits, the plaintiff must have an impairment severe enough to significantly limit the physical or mental ability to do basic work activities. See 20 C.F.R. §§ 404.1520(c), 416.920(c).

At step two, Section 404.1520(a)(4)(ii) requires the ALJ to determine whether the claimant has a severe impairment before proceeding with the sequential disability evaluation.

POWELL v. O'MALLEY · filed 2025-03-26(a)(4)(ii)

Step two is a threshold determination of whether claimants have a severe impairment (or combination of impairments) that meets the twelve-month duration requirement and significantly limits their ability to do basic work activities. ... However, if a claimant does have a severe impairment or combination of impairments, the ALJ must consider the effects of both the severe and non-severe impairments at the subsequent steps of the process, including in the determination of RFC. ... In sum, substantial evidence clearly supports the AL]’s determination that Plaintiff's mental impairments were non-severe and required no functional limitations.

Section 404.1520(c) treats an impairment as severe when it significantly limits a claimant’s physical or mental ability to do basic work activities, even when the symptoms are episodic.

Moore v. Dudek · filed 2025-03-25(c)

Third, Plaintiff’s January 9, 2019, statement that her IBS was “better controlled” is consistent with having multiple chronic GI disorders with symptoms that are episodic but could still “significantly limit[ the claimant’s] physical or mental ability to do basic work activities.” See 20 C.F.R. §§ 404.1520(c), 416.920(c).

At Step Two, § 404.1520(c) treats an impairment as severe when it significantly limits a claimant’s physical or mental ability to do basic work activities.

Kishpaugh v. Kijakazi · filed 2025-04-10(c)

An impairment is considered severe if it “significantly limits an individual's physical or mental abilities to do basic work activities.” 20 C.F.R. 404.1520(c).

Section 404.1520(c) requires the medical evidence to show that an impairment has more than a minimal effect on a claimant's ability to work to qualify as severe at Step Two.

Lawton v. Dudek · filed 2025-04-09(c)

To be severe, the medical evidence must establish that the impairment would have more than a minimal effect on the claimant’s ability to work.

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

Hilton v. Commissioner of Social Security Administration · filed 2025-04-23(c)

A severe impairment is one that “significantly limits [a claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c).

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

Bly v. O'Malley · filed 2025-05-06(c)

Step two of the sequential evaluation analysis requires the claimant to establish the existence of a severe medically determinable impairment that meets the twelve-month durational requirement. See Jones v. Comm'r of Soc. Sec., 336 F.3d 469, 474 (6th Cir. 2003). A “medically determinable impairment” is an impairment that “result[s] from anatomical, physiological, or psychological abnormalities that can be shown by medically acceptable clinical and laboratory diagnostic techniques.” 20 C.F.R. § 404.1521. A severe impairment is one that “significantly limits your physical or mental ability to do basic work activities,” and “significantly” is to be liberally construed in the claimant’s favor. 20 C.F.R. § 404.1520(c). ... The Court finds that the ALJ did not err by failing to find Plaintiff’s COPD to be a severe impairment.

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

Jaggars v. O'Malley · filed 2025-05-14(c)

The regulations further provide: “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.” 20 C.F.R. § 404.1520(c).