20 C.F.R. § 404.1520

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

Webb v. Commissioner of Social Security · filed 2022-09-29(c)

To the extent plaintiff contends that the ALJ found depression and anxiety as non-severe impairments, this finding is not an error requiring reversal. A “severe impairment” is defined as an impairment or combination of impairments “which significantly limits your physical or mental ability to do basic work activities.” 20 C.F.R. §404.1520(c). As discussed, the ALJ found that plaintiff had severe impairments. PageID.48. Upon determining that a claimant has one severe impairment the ALJ must continue with the remaining steps in the disability evaluation. See Maziarz v. Secretary of Health & Human Services, 837 F.2d 240, 244 (6th Cir. 1987). Once the ALJ determines that a claimant suffers from a severe impairment, the fact that the ALJ failed to classify a separate condition as a severe impairment does not constitute reversible error.

At step two, § 404.1520 requires the ALJ to determine whether the claimant has a severe impairment or combination of impairments and assess whether it significantly limits basic work activities.

Ramirez v. Kijakazi · filed 2022-09-30(a)(4)(ii)

At step two, the ALJ determines whether a claimant has a severe impairment or combination of impairments. 20 C.F.R. § 404.1520(a)(4)(ii). When evaluating whether a claimant has a severe impairment or combination of impairments, the ALJ will assess whether those impairments significantly limit a claimant’s ability to perform basic work activities.

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

Dillingham v. Commissioner of Social Security · filed 2022-10-04(c)

From this evidence, the ALJ could reasonably adopt the position that Plaintiff’s mental impairments were nonsevere—i.e., they did not “significantly limit[] [her] . . . mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c).

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

Morris v. Commissioner of Social Security · filed 2022-10-14(c)

At step two of the sequential evaluation process, the ALJ must determine whether the plaintiff has a severe impairment that significantly limits his or her physical or mental ability to do basic work activities. See 20 C.F.R. § 404.1520(c). ... Here, the ALJ concluded Plaintiff’s migraines were a non-severe medically determinable impairment. (T. 18.) ... Overall, the ALJ properly concluded Plaintiff’s migraine headaches were non-severe and substantial evidence in the record supported the ALJ’s determination.

At step two, § 404.1520 requires the Commissioner to determine whether an impairment significantly limits a claimant’s ability to perform basic work activities.

Girolamo v. Kijakazi · filed 2022-10-19(a)(4)(ii), (c)

At step two of the sequential analysis, the ALJ must determine whether the claimant has a “severe impairment” that “significantly limits [claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1520(a)(4)(ii), (c). ... Based on authority cited above, the ALJ inappropriately applied his lay analysis to the limited medical records to assess “severity” of plaintiff’s mental health impairments. He further erred by failing to develop the record by obtaining a medical consultant to examine her and assess her work-related mental health limitations. ... the new treatment notes should have caused a diligent ALJ to reconsider his view that plaintiff’s mental health impairment at least minimally impacted her work-related functions.

At step two, the regulation allows denial only when a claimant has no severe medically determinable impairment or combination of impairments, so one severe impairment requires the ALJ to continue evaluating all impairments.

Rivera v. Commissioner, SSA · filed 2022-11-30(a)(4)(ii)

At step two, “a claimant need only establish, and an ALJ need only find, one severe impairment,” Allman, 813 F.3d at 1330. “The reason is grounded in the Commissioner’s regulation describing step two, which states: ‘If you do not have a severe medically determinable physical or mental impairment or a combination of impairments that is severe, we will find that you are not disabled.’” Id. (quoting 20 C.F.R. § 404.1520(a)(4)(ii) (ellipses omitted)). The plain language of this regulation requires only one severe impairment to avoid the denial of benefits at step two. Id. Thus, so long as a claimant establishes at least one severe impairment, the ALJ cannot deny benefits at step two and must proceed with the sequential evaluation process and account for the limiting effects of all impairments, even those that are not severe.

Section 404.1520 requires a five-step disability evaluation, including determining at step two whether the claimant has a severe impairment or combination of impairments.

Jessup v. Kijakazi · filed 2022-12-21(a)(4)(ii)

The Commissioner has established a five-step sequential evaluation process for determining whether a claimant is disabled. 20 C.F.R. §§ 416.920, 404.1520. Step one determines if he is engaged in substantial gainful activities. If the claimant is engaged in substantial gainful activities, benefits are denied. 20 C.F.R. §§ 416.920(a)(4)(i), 404.1520(a)(4)(i). 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. ... Since there is evidence in the record that Plaintiff may have functional limitations from her mental health symptoms, the ALJ erred at step two in failing to discuss whether depression and/or anxiety are severe impairments. See Lewis, 498 F.3d at 911. Furthermore, the Court cannot determine that the ALJ’s error at step two is harmless because the ALJ did not consider Plaintiff’s depression and anxiety symptoms at later steps. This was legal error.

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

Hussen v. Commissioner of Social Security · filed 2022-12-28(c)

At step two, a claimant must make a threshold showing that her medically determinable impairments significantly limit her ability to perform basic work activities. See Bowen v. Yuckert, 482 U.S. 137, 145 (1987); 20 C.F.R. §§ 404.1520(c), 416.920(c). ... Because Plaintiff has failed to show his diabetes and diabetic neuropathy were severe as defined in the regulations, Plaintiff fails to meet his burden to show harmful legal error in the ALJ’s step-two findings.

Section 404.1520(c) requires the ALJ at step two to determine whether an impairment is medically determinable and severe, and treats an impairment as not severe if it does not significantly limit basic work activities.

Bell v. Commissioner Social Security Administration · filed 2022-12-30(c)

At step two, the ALJ determines whether the claimant has an impairment that is both medically determinable and severe. 20 C.F.R. § 404.1520(c). ... An impairment is “not severe” if it does not “significantly limit” a claimant’s ability to conduct basic work activities. 20 C.F.R. §§ 404.1520(c), 416.920(c); see also Sullivan v. Zebley, 493 U.S. 521, 525 (1990). ... Plaintiff contends the ALJ erred in failing to find that her cervical impairment was severe at step two. But, for the reasons discussed above, plaintiff failed to meet her burden of showing she had a cervical impairment that lasted at least 12 continuous months.

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

(SS) Hanson v. Commissioner of Social Security · filed 2023-01-09(c)

Step two is “a de minimis screening device [used] to dispose of groundless claims.” Smolen v. Chater, 80 F.3d 1273, 1290 (9th Cir. 1996). A “severe” impairment or combination of impairments is one that significantly limits physical or mental ability to do basic work activities. 20 C.F.R. § 404.1520. An impairment or combination of impairments should be found to be “non-severe” only when the evidence establishes merely a slight abnormality that has no more than a minimal effect on an individual’s physical or mental ability to do basic work activities. Webb v. Barnhart, 433 F.3d 683, 686 (9th Cir. 2005); 20 C.F.R. §§ 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.

Resco v. Kijakazi · filed 2023-01-11(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). ... The ALJ found Plaintiff’s carpal tunnel syndrome causes no more than a minimal effect on her ability to perform basic work-related activities for a period of 12 months or more. Tr. 18. ... The ALJ’s finding is supported by substantial evidence.

Section 404.1520(c) requires the ALJ to determine whether a claimant has a severe impairment or combination of impairments that significantly limits the ability to perform basic work activities, after which the sequential evaluation proceeds to assessment of residual functional capacity.

McNutt v. Commissioner of Social Security · filed 2023-01-17(c)

At step two, an ALJ decides whether the claimant has a “severe impairment” or combination of impairments that “significantly limits [the plaintiff’s] physical or mental ability to do basic work activities[.]” 20 C.F.R. §§ 404.1520(c); 416.920(c); SSR 85-28, 1985 WL 56856, at *3 (Jan. 1, 1985). If the claimant has at least one severe impairment, the ALJ must then assess the claimant’s RFC. 20 C.F.R. §§ 404.1520(a)(4)(iv); 416.920(a)(4)(iv).

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 failure to find one particular impairment severe is harmless when the ALJ finds another severe impairment and proceeds with the sequential evaluation.

Walters v. Commissioner, Social Security Administration · filed 2023-01-18(c)

At Step Two the Commissioner determines whether a claimant has any severe physical or mental impairments. See Williams, 844 F.2d at 750. An impairment is “severe” if it “significantly limits” a claimant’s “physical or mental ability to do basic work activities,” 20 C.F.R. §§ 404.1520(c), 416.920(c), such as walking, standing, sitting, seeing, hearing, speaking, carrying out simple instructions, using judgment, responding appropriately to supervision or coping with changes in routine. ... First, the ALJ was not required to evaluate Plaintiff’s headache impairment at Step Two because he found other severe impairments at that stage of the sequential evaluation process. Thus, any such error in this regard is harmless.

At step two, the regulation provides that an impairment is not severe when it does not significantly limit basic work activities, ending the disability determination and making age, education, and work experience immaterial.

Robbins v. Commissioner of Social Security · filed 2023-01-23(c)

However, the ALJ found that Plaintiff was not disabled at step-two of the sequential process, obviating the need for formal findings as to her past work experience. 20 C.F.R. § 404.1520(c) (“If you do not have any impairment or combination of impairments which significantly limits your physical or mental ability to do basic work activities, we will find that you do not have a severe impairment and are, therefore, not disabled. We will not consider your age, education, and work experience.”). Therefore, any finding as to Plaintiff’s work history, even if erroneous, is irrelevant.

Section 404.1520(c) requires a step-two determination of whether an impairment significantly limits basic work activities, using a nonstringent screen intended to exclude only de minimis claims.

Estridge v. Commissioner of Social Security · filed 2023-01-24(c)

In the context of step two of the sequential test for determining disability, “[a] ‘severe’ impairment is one that significantly limits an individual’s physical or mental ability to do basic work activities.’” Meadors v. Astrue, 370 F. App’x 179, 182 (2d Cir. 2010) (citing 20 C.F.R. §§ 404.1520(c), 416.920(c)). A claimant’s burden at step two is not stringent; it is intended to primarily to screen out only de minimis claims. Patrick J. v. Comm’r of Soc. Sec., 17-CV-1377, 2019 WL 917963, at *4 (N.D.N.Y. Feb. 22, 2019) (Baxter, M.J.). As with every other part of the ALJ’s decision, an ALJ’s findings regarding whether impairments are severe should be upheld where there is substantial evidence in the record to support the step two finding.

At Step Two, § 404.1520(c) requires a claimant to show a medically determinable impairment that significantly limits the ability to perform basic work activities.

Cotto-Ramos v. Commissioner of Social Security · filed 2023-02-02(c)

At Step Two, a claimant must produce evidence that he has a medically determinable physical or mental impairment(s), which must significantly limit his physical or mental ability to do basic work activities. 20 C.F.R. §§ 404.1520(c), 404.1522.

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; a claim ends if none exists, and evaluation proceeds to step three if one does.

Parker v. Kijakazi · filed 2023-02-13(a)(4)(ii)

Step Two: Does the claimant have a medically-severe impairment or combination of impairments? 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii). ... If the claimant does not have a severe impairment or combination of impairments, the disability claim is denied. Id. § 404.1520(a)(4)(ii), 416.920(a)(4)(ii). If the impairment is severe, the evaluation proceeds to the third step. ... As such, the ALJ Step Two evaluation of Plaintiff’s mental health impairments were not supported by substantial evidence in the record.

At step two, § 404.1520 requires determining whether a medically determinable impairment significantly limits a claimant’s ability to perform basic work activities, while considering all the evidence.

(SS) Callahan v. Commissioner of Social Security · filed 2023-02-22(c)

At step two of the sequential evaluation, the ALJ determines which of Plaintiff’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.” Id. An ALJ must consider all the evidence at step two to determine whether a medically determinable impairment significantly limits the claimant’s ability to perform basic work activities.

Section 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, and the claimant bears the burden of showing severity.

Morales v. Kijakazi · filed 2023-02-23(c)

As we have noted, at step-two of this sequential analysis, the ALJ determines whether a claimant has a medically severe impairment or combination of impairments. ... An impairment is only 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). The burden is on the claimant to show that an impairment qualifies as severe. Applying these benchmarks, we find that the ALJ's step two evaluation in this case is supported by substantial evidence.

Section 404.1520(a)(4)(ii) makes step two a threshold screen for severe medically determinable impairments, and failure to classify additional conditions as severe is harmless when the claim proceeds past that step.

West v. Commissioner of Social Security Administration · filed 2023-03-02(a)(4)(ii)

At step two, the ALJ determines whether Plaintiff has any severe MDIs. 20 C.F.R. § 404.1520(a)(4)(ii). “Step two is merely a threshold determination meant to screen out weak claims.” ... Because the ALJ did not “screen out” Plaintiff’s claim at this step, however, there is no harmful error.

At step two, § 404.1520(a)(4)(ii) requires the claimant to show an impairment or combination of impairments that significantly limits the ability to perform basic work activities.

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

At step two, a claimant must show that he or she suffers from an impairment or combination of impairments that significantly limits his or her physical or mental ability to perform basic work activities, including physical work activities, such as walking, standing, sitting, lifting, reaching, carrying, and handling, and mental work activities, such as understanding, carrying out, and remembering simple instructions; use of judgment; ... responding appropriately to supervision, coworkers, and usual work situations; and dealing with changes in a routine work setting. See 20 C.F.R. §§ 404.1520(a)(4)(ii), 404.1521, 404.1522(a), 416.920(a)(4)(ii), 416.921, 416.922(a). ... As the Commissioner contends, Plaintiff failed to point to any evidence demonstrating that Plaintiff’s impairments would limit her ability to perform basic work activities, thus rendering them severe impairments, prior to January 1, 2020.

At Step Two, an impairment is severe only if it significantly limits the claimant's physical or mental ability to do basic work activities, and the claimant must also satisfy the applicable duration requirement.

Pratt v. Kijakazi · filed 2022-09-28(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 [and § 416.909], or a combination of impairments that is severe and meets the duration requirement . . . ” 20 C.F.R. §§ 404.1509, 404.1520(a)(4)(ii) 416.909, 416.920(a)(ii). To be a “severe impairment,” an impairment must “significantly limit[] [the claimant’s] physical or mental ability to do basic work activities.” §§ 404.1520(c), 416.920(c).

Section 404.1520(c) requires a medically determinable impairment to significantly limit basic work activities before it qualifies as a severe impairment at step two.

MARTINEZ v. COMMISSIONER OF SOCIAL SECURITY · filed 2022-09-28(c)

As noted above, a severe impairment or combination of impairments must significantly limit a person’s “physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c). ... The ALJ determined at step two that Jorge M.’s claimed history of fibromyalgia was not sufficient to support a finding that it was a “medically determinable” impairment that rose to the level of being “severe.” ... Unpacking that analysis, I conclude that the ALJ’s conclusion, if not inescapable, was well supported.

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

Bogner v. Commissioner of Social Security · filed 2022-09-30(a)(4)(ii)

If not, the second step requires the ALJ to consider whether the claimant has a “severe impairment” that significantly limits his or her physical or mental ability to do basic work activities. 20 C.F.R. § 404.1520(a)(4)(ii).

Section 404.1520(a)(4)(ii) provides that a claimant is not disabled if the claimant lacks a severe medically determinable impairment or combination of impairments, and the court held that failure to classify one impairment as severe is not reversible error when another impairment is severe.

Brewer v. Commissioner, Social Security Administration · filed 2023-01-09(a)(4)(ii)

As an initial matter, the Court recognizes that “the failure to find a particular impairment severe at step two is not reversible error when the ALJ finds that at least one other impairment is severe.” ... see also 20 C.F.R. § 404.1520(a)(4)(ii) (“If you do not have a severe medically determinable physical or mental impairment . . . or a combination of impairments that is severe . . . , we will find that you are not disabled.” (emphasis added)). ... As such, Defendant’s categorization of Plaintiff’s kidney disease as non-severe at Step Two does not constitute reversible error.

Section 404.1520(a)(4)(ii) requires the Commissioner to determine at step two whether a claimant has a severe impairment.

Greger v. Commisioner of Social Security · filed 2023-01-26(a)(4)(ii)

At step two, the Commissioner must determine whether the claimant has a severe impairment. 20 C.F.R. § 404.1520(a)(4)(ii). ... The Sixth Circuit has described the step two analysis as a “de minimus hurdle,” explaining, “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.” ... Thus, if an impairment has “more than a minimal effect” on the claimant's ability to do basic work activities, then the ALJ must treat it as “severe.” ... Therefore, the ALJ’s step two finding is unsupported by substantial evidence.

Section 404.1520(c) treats an impairment as non-severe when it causes no more than a minimal effect on a claimant’s ability to work, and the court upheld that finding for diabetes.

Rose v. Kijakazi · filed 2023-03-07(c)

At step two, an ALJ must consider a claimant’s medically determinable impairments. 20 C.F.R. §§ 404.1520(a)(4)(ii), 404.1521. ... A severe impairment causes more than a minimal effect on one’s ability to work. Id.§ 404.1520(c). ... Upon review, the undersigned finds no error in the ALJ’s step two findings, and substantial evidence supports the ALJ’s conclusion that Plaintiff’s diabetes was non-severe.

Section 404.1520(a)(4)(ii) requires the ALJ to determine at step two whether a medically severe impairment or combination significantly limits the claimant’s ability to do basic work activities.

Evans v. Social Security · filed 2023-03-08(a)(4)(ii)

At step two of the ALJ’s evaluation of a claimant’s case, “the ALJ assesses whether the claimant has a medically severe impairment or combination of impairments that significantly limits his ability to do basic work activities.” Webb v. Barnhart, 433 F.3d 683, 686 (9th Cir. 2005), citing 20 C.F.R. 404.1520(a)(4)(ii).

Under § 404.1520, step two asks whether the claimant has a severe impairment, defined as one that significantly limits physical or mental ability to perform basic work activities.

Reese v. Commissioner of Social Security · filed 2023-03-08(a)(4)(ii), (c)

At Step Two of the sequential evaluation process, the ALJ must determine whether a claimant has a severe impairment. See 20 C.F.R. § 404.1520(a)(4)(ii). ... The applicable regulations generally define a “severe” impairment as an “impairment or combination of impairments which significantly limits [the claimant's] physical or mental ability to do basic work activities. . . .” 20 C.F.R. § 404.1520(c). ... The ALJ applied the proper legal standards and reached a decision supported by substantial evidence in finding that Plaintiff’s rheumatoid arthritis was a non-severe impairment.

At step two, an impairment is severe if it significantly limits a claimant’s physical or mental ability to do basic work activities, and the ALJ must consider all impairments in evaluating the claimant’s remaining limitations.

Pendergrass v. Commissioner of Social Security · filed 2023-03-08(c)

At step two, an ALJ considers if a claimant’s impairment constitutes a “medically determinable” impairment, i.e., an impairment that results from anatomical, physiological or psychological abnormalities that can be shown by medically acceptable clinical and laboratory diagnostic techniques. 20 C.F.R. §§ 404.1520; 404.1521. If an impairment is medically determinable, then an ALJ must determine whether it is severe. Id. 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 C.F.R. § 404.1520(c). ... In sum, there was no error in the ALJ’s decision to not label migraine headaches as severe at step two, because she proceeded to fully evaluate the limitations imposed by the headaches for purposes of the RFC. And her conclusion that the migraine headaches did not support work-preclusive limitations is supported by substantial evidence. Accordingly, Plaintiff’s assignment of error is without merit.

Section 404.1520(c) treats step two as a threshold inquiry into severe impairment; after a severe impairment is found, the evaluation proceeds and established functional limitations must be considered regardless of severity.

(SS) Dalton v. Commissioner of Social Security · filed 2023-03-13(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). ... Once the ALJ determined the existence of a severe impairment or combination of impairments, the ALJ then considered all the functional limitations established by the reliable medical evidence, regardless of severity. Accordingly, any error at step two not have affected the ultimately disability determination, and therefore would have been harmless as a matter of law.

Section 404.1520(c) requires a claimant to have a severe impairment that significantly limits physical or mental ability to do basic work activities to proceed beyond step two, which serves as a threshold screen for weak claims.

Guinn v. Commissioner of Social Security Administration · filed 2023-03-14(c)

To proceed beyond step two in the sequential evaluation, the claimant must have a severe impairment, or a combination of severe impairments, that “significantly limits [his] physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c). “An impairment is not severe if it is merely ‘a slight abnormality (or combination of slight abnormalities) that has no more than a minimal effect on the ability to do basic work activities.’” Webb v. Barnhart, 433 F.3d 683, 686 (9th Cir. 2005) (citations omitted). Notably, “[s]tep two is merely a threshold determination meant to screen out weak claims.” Buck v. Berryhill, 869 F.3d 1040, 1048 (9th Cir. 2017) (citation omitted).

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

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

At step two, a claimant must make a threshold showing her medically determinable impairments significantly limit her ability to perform basic work activities. ... The ALJ accordingly reasonably found Plaintiff’s mental impairments non-severe during the DIB period. ... The ALJ accordingly did not err by finding no severe impairments at step two with respect to Plaintiff’s DIB claim.

At step two, the regulation requires a severe impairment that significantly limits basic work activities, but only a de minimis showing is needed to advance beyond that step.

Desjardins v. Kijakazi · filed 2023-03-20(c)

Plaintiff has the burden to prove that he has an impairment or combination of impairments that is severe, meaning that it “significantly limits [his] ability to do basic work activities.” 20 C.F.R. § 404.1520(c). A claimant must only make a “de minimus” showing to advance beyond step two. ... The ALJ’s inconsistent findings on this issue suggests that the ALJ did not adequately consider the relationship between Plaintiff’s TBI and headaches. To conclude otherwise would require mere speculation regarding the ALJ’s analysis. Remand is therefore necessary for the ALJ to properly evaluate Plaintiff’s TBI and headaches at step two and subsequent steps if necessary.

Under § 404.1520(c), an impairment must significantly limit basic work activities to qualify as severe at step two, but an erroneous nonseverity finding is harmless when the ALJ considers the impairment’s effects in the remaining steps.

Hayden v. Commissioner of Social Security · filed 2023-03-21(c)

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). ... An ALJ's failure to consider an impairment to be severe is harmless provided in proceeding through the remaining steps of the sequential disability analysis, the ALJ considers the effects of all of the Plaintiff's impairments. ... In the instant case, despite considering Plaintiff’s CRPS to be a nonsevere impairment at Step Two, the ALJ specifically stated that “the residual functional capacity assessment fully accounts for any dysfunction from the claimant’s nonsevere impairments.” ... Accordingly, even if the ALJ erred in failing to consider Plaintiff’s CRPS to be a nonsevere impairment, such error was harmless and provides no basis for remand.

At step two of the disability evaluation, the ALJ must determine whether the claimant has a severe impairment.

Gonzalez-Dominicci v. Commissioner of Social Security · filed 2023-03-22(a)(4)(ii)

Step two of the sequential evaluation process requires the ALJ to determine whether a claimant suffers from a severe impairment. See 20 C.F.R. § 404.1520(a)(4)(ii).

Section 404.1520 requires the ALJ, at step two of the sequential evaluation, to determine whether the claimant has a medically determinable severe impairment.

Ibarra v. Kijakazi · filed 2023-03-31(a)(4)(ii)

At step two of the sequential evaluation process, the ALJ must determine whether the claimant has any medically determinable severe impairments.

Section 404.1520(a)(4)(ii) provides that a claimant passes step two when the claimant has at least one severe medically determinable impairment.

Bagnell v. Commissioner of Social Security Administration · filed 2023-04-14(a)(4)(ii)

A claimant passes step two if he has at least one severe medically determinable impairment. Id. § 404.1520(a)(4)(ii).

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

Felker v. Commissioner of Social Security · filed 2023-04-18(c)

At step two, the ALJ must determine whether the claimant has a medically determinable impairment that is “severe” or a combination of impairments that is “severe.” 20 C.F.R. § 404.1520(c). ... The ALJ found that Felker had several severe impairments. (Tr. 13.) Thus, regardless of any mistake with the treatment of her mental limitations, there is no reversible error with step two.

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

Morway v. Commissioner of Social Security · filed 2023-04-21(c)

It is Plaintiff’s burden to show at step two that she has a “severe” impairment or combination of impairments, meaning an impairment or combination of impairments that “significantly limits [her] physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1520(c), 416.920(c); see 20 C.F.R. §§ 404.1522, 416.922; Bowen v. Yuckert, 482 U.S. 137, 146 n.5 (1987) (“It is not unreasonable to require the claimant, who is in a better position to provide information about his own medical condition, to do so.”).

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

(SS) Gegan v. Commissioner of Social Security · filed 2023-05-08(c)

A “severe” impairment or combination of impairments is one that significantly limits physical or mental ability to do basic work activities. 20 C.F.R. § 404.1520. ... Notwithstanding, the ALJ’s broader reasoning (minimal mental health treatment with psychiatric findings within normal limits) is on balance sufficiently substantial evidence to support the ALJ’s conclusion that Plaintiff’s adjustment disorder with anxiety caused no more than mild functional limitations and therefore not severe. ... Thus, substantial evidence supports the ALJ’s conclusion at step two that Plaintiff’s adjustment disorder with anxiety was non-severe, and substantial evidence supported the ALJ’s rejection of the contrary opinions of Drs. Chandler and Diego.

Section 404.1520(c) treats an impairment as severe when it is more than slight and affects the claimant’s ability to perform basic work activities, applying a low or de minimis threshold.

Williams v. Social Security Administration Commissioner · filed 2023-06-12(c)

A claimant suffers from a severe impairment if that impairment is more than slight and if that impairment affects the claimant’s ability to do his or her basic work activities. ... Furthermore, the standard for determining whether a claimant suffers from a severe impairment is a low standard. ... Based upon the foregoing, the Court finds the ALJ erred in finding Plaintiff’s left-hand impairment did not meet the low or de minimis standard for a “severe impairment.” Thus, this case must be reversed and remanded.

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

CICCONE v. COMMISSIONER OF SOCIAL SECURITY · filed 2023-07-11(c)

At step two, an ALJ determines whether the plaintiff has an impairment or combination of impairments that “significantly limits [the plaintiff’s] physical or mental ability to do basic work activities[.]” 20 C.F.R. § 404.1520(c). ... In the case presently before the Court, the ALJ decided in Plaintiff’s favor at step two, finding that Plaintiff’s chronic pain syndrome, spondylosis of the lumbar region, lumbar disc herniation, right shoulder bursitis, and cervical spondylosis with radiculopathy (protrusion of disc at cervical spine) are severe. R. 13. ... Accordingly, even if the ALJ erred by not finding other severe impairments at step two of the sequential evaluation, any such error is harmless based on this record. See Salles, 229 F. App’x at 145 n.2; Hicks, 2016 WL 8674251, at *8; Auriemma, 2015 WL 5097902, at *6.

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

Asiedu v. Commissioner of Social Security · filed 2023-07-12(c)

At step two of the sequential evaluation process, the ALJ must determine whether the claimant has a severe impairment that significantly limits his or her physical or mental ability to do basic work activities. See 20 C.F.R. §§ 404.1520(c), 416.920(c). ... The ALJ’s conclusions, particularly regarding Plaintiff’s ability to maintain social functioning and self-regulation/management, are at odds with the opinions of Dr. Bhuiyan and Dr. Gordon-Fitzsimons, both of whom found at least moderate impairment in these domains. (T at 446, 640-42). Accordingly, for the reasons outlined above, the ALJ did not adequately support her decision to deem the assessments of both the treating and examining physicians unpersuasive. This error also undermines the step two analysis.

Section 404.1520 requires the ALJ at step two to distinguish severe from non-severe impairments, treating an impairment as severe when it significantly limits basic work activities.

(SS) Eilrich v. Commissioner of Social Security · filed 2023-07-31(a)(4)(ii)

At step two, the ALJ is to distinguish between those impairments that are “severe” and “non-severe.” See 20 C.F.R. § 404.1520. A “severe” impairment is one that significantly limits the physical or mental ability to perform basic work activities.

At step two, § 404.1520(a)(4)(ii) requires the Commissioner to determine whether a claimant has a severe impairment, and § 404.1520(a)(3) requires consideration of the relevant evidence in the record before making that determination.

Parker v. Kijakazi · filed 2023-07-31(a)(3), (a)(4)(ii)

As was noted above, at step two of the five-step sequential analysis, an ALJ considers whether a claimant’s impairments are “severe.” 20 C.F.R. §§ 404.1520(a)(4)(ii) & 416.920(a)(4)(ii). An ALJ may deem an impairment “not severe” only if it involves a “‘slight abnormality’” that has “‘no more than a minimal effect’” on the individual’s ability to work. ... The ALJ’s process at step two with regard to this condition amounted to error. More specifically, the ALJ: (1) committed legal error in failing to substantively consider certain of Plaintiff’s medical records regarding her foot and ankle problems dating from between June 2019 and her August 2020 hearing, see 20 C.F.R. §§ 404.1520(a)(3) & 416.920(a)(3); and (2) issued a decision on severity that, in light of those records and other evidence, was not supported by substantial evidence.

Section 404.1520(c) requires the ALJ at step two to determine whether the claimant has a severe impairment or combination of impairments that significantly limits basic work activities, ending the inquiry if none exists.

DOMINGUEZ v. COMMISSIONER OF SOCIAL SECURITY · filed 2023-08-01(c)

At step two, the ALJ decides whether the plaintiff has a “severe impairment” or combination of impairments that “significantly limits [the plaintiff’s] physical or mental ability to do basic work activities[.]” 20 C.F.R. §§ 404.1520(c), 416.920(c). If the plaintiff does not have a severe impairment or combination of impairments, then the inquiry ends because the plaintiff is not disabled. Otherwise, the ALJ proceeds to step three. ... In the present case, the ALJ denied Plaintiff’s claim at step two, finding that none of Plaintiff’s medically determinable impairments of rheumatoid arthritis, diabetes mellitus, and hypertension, nor the combination of her impairments, was severe. R. 25–27. ... The Court finds no error with the ALJ’s consideration of Plaintiff’s medically determinable impairments in this regard.

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.

Sorrell v. Commissioner of Social Security · filed 2023-08-21(c)

A severe impairment is one that significantly limits the plaintiff’s physical and/or mental ability to do basic work activities. See 20 C.F.R. §§ 404.1520(c), 416.920(c); see also 20 C.F.R. §§ 404.1522(a), 416.922(a) (noting that an impairment is not severe at step two if it does not significantly limit a plaintiff’s ability to do basic work activities).

Section 404.1520(a)(4)(ii) treats whether an impairment is severe as a step-two issue, and failure to label one impairment severe is harmless when another impairment is severe and all impairments are considered at later steps.

Stewart v. Social Security Administration · filed 2023-08-22(a)(4)(ii)

Whether an ALJ finds an impairment to be severe is a step-two consideration. See 20 C.F.R. § 404.1520(a)(4)(ii). ... Here, the ALJ found multiple other impairments to be severe (R. 24-25) and, as noted below, continued to consider Plaintiff’s diabetes at other steps of the evaluation (R. 29, 32-34). As such, there was no error in finding Defendant’s diabetes non-severe.

Section 404.1520(a)(4)(ii) requires an ALJ to assess the severity of a claimant’s impairments at step two, and any one severe impairment is enough to proceed with the disability analysis.

HOWARD v. COMMISSIONER OF SOCIAL SECURITY · filed 2023-08-24(a)(4)(ii)

At the second step of the disability analysis, [an ALJ] considers the medical severity of a claimant’s impairments. See 20 C.F.R. §§ 404.1520(a)(4)(ii) and 416.920(a)(4)(ii). A claimant must have at least one severe physical or mental impairment to be disabled. Id. Therefore, at least one severe impairment is needed to proceed past step two in the disability analysis. Id.; see also Hearn v. Comm’r, Soc. Sec. Admin., 619 F. App’x 892, 895 (11th Cir. 2015) (citing Jamison v. Bowen, 814 F.2d 585, 588 (11th Cir. 1987)) (“[F]inding any severe impairment…is enough to satisfy step two.”)

Section 404.1520(a)(4)(ii) requires the ALJ to determine whether the claimant has a severe impairment at step two; once at least one severe impairment is found, failure to designate additional impairments as severe is not reversible error.

Fulton v. Social Security Administration · filed 2023-08-29(a)(4)(ii)

At step two of the evaluative sequence, the ALJ must determine whether a claimant suffers from severe impairments. That is all that is required of the ALJ at step two. Oldham v. Astrue, 509 F.3d 1254, 1256 (10th Cir. 2007). Once an ALJ finds that a claimant has at least one severe impairment, a failure to designate others as “severe” at step two does not constitute reversible error.

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.

Zapp v. Commissioner of Social Security · filed 2023-09-01(c)

By definition, under the Commissioner's regulations at 20 C.F.R. § 404.1520(c), a severe impairment is “any impairment or combination of impairments which significantly limits your physical or mental ability to do basic work activities.” Thus, the consultative examiners’ opinions that Plaintiff has no left eye limitations, without a functional analysis, would arguably not be substantial evidence.

Section 404.1520(a)(4)(ii) requires the Commissioner to decide at step two whether a claimant has a medically severe impairment or combination of impairments; an impairment is nonsevere only if it is a slight abnormality with no more than a minimal effect on the ability to work.

Taylor v. Kijakazi · filed 2023-09-07(a)(4)(ii)

At step two of the five-step sequential inquiry, the Commissioner must decide whether the claimant has a medically severe impairment or combination of impairments. 20 C.F.R. § 404.1520(a)(4)(ii). An impairment or combination of impairments is nonsevere only if it is “a slight abnormality that has no more than a minimal effect on an individual[’]s ability to work.” Smolen v. Chater, 80 F.3d 1273, 1290 (9th Cir. 1996) (internal quotation marks and citation omitted). The inquiry at step two is not a high barrier; it is “‘a de minimis screening device” designed to “dispose of groundless claims.’” Edlund v. Massanari, 253 F.3d 1152, 1158 (9th Cir. 2001) (quoting Smolen, 80 F.3d at 1290).

Section 404.1520(c) makes step two a threshold inquiry: an impairment is severe when it significantly limits basic work activities, and one severe impairment is enough to proceed to the next step if all impairments are considered later.

Pugh v. Kijakazi(CONSENT) · filed 2023-09-11(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), 404.1505(a). ... At step two in this case, the ALJ satisfied the requirements of the threshold inquiry by finding that Plaintiff has severe impairments, namely left lower extremity lymphedema, hypertension, obstructive sleep apnea, and obesity. ... Because the ALJ found that Plaintiff has at least one severe impairment, the ALJ was not required to identify all of Plaintiff’s severe impairments before moving to step three of the sequential evaluation process.

Section 404.1520 requires a five-step disability evaluation, including a Step Two determination of whether the claimant has a medically severe impairment or combination of impairments.

Robinson v. Commissioner of Social Security · filed 2023-09-12(a)(4)(ii)

Step Two of the evaluation process requires the ALJ to determine “whether the claimant has a medically severe impairment or combination of impairments.” ... To be considered “severe,” an impairment or combination of impairments must significantly limit the claimant’s physical or mental ability to conduct basic work activities. ... The failure to consider evidence of a diagnosis and limitations is error.

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

Mejia v. Kijakazi · filed 2023-09-11(c)

The evaluation at step two is a “de minimis screening device to dispose of groundless claims.” Smolen v. Chater, 80 F.3d 1273, 1290 (9th Cir. 1996); Bowen v. Yuckert, 482 U.S. 137, 153-154 (1987). “At step two, the ALJ assesses whether the claimant has a medically severe impairment or combination of impairments that significantly limits [her] ability to do basic work activities.” Webb v. Barnhart, 433 F.3d 683, 686-87 (9th Cir. 2005); 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”).

At step two, § 404.1520(c) requires a claimant to have a severe impairment, or combination of severe impairments, that significantly limits the claimant’s physical or mental ability to do basic work activities.

Skelton v. Commissioner of Social Security Administration · filed 2023-09-13(c)

To proceed beyond step two, a claimant must have a severe impairment, or a combination of severe impairments, that “significantly limits [her] physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c).

Section 404.1520(c) requires the Commissioner at step two to decide whether a medically determinable impairment or combination of impairments significantly limits the claimant's ability to perform basic work activities.

Linval v. Commissioner of Social Security · filed 2023-09-19(c)

Step two requires the Commissioner to “determine whether the claimant has a severe impairment that significantly limits his or her physical or mental ability to do basic work activities.” ... A “severe impairment” is a medically determinable impairment or combination of impairments that “significantly limits [the claimant’s] ability to do basic work activities.” 20 C.F.R. §§ 404.1520(c), 416.920(c). ... Accordingly, the Court finds that the ALJ’s conclusion that Plaintiff’s carpal tunnel syndrome is not severe is not supported by substantial evidence.

Section 404.1520(c) considers an impairment severe when it significantly limits an individual's physical or mental abilities to do basic work activities.

Drake v. Kijakazi · filed 2023-04-24(c)

At step-two of the sequential analysis, the ALJ determines whether a claimant has a medically severe impairment or combination of impairments. ... 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). ... Therefore, we find that any error regarding this Step 2 analysis was harmless and does not require a remand.

At step two, § 404.1520 requires the ALJ to determine whether the claimant has a severe medically determinable impairment, and directs a finding of not disabled if the claimant has none that meets the duration requirement.

Grisham v. Commissioner Social Security Administration · filed 2023-08-14(a)(4)(ii)

At step two, the ALJ determines whether the claimant has any medically determinable impairments that are “severe.” 20 C.F.R. § 404.1520(a)(4)(ii). A severe impairment is one that significantly impairs the claimant’s ability to perform basic work activities for at least 12 months. See 20 C.F.R. §§ 404.1509; 404.1520(a)(4)(ii). If the claimant “do[es] not have a severe medically determinable physical or mental impairment that meets the duration requirement in § 404.1509, or a combination of impairments that is severe and meets the duration requirement,” the claimant is “not disabled.” 20 C.F.R. § 404.1520(a)(4)(ii).

Section 404.1520 requires disability claims to be evaluated through a five-step sequence, with step two addressing whether the claimant has a severe impairment.

Canoe v. Social Security Administration · filed 2023-08-15(c)

Social security regulations implement a five-step sequential process to evaluate a disability claim. See 20 C.F.R. §§ 404.1520, 416.920.1 ... The Court finds that the Claimant has met his de minimus burden to show a severe impairment or combination of impairments at step two. ... Because Claimant has met his burden of showing he had a severe impairment at step two, the decision of the Commissioner is hereby reversed and the case remanded for further analysis.

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

Young v. Social Security Administration · filed 2023-09-25(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).

At step two, § 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.

(SS)Kaur v. Commissioner of Social Security · filed 2023-09-26(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. Id. at 146-47; see also 20 C.F.R. §§ 404.1520(c), 416.920(c). For an impairment to be “severe,” it must significantly limit the claimant’s physical or mental ability to do basic work activities, or the “abilities and aptitudes necessary to do most jobs.” 20 C.F.R. §§ 404.1520(c), 416.920(c).

Section 404.1520(a)(4)(ii) requires only one severe impairment to proceed beyond step two; failing to classify additional impairments as severe is harmless if their limiting effects are considered at later steps.

Watts v. Kijakazi · filed 2023-09-28(a)(4)(ii)

Since, again, an ALJ need find only one severe impairment to proceed past Step Two, any error in not classifying additional impairments as severe has no effect on the ultimate outcome of the decision, so long as the ALJ, based on substantial evidence, accounts for the “true” limiting effects of those impairments at the later steps of the sequential evaluation.

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

Thomason v. Social Security Administration · filed 2023-09-28(c)

Claimant bears the burden, at step two, of showing the existence of an impairment or combination of impairments which “significantly limits [her] physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1520(c), 416.920(c). ... Clearly, Claimant met this burden as the ALJ determined Claimant’s severe medically determinable impairments included both bipolar disorder and another personality disorder at step two.

Section 404.1520(c) places on the claimant the burden to show an impairment that significantly limits the ability to perform basic work activities; an ALJ's failure to consider a nonsevere impairment in the RFC determination is not harmless.

Taylor v. Social Security Administration · filed 2023-09-29(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). ... Any failure to find Claimant’s migraines or urinary tract infections to be severe at step two is only harmless if he considered both impairments in his RFC determination. ... On remand, the ALJ shall be explicit in his reasoning for finding medically determinable impairments as nonsevere as well as in his consideration of nonsevere impairments during his RFC determination.

Section 404.1520(a)(4)(ii) requires the ALJ to determine whether a claimant has a medically determinable impairment or combination of impairments severe enough to limit basic work activities for at least twelve months.

ROSELLI v. COMMISSIONER OF SOCIAL SECURITY · filed 2023-09-30(a)(4)(ii)

Step two of the analysis requires the ALJ to determine whether Plaintiff has a “medically determinable impairment” or a combination of impairments severe enough to limit the claimant’s ability to perform basic work activities for a continuous period of at least twelve months. 20 C.F.R. §§ 404.1520(a)(4)(ii), 404.1509.

At step two, § 404.1520 requires a claimant to show that a medically determinable impairment significantly limits the ability to perform basic work activities; omitting an impairment at that step is harmless only if its limitations are adequately addressed in the RFC.

Honaker v. Kijakazi · filed 2023-10-10(a)(4)(ii), (c)

At step two of the ALJ’s sequential disability evaluation, a claimant must make a threshold showing that her medically determinable impairments significantly limit her ability to perform basic work activities. ... Because the ALJ must consider all available evidence in assessing complaints of pain, the ALJ’s failure to acknowledge or discuss Plaintiff’s chronic pain syndrome was error. ... However, as stated above, any error at step two in identifying chronic pain syndrome as a medically determinable impairment is harmless if the ALJ adequately addressed Plaintiff’s limitations in the RFC.

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

Polini v. Commissioner of the Social Security Administration · filed 2023-10-16(c)

At step two of the sequential evaluation process, the ALJ must determine whether the claimant has a severe impairment that significantly limits his or her physical or mental ability to do basic work activities. See 20 C.F.R. §§ 404.1520(c), 416.920(c). ... The Court finds the ALJ’s step two analysis supported by substantial evidence.

Section 404.1520(c) requires an ALJ at step two to determine whether a claimant has a medically determinable impairment or combination of impairments that is severe, meaning it significantly limits basic work activities and is expected to last at least 12 months.

Crow v. Commissioner of Social Security Administration · filed 2023-10-25(c)

At step two, an ALJ must determine whether the claimant 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” and “is expected to last for a continuous period of at least 12 months.” 20 C.F.R. §§ 404.1520(c), 404.1509.

At step two, the ALJ determines whether an impairment significantly limits basic work activities and may not screen out a medically determinable impairment from consideration at later steps merely because it is non-severe.

BROOKS v. COMMISSIONER OF SOCIAL SECURITY · filed 2023-10-31(c)

At step two of the sequential evaluation, an ALJ determines whether the claimant has a “severe impairment” or combination of impairments that “significantly limits [the plaintiff’s] physical or mental ability to do basic work activities[.]” 20 C.F.R. § 404.1520(c). ... “However, an error [at step two] can harm the claimant if an impairment is improperly found to be not medically determinable or when non-severe impairments are not considered at later steps.” ... Moreover, the Court cannot conclude that ALJ Cerulli’s error in this regard is harmless because it permeated the remainder of his decision. ... Thus, the Court finds that the decision of the Acting Commissioner, which is based at least in part on a mischaracterization of the evidence of record, is not supported by substantial evidence.

Section 404.1520(c) defines a severe impairment at step two as an impairment or combination of impairments that significantly limits a claimant's physical or mental ability to do basic work activities.

Shead v. Commissioner of the Social Security Administration · filed 2023-10-31(c)

A severe impairment is defined by the regulations as “any impairment or combination of impairments which significantly limits your physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c). Plaintiff bears the burden of demonstrating that he has a severe impairment. See Bowen v. Yuckert, 482 U.S. 137, 146 n.5 (1987).

Section 404.1520 requires the ALJ to determine at Step Two whether the claimant has at least one severe impairment, and a claimant without a severe impairment is not disabled.

Mason v. Commissioner of Social Security · filed 2023-11-08(a)(4)(ii), (c)

At Step Two, the ALJ must determine whether the claimant has a medically determinable impairment or combination of impairments that is “severe.” 20 C.F.R. § 404.1520(a)(4). ... The claimant has the burden to show that she has at least one “severe impairment.” 20 C.F.R. § 404.1520(a)(4)(ii), (c). ... If the claimant doesn’t show she has at least one “severe” impairment, she’s categorically not disabled. 20 C.F.R. § 404.1520(c).

Section 404.1520 requires an ALJ to evaluate documented impairments at step two for severity and at step three for whether they meet or equal a listed impairment; failing to address them makes the disability decision unsupported by substantial evidence.

Bryson v. Kijakazi · filed 2023-11-15(c), (a)(4)(iii)

At step two, the ALJ considers whether a claimant’s impairments are “severe.” 20 C.F.R. §§ 404.1520(a)(4)(ii) & 416.920(a)(4)(ii). 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). ... At step three, the ALJ must consider the medical severity of the claimant’s impairment(s) and whether the impairment(s) “meets or equals one of the impairments in Appendix 1.” Torres v. Comm'r of Soc. Sec., 279 F. App’x 149, 151 (3d Cir. 2008) (citing 20 C.F.R. § 404.1520(a)(4)(iii)). ... Thus, in failing to address Mr. Bryson’s ailments and failing to address the cumulative effect of Mr. Bryson’s lumbar radiculopathy, neuropathy, and peroneal nerve injury throughout the five-step analysis, the ALJ’s decision is not supported by substantial evidence.

Section 404.1520(c) requires the ALJ at step two to find that a claimant is not disabled only when no impairment significantly limits the claimant's physical or mental ability to perform basic work activities.

Hughes v. Commissioner of Social Security · filed 2023-11-15(c)

At the second step, an ALJ determines whether a claimant has a “severe” impairment. 20 C.F.R. § 404.1520(a)(4)(ii). ... If an ALJ finds that the claimant is not disabled based on the above criteria, then the ALJ need not proceed to the remaining steps. 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.”); see also Young v. Sec'y of Health & Human Servs., 957 F.2d 386, 389 (7th Cir. 1992) (“A negative conclusion at any step (except for step three) precludes a finding of disability.”). ... The ALJ erred in his step-two analysis because there was enough evidence to suggest that Kirk H. satisfied the de minimis severe impairment requirement, warranting remand.

Section 404.1520(c) requires the Commissioner to determine at step two whether the claimant has a medically determinable impairment or combination of impairments that is severe, using a low threshold.

Burgess v. Commissioner Social Security Administration · filed 2023-12-15(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). The step two threshold is low; it 1s “de minimus screening device to dispose of groundless claims.”

At step two, § 404.1520 treats an impairment as severe when it significantly limits basic work activities and denies benefits when no severe impairment meets the duration requirement.

Paige v. Social Security Administration · filed 2024-01-03(a)(4)(ii), (c)

At Step Two, the ALJ makes a determination of whether the claimant has an impairment or combination of impairments which is “severe” and meets the duration requirement. 20 C.F.R. §§ 404.1520(a)(4)(ii); 416.920(a)(4)(ii). If not, benefits are denied. Id. A “severe” impairment significantly limits a claimant’s ability to perform basic work activities. 20 C.F.R. §§ 404.1520(c); 416.920(c). The claimant has the burden of proving that an impairment is severe. Gonzales v. Barnhart, 465 F.3d 890, 894 (8th Cir. 2006). In this case, Paige’s symptoms were not interfering with ability to function, medical visits were infrequent, and treatment improved Paige’s conditions. She had multiple occasions of telling her doctors she had no complaints. Paige said she could prepare meals, shop in stores, and socialize. (Tr. at 265-269). She did not seek medical care for her alleged conditions after August 2019. The consultative examiner found no significant functional limitations. The record simply does not suggest that her impairments were 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 do basic work activities.

(SS) Hedrick v. Commissioner of Social Security · filed 2024-01-04(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).

Section 404.1520(a)(4)(ii) requires an ALJ at step two to determine whether a claimant has a medically severe impairment or combination of impairments using a de minimis test intended to weed out patently groundless claims and the most minor impairments.

Noel v. Kijakazi · filed 2024-01-10(a)(4)(ii)

Step two of the SSA’s evaluation process requires the ALJ to determine if the claimant has a medically severe impairment or combination of impairments. 20 C.F.R. § 404.1520(a)(4)(ii). This evaluation is a de minimis test intended to weed out patently groundless claims and the most minor of impairments.

At step two, § 404.1520(c) treats an impairment as severe only when it significantly limits basic work activities and is expected to last for at least 12 continuous months.

Gisler v. Commissioner of Social Security Administration · filed 2024-01-19(c)

At step two, an ALJ must determine whether the claimant 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” and “is expected to last for a continuous period of at least 12 months.” 20 C.F.R. §§ 404.1520(c), 404.1509. ... The Court agrees with Gisler regarding the appropriate standard for determining severity of an impairment at step two. Smolen, 80 F.3d at 1290. However, the Court is not persuaded that the ALJ erred.

Section 404.1520 treats step two as a threshold inquiry requiring a severe impairment, or combination of impairments, that meets the twelve-month duration requirement and significantly limits the claimant’s ability to perform basic work activities.

Anderson v. Commissioner of the Social Security Administration · filed 2024-01-23(a)(4)(ii), (c)

Step Two is a threshold determination of whether a claimant has a severe impairment (or combination of impairments) that meets the twelve-month duration requirement and significantly limits the claimant’s ability to do basic work activities. 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).

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

Muncy v. Commissioner of Social Security · filed 2024-02-09(c)

The regulations define a severe impairment as one that significantly limits the ability to perform basic work activities.

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

Richardson v. SSA · filed 2024-02-09(c)

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

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.

Gomez v. Social Security Administration, Commissioner of · filed 2024-03-04(c)

At step two in the sequential process, a claimant is required to show that they suffer from a “severe impairment” in order to be found disabled. Heston v. Comm’r of Soc. Sec., 245 F.3d 528, 534 (6th Cir. 2001). A “severe impairment” is one that “significantly limits your physical or mental ability to do basic work activities[.]” 20 C.F.R. § 404.1520(c). Once an ALJ finds that a claimant has one severe impairment, they must consider both severe and non-severe impairments at the remaining steps. Pompa v. Comm’r of Soc. Sec., 73 F. App’x 801, 803 (6th Cir. 2003).

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

Herrero v. Commissioner of Social Security · filed 2024-03-20(a)(4)(ii)

Step two of the sequential evaluation process requires the ALJ to determine whether a claimant suffers from a severe impairment. See 20 C.F.R. § 404.1520(a)(4)(ii). ... In making the step two findings, the ALJ did not recognize Plaintiff’s sleep apnea or address it in any way. See Tr. at 839. ... The matter must be reversed and remanded for consideration of Plaintiff's alleged impairment of sleep apnea.

At step two, Section 404.1520(c) requires determining whether the claimant has a medically severe impairment or combination of impairments; the court held that the ALJ improperly found the claimant's carpal tunnel syndrome was not severe.

Nguyen v. Colvin · filed 2024-03-25(c)

If she is not, the decision maker proceeds to step two, which determines whether the claimant has a medically severe impairment or combination of impairments. If the claimant does not have a severe impairment or combination of impairments, the disability claim is denied. 20 C.F.R. §§ 404.1520(c), 416.920(c). ... The Court finds the ALJ’s determination that Plaintiff’s CTS is not severe is not supported by the evidence of record. See Smolen v. Chater, 80 F.3d 1273, 1290 (9th Cir. 1996) (Explaining “[a]n impairment or combination of impairments can be found ‘not severe’ only if the evidence establishes a slight abnormality that has no more than a minimal effect on an individuals [sic] ability to work.”).

Section 404.1520 requires an ALJ at step two to determine whether an alleged impairment or combination is severe, meaning it has more than a minimal effect on the claimant’s ability to perform basic work activities.

Stover v. Commissioner, Social Security Administration · filed 2024-03-25(a)(4)(ii), (c)

At step two, an ALJ determines whether the claimant’s alleged impairment or combination of impairments is “severe.” 20 C.F.R. § 404.1520(a)(4)(ii), (c). “To find a ‘severe’ impairment at step two requires only a threshold showing that the claimant’s impairment has ‘more than a minimal effect on [her] ability to do basic work activities.’” Covington v. Colvin, 678 F. App’x 660, 664 (10th Cir. 2017) (quoting Williams v. Bowen, 844 F.2d 748, 751 (10th Cir. 1988)). ... The Court finds no reversible error in the ALJ’s determination that these impairments did not impose more than a minimal effect on Plaintiff’s ability to perform basic work activities, or did not do so for the required duration of at least 12 continuous months. Id.

Section 404.1520(c) requires an ALJ at step two to determine whether an impairment significantly limits basic work abilities, with only minimal effects treated as non-severe.

Regan v. Commissioner of Social Security · filed 2024-03-25(c)

In the second step of the five-step analysis, the ALJ must determine whether a claimant has a severe impairment or a combination of impairments. An impairment is considered “severe” if it significantly limits an individual’s physical or mental abilities to do basic work activities and persists for at least twelve months. ... An impairment is considered “not severe” if it only has a minimal effect on an individual’s ability to perform basic work functions. ... The ALJ erred in her determination that Plaintiff’s carpal tunnel syndrome was non-severe because the ALJ’s opinion did not consider the additional evidence offered by Plaintiff’s treating physician.

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.

Diggs v. Social Security Administration, Commissioner of · filed 2024-05-20(c)

At step two in the sequential process, a claimant is required to show that they suffer from a “severe impairment” in order to be found disabled. Heston v. Comm’r of Soc. Sec., 245 F.3d 528, 534 (6th Cir. 2001). A “severe impairment” is one that “significantly limits your physical or mental ability to do basic work activities[.]” 20 C.F.R. § 404.1520(c). Once an ALJ finds that a claimant has one severe impairment, they must consider both severe and non-severe impairments at the remaining steps.

Section 404.1520 requires the ALJ to determine at step two whether the claimant has a severe medically determinable impairment; without one, the claimant is found not disabled.

DeWitt v. Commissioner of Social Security · filed 2024-05-30(a)(4)(ii)

At step two of the disability determination process, the ALJ will determine whether a claimant has a severe medically determinable impairment. 20 C.F.R. § 404.1520(a)(4)(ii). If the claimant does not have a severe medically determinable impairment, they will be found not disabled. Id.

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

Delgado v. Commissioner of Social Security · filed 2024-06-03(c)

At step two of the sequential evaluation process, the ALJ must determine whether the claimant has a severe impairment that significantly limits his or her physical or mental ability to do basic work activities. See 20 C.F.R. §§ 404.1520(c), 416.920(c).

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

Phillips v. Commissioner of Social Security · filed 2024-06-03(c)

At step two, “[a]n impairment is ‘severe’ if it ‘significantly limits [the claimant’s] physical or mental ability to do basic work activities.’”

At step two, § 404.1520(c) requires the ALJ to determine whether an impairment is severe because it significantly limits a claimant’s ability to perform basic work activities.

Weiman v. Kijakazi · filed 2024-06-12(c)

At step two of the sequential evaluation, the ALJ determines which of Plaintiff’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.” Id. An ALJ must consider all the evidence at step two to determine whether a medically determinable impairment significantly limits the claimant’s ability to perform basic work activities. Id. § 404.1520(a); Bowen v. Yuckert, 482 U.S. 137, 153 (1987).

At step two, the Commissioner must determine whether a claimant’s medically determinable impairments are severe by asking whether they significantly limit the claimant’s ability to perform basic work activities.

Smith v. Commissioner of Social Security · filed 2024-06-17(c)

At step two of the sequential evaluation process, the ALJ identifies the claimant’s medically determinable impairments and then determines whether those impairments are “severe,” i.e. whether they 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).

Section 404.1520 requires a claimant to have a severe impairment that meets the duration requirement at Step Two, and defines a severe impairment as one that significantly limits basic work activities.

Williams v. Social Security Administration · filed 2024-06-25(a)(4)(ii), (c)

Step Two involves a determination of whether the claimant has an impairment or combination of impairments which is “severe” and meets the duration requirement. 20 C.F.R. §§ 404.1520(a)(4)(ii); 416.920(a)(4)(ii). If not, benefits are denied. Id. A “severe” impairment significantly limits a claimant’s ability to perform basic work activities. 20 C.F.R. §§ 404.1520(c); 416.920(c). ... The ALJ was not required to discuss every shred of evidence or every diagnosis in the record. When he labeled anxiety a severe impairment at Step Two, and when he crafted an RFC for simple work based thereon, he covered limitations from Ms. Williams’s mental illness. ... Additionally, the ALJ discussed the cardiac issues as outline above. (Tr. at 23-25). With grossly normal cardiac exams, and conservative treatment for cardiac issues, the ALJ was right to discount this as a severe impairment.

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

Baldazo v. Kijakazi · filed 2024-06-26(a)(4)(ii), (c)

“Step two inquires whether the claimant had severe impairments during the period for which he seeks disability benefits. 20 C.F.R. § 404.1520(a)(4)(ii). An impairment is severe if it ‘significantly limits’ an individual’s ‘ability to do basic work activities.’ 20 C.F.R. § 404.1520(c).”

Section 404.1520(c) defines a severe impairment as one that significantly limits basic work abilities, but in the Fifth Circuit the applicable threshold is an impairment with more than a slight effect that would be expected to interfere with the claimant’s ability to work.

Ojeda v. O'Malley, Commissioner of the Social Security Administration · filed 2024-07-31(c)

To evaluate whether a claimant’s medical condition qualifies as a “severe impairment” at Step Two, the Commissioner has issued regulations that defined a “severe impairment” as one that “significantly limits [a claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c). As Ojeda correctly notes in her brief, the Fifth Circuit has held that a literal application of that definition is inconsistent with the statutory language and legislative history of the SSA. See Stone, 752 F.2d at 1104-05. As a result, under Fifth Circuit precedent, a claimant’s impairment is severe when it is more than 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.” fd. at 1101.

Section 404.1520(c) makes the step-two severe-impairment determination a threshold inquiry, and the disability inquiry ends when no impairment is severe; the court treated the threshold as requiring only minimal limitations to be shown.

Roberts v. Commissioner of Social Security Administration · filed 2024-08-06(c)

At step two, the ALJ determines whether the claimant has a severe medically determinable physical or mental impairment. ... If none of the plaintiff’s impairments are severe, then she is not disabled. 20 C.F.R. 404.1520(c). ... The severity determination at step two is a “threshold showing.” ... As such, the step two determination is de minimis in nature, and “properly denying a claim at step two requires an unambiguous record showing only minimal limitations.” ... Thus, the ALJ erred in finding that Plaintiff’s medically determinable mental impairments were not severe. See (Doc. 14-3 at 23–25).

Section 404.1520 requires the Commissioner to determine at step two whether a claimant has a severe impairment or combination of impairments that has lasted or is expected to last at least twelve months.

Coons v. O'Malley · filed 2024-08-07(a)(4)(ii)

At Step Two, the ALJ must determine whether the claimant has “a severe medically determinable physical or mental impairment,” or “a combination of impairments that is severe,” that lasted or is expected to last for at least twelve months. See 20 C.F.R. §§ 404.1509, 416.909; 404.1520(a)(4)(ii); 416.920(a)(4)(ii).

Section 404.1520(c) treats an impairment as severe when it significantly limits the claimant's physical or mental ability to perform basic work activities, making step two a de minimis screening threshold.

Rohleder · filed 2024-08-20(c)

A severe impairment is “any impairment or combination of impairments which significantly limits your physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c). ... Courts construe “step two as a de minimis hurdle, intended to screen out totally groundless claims.” Kestel v. Comm’r of Soc. Sec., 756 F. App’x. 593, 597 (6th Cir. 2018) (cleaned up). ... Plaintiff met his minimal burden of showing that he had a severe bilateral knee impairment.

At step two, a claimant must show a medically determinable severe impairment or combination of impairments that meets the duration requirement, and severity requires a significant limitation in basic work activities.

Butler Li v. Kijakazi · filed 2024-08-22(a)(4)(ii)

At step two, the claimant has the burden to establish a medically determinable impairment “or a combination of impairments that is severe and meets the duration requirement.” 20 C.F.R. § 404.1520(a)(4)(ii); see also Maxwell, 971 F.3d at 1130 n.2. ... In addition, for an impairment to be severe, it must “significantly limit[] [the claimant’s] physical or mental ability to do basic work activities.” Id. § 404.1520(a). ... Substantial evidence supports the ALJ’s step-two determination here. ... Hence, the Court concludes the ALJ did not err in determining Plaintiff lacks a severe impairment at step two.

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, but that threshold is only a de minimis screen and does not itself establish work-related restrictions.

Salik v. Commissioner of Social Security · filed 2024-09-20(c)

As the plaintiff says, a severe impairment is defined as one “which significantly limits your physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c); see also Sevec v. Kijakazi, 59 F.4th 293, 298 (7th Cir. 2023). That’s not much; indeed, the Seventh Circuit maintains that the determination of whether one has a severe impairment is “a de minimis screening for groundless claims.” Meuser v. Colvin, 838 F.3d 905, 910 (7th Cir. 2016); O’Connor–Spinner v. Colvin, 832 F.3d 690, 697 (7th Cir. Aug. 9, 2016). So, one should perhaps not build too much on the foundation that an impairment was found to be severe.

At step two, § 404.1520(a)(4)(ii) permits the sequential evaluation to continue when at least one impairment is severe, but the ALJ must consider even non-severe impairments in the later residual-functional-capacity analysis.

Tyo v. Commissioner of Social Security · filed 2024-09-30(a)(4)(ii)

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

At step two, § 404.1520(c) asks whether an impairment or combination of impairments significantly limits a claimant’s ability to do basic work activities; if not, the disability inquiry ends.

GEORGE v. COMMISSIONER OF SOCIAL SECURITY · filed 2024-10-18(c)

To reiterate, at step two, the ALJ decides whether the plaintiff has a “severe impairment” or combination of impairments that “significantly limits [the plaintiff’s] physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c). If the plaintiff does not have a severe impairment or combination of impairments, then the inquiry ends because the plaintiff is not disabled. ... This argument is without merit. ... Therefore, having found that at least one of Plaintiff’s impairments was severe at step two, the ALJ allowed Plaintiff’s claim to proceed in the sequential analysis, and any error that other conditions were not severe is harmless.

Section 404.1520(c) requires an ALJ to determine whether an alleged impairment is medically determinable and severe, with an impairment considered severe when it significantly limits the claimant’s ability to perform basic work activities.

Row v. Commissioner of the Social Security Administration · filed 2024-10-28(c)

At step two, an ALJ first must decide whether an alleged impairment is an impairment at all. If not, there is no error in failing thereafter to mention or analyze the alleged impairment further. ... Next, the ALJ “must consider the medical severity of [the claimant’s] impairments.” 20 C.F.R. § 404.1520(a)(4)(ii), (c). To comply with this regulation, the ALJ “must determine whether any identified impairments are ‘severe’ or ‘not severe.’” ... A prerequisite to this consideration is deciding whether claimants have a “medically determinable physical or mental impairment,” because claimants are deemed not disabled if they cannot prove that an impairment is medically determinable. Id. § 404.1520(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.

Olsen v. O'Malley · filed 2024-10-25(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. §§ 416.920(c), 404.1520(c).

Section 404.1520(a)(4)(ii) requires an ALJ at Step Two to determine whether the claimant has a severe impairment that significantly limits the ability to perform basic work activities.

Kabroo v. Commissioner of Social Security · filed 2024-11-12(a)(4)(ii)

At Step Two of the five-step sequential-evaluation process by which ALJs evaluate disability claims, it is the claimant’s burden to prove his impairments are severe. Castile v. Astrue, 617 F.3d 923, 926 (7th Cir. 2010); 20 C.F.R. §§ 404.1512, 404.1520(a)(4)(ii), 404.1521. An impairment is severe if, for twelve months, it significantly limits one’s ability to perform basic work-related activities like walking and understanding simple instructions. 20 C.F.R. §§ 404.1520(a)(4)(ii), 404.1522; Social Security Ruling (“SSR”) 85-28. ... Plaintiff has failed to establish the ALJ ignored evidence that compelled a finding that his impairments significantly limited his ability to perform basic work activity. The Court cannot remand on this basis.

Section 404.1520(c) uses a step-two severe-impairment screen, but in this circuit an impairment is severe unless it is only a slight abnormality with a minimal effect that would not interfere with work.

Normand v. Social Security Administration · filed 2024-11-15(c)

To evaluate whether a claimant’s medical condition qualifies as a “severe impairment” at Step Two of the analysis, the Commissioner has issued regulations that define a “severe impairment” as 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), 404.1521 (“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.”). The Fifth Circuit has held that a literal application of that definition is inconsistent with the statutory language and legislative history of the Social Security Act. Stone v. Heckler, 752 F.2d 1099, 1104–05 (5th Cir. 1985). Therefore, in Stone v. Heckler, the Fifth Circuit established the following standard for determining whether a claimant’s impairment is severe: an impairment is not severe only when 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.” Id. at 1101.

Section 404.1520(a)(4)(ii) requires the ALJ to assess the severity of the claimant’s impairment and determine whether a severe medically determinable impairment or combination meets the agency’s duration requirements.

Figueroa v. Commissioner of Social Security · filed 2024-11-22(a)(4)(ii)

At Step Two, the ALJ considers the medical severity of a claimant’s impairment and whether there is a severe medically determinable physical or mental impairment – or combination of impairments – that meets Agency duration requirements. 20 C.F.R. § 404.1520(a)(4)(ii).

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

NIETO v. COMMISSIONER OF SOCIAL SECURITY · filed 2024-11-26(c)

Step Two is a threshold analysis which determines whether the ALJ should continue to evaluate Plaintiffs claims for disability. ... According to the Commissioner's regulations, “an impairment is not severe if it does not significantly limit [the claimant's] physical ability to do basic work activities.” Newell, 347 F.3d at 546 (citations omitted); 20 C.F.R. §§ 404.1520(c), 404.1521{a). ... The Court finds the ALJ did not err at Step Two, Although Plaintiff postulates that the MDIs categorized as non-severe could cause limitations, he offers no evidence from the record that Plaintiffs obesity in combination with his other non-severe physical impairments actually limited his ability to do work activities during the period in question.

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

Bichler v. Colvin · filed 2024-12-12(c)

At step two of the sequential process, the ALJ determines whether the claimant suffers from a “severe” impairment, i.e., one that significantly limits her physical or mental ability to do basic work activities. ... 20 C.F.R. § 404.1520(c). ... This is error because a limitation need not be “work preclusive” to be severe for purposes of a step-two evaluation.

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

Skyla L. v. Colvin · filed 2024-12-18(c)

The ALJ must follow five steps in evaluating a claim of disability. See 20 C.F.R. §§ 404.1520, 416.920. ... 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). ... First, the Court agrees that the ALJ erred at Step 2 by not finding that Plaintiff’s documented history of migraine headaches was a severe impairment. ... These errors are not harmless as suggested by the Commissioner and result in a failure to properly evaluate Plaintiff’s migraine headaches. The interests of justice require a remand to determine if Plaintiff’s migraine headaches are a “severe” impairment and to assess an RFC that accurately accounts for any functional limitations related to such impairment.

At step two, § 404.1520(c) requires an ALJ to determine whether a claimant has a severe impairment that significantly limits basic work activities; an omitted impairment is harmless if its effects are considered later.

Cruz v. Commissioner of Social Security · filed 2025-01-03(c)

At step two, the ALJ must determine whether the claimant has a severe impairment that significantly limits the claimant’s physical or mental ability to do basic work activities. See C.F.R. § 404.1520(c). ... Finally, because the ALJ proceeded past step two and considered all the plaintiff’s impairments in the remainder of the sequential analysis, any error in finding that the plaintiff’s manipulative limitations were not the result of a separate severe impairment was harmless. ... Therefore, the ALJ considered all impairments, whether severe or not, in the remaining steps. Accordingly, the ALJ’s failure to identify peripheral neuropathy or chronic pain as severe impairments was harmless.

At step two of the disability analysis, a claimant must show a severe impairment or combination of impairments that significantly limits the physical or mental ability to perform basic work activities.

Marshall v. Colvin · filed 2025-01-06(c)

Under step two of the five-step disability analysis framework, a claimant must demonstrate a severe impairment or combination of impairments which “significantly limit[] [the claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c).

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

Boulter v. Colvin · filed 2024-12-17(c)

At step two of the sequential evaluation process, the ALJ must determine whether the plaintiff has a severe impairment that significantly limits his or her physical or mental ability to do basic work activities. See 20 C.F.R. §§ 404.1520(c); 416.920(c). ... In the face of mild limitations and improvements, an absence of mental health treatment and adequate medication management, and plaintiffs working during the Title Il period, substantial evidence supports the ALJ’s non-severe finding at step two, as wel as the ALJ's discounting of the more severe aspects of plaintiff’s symptom testimony.

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

Grasser v. Commissioner of Social Security · filed 2025-01-07(c)

At step two, claimants must make a threshold showing that their medically determinable impairments significantly limit their ability to perform basic work activities. See Bowen v. Yuckert, 482 U.S. 137, 145 (1987); 20 C.F.R. §§ 404.1520(c), 416.920(c).

Section 404.1520(c) treats an impairment as not severe only when it does not significantly limit the claimant’s ability to perform basic work activities.

Winchester v. O'Malley · filed 2025-01-13(c)

According to the Commissioner’s regulations, “an impairment is not severe if it does not significantly limit [the claimant’s] physical ability to do basic work activities,” 20 C.F.R. §§ 404.1520(c), 404.1521(a) (2024). ... “Finally, as the Supreme Court has recognized, the Step-Two inquiry is a ‘de minimis’ screening device meant to dispose of groundless claims.” ... “An impairment or combination of impairments can be found ‘not severe’ only if the evidence establishes a slight abnormality that has ‘no more than a minimal effect on an individuals ability to work.’”

Section 404.1520(a)(4)(ii) requires the Commissioner to determine at step two whether the claimant has a severe impairment, with step two serving as a de minimis screening hurdle.

Sanchez v. Commissioner of Social Security · filed 2025-01-15(a)(4)(ii)

At Step Two, the ALJ must determine whether the claimant has a severe impairment. 20 C.F.R. § 404.1520(a)(4)(ii). Step Two represents “a de minimis hurdle” in the sequential analysis. Higgs v. Bowen, 880 F.2d 860, 862 (6th Cir. 1988) (italics in original).

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

St. Francis v. Commissioner of Social Security · filed 2025-01-22(c)

It is the claimant’s burden to show at step two that he has a “severe impairment,” meaning an impairment that “significantly limits [his] physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1520(c), 416.920(c); Meadors v. Astrue, 370 F. App’x 179, 182 (2d Cir. 2010); see Bowen v. Yuckert, 482 U.S. 137, 146 n.5 (1987) (“It is not unreasonable to require the claimant, who is in a better position to provide information about his own medical condition, to do so.”). ... Accordingly, Plaintiff has not met his burden of showing that “no reasonable factfinder could have reached the same conclusion as the ALJ” with respect to the severity of Plaintiff’s cervical radiculopathy.

Section 404.1520(c) treats an impairment as non-severe when it has no more than a minimal effect on a claimant’s ability to perform basic work activities.

Kimberly S. v. Colvin · filed 2025-01-24(c)

An impairment is not “severe” when it does not significantly limit a claimant’s physical or mental ability to do basic work activities. 20 C.F.R. § 404.1520(c). ... While reasonable minds may differ as to whether or not Plaintiff’s migraines are disabling, there is no reasonable way to read this record in its entirety and find at Step 2 that they have no more than a minimal effect on Plaintiff’s ability to perform basic work activities.2 Based on this Step 2 error and the inordinate period of time that this case was under review, the interests of justice warrant a second look at this DIB application.

At step two, a claimant is not disabled if the claimant lacks a severe impairment that has lasted or is expected to last continuously for at least 12 months.

Jenkins v. Commissioner of Social Security · filed 2025-01-28(a)(4)(ii)

Title 20 C.F.R. § 404.1520(a)(4)(ii) states that if a disability claimant “do[es] not have a severe medically determinable physical or mental impairment that meets the duration requirement in § 404.1509, or a combination of impairments that is severe and meets the duration requirement, [the Commissioner] will find that [the claimant is] not disabled.” Section 404.1509 provides the duration requirement: “Unless your impairment is expected to result in death, it must have lasted or must be expected to last for a continuous period of at least 12 months.” ... But the medical records indicate Suresh J.’s peptic ulcer disease did not first appear in March 2022. ... Thus, the medical records show Suresh J. suffered from issues relating to stomach ulcers for almost three years. Substantial evidence does not support the ALJ’s conclusion to the contrary.

Section 404.1520(c) requires the ALJ at step two to determine whether a medically determinable impairment significantly limits a claimant’s ability to perform basic work activities.

Stueckle v. Dudek · filed 2025-02-26(c)

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

At step two, § 404.1520 requires determining whether the claimant has a severe impairment or combination of impairments that meets the duration requirement, and a severe impairment significantly limits basic work activities.

Ritter v. Social Security Administration · filed 2025-02-10(a)(4)(ii), (c)

Step two involves a determination of whether the claimant has an impairment or combination of impairments which is “severe” and meets the duration requirement. 20 C.F.R. §§ 404.1520(a)(4)(ii); 416.920(a)(4)(ii). A “severe” impairment significantly limits a claimant’s ability to perform basic work activities; the claimant has the burden of proving that an impairment is severe. ... I find no error at step two.

At step two of the sequential evaluation, the Commissioner considers whether the claimant has a severe medically determinable impairment meeting the duration requirement, and otherwise finds the claimant not disabled.

Irizarry v. Commissioner of Social Security · filed 2025-03-06(a)(4)(ii)

At the second step, we consider the medical severity of your impairment(s). If you do not have a severe medically determinable physical or mental impairment that meets the duration requirement in § 404.1509, or a combination of impairments that is severe and meets the duration requirement, we will find that you are not disabled.

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.

LeFebvre v. Dudek · filed 2025-03-10(c)

A severe impairment is an impairment that significantly limits the plaintiff's physical and/or mental ability to do basic work activities. See 20 C.F.R. § 404.1520(c); see also 20 C.F.R. § 404.1521(a) (noting that an impairment is not severe at step two if it does not significantly limit a claimant's ability to do basic work activities).

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

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

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). ... Accordingly, Plaintiff cannot establish that migraines were a severe impairment or even a non-severe impairment that must be considered in combination with severe impairments so as to establish disability as of her date last insured, March 31, 2014, based on migraines.

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.

Martin v. Commissioner of Social Security · filed 2025-03-13(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); Social Security Ruling 16-3p, 2017 WL 5180304, at *11 (Oct. 25, 2017); Higgs v. Bowen, 880 F.2d 860, 863 (6th Cir. 1988) (per curiam). ... In sum, because in all four functional areas Plaintiff has no more than a mild limitation and the medical evidence does not support more than a minimal limitation on Plaintiff’s basic activities, the ALJ concluded that Plaintiff’s depression and post-traumatic stress disorder are nonsevere (Tr. 70). Because the ALJ’s analysis comported with applicable law and is supported by substantial evidence, Plaintiff is not entitled to relief on this challenge.

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

Reeves v. Commissioner of Social Security · filed 2025-03-14(a)(4)(ii)

At step two, the ALJ must determine whether the claimant has a medically severe impairment or combination of impairments. 20 CFR § 404.1520(a)(4)(ii).

At step two, the regulation requires only one severe impairment for the disability evaluation to continue to step three.

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

But as Defendant points out, step two requires only a finding that any impairment is severe in order to continue to step three. ... Here, the ALJ found that several of Plaintiff’s conditions are severe—including his headaches and his shoulder and knee injuries—so the Court finds no reversible error at step two.

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

Teutsch v. Commissioner of Social Security · filed 2025-03-21(c)

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

At step two, § 404.1520(a)(4)(ii) directs the ALJ to determine whether a claimant has a medically determinable impairment or combination of impairments that is severe and significantly limits basic work activities.

Hennemann v. Kijakazi · filed 2025-03-24(a)(4)(ii)

At Step 2, the ALJ determines whether the claimant has a medically determinable impairment or combination of impairments that is “severe” and significantly limits an individual’s ability to perform basic work activities. See 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii). ... As a result, the ALJ did not err in evaluating Hennemann’s mental impairments.

At step two, § 404.1520(a)(4)(ii) requires the ALJ to determine whether a claimant suffers from a severe impairment.

Cutchineal v. Commissioner of Social Security · filed 2025-03-26(a)(4)(ii)

Step two of the sequential evaluation process requires the ALJ to determine whether a claimant suffers from a severe impairment. See 20 C.F.R. § 404.1520(a)(4)(ii). At this step, “[a]n impairment can be considered as not severe only if it is a slight abnormality which has such a minimal effect on the individual that it would not be expected to interfere with the individual’s ability to work[.]” Brady v. Heckler, 724 F.2d 914, 920 (11th Cir. 1984).

Section 404.1520(a)(4)(ii) makes step two a threshold inquiry; an alleged failure to classify additional impairments as severe is harmless when the ALJ finds other severe impairments and considers the non-severe impairments at later steps.

Byars v. Kijakazi · filed 2025-03-31(a)(4)(ii)

Second, a finding must be made that the claimant suffers from a severe impairment. 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(5)(ii). ... “An erroneous finding of nonseverity at step two is therefore harmless where the ALJ properly considers nonsevere impairments at later steps.” ... Because ALJ Heath considered these non-severe impairments at a later step, the court finds that Plaintiff’s argument is legally irrelevant. Emard, 953 F.3d at 844.

At step two, § 404.1520(a)(4)(ii) asks whether a claimant has a severe impairment; if one is found, the evaluation continues, and an earlier step-two error is immaterial when all impairments are considered later.

Ryan v. Social Security Administration · filed 2025-04-16(a)(4)(ii)

Further, the question at step two of the sequential evaluation is only whether a claimant has any impairment or combination of impairments that is severe, that is, an impairment that significantly limits her ability to perform basic work activities. 20 C.F.R. §§ 404.1520(a)(4)(ii), 404.1522. If a claimant has any severe impairment, the ALJ continues with the sequential evaluation and, between steps three and four, assesses a claimant’s workplace limitations considering all impairments, severe and non-severe. 20 C.F.R. § 404.1545(a)(2). So long as the ALJ finds some severe impairment at step two and then continues to consider all impairments at subsequent steps, earlier errors at step two are immaterial and do not justify remand.

Section 404.1520(c) requires the ALJ at step two to determine whether a medically determinable impairment is severe or whether a combination of impairments significantly limits the claimant’s ability to perform basic work activities.

Percy v. Dudek · filed 2025-05-01(c)

Step two addresses whether the claimant has a medically determinable impairment that is severe or a combination of impairments that significantly limits her ability to perform basic work activities. ... Any error in the ALJ’s finding at step two is harmless if all impairments, both severe and non-severe, are considered when determining the plaintiff’s RFC.

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.

Wilcox v. Commissioner of Social Security · filed 2025-05-21(c)

A severe impairment significantly limits the plaintiff’s physical and/or mental ability to do basic work activities. See 20 C.F.R. §§ 404.1520(c), 416.920(c); see also 20 C.F.R. §§ 404.1521(a), 416.921(a) (stating an impairment is not severe at step two if it does not significantly limit a claimant’s ability to do basic work activities). ... Accordingly, the ALJ’s analysis at step two provides sufficient explanation indicating adequate consideration of the evidence related to Plaintiff’s severe and non-severe impairments. (T. 14-15.) Therefore, for the reasons above, the ALJ’s findings regarding Plaintiff’s impairments at step two are supported by substantial evidence and do not suggest a basis for remand.

Section 404.1520 requires the ALJ to use a five-step sequential evaluation and allows the evaluation to end at step two when the claimant has not established a severe impairment.

Loveland v. Commissioner of Social Security · filed 2025-06-06(c)

“At step two of the five-step sequential evaluation, the ALJ determines if the claimant has an impairment, or a combination of impairments, that is severe and meets the duration requirement.” ... (citing 20 C.F.R. § 404.1520(a)(4)(ii)). ... The claimant bears the burden of proving that an impairment is severe. ... Thus, the ALJ properly halted at step two, having found no medically determinable impairment prior to Plaintiff’s DLI.

Section 404.1520(c) requires a claimant to have a severe impairment or combination of impairments that significantly limits basic work activities; without one, the claimant is not disabled.

Lugo v. Commissioner of Social Security · filed 2025-06-12(c)

According to the regulations, if the ALJ finds no severe impairment or combination of impairments, then a plaintiff is not disabled under the regulations. See 20 C.F.R. § 1520(c) (“You must have a severe impairment. 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(c) requires the Commissioner to determine whether a claimant has a severe impairment that significantly limits the claimant’s physical or mental ability to perform basic work activities.

Pondi v. O'Malley · filed 2025-03-27(c)

At step two of the sequential evaluation process, the ALJ must determine whether the claimant has a severe impairment that significantly limits his or her physical or mental ability to do basic work activities. See 20 C.F.R. §§ 404.1520(c), 416.920(c).

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

Scielzi v. Commissioner of Social Security · filed 2025-06-27(c)

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

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

Espinal v. Commissioner of Social Security · filed 2025-06-30(c)

At step two of the sequential evaluation process, the ALJ must determine whether the claimant has a severe impairment that significantly limits his or her physical or mental ability to do basic work activities. See 20 C.F.R. §§ 404.1520(c), 416.920(c).

Section 404.1520(a)(4)(ii) makes step two a threshold inquiry into whether a claimant has a severe medically determinable impairment; when the claim proceeds beyond step two, an error at that step is harmless.

Melhus v. Commissioner Social Security Administration · filed 2025-07-02(a)(4)(ii)

The ALJ determines if a claimant has “a medically determinable physical or mental impairment” at step two of the disability evaluation. Tackett v. Apfel, 180 F.3d 1094, 1098-99 (9th Cir. 1999); 20 C.F.R. § 404.1520(a)(4)(ii). At step two, a claimant is not disabled if the claimant does not have any medically severe impairments. Stout v. Comm’r, Soc. Sec. Admin., 454 F.3d 1050, 1052 (9th Cir. 2006); 20 C.F.R. § 404.1520(a)(4)(ii). ... Because step two was resolved in plaintiff’s favor, and the ALJ continued with the sequential analysis, any error at step two was harmless. ... The ALJ did not err by finding Plaintiff’s mental health impairments non-severe at step two.

Section 404.1520 uses a five-step disability evaluation, and at step two an error in classifying an impairment as non-severe is harmless when at least one severe impairment is found and all impairments are considered at later steps.

Febo v. O'Malley · filed 2025-07-18(a)(4)(ii), (c)

The primary purpose of Step two is to determine if the claimant has at least one severe impairment, and if not, to end the evaluation process. 20 C.F.R § 404.1520(a)(4)(ii), (c). Therefore, as long as one severe impairment is identified at Step two, and any non-severe impairments are considered at later steps, any error in failing to find those impairments severe is harmless.

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

Anes v. Commissioner of Social Security · filed 2025-07-18(c)

At step two of the sequential evaluation process, the ALJ must determine whether the claimant has a severe impairment that significantly limits his or her physical or mental ability to do basic work activities. See 20 C.F.R. §§ 404.1520(c), 416.920(c).

Section 404.1520(a)(4)(ii) requires the Step Two evaluation to determine whether a claimant has a medically determinable impairment or combination of impairments that substantially limits the ability to perform basic work activities.

Johnson v. Commissioner of Social Security · filed 2025-07-24(a)(4)(ii)

The central question at Step Two is whether the claimant has a medically determinable impairment or combination of impairments that substantially limits [their] ability to perform basic work activities. 20 C.F.R. § 404.1520(a)(4)(ii). Claimants must make a de minimis showing that their impairment or combination of impairments is severe enough to interfere with their ability to work. Bowen v. Yuckert, 482 U.S. 137, 153-54 (1987).

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

Barnes v. Commissioner of Social Security · filed 2025-08-14(c)

At step two of the sequential evaluation process, the ALJ must determine whether the claimant has a severe impairment that significantly limits his or her physical or mental ability to do basic work activities. See 20 C.F.R. §§ 404.1520(c), 416.920(c). ... In the present case, the ALJ recognized Plaintiff’s obsessive- compulsive disorder as a medically determinable impairment but concluded that it did not cause more than minimal limitation in Plaintiff’s ability to meet the mental demands of basic work activity. (T at 19). ... So, the ALJ concluded that Plaintiff had no severe mental impairment(s), as defined under the Social Security Act. (T at 20-21). The Court finds that the ALJ’s decision must be sustained under the deferential standard of review applicable here.

At step two, the regulation requires the ALJ to determine whether an impairment or combination of impairments is severe before the sequential evaluation proceeds.

Patrick v. Commissioner of Social Security · filed 2025-09-12(a)(4)(ii)

As noted above, at the second step of the sequential evaluation process, the ALJ determines whether the claimant has an impairment or combination of impairments that is severe. 20 C.F.R. § 404.1520(a)(4)(ii). ... The evidence thus supports the ALJ’s finding that this condition was not a severe impairment. So the court rejects Patrick’s claim on this issue.

At step two, § 404.1520(a)(4)(ii) requires consideration of impairment severity and the twelve-month duration requirement; an unsuccessful work attempt at step one does not automatically require a severe-impairment finding.

Gray v. Bisignano (CONSENT) · filed 2025-09-15(a)(4)(ii)

It is theoretically possible that, in some cases, a medically determinable impairment could force a claimant to stop working after a brief period of six months or less, thus rendering a work attempt unsuccessful at step one, yet still allow a finding of no disability at step two because the impairment itself would not be expected to last at least twelve months or result in death. ... At the second step, we consider the medical severity of your impairment(s). If you do not have a severe medically determinable physical or mental impairment that meets the duration requirement in § 404.1509, or a combination of impairments that is severe and meets the duration requirement, we will find that you are not disabled.

Section 404.1520 requires disability claims to be evaluated through a five-step sequence, including a step-two determination whether an impairment is severe.

Gill v. Commissioner of Social Security · filed 2025-09-15(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. ... For those reasons, the Court finds that the ALJ did not err when she did not assess lymphocytic colitis as a severe impairment at step 2, nor did she err by not incorporating limitations for any such impairment in the RFC. ... Accordingly, remand is not required on this basis.

At step two, § 404.1520 requires an ALJ to determine whether a claimant has a severe impairment, meaning one that interferes with the ability to perform basic work activities.

Lopez Pagan v. Commissioner of Social Security · filed 2025-09-24(a)(4)(ii), (c)

Step two of the sequential evaluation process requires the ALJ to determine whether a claimant suffers from a severe impairment. See 20 C.F.R. § 404.1520(a)(4)(ii). ... A severe impairment interferes with a claimant’s ability to perform “basic work activities.” See Bowen, 482 U.S. at 141; Simon v. Comm’r, Soc. Sec. Admin., 7 F.4th 1094, 1101 (11th Cir. 2021) (citing 20 C.F.R. § 404.1520(c)).