20 C.F.R. § 416.920
Evaluation of disability claims: the cases that interpreted this section
9,744 citing cases reviewed of 18,114 in the citation index: 2,028 interpreted the section (annotated below), 7,716 cited it only in passing. Cases filed after 2026-06-26 may not have been reviewed yet.
Have a situation under 20 C.F.R. § 416.920?
These notes show how courts have ruled. Ask about your specific facts and see which of these rulings apply, with citations you can check.
Step three: meeting or equaling a Listing
The Listings conclusively establish disability for claimants whose impairments meet or equal them at step three, but they do not define disability; the underlying standard remains inability to perform substantial gainful activity for at least 12 months.
Harris v. Kijakazi · filed 2025-02-19(a)(4)(iii)
The listed impairments of 20 C.F.R. 404, Subpart P, Appendix 1 (colloquially known as the “Listings”) are a potent tool for adjudicating benefits applications because they establish a regulatory ceiling for various impairments such that any applicant whose impairments are at least as bad as the Listings is conclusively deemed disabled. See 20 C.F.R. § 416.920(a)(4)(iii); Garcia v. Comm’r of Soc. Sec., 768 F.3d 925, 931 (9th Cir. 2014). But the Listings do not actually set the standard for whether an applicant is disabled because the test for disability is always whether the applicant shows “the inability to do any substantial gainful activity by reason of any medically determinable physical or mental impairment which can be expected to result in death or which has lasted or can be expected to last for a continuous period of not less than 12 months.” 20 C.F.R. § 416.905.Read the full opinion on CourtListener →
At step three, the ALJ determines whether the claimant meets or medically equals the requirements for disability.
Bisignano · filed 2026-06-22(a)(4)(iii)
Relevant here, at Step Three, the ALJ must determine whether the individual meets or medically equals the requirements of being disabled to qualify for benefits under the Social Security Act as of the DLI. ... As such, the Court is unconvinced by John’s argument that the ALJ did not consider the objective medical evidence in the record before the DLI as he was required to do.Read the full opinion on CourtListener →
Sequential evaluation—steps two and three
Section 416.920 requires sequential evaluation of a disability claim, including deciding at step two whether the claimant has a severe impairment, at step three whether the impairment meets or equals a listed impairment, and rating functional limitation severity on a five-point scale.
Matsui v. O'Malley · filed 2025-05-12(a)(4)(ii), (a)(4)(iii), (c)(4)
At step two of the sequential analysis, the ALJ considers whether a claimant suffers from a “severe” impairment, or combination of impairments. 20 C.F.R. § 416.920(a)(4)(ii). ... At step three of the disability evaluation, the ALJ must determine whether the claimant’s impairment or combination of impairments meets or is medically equivalent to a listed impairment. ... 20 C.F.R. § 416.920(a)(4)(iii). ... The ALJ rates the degree of limitation in each of the four areas using a five-point scale: “None, mild, moderate, marked, and extreme.” 20 C.F.R. § 416.920(c)(4); see also Hoopai v. Astrue, 499 F.3d 1071, 1077–78 (9th Cir. 2007).Read the full opinion on CourtListener →
Harmless error
Section 416.920(b) does not require an initial SSI eligibility determination within a particular or reasonable time.
Quintana v. Harris · filed 1980-05-09(b)
Neither the statutory provisions relating to the SSI program nor the federal regulations promulgated thereunder require that an initial determination of eligibility for SSI benefits be made within any particular time or even within a “reasonable time.” 42 U.S.C. §§ 1381 et seq.; 20 C.F.R. § 416.920(b).Read the full opinion on CourtListener →
What counts as a severe impairment
Section 416.920(c) treats an impairment as severe when it significantly limits the claimant’s physical or mental ability to perform basic work activities, so severity is based on functional impact rather than medical severity alone.
Jones v. Schweiker · filed 1982-09-15(c)
In view of the uncontroverted evidence of plaintiff’s physical limitations from arthritis and its associated pain, the ALJ’s decision could stand only if there were substantial evidence that these limitations were not significant. ... Therefore, the ALJ erred in viewing severity of impairment solely as a medical issue, as he apparently did, rather than adhering to the regulatory scheme, in which severity is defined in terms of significant functional limitation.Read the full opinion on CourtListener →
Section 416.920(c) requires a claimant to have a severe impairment, applying a de minimus threshold under which an impairment is not severe only when it has no more than a minimal effect on the individual's ability to work.
Ter-Haroutunian v. Louis W. Sullivan, Secretary, Hhs · filed 1991-10-25(c)
In order to be found disabled, a claimant for SSI must have a severe impairment. 20 C.F.R. § 416.920(c) (1991). ... This ruling states that an impairment is not severe when "medical evidence establishes only a slight abnormality or a combination of slight abnormalities which would have no more than a minimal effect on an individual's ability to work even if the individual's age, education, or work experience were specifically considered." Id. We have endorsed a de minimus interpretation of the severity requirement. Yuckert v. Bowen, 841 F.2d 303, 306 (9th Cir.1988).Read the full opinion on CourtListener →
Section 416.920(f) requires the disability determination to consider whether the claimant retains the residual functional capacity to perform other work.
Wilson v. Schweiker · filed 1982-12-15(f)
Accordingly, based upon the undisputed medical evidence in the record, this court must conclude that substantial evidence does not exist for finding the residual functional capacity for doing any kind of work. See 20 C.F.R. § 416.920(f).Read the full opinion on CourtListener →
Section 416.920(f) requires the Secretary to determine whether a claimant who cannot perform past relevant work can perform other work existing in significant numbers in the national economy.
Rivera v. Sullivan · filed 1991-07-17(f)
Once a claimant demonstrates her inability to do her past relevant work, as plaintiff has done, the Secretary bears the burden of proof as to whether plaintiff would be able to perform other work that exists in significant numbers in the national economy. See 20 C.F.R. §§ 416.920(f), 416.966. In the present case, the Secretary did not reach this issue, since he found that plaintiff could perform her past relevant work. However, based on the evidentiary record and application of the so-called grid regulations, set out at 20 C.F.R. Part 404, Subpt. P, App. 2 (1989), a finding of disability would be compelled.Read the full opinion on CourtListener →
Section 416.920(f)(1) requires the Secretary, at the other-work step, to prove that a claimant can perform a different job considering age, experience, education, physical capacity, and available matching jobs.
Tackett v. Louis W. Sullivan, Secretary of Health and Human Services · filed 1992-03-03(f)(1)
At this step in the analysis, it becomes the Secretary's burden to establish the claimant's ability to work. Allen, 613 F.2d at 145. The Secretary must prove that, taking into consideration present job qualifications such as age, experience, education, and physical capacity, and the existence of jobs to match those qualifications, the claimant retains the capacity to perform a different kind of job. 20 C.F.R. § 416.920(f)(1); Heckler v. Campbell, 461 U.S. 458, 460 (1983).Read the full opinion on CourtListener →
Section 416.920(c) treats an impairment as severe when it significantly limits a person's physical or mental ability to perform basic work activities; that severity satisfies the additional-and-significant work-related limitation requirement under Listing 12.05C.
Monroe v. Astrue · filed 2011-09-19(c)
Based on these statements of the Commissioner and corresponding regulations, an impairment will be deemed to impose an additional and significant work-related limitation of function if the impairment is “severe” as defined by § 416.920(c).Read the full opinion on CourtListener →
Section 416.920(c) defines a severe impairment as an impairment or combination of impairments that significantly limits a claimant’s physical or mental ability to do basic work activities; in the Fifth Circuit, an impairment is not severe only if it is a slight abnormality with minimal effect on the ability to work.
Bragg v. Commissioner of Social Security Administration · filed 2008-06-06(c)
Pursuant to the Commissioner’s regulations, a severe impairment is “any impairment or combination of impairments which significantly limits [the claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. § 416.920(c). The Fifth Circuit has held that a literal application of § 404.1520(c) would be inconsistent with the Social Security Act because the regulation includes fewer conditions than indicated by the statute. Stone v. Heckler, 752 F.2d 1099, 1104-05 (5th Cir.1985). Accordingly, in the Fifth Circuit, an impairment is not severe “only if it is a slight abnormality having such minimal effect on the individual that it would not be expected to interfere with the individual’s ability to work.” Id. at 1101. Additionally, the determination of severity may not be “made without regard to the individual’s ability to perform substantial gainful activity.” Id. at 1104.Read the full opinion on CourtListener →
Section 416.920(c) requires an impairment or combination of impairments to significantly limit a claimant's ability to perform basic work activities; otherwise, the claimant is not disabled.
Kliment v. Astrue · filed 2010-04-28(c)
Section 416.920, which deals with the "Evaluation of disability of adults, in general,” section c states: 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. We will not consider your age, education, and work experience. 20 C.F.R. § 416.920(c).Read the full opinion on CourtListener →
Section 416.920(c) treats an impairment as severe when it significantly limits a claimant’s physical or mental ability to perform basic work activities.
Hoy v. Astrue · filed 2010-08-12(c)
But whether a condition or injury is a severe impairment does not turn on whether it can be improved; an impairment, or combination of impairments, is severe if it significantly limits the claimant’s physical or mental ability to perform basic work activities.Read the full opinion on CourtListener →
An impairment is severe when it significantly limits a claimant’s physical or mental ability to do basic work activities, regardless of age, education, and work experience.
Lindsey v. Social Security Administration, Commissioner · filed 2021-09-10(c)
An impairment or combination of impairments is severe if it/they “significantly limits [the claimant’s] physical or mental ability to do basic work activities[,]” irrespective of age, education, and work experience. 20 C.F.R. § 416.920(c). Thus, an impairment or combination of impairments is not severe if it does not significantly limit the claimant’s ability to do basic work activities.Read the full opinion on CourtListener →
An impairment is severe only if it significantly limits the claimant’s ability to perform basic work activities; an impairment with a minimal effect on the ability to work may be found non-severe.
Vogt v. Social Security Administration · filed 2023-03-02(c)
A “severe” impairment is one that significantly limits a claimant’s physical or mental ability to do basic work activities. ... While Ms. Vogt’s burden of proving these impairments significantly limit her ability to perform basic work activities “is not great,” Caviness v. Massanari, 250 F.3d 603, 605 (8th Cir. 2001), the ALJ could rightly find it was not a “severe” impairment when its impact was minimal on her ability to work.Read the full opinion on CourtListener →
Combined impairments in severity determination
Section 416.920(c) requires the adjudicator to consider whether the claimant’s impairments, singly and in combination, are severe in evaluating disability.
Felshina v. Richard Schweiker, as Secretary of Health and Human Services · filed 1983-05-13(c)
The applicable regulation, 20 C.F.R. § 416.920 (1982) describes the steps in evaluating disability. The Secretary reviews current work activity (there was none in this case), the severity of impairment(s), residual functional capacity, and age/education/work experience. “If we can find that you are disabled or not disabled at any point in the review, we do not review further.” “Severe impairment” can be proved in two ways: (1) by determining that the impairment “does not significantly limit your physical or mental abilities to do basic work activities” and (2) by comparing the medical facts to a list in the *73Appendix. Id. (c), (d). The Administrative Law Judge must consider whether impairments in combination are severe. Id. (c); Kolodnay v. Schweiker, 680 F.2d 878, 880 (2d Cir.1982). ... In sum, the Secretary considered the claimant’s impairments singly and in combination except that he did not treat of her obesity in combination with her hypertension. ... There was therefore no obligation to consider vocational factors unless the combination of obesity and hypertension alone gave her a severe impairment.Read the full opinion on CourtListener →
Section 416.920(c) allows severe impairment to be established by showing that a claimant's impairments significantly limit the ability to perform basic work activity, even without relying solely on Appendix I criteria.
Brownton v. Heckler · filed 1983-08-05(c)
Severe impairment can be proved either by reference to the criteria in Appendix I or by an evaluation whether a claimant’s impairments significantly limit his ability to do basic work activity. 20 C.F.R. § 416.920(c), (d) (1982); ... The ALJ made the evaluation called for in 20 C.F.R. § 416.920(c) and assessed the medical experts’ opinion in the light of the Appendix I criteria, even though he did not cite that regulation.Read the full opinion on CourtListener →
Section 416.920(c) permits the disability evaluation to end without considering age, education, or work experience when medical evidence shows no severe impairment; an impairment is non-severe only when it could not affect the claimant’s ability to work regardless of those vocational factors.
Jan M. Sexton Salmi v. Secretary of Health and Human Services · filed 1985-09-19(c)
Nevertheless, the Joint Explanatory Statement indicates that Congress was fully aware of the challenged regulation. The Joint Statement demonstrates the conferees’ acceptance of the sequential evaluation process and acceptance of the fact that once the Secretary has established, based on the medical evidence alone, that a claimant does not have a severe impairment, the Secretary may terminate review of the claimant’s application without evaluation of the claimant’s age, education, or work experience. Consequently, we uphold the regulation’s validity. ... We hold that an impairment qualifies as non-severe only if, regardless of a claimant’s age, education, or work experience, the impairment would not affect the claimant’s ability to work.Read the full opinion on CourtListener →
At step two, an impairment need not be classified as severe when the ALJ continues the sequential evaluation and adequately accounts for the impairment's limitations in the later analysis.
Summers v. Kijakazi · filed 2023-03-30(c)
Further, even if the ALJ erred in failing to include ASD as a severe impairment, this error was harmless. Notably, to the extent Dr. Nieder intended to diagnose Summers with ASD, she found that the disorder was “of mild severity.” Id. As discussed below, the ALJ adequately considered all of Summers’ ASD symptoms as set out by Dr. Nieder when assessing whether he met a listing and in determining his RFC. Accordingly, the ALJ’s failure to include ASD as a severe impairment at step two was not reversible error.Read the full opinion on CourtListener →
Section 416.920(a)(4)(ii) requires the ALJ to consider whether the claimant has a severe impairment or combination of impairments meeting the duration requirement when applying the sequential evaluation.
Sutherlin v. Kijakazi · filed 2023-11-07(a)(4)(ii)
SSA regulations require an ALJ to consider the severity of each of a claimant’s impairments, both individually and in combination.Read the full opinion on CourtListener →
Severe impairment requirement
Section 416.920(c) requires a claimant to establish a severe medically determinable impairment before the medical-vocational guidelines may be applied to decide disability.
Strunk v. Margaret Heckler, Secretary of Health and Human Services · filed 1984-04-27(c)
A claimant is disabled within the meaning of the Social Security Act only if he or she has a severe impairment. 20 C.F.R. § 416.920(c). ... It is clear that before the medical-vocational guidelines can be applied to a given case, a claimant must prove that he or she suffers from a severe medically determinable physical or mental impairment. ... Thus, the application of the medical-vocational guidelines to the plaintiff's claim is not warranted since the AU found her impairments not severe when considered singly or in combination, a finding we hold is supported by substantial evidence.Read the full opinion on CourtListener →
Section 416.920(c) permits a finding of no severe impairment only when the impairment is a slight abnormality with a minimal effect that would not be expected to interfere with the person’s ability to work, regardless of age, education, or work experience.
Romero v. Heckler · filed 1984-05-23(c)
An impairment can be considered as not severe only if it is a slight abnormality which has such a minimal effect on the individual that it would not be expected to interfere with the individual’s ability to work, irrespective of age, education, or work experience.Read the full opinion on CourtListener →
The severity regulation cannot end the disability inquiry based solely on the absence of a severe impairment because it conflicts with the statutory requirement to consider age, education, and work experience once the claimant cannot perform past work.
Glover v. Heckler · filed 1984-06-04(c)
It seems clear to us that the “severity regulation” conflicts squarely with 42 U.S.C. § 1382c(a)(3)(B) [§ 423(d)(2)(A)], which provides that if a person is unable to perform his or her past work, the Secretary will consider the claimant’s age, education and work experience to determine whether he or she is able to perform other substantial gainful work which exists in the national economy. ... In the case at bar the ALJ based his decision solely on the questioned regulation (Tr. 12, 13). As we have found such regulation to be invalid, we reverse the decision.Read the full opinion on CourtListener →
Section 416.920(c) treats an impairment as severe when it limits a claimant’s physical or mental ability to perform basic work activities.
Griffin v. Secretary of Health & Human Services · filed 1985-04-09(c)
The Secretary’s regulations at 20 C.F.R. § 416.920 provide for the sequential evaluation of a claim for disability. ... A severe impairment under the regulations is described as one which limits physical or mental ability to “do basic work activity.” 20 C.F.R. § 416.920(c). ... We have no doubt that the evidence establishes that Mr. Griffin’s ability to do basic work activity as it is defined in 20 C.F.R. § 416.921(a) is limited by his physical impairments. This constitutes a severe- impairment. 20 C.F.R. § 416.920(c). The Secretary’s decision that Mr. Griffin’s impairment is not severe is not supported by substantial evidence.Read the full opinion on CourtListener →
Section 416.920(c) requires an impairment to significantly limit a claimant’s physical or mental ability to perform basic work activities to qualify as severe.
Ferguson v. Richard S. Schweiker, Secretary United States Department of Health and Human Services · filed 1985-06-11(c)
We believe that the evidence offered by the treating physician is substantial evidence for the conclusion that Ferguson is significantly limited in those physical abilities necessary to do basic work activities such as lifting, pushing, pulling, carrying, prolonged standing, walking, bending, climbing, and running, and also for the determination that she cannot return to any prior work which involves the same.Read the full opinion on CourtListener →
Section 416.920(c) cannot be applied as a stand-alone de minimis screen to deny benefits without considering the claimant’s vocational factors.
Wilson v. Secretary of Health & Human Services · filed 1986-07-14(c)
In granting the appellees’ motion for a preliminary injunction, the district court enjoined the Secretary “from denying or terminating Social Security Disability or Supplemental Security Income Benefits due to the policies set forth in 20 C.F.R. §§ 404.1520(c) and .1521, 416.920(c) and .921 (1983), and Social Security Ruling 82-55.” ... By continuing to apply section 404.1520(c) as clarified by SSR 85-28, the Secretary is following the path that we explicitly rejected. ... As the district court held, Baeder’s invalidation of section 404.1520(c) forecloses the Secretary from applying that regulation in any way.Read the full opinion on CourtListener →
Section 416.920(a) requires disability claims to be evaluated in sequence, stopping once a finding of disabled or not disabled is made.
Barajas v. Margaret M. Heckler, Secretary, Department of Health and Human Services · filed 1984-06-21(a)
In determining whether a claimant is eligible for Supplemental Security Income, the Secretary must follow a sequential process of evaluation specified by the regulations. ... The regulations provide “a set order to determine whether you are disabled. We review any current work activity, the severity of your impairment(s), your residual functional capacity and your age, education, and work experience. If we can find that you are disabled or not disabled at any point in the review, we do not review further.” 20 C.F.R. § 416.920(a)(1983). Having determined that Barajas’ impairment was not severe, the Secretary need not have considered whether she was capable of performing other types of work.Read the full opinion on CourtListener →
Section 416.920 ends the sequential disability evaluation when a claimant lacks a severe impairment, because no consideration of age, education, or vocational skills can establish eligibility without that requirement.
Gist v. Secretary of Health and Human Services · filed 1984-08-13(a), (c)
We find no merit in Gist’s contention that the sequential procedure for evaluating disability, under which no further inquiry is necessary if a claimant is determined not to have a severe impairment, see 20 C.F.R. § 416.920(a) (1983), is improper. The requirement that an impairment be severe flows directly from the statute. See 42 U.S.C. § 1382c(a)(3)(B). Since the severe impairment requirement is an absolute one, in that if a claimant lacks a severe impairment he can receive benefits under no conceivable set of facts, there is no need for the Secretary to consider other factors, such as age, education and vocational skills, if this crucial element is lacking.Read the full opinion on CourtListener →
Section 416.920 requires disability claims to be evaluated through the sequential process, with vocational as well as medical factors considered rather than denying a claim solely on the step-two severity test.
DuBreuil v. Bowen · filed 1986-03-21(d) and (e)
The validity of step two has been a source of controversy within and among the various circuit courts of appeal. Under step two, as discussed hereinbefore, a finding of “not disabled” can be made on medical reasons alone. The Social Security Act, however, requires that both medical and vocational factors be considered in a disability determination. See 42 U.S.C. § 423(d)(1)(A) (1982) (an individual is disabled “only if his physical or mental impairment ... is of such severity that ..., considering his age, education and work experience, [he cannot] engage in ... substantial gainful work ...”). Because of this conflict, this Court and others have ruled the step two severity test invalid. See McDonald v. Heckler, No. 84-2190-G, slip op. at 10 (D.Mass. Dec. 19, 1985); Dube v. Heckler, No. 84-2634-Mc, slip op. at 5-6 (D.Mass. Mar. 10, 1986); Johnson v. Heckler, 769 F.2d 1202 (7th Cir.1985). Accordingly, we cannot affirm a denial of benefits which is based upon a claimant’s failure to meet the step two severity test. ... The decision of the Secretary denying benefits to the plaintiff, whether it be based upon a step two denial or upon the alternative analysis given by the AU, must be reversed. The plaintiff is entitled to a full-scale evaluation which takes into consideration vocational, as well as medical factors. Accordingly, the plaintiff’s claim is remanded for further consideration under steps three through five of 20 C.F.R. § 404.1520 and § 416.920.Read the full opinion on CourtListener →
Section 416.920(c) treats severity as a de minimis threshold: an impairment is severe when it significantly limits basic work activities, and the agency must apply that standard to the evidence as a whole.
McKenzie v. Heckler · filed 1984-08-10(c)
A severe impairment is described as one which “significantly” limits the claimant’s ability to do basic work activities. 20 C.F.R. §§ 416.920(c), 416.921(a). The regulations do not define “significant.” ... Secretary fails to acknowledge she misapplied the existing law on the “severity” requirement, using it as more than a de minimis threshold showing. This Court held if Secretary had properly applied the severity requirement and the correct legal standards in evaluating the existing evidence, Secretary’s own regulations mandated a finding McKenzie was disabled.Read the full opinion on CourtListener →
At Step 2, an impairment is not severe only when it is a slight abnormality with such minimal effect that it would not be expected to interfere with the claimant's ability to work, regardless of age, education, or work experience.
Davis v. Margaret M. Heckler, Secretary of Health and Human Services · filed 1985-05-02(c)
In determining whether a claimant is disabled, the Secretary, pursuant to statutory authority, has promulgated regulations that establish a five-step process to determine whether a claimant is disabled within the meaning of the statute. 20 C.F.R. § 416.920 (1984). First, a claimant who at the time of his disability claim is engaged in substantial gainful employment is not disabled. 20 C.F.R. § 416.920(b) (1984). Second, the claimant is automatically denied benefits if the asserted impairment is not “severe,” without consideration of his residual functional capacity, age, education, or work experience. 20 C.F.R. § 416.920(c) (1984). Third, if the asserted impairment is severe, the claimant is per se disabled if his impairment meets or equals an impairment described in 20 C.F.R. 404, Subpart P, Appendix 1 (1984). 20 C.F.R. § 416.920(d) (1984). Fourth, a claimant with a severe impairment that is not per se disabling is denied benefits if he is capable of doing past relevant work. 20 C.F.R. § 416.920(e) (1984). Fifth, a claimant who cannot return to past relevant work is denied benefits if he can engage in work available in the national economy. In this step, the claimant’s residual functional capacity, age, education, and work experience are considered. 20 C.F.R. § 416.920(f) (1984). A claimant who cannot return to work and who cannot engage in other work is disabled. ... This Court in Estran held that the Secretary had applied the wrong legal standard in determining severity when the AU’s opinion only used the definition contained in the current regulations. Rather, the Court in Estran stated that the current regulation defining nonseverity must be read in light of the 1968 definition and therefore construed the current regulation as setting the following standard in determining whether a claimant’s impairment is severe: “[A]n impairment can be considered as not severe only if it is a slight abnormality which has 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.” ... In the instant case, neither the AU nor the Secretary referred to the “slight abnormality” standard of the 1968 regulations. Under the clear command of Stone, therefore, “the claim must be remanded to the Secretary for reconsideration.”Read the full opinion on CourtListener →
Section 416.920(c) requires a claimant to have an impairment that significantly limits the physical or mental ability to perform basic work activities at step two.
Nally v. Heckler · filed 1986-02-14(c)
The regulations specify that a disability claimant must “have a severe impairment,” 20 C.F.R. § 416.920(c), defined as an impairment that significantly limits a claimant’s “physical or mental ability to do basic work activities.” Id. at § 416.921(a).Read the full opinion on CourtListener →
Section 416.920(c) permits a de minimis Step 2 screening of disability claims based on medical severity, so long as it screens out only impairments that could not prevent work even if vocational factors were considered.
McDonald v. Secretary of Health and Human Services · filed 1986-07-17(c)
Because the Step 2 regulation, as currently construed by the Secretary in Ruling 85-28, constitutes no more than such a de minimis screening policy, we hold that it is valid.Read the full opinion on CourtListener →
Section 416.920(c) sets a de minimis severity threshold at step two of the sequential evaluation, and does not permit the Secretary to impose a more demanding “de minimis plus” standard without properly changing the regulation.
Salmi v. Secretary of Health & Human Services · filed 1989-02-16(c)
Accordingly, the Secretary’s imposition of a “de minimis plus” threshold severity standard to plaintiff’s application in this case directly contradicted the Secretary’s own interpretation of the applicable regulation, an interpretation that was still in force at the time plaintiff filed her application.Read the full opinion on CourtListener →
Under subsection (c), an impairment is severe when it significantly limits a claimant’s physical or mental ability to perform basic work activities.
Vivaritas v. Commissioner of Social Security · filed 2008-02-12(c)
Vivaritas satisfied the first and second requirements. ... In addition, the ALJ found that Vivaritas’ asthma and migraines were “severe” pursuant to 20 C.F.R. § 416.920, which describes “severe impairment” as “any impairment or combination of impairments which significantly limits your physical or mental ability to do basic work activities.” 20 C.F.R. § 416.920(c).Read the full opinion on CourtListener →
Section 416.920(c) governs whether an impairment is severe, and a finding that narcolepsy is not severe cannot stand when the medical evidence does not substantially support that conclusion.
Jones v. Astrue · filed 2012-05-21(c)
Accordingly, I sustain plaintiffs first objection and remand this matter back to the Commissioner for further proceedings for the ALJ to re-assess Dr. Rodin’s opinion and specify which findings are accepted and which are rejected. ... Therefore, I reject Magistrate Judge Perkin’s determination that the ALJ properly concluded that plaintiffs evidence of narcolepsy failed to constitute a severe impairment.Read the full opinion on CourtListener →
Section 416.920(c) treats an impairment as severe when it significantly limits a claimant’s ability to work, rather than when it has only a minimal effect.
Colson v. Colvin · filed 2015-08-14(c)
Under 20 C.F.R. § 416.920(c), *788“severe” means a significant limitation that interferes with a claimant’s ability to work.Read the full opinion on CourtListener →
Section 416.920(c) treats an impairment as severe when it significantly limits a claimant’s physical or mental ability to perform basic work activities.
Shepard v. Social Security Administration · filed 2020-01-10(c)
A “severe” impairment is one that significantly limits a claimant’s physical or mental ability to do basic work activities. Gwathney v. Chater, 104 F.3d 1043, 1045 (8th Cir. 1997); Browning v. Sullivan, 958 F.2d 817, 821 (8th Cir. 1992); 20 C.F.R. § 416.920(c) (2007). It has “more than a minimal effect on the claimant’s ability to work.”Read the full opinion on CourtListener →
Section 416.920(c) defines a severe impairment as one that significantly limits a claimant’s physical or mental ability to perform basic work activities.
Guillar v. Commissioner, Social Security Administration · filed 2020-03-03(c)
An impairment is “severe” if it “significantly limits [a claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c)[; see also 20 C.F.R. § 416.920(c)]. A claimant must make only a de minimis showing to advance beyond step two. ... By its plain terms, the regulation requires a claimant to show only “a severe” impairment—that is, one severe impairment—to avoid a denial of benefits at step two. Id. (emphasis added). As long as the ALJ finds one severe impairment, the ALJ may not deny benefits at step two but must proceed to the next step. Thus, the failure to find a particular impairment severe at step two is not reversible error when the ALJ finds that at least one other impairment is severe. Here, the ALJ found six other impairments severe. ... In the instant case, the ALJ found one other impairment to be severe, i.e. Multiple Sclerosis. Tr. 25. Thus, the ALJ found that Plaintiff could not conclusively be denied benefits at step two and proceeded to steps three and four of her analysis. Therefore, Plaintiff’s argument that the ALJ erred at step two “fails as a matter of law.” Allman, 813 F.3d at 1330.Read the full opinion on CourtListener →
At step two, an impairment is severe only if it significantly limits the claimant's physical or mental ability to perform basic work activities; omitting an impairment is harmless when its limitations are considered in the later RFC analysis.
Johnson v. Berryhill · filed 2020-04-01(c)
At step two of the sequential process, the ALJ must determine that the claimant has a severe mental or physical impairment that has or is expected to last twelve months or will result in death. 20 C.F.R. §§ 404.1509, 404.1520(a)(4)(i)-(ii); 416.909, 416.920(a)(4)(i)-(ii). “An impairment is not severe if it amounts only to a slight abnormality that would not significantly limit the claimant's physical or mental ability to do basic work activities.” Kirby v. Astrue, 500 F.3d 705, 707 (8th Cir. 2007); 20 C.F.R §§ 404.1520(c), 416.920(c). ... A failure to list a specific impairment at step two of the sequential evaluation process is not an error unless the impairment is “separate and apart” from the other listed impairments. ... Moreover, even if the ALJ erred in excluding Plaintiff’s osteoporosis from the list of severe impairments, the Court finds such error was harmless because the ALJ clearly considered all of Plaintiff’s credible limitations throughout the RFC analysis.Read the full opinion on CourtListener →
Section 416.920(c) treats an impairment as severe when it significantly limits a person's ability to perform basic work activities.
Mendoza v. Saul · filed 2020-08-31(c)
The regulations, 20 C.F.R. §§ 404.1520(c), 416.920(c), provide that an impairment is severe if it significantly limits one’s ability to perform basic work activities.Read the full opinion on CourtListener →
Section 416.920(c) defines a severe impairment as one that significantly limits a claimant’s physical or mental ability to perform basic work activities.
Schrichten v. Commissioner of Social Security · filed 2022-01-19(c)
The regulations define a “severe” impairment or combination of impairments as one that significantly limits the physical or mental ability to perform basic work activities. ... Given the dearth of evidence concerning plaintiff’s bunion impairment, the ALJ’s conclusion that this condition is not severe is supported by substantial evidence.Read the full opinion on CourtListener →
Section 416.920(c) treats an impairment as severe when it significantly limits a claimant’s physical or mental ability to perform basic work activities.
Grable v. Kijakazi · filed 2022-03-28(c)
Under the Social Security regulations, a severe impairment is “an impairment or combination of impairments that significantly limits a claimant’s physical or mental ability to perform basic work activities.” 20 C.F.R. §§ 416.920(c), 416.921.Read the full opinion on CourtListener →
Section 416.920(c) defines a severe impairment as one that significantly limits a claimant’s physical or mental ability to perform basic work activities.
BENEDETTO v. COMMISSIONER OF SOCIAL SECURITY · filed 2022-04-25(c)
A “severe impairment” is a condition that “significantly limits [a claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. § 416.920(c).Read the full opinion on CourtListener →
Section 416.920(c) treats an impairment as severe only when it significantly limits a claimant's physical or mental ability to do basic work activities; an impairment with minimal impact on the ability to work may be found non-severe at step two.
Uekman v. Social Security Administration · filed 2022-05-18(c)
A “severe” impairment is one that significantly limits a claimant’s physical or mental ability to do basic work activities. Gwathney v. Chater, 104 F.3d 1043, 1045 (8th Cir. 1997); Browning v. Sullivan, 958 F.2d 817, 821 (8th Cir. 1992); 20 C.F.R. § 416.920(c) (2007). ... While Ms. Uekman’s burden of proving her fibromyalgia significantly limits her ability to perform basic work activities “is not great,” Caviness v. Massanari, 250 F.3d 603, 605 (8th Cir. 2001), the ALJ could rightly find it was not a “severe” impairment when its impact was minimal on her ability to work. ... Thus, Plaintiff failed to meet her burden at step two.Read the full opinion on CourtListener →
Section 416.920(c) treats an impairment as severe only when it significantly limits a claimant’s physical or mental ability to perform basic work activities.
Lumpkin v. Saul · filed 2022-09-20(c)
A severe impairment is “any impairment or combination of impairments which significantly limits [a plaintiff’s] physical or mental ability to do basic work activities.” 20 C.F.R. 416.920(c). A severe impairment must meet the durational requirement, such that the impairment be “expected to result in death, [or] it must have lasted or must be expected to last for a continuous period of at least 12 months.” 20 C.F.R. 416.909.Read the full opinion on CourtListener →
Section 416.920(c) treats an impairment as severe when it significantly limits a claimant’s physical or mental ability to perform basic work activities.
McBryde v. Social Security Administration · filed 2023-02-23(c)
A “severe” impairment is one that significantly limits a claimant’s physical or mental ability to do basic work activities. Gwathney v. Chater, 104 F.3d 1043, 1045 (8th Cir. 1997); Browning v. Sullivan, 958 F.2d 817, 821 (8th Cir. 1992); 20 C.F.R. § 416.920(c) (2007). It has “more than a minimal effect on the claimant’s ability to work.”Read the full opinion on CourtListener →
Section 416.920(c) treats an impairment as severe when it significantly limits a claimant’s physical or mental ability to perform basic work activities.
Ridenour v. Commissioner of Social Security · filed 2023-03-27(c)
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. § 416.920(c).Read the full opinion on CourtListener →
Section 416.920(c) treats an impairment as severe when it significantly impacts a claimant’s ability to perform basic work activity.
Alabdullatir V. Saul · filed 2023-04-21(c)
It was illogical for the ALJ to find that Al Abdullatif’s pseudotumor cerebri constituted a severe impairment, and nevertheless include no relevant limitation her RFC assessment. Arguably, this was in itself error, since a severe impairment is defined as one causing a significant impact on a claimant’s ability to do basic work activity. 20 C.F.R. §416.920(c).Read the full opinion on CourtListener →
Section 416.920(c) treats an impairment as severe when it significantly limits a claimant’s physical or mental ability to perform basic work activities.
Swindon v. Kijakazi · filed 2024-09-05(c)
A severe impairment is one that “significantly limits your physical or mental ability to do basic work activities.” 20 C.F.R. § 416.920(c); Woodmancy v. Colvin, 577 F. App’x 72, 74 (2d Cir. 2014).Read the full opinion on CourtListener →
Section 416.920(c) treats an impairment as severe when it causes more than minimal limitations on a claimant’s ability to perform basic work activities.
Krawczyk v. O'Malley · filed 2025-03-06(c)
The ALJ’s finding that obesity was a severe impairment means, by definition, Claimant’s obesity caused more than minimal limits on his ability to perform basic work activities. 20 C.F.R. § 416.920(c); 20 C.F.R. § 416.922(a).Read the full opinion on CourtListener →
Section 416.920(c) treats an impairment as severe when it significantly limits a claimant’s physical or mental ability to perform basic work activities.
Baker v. Social Security Administration · filed 2025-03-19(c)
A “severe” impairment is one that significantly limits a claimant’s physical or mental ability to do basic work activities. Gwathney v. Chater, 104 F.3d 1043, 1045 (8th Cir. 1997); Browning v. Sullivan, 958 F.2d 817, 821 (8th Cir. 1992); 20 C.F.R. § 416.920(c) (2007). It has “more than a minimal effect on the claimant’s ability to work.” Hudson v. Bowen, 870 F.2d at 1396; accord, Kirby v. Astrue, 500 F.3d 705, 707 (8th Cir. 2007); Page v. Astrue, 484 F.3d 1040, 1043 (8th Cir. 2007).Read the full opinion on CourtListener →
Section 416.920(c) treats an impairment as severe when it significantly limits a claimant’s physical or mental ability to do basic work activities.
Hawkins v. Social Security Administration · filed 2025-07-24(c)
A “severe” impairment is one that significantly limits a claimant’s physical or mental ability to do basic work activities. Gwathney v. Chater, 104 F.3d 1043, 1045 (8th Cir. 1997); Browning v. Sullivan, 958 F.2d 817, 821 (8th Cir. 1992); 20 C.F.R. § 416.920(c) (2007).Read the full opinion on CourtListener →
Section 416.920(c) treats an impairment as severe only if it significantly limits a claimant’s physical or mental ability to perform basic work activities.
Gray · filed 2025-11-14(c)
And, given the substantial evidence supporting the ALJ’s decision, I am simply unable to find reversible error here. A “severe” impairment is one that significantly limits a claimant’s physical or mental ability to do basic work activities. Gwathney v. Chater, 104 F.3d 1043, 1045 (8th Cir. 1997); Browning v. Sullivan, 958 F.2d 817, 821 (8th Cir. 1992); 20 C.F.R. § 416.920(c) (2007). It has “more than a minimal effect on the claimant’s ability to work.” Hudson v. Bowen, 870 F.2d at 1396; accord, Kirby v. Astrue, 500 F.3d 705, 707 (8th Cir. 2007); Page v. Astrue, 484 F.3d 1040, 1043 (8th Cir. 2007).Read the full opinion on CourtListener →
Sequential evaluation of disability claims
Section 416.920(a)(4)(ii) and (c) govern the step-two severe-impairment inquiry: an impairment must result in death or last, or be expected to last, at least 12 months, and the absence of a severe impairment requires a finding of no disability. At step five, § 416.920(a)(4)(v) requires consideration of the claimant’s age, education, work history, and RFC in determining whether jobs exist in the national economy.
Erickson · filed 2026-04-28(a)(4)(ii), (c), (a)(4)(v)
At the second step of the sequential analysis, the ALJ considers whether the claimant has a “severe impairment.” 20 C.F.R. § 416.920(a)(4)(ii), (c). An impairment qualifies as a “severe impairment” only if it is “expected to result in death [or has] lasted or is expected to last for a continuous period of at least 12 months.” 20 C.F.R. §§ 416.909, 416.920(a)(4)(ii). ... If the ALJ determines that the claimant does not have a severe impairment, or combination of impairments, the regulations direct the ALJ to find that the claimant is not disabled. 20 C.F.R. § 416.920(c). ... So long as the ALJ considers all the claimant’s impairments – severe and non-severe – in the remaining steps of the disability determination, any error at Step Two is harmless. ... The Step Five regulations required only that the ALJ ask the VE to consider Erickson’s age, education, work history, and RFC when determining if jobs he could perform existed in the national economy. Id.; 20 C.F.R. §416.920(a)(4)(v). As the ALJ had already determined that limitations related to absenteeism were unwarranted when he established the RFC, there was no requirement that the issue be raised again at Step Five.Read the full opinion on CourtListener →
Timing of initial eligibility determinations
Section 416.920 provides a five-step disability evaluation, and at Step Two a claimant is not disabled when the claimant's impairments do not significantly limit the ability to perform basic work activities.
David H. v. Kijakazi · filed 2022-07-19(c)
The ALJ must follow five steps in evaluating a claim of disability. See 20 C.F.R. § 416.920. First, if a claimant is working at a substantial gainful activity, the claimant is not disabled. 20 C.F.R. § 416.920(b). Second, if a claimant does not have any impairment or combination of impairments that significantly limit physical or mental ability to do basic work activities, then the claimant does not have a severe impairment and is not disabled. 20 C.F.R. § 416.920(c). Third, if a claimant’s impairments meet or equal an impairment listed in 20 C.F.R. Part 404, Appendix 1, the claimant is disabled. 20 C.F.R. § 416.920(d). Fourth, if a claimant’s impairments do not prevent doing past relevant work, the claimant is not disabled. 20 C.F.R. § 416.920(e)-(f). Fifth, if a claimant’s impairments (considering RFC, age, education and past work) prevent doing other work that exists in the local or national economy, a finding of disabled is warranted. 20 C.F.R. § 416.920(g). Significantly, the claimant bears the burden of proof at Steps One through Four, but the Commissioner bears the burden at Step Five.Read the full opinion on CourtListener →
Section 416.920 requires disability claims to be evaluated through a five-step sequence: substantial gainful activity, severe impairment, listed impairment, past work, and other available work.
Vargas v. Bowen · filed 1989-04-14
The Secretary has established a five-step procedure for evaluating disability claims, 20 C.F.R. § 416.920, which the Second Circuit has summarized as follows: First, the Secretary considers whether the claimant is currently engaged in substantial gainful activity. If [she] is not, the Secretary next considers whether the claimant has a “severe impairment” which significantly limited [her] physical or mental ability to do basic work activities. If the claimant suffers such an impairment, the third inquiry is whether, based solely on medical evidence, the claimant has an impairment which is listed in Appendix 1 of the regulations. If the claimant has such an impairment, the Secretary will consider [her] disabled without considered vocational factors such as age, education, and work experience; the Secretary presumes that a claimant who is afflicted with a “listed” impairment is unable to perform substantial gainful activity. Assuming the claimant does not have a listed impairment, the fourth inquiry is whether, despite the claimant’s severe impairment, [she] has the residual functional capacity to perform [her] past work. Finally, if the claimant is unable to perform [her] past work, the Secretary then determines whether there is other work which the claimant could perform.Read the full opinion on CourtListener →
Under § 416.920(d), a claimant whose impairment meets or equals a listed impairment is disabled without considering ability to work; under § 416.920(f), once the claimant cannot perform past relevant work, disability depends on residual functional capacity and vocational factors, including the ability to perform other work.
Howard v. Bowen · filed 1986-05-02(d), (f)
A claimant who suffers from a medical impairment in Appendix 1 is considered disabled regardless of his possible ability to work in spite of the impairment. 20 C.F.R. § 416.920(d). ... Once it is determined that a SSI claimant is unable to carry out the work she has done in the past, the Secretary must assess the claimant’s “residual functional capacity” and her age, education, and work experience. To be found disabled, a claimant must, in the judgment of the Secretary on the basis of these factors, be unable to perform other work. 20 C.F.R. § 416.920(f), 961.Read the full opinion on CourtListener →
Section 416.920 establishes a sequential disability evaluation in which the inquiry may end at step two for a non-severe impairment, but a claimant who arguably satisfies a listed impairment must not be screened out at that stage.
Williamson v. Secretary of Health and Human Services · filed 1986-07-07(a)
We cannot accept the Secretary’s argument that, when the evaluation terminates at step two on a finding of no severe impairment, it does not matter whether the claimant satisfies the criteria in the Listing of Impairments. This view of the law is erroneous because it means that impairments that are serious enough to satisfy the listing can be considered not serious enough to be “severe” under sections 416.-920(c) and 416.921. Such a reading of the regulations is illogical. We believe that if a claimant arguably satisfies the criteria of a listed impairment in Appendix 1, it is not proper to preclude a consideration of the listing by finding the impairment non-severe at the second stage of the inquiry. We recognize, of course, that in proper cases the evaluation of disability may terminate at step two upon a finding that the impairments are not severe.Read the full opinion on CourtListener →
Section 416.920 requires disability claims to be evaluated through a five-step sequential process, including a finding of disability at step three when the claimant's impairment meets the duration and listing requirements.
Walker v. DEPT. OF HEALTH & REHAB. SERVS., DIST. I, ESCAMBIA CTY. · filed 1988-10-19(a), (d)
Because it appears that the hearings officer disregarded the sequential evaluation set forth in 20 C.F.R. § 416.920 or misapplied that evaluation, the final order must be vacated and the case remanded. ... Thus, pertinent to the instant case is 20 C.F.R. § 416.920, which describes a five-step sequence to be followed in evaluating whether a claimant is entitled to benefits. ... 20 C.F.R. § 416.920(d), step three of the sequential evaluation, provides that if the claimant has "an impairment(s) which meets the duration requirement and is listed in Appendix 1 or is equal to a listed impairment(s)," the claimant will be found to be disabled.Read the full opinion on CourtListener →
Section 416.920 requires a sequential evaluation of SSI disability claims, moving from substantial gainful activity and severity through listed impairments, past work, and the claimant's ability to perform other work.
Maher v. Secretary of Health & Human Services · filed 1989-11-30(b)-(f)
The claimant has the ultimate burden to establish an entitlement to supplemental security income by proving the existence of a disability as defined in 42 U.S.C. §§ 423(d), 1382c(a)(3). If the claimant is working and the work constitutes substantial gainful activity, benefits are automatically denied. 20 C.F.R. § 416.920(b). If the claimant is not found to have an impairment which significantly limits his or her ability to work (a severe impairment), then he or she is not disabled. 20 C.F.R. § 416.920(c). Since the AU found that Maher suffered from a severe impairment, further inquiry was necessary. If the claimant is not working and has a severe impairment, it must be determined whether he or she suffers from one of the “listed” impairments. 20 C.F.R. § 416.920(d). If so, benefits are owing without further inquiry. In the instant case, the AU found that Maher did not suffer from one of the listed impairments.Read the full opinion on CourtListener →
Section 416.920 requires disability claims to be evaluated through a sequential process addressing substantial gainful activity, severity and listed impairments, past relevant work, and the capacity for other work.
Tavoletti v. Sullivan · filed 1989-12-12
Under the law, our review of the AD’s decision must follow the sequential analysis set forth in the Social Security Regulations. See C.F.R. § 416.920. This analysis establishes a framework for determining whether an individual is disabled according to the regulations. The first inquiry is whether the plaintiff is performing any substantial gainful activity. If so, the plaintiff is not disabled and the inquiry is concluded. 20 C.F.R. § 416.920(b). If not, we must scrutinize whether the individual has a severe impairment as defined by the applicable regulations.Read the full opinion on CourtListener →
Section 416.920 requires a claimant who meets or equals a listed impairment to be found disabled without considering age, education, or work experience.
Groves v. Heckler · filed 1984-12-20
Under the Secretary’s own regulations, 20 CFR § 416.920 (1982), where the plaintiff has an impairment which meets or equals a listed impairment, he is to be found disabled “without consideration of age, education and work experience.” The Secretary’s own witness whose testimony was relied upon in making the determination with respect to regular disability benefits clearly indicated that plaintiff met the listings as of April 1982.Read the full opinion on CourtListener →
Section 416.920 requires a claimant to establish a severe impairment before the agency considers vocational factors, and it denies disability when the claimant can still perform past work.
Wallschlaeger v. Richard S. Schweiker, Secretary of Health and Human Services · filed 1983-04-05(a), (c), (d), (e), (f)(1)
The determination of disability under the Secretary’s regulations is sequential. ... The first is to demonstrate a severe impairment. “If you do not have any 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.” 20 C.F.R. § 416.920(c). If you have a severe impairment, “we then review your residual functional capacity and the physical and mental demands of the work you have done in the past. If you can still do this kind of work, we will find that you are not disabled.” 20 C.F.R. § 416.920(e) (emphasis added). ... So if Mrs. Wallschlaeger either does not have a severe impairment, or has a severe impairment but not one that prevents her from doing the kind of work she has done in the past, she is not disabled no matter how many years ago she last worked. ... “Your impairment must be severe ... before we can find you to be disabled.” 20 C.F.R. § 416.920(a). The administrative law judge had found that Mrs. Wallschlaeger did not have a severe medically determinable impairment; that finding barred her claim under the statute and regulations. ... This is technically incorrect under the regulations. If you do not have a severe impairment you are not disabled even if you have some slight impairment that disables you from performing any work which you have or are qualified to do.Read the full opinion on CourtListener →
Section 416.920 requires the Commissioner to evaluate disability claims through a five-step sequential process, including determining at step five whether the claimant can perform other work in the national economy.
Rebeck v. Barnhart · filed 2004-05-12
To determine whether a claimant is under a disability, the Commissioner applies a five-step sequential evaluation: (1) whether the claimant is currently working; (2) whether the claimant suffers from a severe impairment or combination of impairments; (3) whether the impairment meets an impairment listed in Appendix 1 of the relevant regulation; (4) whether the impairment prevents the clamant from continuing his past relevant work; and (5) whether the impairment prevents the claimant from doing any kind of work. See 20 C.F.R. §§ 404.1520, 416.920.Read the full opinion on CourtListener →
Section 416.920 requires disability claims under Title XVI to be decided through a five-step sequential evaluation: substantial gainful activity, severe impairment, listed impairment, past relevant work, and other national-economy work considering the claimant’s age, education, work experience, and residual functional capacity.
Pieczynski v. Barnhart · filed 2006-03-27
The SSA outlines a five-step sequential evaluation that must be applied in order to make a disability determination. 20 C.F.R. § 416.920. That five-step evaluation consists of the following stages: (1) whether the claimant is currently engaged in substantial gainful activity; (2) if not, whether the claimant has severe impairment; (3) if so, whether the claimant’s severe impairment meets or equals the criteria of an impairment listed in 20 C.F.R. pt. 404 subpt. P., app. 1; (4) if not, whether the claimant’s impairment prevents him from performing his past relevant work; and (5) if so, whether the claimant can perform any other work which exists in the national economy in light of his age, education, work experience and residual functional capacity. 20 C.F.R. §§ 404.1520, 416.920; see Sykes v. Apfel, 228 F.3d 259, 262-63 (3d Cir.2000). If a plaintiff fails to meet the burden of proving the requirements in the first four steps, the administrative law judge may find that plaintiff is not disabled. Burns v. Barnhart, 312 F.3d at 119.Read the full opinion on CourtListener →
Section 416.920 establishes a five-step assessment for adjudicating disability claims, which the court adopted and applied in reviewing the SSI denial.
Rubet v. Commissioner of Social Security · filed 2006-08-10
Specifically, the Court adopts the Commissioner’s analysis and application of the five-step assessment for adjudication of disability claims contained in 20 C.F.R. § 416.920, as elaborated by the Second Circuit in DeChirico v. Callahan, 134 F.3d 1177, 1179 (2d Cir.1998).Read the full opinion on CourtListener →
Section 416.920 requires the Commissioner to evaluate disability claims through a five-step sequence, stopping when a finding of disability or non-disability can be made.
Tucker v. Colvin · filed 2015-07-30(a)(4)
In determining whether a person is disabled, the Commissioner is required to perform a five-step sequential analysis. See 20 CFR § 416.920; Russo v. Astrue, 421 Fed.Appx. 184, 188 (3d Cir. Apr. 6, 2011). If a finding of disability or non-disability can be made at any point in the sequential process, the Commissioner will not review the claim further. See 20 CFR § 416.920(a)(4). At step one, the Commissioner must determine whether the claimant is engaged in any substantial gainful activity. See 20 CFR § 416.920(a)(4)(I) (mandating finding of non-disability when claimant is engaged in substantial gainful activity). If the claimant is not engaged in substantial gainful activity, step two requires the Commissioner to determine whether the claimant is suffering from a severe impairment or a combination of impairments that is severe. See 20 CFR § 416.920(a)(4)(ii) (mandating finding of non-disability when claimant’s impairments are not severe). If the claimant’s impairments are severe, the Commissioner, at step three, compares the claimant’s impairments to a list of impairments that are presumed severe enough to preclude any gainful work. See 20 CFR § 416.920(a)(4)(iii). When a claimant’s impairment or its equivalent matches an impairment in the listing, the claimant is presumed disabled. See 20 CFR § 416.920(a)(4)(iii). If a claimant’s impairment, either singly or in combination, fails to meet or medically equal any listing, the analysis continues to steps four and five. See 20 CFR § 416.920(e). At step four, the Commissioner determines whether the claimant retains the residual functional capacity (“RPC”) to perform her past relevant work. See 20 CFR § 416.920(a)(4)(iv) (stating claimant is not disabled if able to return to past relevant work). A claimant’s RFC is “that which an individual is still able to do despite the limitations caused by his or her. impairment(s).” Fargnoli v. Massanari, 247 F.3d 34, 40 (3d Cir.2001). “The claim, ant bears the burden of demonstrating an inability to return to her past relevant work.” Plummer v. Apfel, 186 F.3d 422, 428 (3d Cir.1999) (internal citation omitted). If the, claimant is unable to return to her past relevant work, step five requires the Commissioner to determine whether the claimant’s impairments. preclude her from adjusting to any other available work. ,See 20 CFR § 416.920(a)(4)(v) (mandating .finding of non-disability when claimant can adjust to other work); Plummer, 186 F.3d at 428. At this last step, the burden is on the Commissioner to show that the claimant is capable, of performing other available work before denying disability benefits. Id. at 428. In other words,' the Commissioner must prove that “there are other jobs existing in significant numbers in the national economy which the claimant can perform, consistent with [her] medical impairments, age, education, past work experience, and [RFC].” Id. In making this determination, the ALJ must analyze the cumulative effect of all of the claimant’s impairments. See id. At this step, the ALJ often seeks the assistance of a vocational expert. See id.Read the full opinion on CourtListener →
Section 416.920 requires disability claims to be evaluated sequentially: work activity, severity, listed impairment, past work, and—if necessary—other work considering vocational factors.
Lewis v. Barnhart · filed 2006-09-26(b) (c) (d) (e) (f)
An ALJ must engage in a five-step inquiry to determine whether the claimant is capable of performing “substantial gainful activity,” or is, in fact, disabled: ... 1. An individual who is working and engaging in substantial gainful activity will not be found disabled regardless of the medical findings. See 20 C.F.R. § 416.920(b). ... 2. An individual who does not have a “severe impairment” will not be found to be disabled. See 20 C.F.R. § 416.920(c). ... 3. An individual who “meets or equals a listed impairment in Appendix 1” of the regulations will be considered disabled without consideration of vocational factors. See 20 C.F.R. § 416.920(d). ... 4. If an individual is capable of performing the work she has done in the past, a finding of “not disabled” must be made. See 20 C.F.R. § 416.920(e). ... 5. If an individual’s impairment precludes performance of her past work, then other factors, including age, education, past work experience, and residual functional capacity must be considered to determine if any work can be performed. See 20 C.F.R. § 416.920(f).Read the full opinion on CourtListener →
Section 416.920 requires disability claims to be evaluated through a five-step sequential analysis, including whether the claimant can perform past relevant work.
Grasty v. Astrue · filed 2009-09-29
Pursuant to the relevant administrative framework, a finding of disability requires the following sequential analysis: (1) whether the claimant is currently employed; (2) whether the record demonstrates that claimant has a severe impairment; (3) whether the claimant’s impairment meets or equals the requirements of a listed impairment; (4) whether the claimant can perform past relevant work; and (5) if not, whether the claimant is able to perform other work, in view of his age, education, and work experience. See 20 C.F.R. § 416.920.Read the full opinion on CourtListener →
Section 416.920 establishes a five-step sequential process for deciding disability claims, including substantial gainful activity, severe impairment, listed impairments, and the ability to perform other work.
GRBA-CRAGHEAD v. Astrue · filed 2009-10-28(b), (c), (d), and (g)
Under the Social Security Act, the Commissioner has established a five-step process for determining whether a person is disabled. 20 C.F.R. §§ 416.920, 404.1529. ... In this sequential analysis, the claimant first cannot be engaged in "substantial gainful activity" to qualify for disability benefits. 20 C.F.R. §§ 416.920(b), 404.1520(b). Second, the claimant must have a severe impairment. 20 C.F.R. §§ 416.920(c), 404.1520(c). ... Third, the ALJ must determine whether the claimant has an impairment which meets or equals one of the impairments listed in the regulations. 20 C.F.R. §§ 416.920(d), 404.1520(d); Part 404, Subpart P, Appendix 1. ... Fifth, the severe impairment must prevent claimant from doing any other work. 20 C.F.R. §§ 416.920(g), 404.1520(g).Read the full opinion on CourtListener →
Section 416.920 requires an ALJ to evaluate disability claims sequentially, including whether the claimant is engaged in substantial gainful activity, has a severe impairment, meets a listed impairment, and can perform other work.
Bryan v. Commissioner Social Security · filed 2010-06-04(b), (c), (a)(iii), and (a)(v)
“[T]o decide whether [a claimant is] disabled” the ALJ engages in a “five-step sequential evaluation process.” 20 C.F.R. §§ 416.920(a)-(f). At Step One, the ALJ must determine whether the claimant is working or engaged in a substantial gainful activity. 20 C.F.R. §§ 416.920(b). If the claimant is not working or engaged in a substantial gainful activity, the ALJ next determines at Step Two whether the claimant is suffering from a “severe impairment which significantly limits his or her physical or mental ability to do basic work activity.” 20 C.F.R. § 416.920(c). If the claimant does not suffer from a “severe impairment,” a finding of not disabled is required. Schaudeck v. Commissioner of Social Sec. Admin., 181 F.3d 429. 431 (3d Cir. 1999). If Step Three is reached, the ALJ must ascertain whether this “severe impairment meets or equals criteria” set forth in the Social Security regulations listed in appendix 1 to subpart P of part 404. 20 C.F.R. § 416.920(a)(iii). If the ailment meets these standards, the claimant is considered disabled. If the claimant’s alleged disability is not listed in the Social Security regulations, the ALJ moves on to Step Four, where he determines whether the claimant has the “residual functional capacity” to perform his prior job. 20 C.F.R. § 416.920(a)(iv). ... Finally, if Step Five is reached, the ALJ must determine whether, considering the claimant’s residual functional capacity, age, education, and work experience, the claimant can engage in any other work available in the national economy. 20 C.F.R. § 416.920(a)(v).Read the full opinion on CourtListener →
Section 416.920 requires an ALJ to determine disability through a mandatory five-step sequential evaluation.
Dashnaw v. SSA · filed 2011-10-24
When determining whether a claimant is disabled, the ALJ is also required to make the following five inquiries: (1) whether the claimant is engaged in substantial gainful activity; (2) whether the claimant has a severe impairment; (3) whether the impairment meets or equals a listed impairment; (4) whether the impairment prevents the claimant from performing past relevant work; and (5) whether the impairment prevents the claimant from doing any other work. 20 C.F.R. § 404.1520. See also 20 C.F.R. § 416.920.Read the full opinion on CourtListener →
Section 416.920 requires an ALJ evaluating SSI disability to use a five-step sequential process, including determining at step three whether the claimant's impairment meets or equals a listed impairment.
Stratton v. Astrue · filed 2012-05-18
To decide whether a claimant is disabled for the purpose of determining eligibility for either DIB or SSI benefits, an ALJ is required to employ a five-step process. See 20 C.F.R. §§ 404.1520(DIB) and 416.920(SSI). The steps are: 1) if the [claimant] is engaged in substantial gainful work activity, the application is denied; 2) if the [claimant] does not have, or has not had within the relevant time period, a severe *142impairment or combination of impairments, the application is denied; 3) if the impairment meets the conditions for one of the “listed” impairments in the Social Security regulations, then the application is granted; 4) if the [claimant’s] “residual functional capacity” is such that he or she can still perform past relevant work, then the application is denied; 5) if the [claimant], given his or her residual functional capacity, education, work experience, and age, is unable to do any other work, the application is granted.Read the full opinion on CourtListener →
Section 416.920 uses a five-step sequential evaluation, and Step Two permits ending a disability claim only when medical evidence shows slight abnormalities having no more than a minimal effect on the claimant’s ability to work.
George v. SSA · filed 2012-06-07
Step Two was designed to implement “a threshold test of medical severity to screen out groundless claims - i.e., those claims that, on a common sense basis, would clearly be disallowed were vocational factors to be considered.” ... A finding that a claimant is not disabled at this step of the analysis is appropriate only “when medical evidence establishes only a slight abnormality or a combination of slight abnormalities which would have no more than a minimal effect on an individual’s ability to work.”Read the full opinion on CourtListener →
Section 416.920 requires disability claims to be evaluated through a five-step sequential process, including severity, listed impairments, past relevant work, and other work.
Branson v. Astrue · filed 2010-01-05(c), (d), (e), and (g)
Under the Social Security Act, the Commissioner has established a five-step process for determining whether a person is disabled. 20 C.F.R. §§ 416.920, 404.1529. "`If a claimant fails to meet the criteria at any step in the evaluation of disability, the process ends and the claimant is determined to be not disabled.'" Goff v. Barnhart, 421 F.3d 785, 790 (8th Cir.2005) (quoting Eichelberger v. Barnhart, 390 F.3d 584, 590-91 (8th Cir.2004)). In this sequential analysis, the claimant first cannot be engaged in "substantial gainful activity" to qualify for disability benefits. 20 C.F.R. § § 416.920(b), 404.1520(b). Second, the claimant must have a severe impairment. 20 C.F.R. §§ 416.920(c), 404.1520(c). The Social Security Act defines "severe impairment" as "any impairment or combination of impairments which significantly limits [claimant's] physical or mental ability to do basic work activities...." Id. "The sequential evaluation process may be terminated at step two only when the claimant's impairment or *951 combination of impairments would have no more than a minimal impact on [his or] her ability to work." Page v. Astrue, 484 F.3d 1040, 1043 (8th Cir. 2007) (quoting Caviness v. Massanari, 250 F.3d 603, 605 (8th Cir. 2001) (citing Nguyen v. Chater, 75 F.3d 429, 430-31 (8th Cir.1996))). Third, the ALJ must determine whether the claimant has an impairment which meets or equals one of the impairments listed in the Regulations. 20 C.F.R. §§ 416.920(d), 404.1520(d); Part 404, Subpart P, Appendix 1. If the claimant has one of, or the medical equivalent of, these impairments, then the claimant is per se disabled without consideration of the claimant's age, education, or work history. Id. Fourth, the impairment must prevent claimant from doing past relevant work. 20 C.F.R. §§ 416.920(e), 404.1520(e). The burden rests with the claimant at this fourth step to establish his or her RFC. Eichelberger, 390 F.3d at 590-91; Masterson v. Barnhart, 363 F.3d 731, 737 (8th Cir.2004); Young v. Apfel, 221 F.3d 1065, 1069 n.5 (8th Cir.2000). The ALJ will review a claimant's residual functional capacity and the physical and mental demands of the work the claimant has done in the past. 20 C.F.R. § 404.1520(f). Fifth, the severe impairment must prevent claimant from doing any other work. 20 C.F.R. §§ 416.920(g), 404.1520(g). At this fifth step of the sequential analysis, the Commissioner has the burden of production to produce evidence of other jobs in the national economy that can be performed by a person with the claimant's RFC. Young, 221 F.3d at 1069 n.5. If the claimant meets these standards, the ALJ will find the claimant to be disabled.Read the full opinion on CourtListener →
Section 416.920(a) provides the framework for evaluating disability claims through the regulatory sequential evaluation process.
Halloran v. Colvin · filed 2013-08-08(a)
The ALJ’s disability determination under § 416.920(a) did not impermissibly place the burden on the plaintiff to show that he remained disabled. ... Under the regulations, the burden is on the agency to make this showing; if it cannot do so, the claimant will receive benefits. ... The Court agrees with the Magistrate that substantial evidence supports the ALJ’s finding that the agency carried its burden on this issue.Read the full opinion on CourtListener →
Section 416.920 establishes a five-step sequential evaluation for deciding whether a claimant is disabled, including assessment of residual functional capacity and ability to perform past or other work.
Henry v. Commissioner of Social Security · filed 2013-09-21
The Commissioner’s regulations governing the evaluation of disability for DIB and SSI are identical for purposes of this case, and are found at 20 C.F.R. §§ 404.1520 and 416.920. ... The Commissioner uses a five-step sequential evaluation process to evaluate a DIB or SSI claim. First, a claimant must demonstrate he is not engaged in “substantial gainful activity” at the time he seeks disability benefits. ... Prior to considering step four, the Commissioner must determine a claimant’s residual functional capacity. ... The Commissioner must next determine whether the claimant has the residual functional capacity to perform the requirements of his past relevant work. 20 C.F.R. §§ 404.1520(f), 416.920(f). If he does, the claimant is not disabled. ... Finally, even if the claimant’s impairment does prevent him from doing past relevant work, the claimant will not be considered disabled if other work exists in the national economy that he can perform. ... A dispositive finding by the Commissioner at any point in the five-step process terminates the review. Colvin, 475 F.3d at 730 (citing 20 C.F.R. §§ 404.1520(a)(4), 416.920(a)(4)).Read the full opinion on CourtListener →
Section 416.920 requires an ALJ to evaluate an SSI disability claim through a five-step sequence, including determining whether the claimant has a severe impairment and whether the claimant can perform other work in the national economy.
Brown v. Colvin · filed 2014-09-10(c), (g)
The Regulations set forth a five-step process to be followed when a disability claim comes before an ALJ for evaluation of the claimant’s eligibility for benefits. See 20 C.F.R. § 416.920. First, the ALJ must determine whether the claimant is presently engaged in substantial gainful activity. If the claimant is not, the ALJ must decide if the claimant has a “severe” impairment, which is an impairment or combination of impairments that “significantly limits [the claimant’s] physical or mental ability to do basic work activities.... ” 20 C.F.R. § 416.920(c). If the claimant’s impairment is severe, the ALJ then determines whether it meets or equals the criteria of an impairment found in the Listings. If the impairment meets or equals a listed impairment, the claimant will be found to be disabled. If the claimant does not have a listed impairment, the fourth step requires the ALJ to determine if, notwithstanding the impairment, the claimant is capable of performing his or her past relevant work. Finally, if the claimant is not capable of performing his or her past relevant work, the fifth step requires the ALJ to determine whether the claimant is capable of performing other work which exists in the national economy, considering the claimants age, education, past work experience, and residual functional capacity. See Curry v. Apfel, 209 F.3d 117, 122 (2d Cir. 2000); Reyes v. Massanari, 2002 WL 856459, at *3 (S.D.N.Y. April 2, 2002); 20 C.F.R. § 416.920(g).Read the full opinion on CourtListener →
Section 416.920 requires the disability determination to proceed through the sequential evaluation, including step five when a claimant cannot perform past relevant work, to determine whether the claimant can adjust to other work.
Villalobos v. Colvin · filed 2018-10-15
This argument is without merit and, as the Commissioner points out, Claimant seems to have a fundamental misunderstanding of the sequential process. The ALJ’s inquiry does not end at step four. See 20 C.F.R. § 416.920 (explaining that if an individual is found not capable of returning to past work, the ALJ proceeds to step five to see if the individual can make an adjustment to other work). Although, at step four, the ALJ found Claimant was not capable of performing his past work, the ALJ properly proceeded to step five.Read the full opinion on CourtListener →
Section 416.920 requires a sequential evaluation of disability claims, and benefits are available only when the claimant cannot perform other work.
Taviere v. Commissioner of Social Security · filed 2019-09-03(a), (g)
These regulations establish a “sequential evaluation process” to determine whether a claimant is disabled. 20 C.F.R. § 416.920. If an individual is found disabled at any point in the sequential review, further inquiry is unnecessary. 20 C.F.R. § 416.920(a). ... A claimant is entitled to benefits only if unable to perform other work. Bowen v. Yuckert, 482 U.S. 137, 140–42 (1987); 20 C.F.R. § 416.920(g).Read the full opinion on CourtListener →
Section 416.920(a) requires disability claims to be evaluated through the sequential steps, and § 416.920(g) permits benefits only when the claimant cannot perform other work.
Besso v. Commissioner of Social Security · filed 2020-03-17(a), (g)
These regulations establish a “sequential evaluation process” to determine whether a claimant is disabled. 20 C.F.R. § 416.920. If an individual is found disabled at any point in the sequential review, further inquiry is unnecessary. 20 C.F.R. § 416.920(a). Under this process, the ALJ must determine, in sequence, the following: (1) whether the claimant is currently engaged in substantial gainful activity; (2) whether the claimant has a severe impairment, i.e., one that significantly limits the ability to perform work-related functions; (3) whether the severe impairment meets or equals the medical criteria of 20 C.F.R. Part 404, Subpart P, Appendix 1; and, (4) whether the claimant can perform his or her past relevant work. If the claimant cannot perform the tasks required of his or her prior work, step five of the evaluation requires the ALJ to decide if the claimant can do other work in the national economy in view of the claimant’s age, education, and work experience. 20 C.F.R. § 416.920(a). A claimant is entitled to benefits only if unable to perform other work. Bowen v. Yuckert, 482 U.S. 137, 140–42 (1987); 20 C.F.R. § 416.920(g).Read the full opinion on CourtListener →
Section 416.920(a)(4) establishes a sequential five-step disability evaluation and permits the agency to stop once it finds the claimant disabled or not disabled at a step.
Molina v. Saul · filed 2020-08-07(a)(4)
Accordingly, the ALJ found that Molina was not disabled within the meaning of the Social Security Act and did not proceed to step five. (R. 188); see 20 C.F.R. § 416.920(a)(4) (“If we can find that you are disabled or not disabled at a step, we make our determination or decision and we do not go on to the next step.”).Read the full opinion on CourtListener →
Section 416.920 establishes a sequential evaluation process for disability claims, ending with a step-five determination whether a claimant unable to perform past work can perform other work in the national economy; if disability is found at any step, further inquiry is unnecessary.
Boone v. Commissioner of Social Security · filed 2021-01-26(a), (g)
The Social Security Administration, to regularize the adjudicative process, promulgated the detailed regulations currently in effect. These regulations establish a “sequential evaluation process” to determine whether a claimant is disabled. 20 C.F.R. § 416.920. If an individual is found disabled at any point in the sequential review, further inquiry is unnecessary. 20 C.F.R. § 416.920(a). Under this process, the ALJ must determine, in sequence, the following: whether the claimant is currently engaged in substantial gainful activity; whether the claimant has a severe impairment, i.e., one that significantly limits the ability to perform work-related functions; whether the severe impairment meets or equals the medical criteria of 20 C.F.R. Part 404 Subpart P, Appendix 1; and whether the claimant can perform his or her past relevant work. If the claimant cannot perform the tasks required of his or her prior work, step five of the evaluation requires the ALJ to decide if the claimant can do other work in the national economy in view of his or her age, education, and work experience. 20 C.F.R. § 416.920(a). A claimant is entitled to benefits only if unable to perform other work. Bowen v. Yuckert, 482 U.S. 137, 140-42 (1987); 20 C.F.R. § 416.920(g).Read the full opinion on CourtListener →
Section 416.920 requires an ALJ to use a five-step sequential evaluation of disability; if the claimant meets or equals the Step 3 standard, the inquiry ends with a finding of disability, and otherwise the evaluation proceeds.
Vasquez v. Saul · filed 2021-03-24(a)(4)
ALJs are required to follow a sequential five-step test to assess whether a claimant is legally disabled. The ALJ must determine: (1) whether the claimant is currently engaged in substantial gainful activity; (2) whether the claimant has a severe impairment; and (3) whether the severe impairment or combination of impairments meets or equals one considered conclusively disabling such that the claimant is impeded from performing basic work-related activities. 20 C.F.R. § 404.1520; 20 C.F.R. § 404.1523; 20 C.F.R. § 404.1545; 20 C.F.R. § 416.920(a)(4)(i)-(v). If the impairment(s) does meet or equal this standard, the inquiry is over and the claimant is disabled. 20 C.F.R. § 416.920(a)(4). If not, the evaluation continues and the ALJ must determine (4) whether the claimant is capable of performing his past relevant work.Read the full opinion on CourtListener →
Section 416.920(a) establishes a five-step sequential evaluation for disability claims, and § 416.920(e) requires the ALJ to assess residual functional capacity and past relevant work at step four before proceeding to step five.
(SS)Martinez v. Commissioner of Social Security · filed 2021-07-12(a), (e)
To achieve uniformity in the decision-making process, the Commissioner has established a sequential five-step process for evaluating a claimant’s alleged disability. 20 C.F.R. §§ 416.920(a)-(f). ... Accounting clerk was the only job identified by the ALJ at step four, and she did not proceed to step five. Thus, her conclusion that Plaintiff was not disabled is unsupported. ... Remand is therefore appropriate for the ALJ to determine at step four whether Plaintiff can perform any past work considering her RFC and, if not, to determine at step five if she can perform any jobs existing in significant numbers in the national economy.Read the full opinion on CourtListener →
Section 416.920 requires disability claims to be evaluated through five sequential steps, with the claimant bearing the burden through step four and the Commissioner at step five.
Young v. Commissioner of Social Security Administration · filed 2021-07-28(b)-(f)
The Commissioner follows a five-step evaluation process—found at 20 C.F.R. § 416.920—to determine if a claimant is disabled: ... Under this five-step sequential analysis, the claimant has the burden of proof in Steps One through Four. Walters, 127 F.3d at 529. The burden shifts to the Commissioner at Step Five to establish whether the claimant has the RFC to perform available work in the national economy. Id. The ALJ considers the claimant’s RFC, age, education, and past work experience to determine if the claimant could perform other work. Id. Only those claimants who satisfy each element of the analysis, including inability to do other work, and meet the duration requirements, are determined to be disabled. 20 C.F.R. § 416.920(b)-(f) see also Walters, 127 F.3d at 529.Read the full opinion on CourtListener →
Section 416.920 requires an ALJ to use a five-step sequential evaluation, including determining at steps one, three, and four whether the claimant is working, meets or equals a listed impairment, and can perform past relevant work.
Robinson v. Commissioner of Social Security · filed 2021-08-20(a)(4)(i), (a)(4)(iii), (a)(4)(iv)
The ALJ must follow five steps in evaluating a claim of disability. 20 C.F.R. §§ 404.1520, 416.920. At the first step, the ALJ must determine whether the claimant is currently engaged in substantial gainful employment. 20 C.F.R. § 404.1520(a)(4)(i), (b); 20 C.F.R. § 416.920(a)(4)(i), (b). At step two, the ALJ must determine whether the impairment or combination of impairments from which the claimant allegedly suffers is “severe.” 20 C.F.R. § 404.1520(a)(4)(ii), (c); 20 C.F.R. § 416.920(a)(4)(ii), (c). At step three, the ALJ must decide whether the claimant’s severe impairments meet or medically equal a listed impairment. 20 C.F.R. § 404.1520(a)(4)(iii), (d); 20 C.F.R. § 416.920(a)(4)(iii), (d). If the ALJ finds the claimant’s severe impairments do not meet or medically equal a listed impairment, then the ALJ must determine whether the claimant has the residual functional capacity (“RFC”) to perform his past relevant work. 20 C.F.R. § 404.1520(a)(4)(iv), (e)–(f); 20 C.F.R. § 416.920(a)(4)(iv), (e)–(f).Read the full opinion on CourtListener →
At step two, an ALJ need only find one severe impairment to proceed to step three, but must then consider all of the claimant’s limitations when assessing residual functional capacity.
Basile v. Commissioner of Social Security · filed 2021-09-03(a)(4)(ii)
At step two, an ALJ considers the severity of a claimant’s impairments. 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii). ... This inquiry “acts as a filter in that the finding of any severe impairment ... is enough to satisfy the requirement of step two and allow the ALJ to proceed to step three.” ... With step two satisfied, the issue then becomes whether the ALJ considered all of Plaintiff’s limitations in assessing the RFC. ... For these reasons, even if the ALJ erred at step two by not including additional severe impairments, the error was harmless because the ALJ discussed additional impairments in the decision and included limitations in the RFC for all of Plaintiff’s impairments.Read the full opinion on CourtListener →
Section 416.920 requires an ALJ to use a five-step sequential inquiry to determine whether a claimant is disabled.
Taylor v. Commissioner Social Security Administration · filed 2022-01-03
The ALJ engages in a five-step sequential inquiry to determine whether a claimant is disabled within the meaning of the Act. 20 C.F.R. § 416.920; Lounsburry v. Barnhart, 468 F.3d 1111, 1114 (9th Cir. 2006) (discussing Tackett v. Apfel, 180 F.3d 1094, 1098-99 (9th Cir. 1999)).Read the full opinion on CourtListener →
Section 416.920(a)(4) requires the Commissioner to stop the sequential disability evaluation once a claimant is found disabled or not disabled at a step.
Shepard v. Commissioner of the Social Security Administration · filed 2022-03-17(a)(4)
If a decision regarding disability may be made at any step, no further inquiry is necessary. 20 C.F.R. § 416.920(a)(4) (providing that if Commissioner can find claimant disabled or not disabled at a step, Commissioner makes determination and does not go on to the next step).Read the full opinion on CourtListener →
Section 416.920 establishes a five-step sequential disability evaluation, and subsection (a)(4) ends the inquiry once the Commissioner can find the claimant disabled or not disabled at a step.
Tripp v. Commissioner of the Social Security Administration · filed 2022-06-14(a)(4)
To facilitate a uniform and efficient processing of disability claims, regulations promulgated under the Act have reduced the statutory definition of disability to a series of five sequential questions. See, e.g., Heckler v. Campbell, 461 U.S. 458, 460 (1983) (discussing considerations and noting “need for efficiency” in considering disability claims). An examiner must consider the following: (1) whether the claimant is working; (2) whether the claimant has a severe impairment; (3) whether that impairment meets or equals an impairment included in the Listings;4 (4) whether such impairment prevents claimant from performing PRW; and (5) whether the impairment prevents the claimant from performing specific jobs that exist in significant numbers in the national economy. See 20 C.F.R. § 416.920. These considerations are sometimes referred to as the “five steps” of the Commissioner’s disability analysis. If a decision regarding disability may be made at any step, no further inquiry is necessary. 20 C.F.R. § 416.920(a)(4) (providing that if Commissioner can find claimant disabled or not disabled at a step, Commissioner makes determination and does not go on to the next step).Read the full opinion on CourtListener →
Section 416.920 requires a five-step disability inquiry: after evaluating substantial gainful activity, severity, and the Listings, the Commissioner assesses residual functional capacity and past work, then must determine whether the claimant can perform other work existing in significant numbers; 12,241 jobs satisfied that step-five requirement on this record.
Maldonado v. Commissioner of Social Security · filed 2023-01-18(4)(i) (4)(ii) (4)(iii) (4)(iv) (4)(v)
To determine whether an individual is disabled and therefore entitled to disability benefits, the Commissioner conducts a five-step inquiry. 20 C.F.R. § 416.920. First, the Commissioner must determine whether the claimant is currently engaged in any substantial gainful activity. 20 C.F.R. § 416.920(4)(i), (b). If so, the claimant is not eligible for benefits and the inquiry ceases. If the claimant is not engaged in any such activity, the Commissioner proceeds to the second step and must determine whether the claimant has a “severe impairment,” which is an impairment or combination of impairments that significantly limits the claimant’s ability to perform basic work activities. 20 C.F.R. § 416.920(4)(ii), (c). If the claimant does not have an impairment or combination of impairments that are “severe,” the claimant is not entitled to benefits and the inquiry ends. ... If the claimant has a severe impairment or combination of impairments, the Commissioner continues to step three and must determine whether the impairment or combinations of impairments is, or medically equals, one of those included in the “Listings” of the regulations contained at 20 C.F.R. Part 404, Subpart P, Appendix 1. If the claimant’s impairment or impairments meet or medically equal one of those listings, the Commissioner will presume the claimant to be disabled, and the claimant will be eligible for benefits. 20 C.F.R. § 416.920(4)(iii), (d). If the claimant does not meet the criteria for being presumed disabled, the Commissioner continues to step four and must assess the claimant’s residual functional capacity (“RFC”), which is the claimant’s ability to perform physical and mental work activities on a sustained basis despite his or her impairments. The Commissioner then determines whether the claimant possesses the RFC to perform the claimant’s past work. 20 C.F.R. § 416.920(4)(iv), (f), (h). If so, the claimant is not eligible for benefits and the inquiry stops. If the claimant is not capable of performing prior work, the Commissioner must continue to step five and determine whether the claimant is capable of performing other available work. 20 C.F.R. § 416.920(4)(v), (g), (h). If the claimant, as limited by her RFC, can perform other available work, the claimant is not entitled to benefits. 20 C.F.R. § 416.920(a)(4)(iv), (v). ... At step five, the ALJ must identify the types of jobs the claimant could perform notwithstanding his disabilities and must “ascertain whether those kinds of jobs ‘exist[ed] in significant numbers in the national economy.’” ... In short, the ALJ’s determination at step five is consistent with the weight of authority in and outside of this Circuit and satisfies the burden of showing that there are relevant jobs in significant numbers nationally. ... Under the existing framework, and on the basis of the record in this case, the Commissioner has satisfied its burden at step five of the sequential analysis. If, however, on remand the ALJ modifies his RFC finding based on the December 2020 MRI, the ALJ will need to conduct a new step five analysis.Read the full opinion on CourtListener →
Section 416.920(a)(4) requires a five-step sequential disability inquiry; at step two, omitting one impairment is harmless when other severe impairments allow the ALJ to continue through the remaining steps.
Harris v. Social Security Administration, Commissioner · filed 2023-09-13(a)(4)
When a claim for disability benefits reaches an ALJ as part of the administrative process, the ALJ follows a five-step sequential analysis to determine whether the claimant is disabled. The ALJ must determine the following: (1) whether the claimant is engaged in substantial gainful activity; (2) if not, whether the claimant has a severe impairment or combination of impairments; (3) if so, whether that impairment or combination of impairments meets or equals any “Listing of Impairments” in the Social Security regulations; (4) if not, whether the claimant can perform his past relevant work in light of his “residual functional capacity” or “RFC”; and (5) if not, whether, based on the claimant’s age, education, and work experience, he can perform other work found in the national economy. 20 C.F.R. § 416.920(a)(4); see Winschel v. Commissioner of Soc. Sec. Admin., 631 F.3d 1176, 1178 (11th Cir. 2011). ... Here, at step two of the sequential process, the ALJ did not specifically include bipolar disorder in the list of Harris’s severe impairments; rather, the ALJ found that Harris had severe impairments of “anxiety, depression, lumbar degenerative disc disease with radiculopathy, and obesity.” ... However, any error in excluding Harris’s bipolar disorder from the list of impairments was harmless. “Step two of the [sequential] test merely ‘acts as a filter’” because, if any severe impairment or combination of severe impairments is found, that is enough for the ALJ to “proceed with the rest of the five-step analysis.” ... In this case, the ALJ found that Harris had multiple severe impairments, then proceeded to the next steps in evaluating Harris’s disability claim.Read the full opinion on CourtListener →
Section 416.920(a)(4)(i) requires the Commissioner first to determine whether the claimant is engaged in substantial gainful activity, while § 416.920(a)(4)(iv) requires determining whether the claimant's residual functional capacity permits performance of past relevant work.
Harris v. Commissioner Social Security Administration · filed 2024-07-12(a)(4)(i), (a)(4)(iv)
The Commissioner must follow five steps in evaluating a claim of disability. 20 C.F.R. §§ 404.1520, 416.920. At the first step, the Commissioner must determine whether the claimant is currently engaged in substantial gainful employment. 20 C.F.R. § 404.1520(a)(4)(i), (b); 20 C.F.R. § 416.920(a)(4)(i), (b). At step two, the Commissioner must determine whether the impairment or combination of impairments from which the claimant allegedly suffers is “severe.” 20 C.F.R. § 404.1520(a)(4)(ii), (c); 20 C.F.R. § 416.920(a)(4)(ii), (c). At step three, the Commissioner must decide whether the claimant’s severe impairments meet or medically equal a listed impairment. 20 C.F.R. § 404.1520(a)(4)(iii), (d); 20 C.F.R. § 416.920(a)(4)(iii), (d). If the Commissioner finds the claimant’s severe impairments do not meet or medically equal a listed impairment, then the Commissioner must determine whether the claimant has the residual functional capacity (“RFC”) to perform his past relevant work. 20 C.F.R. § 404.1520(a)(4)(iv), (e)–(f); 20 C.F.R. § 416.920(a)(4)(iv), (e)–(f).Read the full opinion on CourtListener →
Section 416.920(a)(4) requires the Commissioner to evaluate SSI claims through five sequential steps, and subsection (a)(4)(v) places the step-five burden on the Commissioner to show that the claimant can perform other work existing in significant numbers in the national economy.
Baker v. O'Malley · filed 2024-10-07(a)(4), (a)(4)(v)
The Commissioner uses a five-step process in evaluating SSI claims. See 20 C.F.R. § 416.920 (2023). See also Heckler v. Campbell, 461 U.S. 458, 460-62 (1983); Hall v. Harris, 658 F.2d 260, 264-65 (4th Cir. 1981). This process requires the Commissioner to consider, in order, whether a claimant 1) is working; 2) has a severe impairment; 3) has an impairment that meets or equals the requirements of a listed impairment; 4) can return to her past relevant work; and 5) if not, whether she can perform other work. See 20 C.F.R. § 416.920. If the Commissioner finds conclusively that a claimant is or is not disabled at any point in this process, review does not proceed to the next step. See 20 C.F.R. § 416.920(a)(4) (2023). ... As stated herein, at step five of the sequential disability evaluation, the burden shifts to the Commissioner to demonstrate that there is other work, existing in significant numbers in the national economy, that a claimant can perform, given her residual functional capacity. See 20 C.F.R. §§ 416.920(a)(4)(v), 416.960(c)(2) and 416.966 (2023).Read the full opinion on CourtListener →
Section 416.920(a) establishes the sequential disability-evaluation process, under which step two asks whether a medically determinable impairment is severe and more than minimally limits the claimant’s ability to work.
Lawton v. Dudek · filed 2025-04-09(a)
At step two, the ALJ determines whether the claimant suffers from a “severe” impairment, i.e., one that significantly limits his physical or mental ability to do basic work activities. This involves a two-step process: 1) determining whether the claimant has a medically determinable impairment, and 2) if so, determining whether the impairment is severe. To be severe, the medical evidence must establish that the impairment would have more than a minimal effect on the claimant’s ability to work.Read the full opinion on CourtListener →
Section 416.920 requires the ALJ to determine whether the claimant has a severe impairment, whether the impairment meets or equals a listed impairment, and, if not, to assess residual functional capacity using all relevant medical and other evidence.
Hollinger · filed 2026-01-12(a)(4)(ii), (a)(4)(iii), (e)
At step two, an ALJ considers the severity of a claimant’s impairments. 20 C.F.R. § 416.920(a)(4)(ii). ... At step three, an ALJ must consider whether a claimant’s medical impairments meet or equal one of the listed impairments. 20 C.F.R. § 416.920(a)(4)(iii). ... If a claimant’s impairments do not meet or equal a listing, an ALJ must determine the claimant’s RFC by considering all relevant medical and other evidence. 20 C.F.R. § 416.920(e).Read the full opinion on CourtListener →
Section 416.920(a) requires a five-step disability evaluation, including a step-three determination of whether the claimant's impairment meets or equals a listed impairment, supported by an explanation permitting meaningful review.
Buckley · filed 2026-01-28(a)(4)(iii)
In evaluating whether a claimant is disabled as defined in the Social Security Act, the Commissioner follows a five-step sequential evaluation process. 20 C.F.R. § 416.920(a). Under this process, the Commissioner must determine, in sequence: (1) whether the claimant is engaged in substantial gainful activity; (2) whether the claimant has a severe impairment; (3) whether the claimant's impairment meets or equals a listed impairment; (4) whether the claimant is able to do past relevant work, considering his or her residual functional capacity (“RFC”); and (5) whether the claimant is able to do any other work that exists in significant numbers in the national economy, considering his or her RFC, age, education, and work experience. 20 C.F.R. § 416.920(a). ... We cannot say that substantial evidence supports the ALJ’s conclusion that Ms. B.’s migraines do not meet or equal a listing. Unfortunately, the ALJ’s failure to specifically reference and discuss Listings 11.02B and 11.02D significantly hinders our ability to perform a meaningful review of that conclusion.Read the full opinion on CourtListener →
Section 416.920 requires a claimant to have a severe impairment satisfying the duration requirement at step two, and at step five places on the Commissioner the burden to show that the claimant can perform a significant number of jobs in the national economy considering the claimant’s RFC, age, education, and work experience.
Strain · filed 2026-02-11(a)(4)(ii), (a)(4)(v), and (g)
Clearly, Plaintiff has confused the ALJ’s step two severity findings with her step five disability findings. The purpose of the step two assessment is to determine whether a claimant has at least one severe medically determinable physical or mental impairment that satisfies the duration requirement. 20 C.F.R. § 416.920(a)(4)(ii); ... If an impairment only minimally affects a claimant’s physical or mental ability to do “basic work activities” it is considered a non-severe impairment. ... Thus, the assessment at step two filters out disability claims that are totally groundless from a medical standpoint. ... Here, the ALJ found that Plaintiff has a severe physical impairment—fibromyalgia—and five severe mental impairments—mood disorder, anxiety disorder, post-traumatic stress disorder, and borderline personality disorder (Tr. 22). Consequently, the ALJ moved on to the remaining steps in the disability evaluation process. See Maziarz, 837 F.2d at 244. ... At the fifth step, the Commissioner has the burden to demonstrate a significant number of jobs exist in the national economy that a claimant can perform, given her RFC, age, education, and past work experience. 20 C.F.R. §§ 416.920(a)(4)(v) and (g), 416.966(a); Wyatt v. Sec’y of Health & Hum. Servs., 974 F.2d 680, 684 (6th Cir. 1992); Moon v. Sullivan, 923 F.2d 1175, 1181 (6th Cir. 1990); Allen v. Califano, 613 F.2d 139, 145 (6th Cir. 1980). As Plaintiff’s RFC did not coincide with the criteria of a particular Grid Rule, the regulations limited the ALJ’s use of the Grid Rule to a framework in the decision-making process and she relied on the testimony of the vocational expert to make the disability determination (Tr. 29-30). ... Consequently, because the vocational expert was able to identify a significant number of jobs which Plaintiff could perform, the Commissioner met her burden (Tr. 29-30). See Blacha v. Sec’y of Health & Human Servs., 823 F.2d 922, 928 (6th Cir. 1987).Read the full opinion on CourtListener →
Severity step in sequential evaluation
Law changed since The Supreme Court upheld the severity step in Bowen v. Yuckert (June 8, 1987), rejecting this ruling that § 416.920(c) conflicts with the Social Security Act.
Section 416.920(c)'s severity step is invalid because it substitutes a medical-only basic-work-activities threshold for the statutory previous-work inquiry and thereby increases the claimant's burden.
Moody v. Heckler · filed 1985-06-24(c)
The regulation, however, does not use language applicable to a de minimus threshold standard. The “severity step” does not describe non-severe impairments as those with such a minimal effect that they would not interfere with a claimant’s ability to work regardless of age, education, and work experience. Instead, the regulation requires proof by medical factors of a “severe” impairment which limits basic work abilities without consideration of age, education, and work experience. ... Similarly, the regulation’s reference to “basic work activities” is inconsistent with the Act’s reference to “previous work.” Consequently, the application of the “basic work activities” standard impermissibly increases the burden on the claimant in establishing a prima facie case of disability. Such a prima facie case is established simply by a showing that an impairment prevents a claimant from performing his or her relevant previous work.Read the full opinion on CourtListener →
Section 416.920(d) ends the sequential evaluation at step three when a claimant meets or medically equals a listed impairment, making the claimant presumptively disabled without considering age, education, or work experience.
Pitzer v. Sullivan · filed 1990-07-13(d)
The third question in the inquiry is whether the claimant’s impairment meets or equals one of the medical listings given in 20 C.F.R. Part 404, Subpt. P, App. 1. If a claimant meets a listing or if his or her condition is medically equivalent to a listing, then he or she is presumptively disabled, without consideration of age, education, and work experience. 20 C.F.R. § 416.920(d); Winans v. Bowen, 853 F.2d 643, 647 (9th Cir.1987).Read the full opinion on CourtListener →
Section 416.920 requires a sufficiently detailed five-step analysis before an agency may decide whether an applicant is entitled to benefits.
Carosharo v. DHRS · filed 1992-05-18
We reverse and remand for further proceedings because the appealed order fails to set forth in sufficient detail the five-step analysis required by 20 C.F.R. § 416.920 and the analysis required by 20 C.F.R. § 404, Appendix 2, Subpart P, Rule 202.03 (1991), as a predicate to the hearing officer's decision approving the denial of the claimed benefits.Read the full opinion on CourtListener →
Section 416.920(c)'s step-two severity determination cannot bar consideration of vocational factors or a claimant’s residual functional capacity.
Campbell v. Heckler · filed 1985-10-21(c)
The regulations at 20 C.F.R. §§ 404.1520(c), 404.1521, 416.920(c), 416.-921, SSR 82-55 and SSR 82-56 are in conflict with 42 U.S.C. §§ 423(d)(2)(A) and 1382c(a)(3)(B) insofar as the regulations and rulings do not allow for consideration of vocational factors, or a claimant’s residual functional capacity in determining the severity of an impairment. ... It is declared that the regulations at 20 C.F.R. §§ 404.1520(c), 404.1521, 416.-920(c), 416.921 and SSR 82-55 and those portions of SSR 82-56 relating to non-severe impairments are in conflict with 42 U.S.C. §§ 423(d)(2)(A) and 1382c(a)(3)(B) and are invalid.Read the full opinion on CourtListener →
Section 416.920(c) requires an impairment or combination of impairments to significantly limit a claimant’s ability to perform basic work activities before the claimant can qualify for disability benefits.
Charles R. GROSS, Appellant, v. Margaret HECKLER, Secretary of Health and Human Services, Appellee · filed 1986-02-27(c)
In order to qualify for disability benefits, an applicant must have an “impairment or combination of impairments which significantly limits [his] physical or mental ability to do basic work activities.” 20 C.F.R. § 416.920(c). ... We believe that there is substantial evidence to support the Appeals Council’s finding that Gross’ impairments were not severe, that he was capable of gainful employment, and that he was therefore not entitled to disability benefits.Read the full opinion on CourtListener →
Section 416.920 treats a claimant with no severe impairment as not disabled without further inquiry, while a severe impairment may require consideration of vocational factors.
Webber v. Secretary, Health & Human Services · filed 1986-02-13(c), (d)
If reduced intellectual functioning were the only impairment from which Webber allegedly suffered, the Appeals Council could have properly relied on Ruling 82-55 to conclude that Webber is not disabled, because an individual who does not have a “severe” impairment is considered “not disabled” without further inquiry. See 20 C.F.R. § 416.920(c) (1985). The Appeals Council determined, however, that although Webber’s physical impairments do not render her disabled without consideration of her vocational factors, see 20 C.F.R. § 416.920(d), these impairments are nonetheless “severe.”Read the full opinion on CourtListener →
At the final step, the Commissioner must show that a claimant can perform other work existing in significant numbers in the national economy, and vocational evidence must account for the claimant’s credibly established nonexertional limitations.
Whitmore v. Barnhart · filed 2007-01-09(g)
The court finds that plaintiffs subjective complaints of pain and fatigue are credibly established nonexertional limitations; therefore, under Sykes and the Agency’s Acquiescence Ruling, the ALJ was required to rely on more than just the grids themselves in making her determination that plaintiff was capable of performing medium work despite his headaches and fatigue. The ALJ looked outside of the grids by employing a vocational expert; however, her hypothetical question made no mention of plaintiffs claims of disabling pain and fatigue. Because the ALJ failed to elicit the vocational expert’s opinion on the potential effects of said nonexertional limitations, her hypothetical question was “deficient.” As a result, the expert’s finding that there were jobs in the local and national economies that plaintiff was capable of performing “cannot be considered substantial evidence.”Read the full opinion on CourtListener →
At step three of the sequential evaluation, the ALJ must consider whether the claimant’s impairments meet or equal a listed impairment.
McFarland v. Astrue · filed 2008-07-25(a)(4)(iii)
Step three requires an ALJ to consider whether a claimant’s impairments meet or equal a listed impairment. 20 C.F.R. § 416.920(a)(4)(iii). We find the ALJ gave a sufficient explanation for his finding that McFarland’s impairments neither singularly nor in combination met or equaled a listing.Read the full opinion on CourtListener →
At step three, § 416.920(a)(4)(iii) requires the adjudicator to determine whether the claimant's impairments meet or equal a listed impairment.
Ellinghausen v. Commissioner of Social Security · filed 2020-06-25(a)(4)(iii)
At step three of the sequential evaluation of disability, the ALJ must determine if a claimant's impairments meet or equal a listed impairment. 20 C.F.R. § 416.920(a)(4)(iii).Read the full opinion on CourtListener →
Section 416.920 establishes a five-step disability evaluation in which step two asks whether the claimant has a severe impairment that significantly limits basic work activities, and a step-two finding cannot justify ignoring the impairment at later steps.
WILLIAMS v. COMMISSIONER OF SOCIAL SECURITY · filed 2021-03-18(c)
At step two, an ALJ determines 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. § 416.920(c). “The step-two inquiry is a de minimis screening device to dispose of groundless claims.” Newell v. Comm’r of Soc. Sec., 347 F.3d 541, 546 (3d Cir. 2003) (citations omitted). ... Here, the Court cannot conclude that the ALJ’s error at step two regarding Plaintiff’s mental impairments was harmless. The ALJ never mentioned Plaintiff’s mental impairments again after step two. See generally R. 45–49. Plaintiff’s mental impairments therefore “were effectively screened out of the analysis at step two. As a result, the potential effect of the [mental] impairments, alone or in combination with each other and the [physical] impairments, was not analyzed at step three or subsequently.” ... Accordingly, based on this record, the Court cannot conclude that substantial evidence supports the ALJ’s decision.Read the full opinion on CourtListener →
Section 416.920(a)(4) requires the ALJ to evaluate disability through a five-step process, including a step-two determination of whether the claimant has a severe impairment.
Ledbetter v. Saul · filed 2021-06-09(a)(4)
When determining whether an individual is disabled, the ALJ follows a five-step process. 20 C.F.R. § 416.920(a)(4). At step two, which is at issue in this matter, the ALJ determines whether the individual has an impairment or combination of impairments that is “severe.” Id. § 416.920(c).Read the full opinion on CourtListener →
Section 416.920(a)(4)(iv) requires the ALJ, at step four of the sequential evaluation, to assess the claimant’s residual functional capacity and ability to perform past relevant work based on all relevant evidence.
Fuchs v. Commissioner of Social Security · filed 2021-08-30(a)(4)(iv)
As noted above, at step four of the sequential evaluation process, the ALJ must assess the claimant’s RFC, as well as his ability to perform his past relevant work. See 20 C.F.R. §§ 416.920(a)(4)(iv), 416.945. In making this determination, an ALJ must decide based upon all the relevant evidence what a claimant can do in a work setting despite any physical or mental limitations caused by the claimant’s impairments and related symptoms. Id.Read the full opinion on CourtListener →
Section 416.920(a)(4) places consideration of the medical severity of impairments at step two of the five-step sequential disability evaluation.
Minerd v. Commissioner of Social Security · filed 2022-01-13(a)(4)
At step two of the five-step sequential evaluation process, the ALJ considers the “medical severity of [the applicant’s] impairments.” 20 C.F.R. § 416.920(a)(4).Read the full opinion on CourtListener →
Section 416.920(a)(4)(ii) requires an ALJ to determine at step two whether the claimant has a severe medically determinable impairment, and § 416.920(c) treats an impairment as severe when it significantly limits the claimant’s ability to perform basic work activities.
Martinez v. Social Security Administration · filed 2024-02-27(a)(4)(ii), (c)
Ms. Martinez’s claim of error rests on the distinct ways that an ALJ must analyze mental impairments at steps two and four of the SEP. In general, at step two, an ALJ must determine whether the claimant has a “severe” medically determinable impairment or combination of impairments that meets the agency’s duration requirement. 20 C.F.R. § 416.920(a)(4)(ii). An impairment or combination of impairments is severe when it “significantly limits [the claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. §§ 416.920(c), 416.922(a). ... Although a claimant must have at least one severe impairment or combination of impairments for the SEP to proceed past step two, 20 C.F.R. § 416.920(a)(4)(ii), an ALJ must consider all of the claimant’s medically determinable impairments, including ones that are not severe, in formulating her RFC at step four. 20 C.F.R. § 416.945(a)(2).Read the full opinion on CourtListener →
Section 416.920 requires disability claims to be evaluated through five sequential steps, and an omission at step two may be harmless when another severe impairment is identified and the omitted impairment is considered at later steps.
BOYD v. DUDEK · filed 2025-07-09
The SSA outlines a five-step sequential evaluation that must be applied in order to make a disability determination. 20 C.F.R. § 416.920. That five-step evaluation consists of the following stages: (1) whether the claimant is currently engaged in substantial gainful activity; (2) if not, whether the claimant has severe impairment; (3) if so, whether the claimant’s severe impairment meets or equals the criteria of an impairment listed in 20 C.F.R. pt. 404 subpt. P., app. 1; (4) if not, whether the claimant’s impairment prevents him from performing his past relevant work; and (5) if so, whether the claimant can perform any other work which exists in the national economy in light of his age, education, work experience and residual functional capacity. 20 C.F.R. §§ 404.1520, 416.920; see Sykes v. Apfel, 228 F.3d 259, 262-63 (3d Cir. 2000). ... Here, plaintiffs bipolar disorder was addressed in other steps and was adequately considered. ... Here, the error at step two was harmless.Read the full opinion on CourtListener →
Step two: severe impairment
At step two, if a claimant has no medically determinable severe impairment, the evaluation ends without an RFC assessment.
Wallace v. Commissioner, Social Security Administration · filed 2021-11-02(c)
“If a claimant is found to be ‘disabled’ or ‘not disabled’ at any step in the sequence, there is no need to consider subsequent steps.” Schneider v. Comm’r, 223 F.3d 968, 974 (9th Cir. 2000) (citing 20 C.F.R. § 416.920). Only if the Commissioner determines at step two that a claimant has a medically determinable impairment that is severe, then the Commissioner may proceed to step three. Burch, 400 F.3d at 679. ... As such, the ALJ did not err in declining to determine Plaintiff’s RFC.Read the full opinion on CourtListener →
Section 416.920(c) treats an impairment as severe only if it significantly limits the claimant’s ability to perform basic work activities and satisfies the required continuous-duration condition.
THOMAS v. SAUL · filed 2021-07-15(c)
An impairment is not severe if it does not significantly limit the physical or mental ability to do basic work activities and/or does not last or is not expected to last for a continuous period of at least 12 months. 20 C.F.R. §§416.920(c), 416.921(a), 416.909, 42 U.S.C. §423(d). ... Plaintiff does not suggest how her cellulitis resulted in limitations. As I stated previously, an impairment is not severe if it does not significantly limit the physical or mental ability to do basic work activities and/or does not last or is not expected to last for a continuous period of at least 12 months. Consequently, I find no merit to this argument.Read the full opinion on CourtListener →
Section 416.920(c) sets a low step-two threshold: an impairment is nonsevere only when its effect is so minimal that it clearly would not interfere with work, regardless of age, education, or work experience.
McDaniel v. Otis R. Bowen , Secretary of Health and Human Services · filed 1986-09-09(c)
At step two of § 404.1520 and § 416.920 a claimant’s impairment is determined to be either severe or not severe. Step two is a threshold inquiry. It allows only claims based on the most trivial impairments to be rejected. The claimant’s burden at step two is mild. An impairment is not severe only if the abnormality is so slight and its effect so minimal that it would clearly not be expected to interfere with the individual’s ability to work, irrespective of age, education or work experience. Claimant need show only that her impairment is not so slight and its effect is not so minimal.Read the full opinion on CourtListener →
Section 416.920(e) requires an individualized step-four comparison between the actual demands of a claimant’s past work and the claimant’s present physical capacities.
Pearson v. Bowen · filed 1986-12-01(e)
Step 4 of Secretary’s sequential process required AU Walsh to determine whether Pearson is physically capable of doing her former work (Reg. § 416.920(e)). That evaluation required the AU to: ascertain the demands of that work in relation to the claimant’s present physical capacities. ... Thus the AU should have determined the demands of Pearson’s past work and compared them with her present physical limitations (id.). That requires an individualized comparison (see Heckler v. Campbell, 461 U.S. 458, 467, 103 S.Ct. 1952, 1957, 76 L.Ed.2d 66 (1983)). Because AU Walsh failed to make such an individualized comparison and improperly discounted the limitations caused by Pearson’s pain, his finding that Pearson is still capable of working as a sewing machine operator must be reversed.Read the full opinion on CourtListener →
Section 416.920(e) directs that a claimant is not disabled if the claimant can still perform the kind of work performed in the past, even if the former job itself is no longer available.
Jozefowicz v. Margaret M. Heckler, Secretary of Health and Human Services · filed 1987-02-13(e)
The argument that the claimant’s former job is no longer available to her is irrelevant, so long as the claimant can still do the type of job she did in the past. ... 20 C.F.R. § 416.920(e) (1986) (“If you can still do this kind of work, we will find that you are not disabled.”) (emphasis added).Read the full opinion on CourtListener →
Step four denies benefits when the claimant can return to her past relevant work.
Walden v. Otis R. Bowen, Secretary of Health and Human Services · filed 1987-02-13(e)
The Secretary responds that the claim was denied at “Step 4,” 20 C.F.R. § 416.920(e). The record supports defendant’s characterization of the facts. The ALJ specifically found that plaintiff could return to her past work (Vol. I, Item 4, Administrative Record at 19). Therefore, Hansen v. Heckler, supra, does not require us to remand plaintiff’s case.Read the full opinion on CourtListener →
Section 416.920(e) requires a finding of not disabled when a claimant can still perform past relevant work despite severe physical or mental impairments.
Leonard L. RAY, Jr., Plaintiff-Appellant, v. Otis R. BOWEN, Secretary, Department of Health and Human Services, Defendant-Appellee · filed 1987-04-01(e)
If a claimant can still perform the work he has done in the past, despite severe physical or mental impairments, he must be found not disabled. 20 C.F.R. § 416.920(e).Read the full opinion on CourtListener →
Section 416.920(e) does not restrict the location of a claimant’s previous work, so foreign past work may be considered in deciding whether the claimant can perform it.
QUANG VAN HAN, Plaintiff-Appellant, v. Otis R. BOWEN, Secretary, Department of Health and Human Services, Defendant-Appellee · filed 1989-08-21(e)
Neither is Ruling 82-40 inconsistent with the regulation it interprets. Section 416.920(e) says nothing about whether past work was performed in the United States or abroad. As with the statute, the regulation’s silence can give rise to the reasonable inference that it places no restrictions on the location of the claimant’s previous work.Read the full opinion on CourtListener →
Section 416.920 treats a nonexistent makework training job as not being past relevant work, so the disability inquiry must proceed to whether other jobs exist in significant numbers in the national economy.
John A. KOLMAN, Plaintiff-Appellant, v. Louis W. SULLIVAN, Secretary of Health and Human Services, Defendant-Appellee · filed 1991-02-15
If, then, the CETA job was past relevant work within the meaning of the applicable social security regulations, Kolman loses. ... We are inclined to agree with DeRienzis v. Heckler, 748 F.2d 352 (2d Cir.1984), however, that a makework training job is not the type of work to which the regulations refer. ... But if the work disappeared within that time, the fact that he could perform it if it did exist does not appeal to us as being either a rational ground for denying benefits or one intended by the regulations. ... But if the assumption is dramatically falsified in a particular case, the administrative law judge is required to move on to the next stage and inquire whether some other job that the applicant can perform exists in significant numbers today somewhere in the national economy. A nonexistent makework training job is not past relevant work within the meaning of the regulations as we interpret them.Read the full opinion on CourtListener →
At the past-work step, § 416.920(e) requires a claimant with severe impairments to show that they prevent performance of the claimant’s past work.
Connie L. BAKER, Appellant, v. SECRETARY OF HEALTH AND HUMAN SERVICES, Appellee · filed 1992-01-29(e)
Given her work and medical history, Baker must show that her severe combination of impairments prevents her from doing her past work. See 20 C.F.R. § 416.-920(e). Thus, we must affirm if there is substantial evidence to support the Secretary’s finding that Baker has the residual functional capacity to perform her past work. We conclude that there is.Read the full opinion on CourtListener →
At step five, the regulations require considering the claimant’s residual functional capacity together with age, education, and work experience to determine whether the claimant can perform other work; on these facts, they required a finding of disability.
Rivera v. Bowen · filed 1987-04-22(f)
The court had intended by this direction to remand for the purpose of determining whether, under step 5 of the Secretary’s disability-evaluation sequence, 20 C.F.R. § 416.920(f) (1986), plaintiff is disabled. ... It is undisputed that at 62 years old plaintiff is of “advanced” age; that his fourth-grade education is “marginal”; and that his work experience is “unskilled.” ... Moreover, the finding of plaintiffs treating physician — that he is unable to perform medium or light work — was binding on the Secretary. ... Under these circumstances, the Secretary’s regulations direct the conclusion that plaintiff is disabled.Read the full opinion on CourtListener →
At step five, a claimant unable to perform past work is disabled unless the Secretary shows that the claimant can perform other work available in the national economy, considering age, education, past work experience, and residual functional capacity.
Benjamin S. GOSSETT, Plaintiff-Appellant, v. Otis R. BOWEN, M.D., Secretary, Department of Health and Human Services, Defendant-Appellee · filed 1989-02-13(f)
(5) A person whose impairment precludes performance of past work is disabled unless the Secretary demonstrates that the person can perform other work available in the national economy. Factors to be considered are age, education, past work experience, and residual functional capacity. 20 C.F.R. § 416.920(f). ... The finding of the AU that Mr. Gossett suffered from no nonexertional impairment serious enough to limit the range of jobs available to him was supported by substantial evidence. Thus the AU properly relied on the medical-vocational guidelines to demonstrate the existence of substantial gainful work in which Mr. Gossett could engage.Read the full opinion on CourtListener →
Law changed since Effective February 11, 1991, SSA made § 416.920 the adult disability evaluation rule and moved child disability evaluation to separate regulations.
Section 416.920(d) excludes age, education, and work experience from consideration when evaluating a child’s entitlement to SSI.
David C. Wilkinson, on Behalf of James D. Wilkinson v. Otis R. Bowen, Secretary of Health and Human Services · filed 1987-07-15(d)
The vocational factors of age, education, and work experience are not considered when evaluating a child’s entitlement to SSI. 20 C.F.R. § 416.920(d).Read the full opinion on CourtListener →
Section 416.920 requires disability claims to be evaluated through a five-step sequential process, with step two applying a de minimis threshold for deciding whether an impairment is severe.
Town v. Rhode Island Department of Human Services, 03-6427 (r.I.super. 2006) · filed 2006-05-10(a)(4)(ii)
To determine whether a particular individual is disabled, the DHS is required to employ the five-step sequential evaluation method set forth in the federal regulations. See 20 C.F.R. § 416.920. ... Step two of the sequential disability evaluation is "a de minimis standard." Lisi v. Apfel,111 F. Supp. 2d 103, 110 (D.R.I. 2000) (citing McDonald v. Secretary ofHealth and Human Servs., 795 F.2d 1118, 1124 (1st Cir. 1986)). ... "[A] finding of `non-severe' is only to be made where `medical evidence establishes only a slight abnormality or combination of slight abnormalities which would have no more than a minimal effect on an individual's ability to work even if the individual's age, education, or work experience were specifically considered[.]'" ... In the case at hand, the hearing officer failed to articulate and apply the appropriate legal standard at step two of the sequential evaluation process. ... Accordingly, this Court must vacate the decision and remand the matter back to the agency for further consideration under the appropriate legal standard.Read the full opinion on CourtListener →
At step two, § 416.920(a) requires a claimant to show a severe medically determinable physical or mental impairment, and a sister agency’s determination about such an impairment must be considered.
Malcom v. Barnhart · filed 2006-09-15(a)
Since, “[a]t step two, the claimant must demonstrate that she suffers from a ‘severe medically determinable physical or mental impairment,’ ” ... it stands to reason that a sister agency’s determination regarding physical or medical impairment bears consideration.Read the full opinion on CourtListener →
At step two, § 416.920(c) requires a severe impairment or combination of impairments that significantly limits physical or mental ability to do basic work activities, and the court applies Stone’s minimal-effect standard to that requirement.
Sweeney v. Astrue · filed 2011-06-20(c)
The comparable regulation applicable to Title XVI claims is 20 C.F.R. § 416.920(c), which is worded identically to 20 C.F.R. § 404.1520(c) except for the omission in § 416.920(c) of the final sentence of § 404.1520(c). The court considers that Stone is applicable to both sections 404.1520(c) and 416.920(c).Read the full opinion on CourtListener →
Section 416.920(c) treats an impairment as severe when it significantly limits a claimant’s physical or mental ability to perform basic work activities, without considering age, education, or work experience at Step Two.
Fort v. Astrue · filed 2012-03-12(c)
Step Two requires a determination whether the claimant is suffering from a severe impairment. A severe impairment is one which significantly limits the claimant’s physical or mental ability to do basic work activities. 20 C.F.R. § 416.920(c). The claimant’s age, education, and work experience are not considered in making a Step Two severity determination. 20 C.F.R. § 416.920(c). If the claimant suffers a severe impairment, then the inquiry moves on to Step Three; if not, then the claimant is found to be not disabled, and the inquiry ends.Read the full opinion on CourtListener →
Section 416.920(a)(4)(ii) requires evaluating at step two whether a medically determinable impairment is severe, and subsection (c) defines severe as significantly limiting the claimant’s ability to perform basic work activities.
Miller v. Colvin · filed 2013-05-07(a)(4)(ii), (c)
At step two, the ALJ must consider whether a medically determinable impairment is “severe.” 20 C.F.R. § 416.920(a)(4)(ii). A severe impairment is one which “significantly limits your physical or mental ability to do basic work activities.” 20 C.F.R. § 416.920(c). Basic work activities include physical functions such as walking, standing, sitting, lifting, pushing, pulling, reaching, carrying or handling; capacities for seeing, hearing and speaking; understanding, carrying out, and remembering simple instructions; use of judgment; responding appropriately to supervision, co-workers and usual work situations; and dealing with changes in a routine work setting. 20 C.F.R. § 416.921(b). If the impairment would have no more than a minimal effect on the claimant’s ability to work, then it does not satisfy the requirement of step two. Page, 484 F.3d at 1043. ... Here, the ALJ acknowledged that Miller had medically determinable physical impairments of degenerative disc disease, osteopenia, GERD, benign hypertension and benign prostatic hyperplasia. AR 13. However, the ALJ failed to consider Miller’s symptom-related limitations and make a credibility finding on his alleged limitations, which was érror.Read the full opinion on CourtListener →
Section 416.920(c) requires an impairment to significantly limit a claimant’s physical or mental ability to perform basic work activities for at least 12 consecutive months to qualify as severe at step two.
Reutov v. Colvin · filed 2014-03-06(c)
At step two of the sequential evaluation process, the ALJ must determine whether the claimant has a “severe” impairment. See 20 C.F.R. §§ 404.1520(c), 416.920(c). The fact that a claimant has been diagnosed with and treated for a medically determinable impairment does not necessarily mean the impairment is “severe,” as defined by the Social Security Regulations. See, e.g., Fair v. Bowen, 885 F.2d 597, 603 (9th Cir.1989); Key v. Heckler, 754 F.2d 1545, 1549-50 (9th Cir.1985). To establish severity, the evidence must show the diagnosed impairment significantly limited the claimant’s physical or mental ability to do basic work activities for at least 12 consecutive months. 20 C.F.R. § 416.920(c).Read the full opinion on CourtListener →
At step two, § 416.920(c) defines a severe impairment as an impairment or combination of impairments that significantly limits a claimant’s physical or mental ability to do basic work, and the claimant bears the burden of establishing it.
Woodmancy v. Colvin · filed 2014-09-02(c)
A claimant has the burden of establishing that she has a “severe impairment,” which is “any impairment or combination of impairments which significantly limits [her] physical or mental ability to do basic work.” 20 C.F.R. § 416.920(c); see Green-Younger v. Barnhart, 335 F.3d 99, 106 (2d Cir. 2003). ... For the reasons set forth in the district court’s thorough opinion, see Woodmancy v. Colvin, No. 5:12-CV-991 GLS, 2013 WL 5567553, at *2 (N.D.N.Y. Oct. 9, 2013), we conclude that substantial evidence supports the agency determination that Woodmancy did not carry her burden of demonstrating that these conditions were severe impairments.Read the full opinion on CourtListener →
At step two of the sequential evaluation, an impairment is severe only if it significantly limits the claimant’s ability to perform basic work activities; without a severe impairment or combination of impairments, the claimant is not disabled.
Nathanial Stone v. Commissioner of Social Security · filed 2014-09-26(a)(4)(ii), (c)
An impairment or combination of impairments is “severe” if it significantly limits the claimant’s physical or mental abilities to perform basic work activities. 20 C.F.R. §§ 416.920(c), 416.921(a); Crayton, 120 F.3d at 1219. ... If the claimant does not have a severe impairment or combination of impairments, he is not disabled. Id. (citing 20 C.F.R. § 416.920(c)). ... The claimant’s burden at step two is mild, since this inquiry “allows only claims based on the most trivial impairments to be rejected.”Read the full opinion on CourtListener →
At step two, an impairment is not severe unless it significantly limits a claimant’s physical or mental ability to perform basic work activities.
Dias v. Colvin · filed 2014-09-30(c)
The step two analysis assesses “the medical severity of [a claimant’s] impairment(s).” 20 C.F.R. § 416.920(a)(4). “An impairment or combination of impairments is not severe if it does not significantly limit [a claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. § 416.920(c) (claimant lacks severe impairment if she does “not have any impairment or combination of impairments which significantly limits [her] physical or mental ability to do basic work activities”). ... Substantial evidence supports the finding that the injury was a non-severe impairment that did not significantly limit plaintiffs ability to perform basic work activities.Read the full opinion on CourtListener →
Section 416.920(c) ends the sequential disability inquiry at step two when the claimant lacks a severe impairment.
Thomas v. Carolyn Colvin, Acting Cmsnr · filed 2014-10-21(c)
The ALJ concluded his analysis at the second step, after finding that Thomas did not have a severe impairment based on a lack of medical evidence supporting her application. ... Accordingly, the ALJ concluded that Thomas was not disabled during the relevant period, and was therefore not entitled to DIB or SSI benefits. ... However, the ALJ’s five-step analysis only incorporates such considerations during steps three through five; since we have concluded that the ALJ’s decision was sufficiently supported at step two, these issues are not grounds for remand.Read the full opinion on CourtListener →
Section 416.920(a)(4)(ii) requires the disability evaluator to consider whether the claimant has a severe impairment or combination of impairments, and the ALJ must consider the combined effects of the impairments.
McCormick v. Social Security Administration, Commissioner · filed 2015-07-23(a)(4)(ii)
Step two is a “threshold inquiry” where only the most trivial impairments are to be rejected. ... We have explained that step two serves as a filter, and if any severe impairment is found, the requirements of step two are satisfied. ... A single impairment or a combination of impairments that together qualify as severe may meet the requirements for step two. ... The ALJ “must make specific and well-articulated findings as to the effect of the combination of impairments and [ ] decide whether the combined impairments cause the claimant to be disabled.” ... The ALJ did not fail to consider the combined effects of Mr. McCormick’s impairments. ... In sum, we conclude that the ALJ did not fail to consider the combined effects of impairments in determining that Mr. McCormick is not disabled under § 416.920.Read the full opinion on CourtListener →
Section 416.920(c) makes Step Two a threshold inquiry requiring a severe impairment that significantly limits a claimant’s physical or mental ability to do basic work activities.
Stacy v. Commissioner, Social Security Administration · filed 2016-07-07(c)
At Step Two, the ALJ’s inquiry is whether the claimant has a severe impairment that significantly limits his physical or mental ability to do basic work activities. 20 C.F.R. § 416.920(c). Step Two is a threshold inquiry for the ALJ. McDaniel v. Bowen, 800 F.2d 1026, 1031 (11th Cir. 1986). Only de minimus claims, based on the most trivial impairments, may be rejected. Id.Read the full opinion on CourtListener →
At step two, the regulation requires deciding whether the claimant has a medically severe impairment based on medical evidence; an impairment is not severe when it does not significantly limit basic work activities.
Andersen v. Colvin · filed 2016-07-11(a)
At step two, the ALJ determines whether the claimant has a medically severe impairment or combination of impairments; step two findings must be based upon medical evidence. 20 C.F.R. § 416.920(a). An impairment is “not severe” if it “does not significantly limit [the claimant’s] ability to do basic work activities.” Id.Read the full opinion on CourtListener →
At step two, an impairment is severe only if it significantly limits basic work activities, and an omitted impairment is harmless when the ALJ finds another severe impairment and continues the sequential evaluation while considering all impairments.
Anderson v. Colvin · filed 2016-09-30(a)(4)(ii), (c)
At step two of the analysis, the ALJ determines whether the claimant has an impairment or combination of impairments that is severe. Castile v. Astrue, 617 F.3d 923, 926 (7th Cir. 2010); 20 C.F.R. § 416.920(a)(4)(h). An impairment is severe if it “significantly limits [a claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. § 416.920(c). The step two determination “is a threshold issue only.” Arnett v. Astrue, 676 F.3d 586, 591 (7th Cir. 2012.). If the ALJ fails to find one impairment severe, but finds that another is severe and continues with the sequential analysis, any step two error is harmless. See id. (holding that any error in omitting a severe impairment was harmless where the ALJ found two impairments severe and continued with the remaining steps of the evaluation process); Castile, 617 F.3d at 927. In this case, any error at step two is harmless because the ALJ found that Anderson’s alcohol dependence and anxiety disorder are severe, and because the ALJ evaluated the effect of all Anderson’s impairments on his RFC.Read the full opinion on CourtListener →
Section 416.920(c) treats an impairment as severe when it significantly limits a claimant’s ability to do basic work activities.
Buxton v. Colvin · filed 2018-03-19(c)
In order for an impairment to be severe, it must be more than a slight abnormality or a combination of slight abnormalities “that causes no more than minimal functional limitations.” 20 C.F.R. § 416.924(c) (emphasis added). Indeed, it must “significantly limit[]” an individual’s “ability to do basic work activities.” 20 C.F.R. § 416.920(c) (emphasis added).Read the full opinion on CourtListener →
Section 416.920(c) requires the ALJ at step two to determine whether the claimant has a severe impairment or combination of impairments, including whether medically determinable impairments significantly limit basic work activities.
Quinn v. Berryhill · filed 2018-03-20(c)
In step two, the ALJ must determine whether the claimant has an impairment or combination of impairments that are severe. 20 C.F.R. § 404.1520(c); 20 C.F.R. § 416.920(c). In other words, the ALJ must determine if the claimant’s impairment(s) “significantly limits [her] physical or mental ability to do basic work activities[.]” 20 C.F.R. § 1520(c). ... The court agrees with Quinn. Here, the ALJ did not mention Quinn’s obesity, and he did not make a finding as to whether Quinn’s scoliosis or neck impairment—which he noted Quinn testified about—were medically determinable impairments that were either severe or not severe. There is evidence in the record to support such diagnoses, so they should have been addressed in the step two analysis. Because medically determinable impairments are so important to the RFC analysis at step four, the court finds that the ALJ’s insufficient findings regarding Quinn’s medically determinable severe impairments at step two require remand for further development.Read the full opinion on CourtListener →
An impairment is severe at step two only if it significantly limits an individual’s ability to do basic work activities.
Moorer v. Berryhill · filed 2018-09-11(c)
Indeed, it must “significantly limit[]” an individual’s “ability to do basic work activities.” 20 C.F.R. § 416.920(c) (emphasis added).Read the full opinion on CourtListener →
Section 416.920(a)(4)(ii) requires the ALJ, at step two, to determine whether the claimant has a medically determinable impairment or combination of impairments that is severe.
Langway v. Commissioner of Social Security · filed 2019-02-08(a)(4)(ii)
At step two of the sequential evaluation process, the ALJ must gauge whether the claimant has a medically determinable impairment (or combination of impairments) that is severe. 20 C.F.R. § 416.920(a)(4)(ii).Read the full opinion on CourtListener →
At step two, § 416.920(c) treats an impairment as severe when it significantly limits a claimant’s physical or mental ability to perform basic work activities.
Gress v. Berryhill · filed 2019-06-07(c)
A severe impairment is one that significantly limits the claimant’s “physical or mental ability to do basic work activities.” 20 C.F.R. §§ 416.920(c), 416.920(c). ... As these medical records reflect, there is objective evidence in the record suggesting that Plaintiff’s impairments are more than de minimis. ... Because there is objective evidence in the record suggesting that Plaintiff’s impairments significantly limited his ability to perform certain basic work activities, the ALJ erred by finding that Plaintiff did not have any severe impairments and ending his analysis at step two.Read the full opinion on CourtListener →
Section 416.920(a) establishes a five-step disability evaluation, and at step two requires screening out claims lacking a severe impairment that lasts or is expected to last at least twelve months.
Holbrooks v. Social Security Administration · filed 2019-08-07(a)(4)(ii)
Plaintiff is correct that “step two of the five-step sequential analysis . . . presents only a de minimis hurdle for a claimant to clear.” Sullivan v. Comm’r of Soc. Sec., No. 18-5523, 2018 WL 8344632, at *3 (6th Cir. Dec. 17, 2018) (citing Higgs v. Bowen, 880 F.2d 860, 862 (6th Cir. 1988) (per curiam)). “At step two, the Commissioner must determine whether the claimant has a severe impairment,” and is “‘ intended to “screen out totally groundless claims.’” Nejat v. Comm’r of Soc. Sec., 359 F. App'x 574, 576 (6th Cir. 2009) (quoting Farris v. Sec’y of Health & Human Servs., 773 F.2d 85, 89 (6th Cir.1985)). “[I]f an impairment has ‘more than a minimal effect’ on the claimant’s ability to do basic work activities, the ALJ must treat it as ‘severe.’” Id. at 576-77.Read the full opinion on CourtListener →
Section 416.920(c) requires a finding that an impairment or combination of impairments significantly limits the claimant's ability to do basic work activities to qualify as severe at step two.
Puckett v. Commissioner of Social Security · filed 2019-08-08(c)
To determine that a claimant has a severe impairment, the ALJ must find that an impairment or combination of impairments significantly limits the claimant’s ability to do basic work activity.” Rogers v. Comm’r of Soc. Sec., 486 F.3d 234, 243 n2 (6th Cir. 2007) (citing 20 C.F.R. § 416.920).Read the full opinion on CourtListener →
At step two of the sequential evaluation, a claimant satisfies the severe-impairment requirement if at least one severe impairment is found; the ALJ must then consider the claimant’s entire medical condition, including impairments found non-severe.
Gomez v. Commissioner of Social Security · filed 2019-08-19(a)(4)(ii)
In the Eleventh Circuit, “[t]he finding of any severe impairment . . . is enough to satisfy step two because once the ALJ proceeds beyond step two, he is required to consider the claimant’s entire medical condition, including impairments the ALJ determined were not severe.”Read the full opinion on CourtListener →
Notes 1651–1800 of 2,028, oldest cases first.
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