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 two severity
At step two, the ALJ determines whether a claimant has severe impairments; if not, the application is denied, and if so, the evaluation proceeds to later sequential steps.
Keller v. Commissioner of Social Security · filed 2019-09-30(a)(4)(ii)
At step two of sequential evaluation, an ALJ must decide whether a claimant has “severe impairments.” 20 C.F.R. § 416.920(a)(4)(ii). If not, the claimant’s application is denied. Id. If so, evaluations proceed to subsequent sequential steps. Id. § 416.920(a)(4).Read the full opinion on CourtListener →
At step two, a claimant must show that an impairment or combination of impairments significantly limits the ability to perform basic work activities.
Doty v. Social Security Administration · filed 2019-09-30(c)
At step two, Claimant bears the burden of showing the existence of an impairment or combination of impairments which “significantly limits [his] physical or mental ability to do basic work activities.” 20 C.F.R. § 416.920(c).Read the full opinion on CourtListener →
At step two, an impairment is severe when it significantly limits a claimant's physical or mental ability to perform basic work activities.
Huffstetler v. Social Security Administration, Commissioner of · filed 2019-09-30(c)
An impairment, or combination of impairments, will be found severe if the impairment(s) “significantly limit[ ] [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 →
At step two of the sequential evaluation, an ALJ must identify the claimant’s severe medically determinable impairments.
Piercy v. Commissioner of Social Security · filed 2019-11-15(c)
At Step Two, an ALJ must identify a claimant’s “severe” medically determinable impairments. See 20 C.F.R. § 416.920.Read the full opinion on CourtListener →
At step two, 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.
Marquis v. Saul · filed 2019-11-27(c)
At step two of the sequential process, the ALJ must determine whether claimant suffers from a “severe” impairment, i.e., one that significantly limits his 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 limits a claimant’s physical or mental ability to perform basic work activities, and a claimant need show only one severe impairment to proceed beyond step two.
Mucilli v. Commissioner, Social Security Administration · filed 2019-12-16(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). ... 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 three other impairments to be severe. Tr. 17. 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. Thus, 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 →
Section 416.920(c) requires the Commissioner to find an impairment nonsevere when it does not significantly limit the claimant’s physical or mental ability to do basic work activities.
(SS) Mendez v. Commissioner of Social Security · filed 2019-12-23(c)
At step two, the Commissioner determines whether the claimant has a medically severe impairment or combination of impairments. Bowen v. Yuckert, 482 U.S. 137, 140-41 (1987); 20 C.F.R. §416.920(a)(4)(ii). ... If a claimant does not have an impairment of combination of impairments which significantly limit the claimant’s physical or mental ability to do basic work activities, the Commissioner will find that the claimant does not have a severe impairment. 20 C.F.R. § 416.920(c). ... Strict application of the legal standards articulated in Smolen indicate that the ALJ erred in failing to include Plaintiff’s mental health impairments among her severe impairments at step two; however, the error is harmless.Read the full opinion on CourtListener →
Section 416.920(c) requires the ALJ at step two to determine whether an impairment significantly limits the claimant’s physical or mental ability to perform basic work activities.
Shaman v. Saul · filed 2020-01-21(c)
At step two of the sequential process, the ALJ must determine whether the claimant suffers from a “severe” impairment, i.e., one that significantly limits her physical or mental ability to do basic work activities. 20 C.F.R. § 416.920(c). ... On this record, the ALJ reasonably concluded that Plaintiff’s back pain was not a severe impairment. Tr. 17-18. ... On this record, the ALJ reasonably concluded that Plaintiff’s hand pain was not a severe impairment. ... Thus, the ALJ’s step two finding is legally sufficient.Read the full opinion on CourtListener →
Section 416.920(c) treats an impairment as not severe when it does not significantly limit the claimant’s ability to perform basic work activities.
Little v. Commissioner of Social Security · filed 2020-01-23(c)
An impairment is “not severe” if it does not “significantly limit” the ability to perform basic work activities. 20 C.F.R. § 416.920(c).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, and one severe impairment is enough to require proceeding to the next step.
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.Read the full opinion on CourtListener →
At step two, an impairment is severe when it significantly limits basic work abilities and lasts at least twelve months; finding one severe impairment satisfies step two if all impairments are considered at later steps.
Nolan v. Berryhill · filed 2020-03-03(c)
Step two of the five-step, sequential evaluation process asks whether the claimant’s impairment is severe. See 20 C.F.R. § 416.920. An impairment or combination of impairments is “severe” if it “significantly limits [Plaintiff’s] physical or mental ability to do basic work activities” and persists for at least twelve consecutive months. 20 C.F.R. §§ 416.920(c), 416.905(a). ... At step two in this case, the ALJ found Plaintiff has the severe impairments of degenerative disc disease and obesity. Doc. 12-2 at 19 (R. 18). ... Because the ALJ found Plaintiff has at least one severe impairment, she was not required to identify all of Plaintiff’s severe impairments before moving to step three of the sequential evaluation process. See Tuggerson-Brown, 572 F. App’x at 951–52. Therefore, the ALJ did not err at step two.Read the full opinion on CourtListener →
At step two, § 416.920(c) requires the Commissioner to determine whether an impairment significantly limits the claimant’s ability to perform basic work activities; the impairment must be considered throughout the sequential evaluation.
Dixon v. Commissioner of Social Security · filed 2020-03-10(c)
After a medically determinable impairment is established, the ALJ must determine whether the impairment is “severe,” i.e., one that significantly limits his or her physical or mental ability to do basic work activities. 20 C.F.R. § 416.920(c). ... Thus, diabetes is a medically determinable impairment and should have been considered by the ALJ throughout the sequential evaluation. However, the ALJ did not mention diabetes at step two or anywhere in the decision. Tr. 15-30. Thus, the ALJ erred. ... Because the ALJ failed to assess the medically determinable impairment of diabetes, it is not apparent that the ALJ evaluated the impact of that impairment, if any, on the RFC. Thus, the Court cannot conclude the error is harmless.3 As a result, this matter must be remanded for consideration of the impact of diabetes on the RFC finding and throughout the sequential evaluation.Read the full opinion on CourtListener →
At Step Two, § 416.920 requires the ALJ to determine whether the claimant has a medically severe impairment or combination of impairments, using a de minimis screen and addressing significant probative evidence bearing on severity.
Karakoc v. Berryhill · filed 2020-03-11(a)(4)(ii)
At Step Two, the claimant bears the burden of showing that she has a medically severe impairment or combination of impairments. See 20 C.F.R. § 416.920(a)(4)(ii), (c). “An impairment is not severe if it is merely ‘a slight abnormality (or combination of slight abnormalities) that has no more than a minimal effect on the ability to do basic work activities.’” Webb v. Barnhart, 433 F.3d 683, 686 (9th Cir. 2005) (quoting S.S.R. No. 96–3(p) (1996)). ... As mentioned above, at Step Two of the disability determination process, it is incumbent on the ALJ to determine whether the claimant has a medically severe impairment or combination of impairments. Step Two, is “a de minimis screening device [used] to dispose of groundless claims.” Webb, 433 F.3d at 687. In this case, there was significant evidence presented by Plaintiff regarding his depressive disorder and anxiety disorder from late 2015 through 2017. ... The ALJ’s failure to address that evidence of Plaintiff’s limitations at Step Two falls short of the ALJ’s obligation to state reasons for disregarding “significant probative evidence.”Read the full opinion on CourtListener →
Section 416.920(a)(4)(ii) requires the ALJ to determine at step two whether the claimant has a medically severe impairment or combination of impairments, applying a minimal-effect threshold.
Karakoc v. Berryhill · filed 2020-03-11(a)(4)(ii)
At Step Two, the claimant bears the burden of showing that she has a medically severe impairment or combination of impairments. See 20 C.F.R. § 416.920(a)(4)(ii), (c). “An impairment is not severe if it is merely ‘a slight abnormality (or combination of slight abnormalities) that has no more than a minimal effect on the ability to do basic work activities.’” Webb v. Barnhart, 433 F.3d 683, 686 (9th Cir. 2005) (quoting S.S.R. No. 96–3(p) (1996)).Read the full opinion on CourtListener →
At Step Two of the sequential evaluation, § 416.920 requires determining whether the claimant has a severe impairment, and the ALJ must evaluate the relevant mental-functioning factors and their resulting effect on residual functional capacity.
Silva v. Saul · filed 2020-03-16(a)(4)(ii)
At Step Two, the claimant bears the burden of showing that she has a medically severe impairment or combination of impairments. See 20 C.F.R. § 416.920(a)(4)(ii), (c). ... Because Dr. Velleman’s 2016 opinion remained uncontradicted by contemporaneous or later medical evidence and was not addressed by the ALJ, the conclusion was not clearly established by medial evidence. ... On remand, the ALJ will consider and address the four factors in light of Dr. Vellerman’s opinion at Step Two and then address and resulting effect to the RFC.Read the full opinion on CourtListener →
Section 416.920(c) requires a claimant's impairment or combination of impairments to significantly limit basic work activities before the Commissioner can find a severe impairment, using a de minimus step-two screening standard.
(SS) Havsgaard v. Commissioner of Social Security · filed 2020-03-23(c)
If a claimant does not have an impairment of combination of impairments which significantly limit the claimant’s physical or mental ability to do basic work activities, the Commissioner will find that the claimant does not have a severe impairment. 20 C.F.R. § 416.920(c). ... Having reviewed the hearing decision and the record as a whole, the Court concludes that the ALJ’s analysis at step two imposed an inappropriately high standard for determining a severe impairment or combination of impairments.Read the full opinion on CourtListener →
Section 416.920(c) treats step two as a de minimis screen: an impairment is not severe only when it has no more than a minimal effect on basic work activities, and the combined effects of impairments must be considered.
(SS) Havsgaard v. Commissioner of Social Security · filed 2020-03-23(c)
At step two, the Commissioner determines whether the claimant has a medically severe impairment or combination of impairments. Bowen v. Yuckert, 482 U.S. 137, 140-41 (1987); 20 C.F.R. §416.920(a)(4)(ii). An impairment is a medically determinable physical or mental impairment or combination of physical or mental impairments. 20 C.F.R. § 416.902(f). If a claimant does not have an impairment of combination of impairments which significantly limit the claimant’s physical or mental ability to do basic work activities, the Commissioner will find that the claimant does not have a severe impairment. 20 C.F.R. § 416.920(c). ... Having reviewed the hearing decision and the record as a whole, the Court concludes that the ALJ’s analysis at step two imposed an inappropriately high standard for determining a severe impairment or combination of impairments. ... “The step-two inquiry is a de minimus screening device to dispose of groundless claims.” Smolen v. Chater, 80 F.3d 1273, 1290 (9th Cir. 1996). “An impairment or combination of impairments can be found ‘not severe’ only if the evidence establishes a slight abnormality that has no more than a minimal effect on an individual[‘]s ability to work.” Id. at 1290; SSR 85-28. ... Even if an individual impairment is not sufficiently serious to prevent a person from working, an ALJ must consider the combined effect of all of the claimant’s impairments on his or her ability to function as well as considering the claimant’s subjective symptoms, such as pain or fatigue. Smolen, 80 F.3d at 1290. “If such a finding is not clearly established by medical evidence, however, adjudication must continue through the sequential evaluation process.” SSR 85-28.Read the full opinion on CourtListener →
Section 416.920(c) requires an ALJ at step two to determine whether an impairment significantly limits the claimant’s physical or mental ability to perform basic work activities.
Lord v. Commissioner of Social Security · filed 2020-03-24(c)
At step two of the sequential evaluation process, the ALJ must determine whether the plaintiff has a severe impairment that significantly limits his physical or mental ability to do basic work activities. See 20 C.F.R. §§ 404.1520(c), 416.920(c).Read the full opinion on CourtListener →
At step two, an impairment is severe when it significantly limits the claimant’s physical or mental ability to perform basic work activities and has lasted or is expected to last at least 12 months; the ALJ must account for such a severe impairment in the sequential evaluation.
Roberson v. Berryhill · filed 2020-03-25(a)(4)(ii), (c)
At step two of the sequential evaluation, the ALJ determines whether the claimant has a medically “severe” impairment or combination of impairments. See 20 C.F.R. §§ 404.1520(a)(4) (ii); see also Smolen, 80 F.3d 1273, 1289–90 (9th Cir. 1996) (citing Bowen v. Yuckert, 482 U.S. 140–41 (1987)). An impairment is severe when it significantly limits a claimant’s “physical or mental ability to do basic work activities” and lasted or is expected to last “for a continuous period of at least 12 months.” See 20 C.F.R. §§ 404.1509, 404.1520(a)(4)(ii), (c), 404.1521(a); accord 20 C.F.R. §§ 416.920(a)(4)(ii), (c), 416.909.Read the full opinion on CourtListener →
Section 416.920(c) treats an impairment as severe when it significantly limits the claimant’s ability to perform basic work activities; an impairment that has no more than a minimal effect is not severe.
Garbe v. Commissioner of Social Security · filed 2020-03-30(c)
To be considered ‘severe’ at step two of the sequential analysis, an impairment must significantly limit an individual’s ability to perform basic work activities. 20 C.F.R. §§ 404.1520(c), 416.920(c); ... Thus, the Court finds the ALJ did not err in finding Plaintiff’s lymphadenopathy, cellulitis, and edema were not severe at step two.Read the full opinion on CourtListener →
At step two, § 416.920(c) requires a claimant to show an impairment or combination of impairments that significantly limits the ability to perform basic work activities.
Tush v. Social Security Administration · filed 2020-03-30(c)
At step two, Claimant bears the burden of showing the existence of an impairment or combination of impairments which “significantly limits [his] physical or mental ability to do basic work activities.” 20 C.F.R. § 416.920(c).Read the full opinion on CourtListener →
At step two, § 416.920(c) requires a claimant to show an impairment or combination of impairments that significantly limits the ability to perform basic work activities.
Isbell v. Social Security Administration · filed 2020-03-31(c)
At step two, Claimant bears the burden of showing the existence of an impairment or combination of impairments which “significantly limits [his] physical or mental ability to do basic work activities.” 20 C.F.R. § 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.
Horne v. Social Security Administration, Commissioner of (PLR2) · filed 2020-03-31(c)
Additionally, to be found disabled, “the ALJ must find that the claimant has a severe impairment or impairments” at step two. Farris v. Sec’y of Health & Human Servs., 773 F.2d 85, 88 (6th Cir. 1985). An impairment, or combination of impairments, will be found severe if the impairment(s) “significantly limit[ ] [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 de minimis hurdle” in that “an impairment will be considered not severe only if it is a slight abnormality that minimally affects work ability regardless of age, education, and experience.” Higgs v. Brown, 880 F.2d 860, 862 (6th Cir. 1988) (citing Farris, 773 F.2d at 90).Read the full opinion on CourtListener →
At step two, an impairment is severe only if it significantly limits a claimant’s physical or mental ability to do basic work activities.
Heddlesten v. Saul · filed 2020-04-17(c)
At step two of the sequential process, the ALJ must determine whether claimant suffers from a “severe” impairment, i.e., one that significantly limits her physical or mental ability to do basic work activities. 20 C.F.R. § 416.920(c). ... The ALJ’s finding that Plaintiff’s mental impairments cause no more than mild limitations, and as such she does not have a severe impairment, is supported by substantial evidence. Plaintiff is not entitled to remand on these grounds.Read the full opinion on CourtListener →
At step two, an impairment is severe only if it significantly limits a claimant’s physical or mental ability to perform basic work activities.
Hornyak v. Commissioner of Social Security · filed 2020-04-20(c)
At step two, an impairment is considered severe when it “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 →
An impairment is severe at step two when it significantly limits the claimant’s ability to work; the ALJ must evaluate supported impairments before proceeding through the sequential analysis.
Johnson v. Berryhill · filed 2020-04-21(c)
An impairment is considered “severe” if it significantly limits the claimant’s ability to work. 20 C.F.R. § 416.920(c).Read the full opinion on CourtListener →
Section 416.920(c) treats an impairment as non-severe when it does not significantly limit basic work abilities or is not expected to last at least 12 months; under § 416.920(a), a severe impairment advances the claimant to the next step.
HILE v. BERRYHILL · filed 2020-04-21(c), (a)
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).Read the full opinion on CourtListener →
At step two, § 416.920(c) requires the ALJ to determine whether the claimant has a severe impairment that significantly limits the claimant's physical or mental ability to do basic work activities.
Kilwien v. Saul · filed 2020-04-22(c)
At step two of the sequential process, the ALJ must determine whether claimant suffers from a “severe” impairment, i.e., one that significantly limits her physical or mental ability to do basic work activities. 20 C.F.R. § 416.920(c).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 that significantly limits the ability to perform basic work activities.
Turner v. Kijakazi · filed 2020-05-12(c)
At step two of the sequential process, the ALJ must determine whether the claimant suffers from a “severe” impairment, i.e., one that significantly limits his physical or mental ability to do basic work activities. 20 C.F.R. § 416.920(c).Read the full opinion on CourtListener →
Section 416.920(c) permits an impairment to be found non-severe at step two only when it has no more than a minimal effect on the claimant’s ability to perform basic work activities.
Sandoval v. Commissioner of Social Security · filed 2020-05-18(c)
At the step two inquiry, an ALJ may find an impairment or combination of impairments to be non-severe only if the evidence shows only a “slight abnormality” that has no more than a minimal effect on an individual’s ability to work. Smolen v. Chater, 80 F.3d 1273, 1290 (9th Cir. 1996); see also 20 C.F.R. §§ 416.920(c), 416.921(a). ... The Court finds substantial evidence in the record to support the ALJ’s conclusion that Plaintiff’s degenerative disc disease causes no more than a minimal impact on his ability to perform basic work activities. ... Therefore, the Court finds that the ALJ did not err in finding that Plaintiff’s degenerative disc disease is a non-severe impairment.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 that significantly limits the claimant’s physical or mental ability to perform basic work activities.
Harrison v. Saul · filed 2020-05-22(c)
At step two of the sequential process, the ALJ must determine whether claimant suffers from a “severe” impairment, i.e., one that significantly limits her physical or mental ability to do basic work activities. 20 C.F.R. § 416.920(c). ... As the ALJ did not properly assess Plaintiff’s PTSD, ADHD, anxiety, or adjustment disorder, the Court cannot conclude that the ALJ accounted for all of Plaintiff’s impairments and limitations during subsequent steps of the sequential evaluation process performed as part of the DAA materiality analysis.Read the full opinion on CourtListener →
Section 416.920(c) treats an impairment or combination of impairments as severe when it significantly limits a claimant’s physical or mental ability to do basic work activities.
Vasquez v. Saul · filed 2020-05-29(c)
An “impairment or combination of impairments” 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).Read the full opinion on CourtListener →
Section 416.920(c) requires the ALJ to determine whether a claimant has a severe impairment at step two, and § 416.920(d) directs the evaluation to proceed to the next step when at least one severe impairment is found.
Harbour v. Commissioner of Social Security · filed 2020-06-19(c), (d)
At step two, the ALJ must determine if the claimant suffers from any impairments that are “severe.” 20 C.F.R. § 416.920(c). As long as the claimant has at least one severe impairment, the disability inquiry moves on to step three. See 20 C.F.R. § 416.920(d). The step-two inquiry “is not meant to identify the impairments that should be taken into account when determining the RFC.” Buck, 869 F.3d at 1048–49. At the RFC phase, the ALJ must consider the claimant’s limitations from all impairments, including those that are not severe. Id. at 1049. “The RFC therefore should be exactly the same regardless of whether certain impairments are considered ‘severe’ or not.” Id. (emphasis omitted). Thus, a claimant cannot be prejudiced by failure to consider a particular impairment severe at step two as long as the ALJ finds the claimant has at least one severe impairment, and still addresses the non-severe impairment when considering the claimant’s RFC. Id. (citing Molina v. Astrue, 674 F.3d 1104, 1115 (9th Cir. 2012)).Read the full opinion on CourtListener →
At step two, § 416.920 requires the Commissioner to find an impairment severe only when it significantly limits the claimant’s ability to perform basic work activities, using a de minimus screening standard rather than the stricter step-three listing standard.
(SS) Longoria v. Commissioner of Social Security · filed 2020-06-29(a)(4)(ii), (c)
At step two, the Commissioner determines whether the claimant has a medically severe impairment or combination of impairments. Bowen v. Yuckert, 482 U.S. 137, 140-41 (1987); 20 C.F.R. §416.920(a)(4)(ii). An impairment is a medically determinable physical or mental impairment or combination of physical or mental impairments. 20 C.F.R. § 416.902(f). If a claimant does not have an impairment or combination of impairments which significantly limit the claimant’s physical or mental ability to do basic work activities, the Commissioner will find that the claimant does not have a severe impairment. 20 C.F.R. § 416.920(c).Read the full opinion on CourtListener →
At Step Two, § 416.920(a)(4)(ii) requires the ALJ to determine whether the claimant has a severe medically determinable impairment; an impairment is not severe only if it has no more than a minimal effect on the ability to work.
Gracie v. Commissioner of Social Security · filed 2020-07-24(a)(4)(ii)
Additionally, the court also finds that the ALJ erred in finding Plaintiff’s ADD, IBS, and chronic adjustment disorder with depressed mood to be non-severe at Step Two. At Step Two of the sequential evaluation process, the ALJ must determine if a claimant has a “severe medically determinable physical or mental impairment.” 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii) (2015); see also Smolen, 80 F.3d at 1289-90. Impairments must result “from anatomical, physiological, or psychological abnormalities which can be shown by medically acceptable clinical and laboratory diagnostic techniques.” 20 C.F.R. § 416.908 (2010). A medically determinable impairment is considered “severe” if it “significantly limits [a claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1520(a)(4)(iii) & (c), 416.920(a)(4)(iii) & (c); see also SSR 96-3p, 1996 SSR LEXIS 10, 1996 WL 374181 *1. Basic work activities are those “abilities and aptitudes necessary to do most jobs,” including, for example, “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. § 404.1521(b), § 416.921(b). It is important to note, however, that the Step Two inquiry is merely a threshold determination as to whether a claimant has raised a “prima facie case of a disability.” Hoopai v. Astrue, 499 F.3d 1071, 1076 (9th Cir. 2007); see also Smolen, 80 F.3d at 1290 (noting the Step Two determination is a de minimis screening device used to dispose of groundless claims). For this reason, “[a]mple authority cautions against a determination of nondisability at step two.” Ortiz v. Commissioner of Social Sec., 425 F. App’x 653, 655 (9th Cir. 2011) (citing Bowen v. Yuckert, 482 U.S. 137, 153 (1987); see also Webb, 433 F.3d 683, 686 (9th Cir. 2005), Smolen, 80 F.3d at 1290. An impairment or combination of impairments may be found “not severe only if the evidence establishes [that there is only] a slight abnormality that has no more than a minimal effect on an individual’s ability to work.” Id.Read the full opinion on CourtListener →
At step two, an impairment is severe only if it significantly limits the claimant’s ability to perform basic work activities; an impairment with no more than a minimal effect is non-severe.
Meredith v. Commissioner of Social Security · filed 2020-07-28(c)
To be severe, and impairment must by itself “significantly” limit a claimant's ability to do “basic work activities,” which include “walking, standing, sitting, lifting, pushing, pulling, reaching, carrying, or handling.” 20 C.F.R. §§416.920(c), 416.921(b)(1). ... Thus, a “non-severe” impairment is one that is “a slight abnormality (or a combination of slight abnormalities) that has no more than a minimal effect on the ability to do basic work activities”.Read the full opinion on CourtListener →
At step two, § 416.920(c) defines a severe impairment as one that significantly limits a claimant’s ability to do basic work activities.
Jeley v. Commissioner of Social Security · filed 2020-08-06(c)
A severe impairment is defined as “any impairment or combination of impairments which significantly limits your physical or mental ability to do basic work activities,” 20 C.F.R. §§ 404.1520(c), 416.920(c), and which lasts or can be expected to last “for a continuous period of not less than 12 months.” 42 U.S.C. § 423(d)(1)(A). ... The Undersigned finds no legal error where, as here, the ALJ reasonably determined that a particular impairment was not severe and went on to consider that impairment as part of the sequential process.Read the full opinion on CourtListener →
Section 416.920(a)(4)(ii) requires a claimant at step two to show a severe impairment and satisfy the Act's durational requirement; the severity threshold is de minimis and excludes impairments with no more than a minimal effect on ability to work.
Mendez-Rodriguez v. Commissioner of Social Security · filed 2020-08-11(a)(4)(ii)
At step two of the sequential evaluation process, a claimant must demonstrate the existence of impairments that are “severe” from a vocational perspective, and that the impairments meet the durational requirement of the Act. 20 C.F.R. § 416.920(a)(4)(ii). The step two severity requirement imposes a de minimis burden, which is designed to screen out groundless claims. McDonald v. Sec'y of HHS, 795 F.2d 1118, 1123 (1st Cir. 1986). An impairment or combination of impairments is not severe when the 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.” Id. at 1124 (quoting Social Security Ruling 85–28).Read the full opinion on CourtListener →
Section 416.920(c) treats an impairment as severe when it significantly limits the claimant’s ability to perform basic work activities.
Lawson v. Saul · filed 2020-09-15(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 →
At step two, § 416.920(c) requires a claimant to show that a medically determinable impairment is severe; a diagnosis alone is insufficient.
(SS) Guzman v. Commissioner of Social Security · filed 2020-09-18(c)
Having established medically determinable mental impairment, Plaintiff must next show her impairment was severe. See Bowen, 482 U.S. at 153 (1987); 20 C.F.R. § 416.920(c). The Ninth Circuit determined that “[t]he mere existence of an impairment is insufficient proof of a disability.” Matthews v. Shalala, 10 F.3d 678 (9th Cir. 1993). In other words, a medical diagnosis alone does not make an impairment qualify as “severe.”Read the full opinion on CourtListener →
Section 416.920 requires the ALJ at step two to determine whether an alleged impairment significantly limits the claimant’s ability to perform basic work activities, considering all the evidence.
(SS) Trevino v. Commissioner of Social Security · filed 2020-09-21(c)
At step two of the sequential evaluation, the ALJ determines which of claimant’s alleged impairments are “severe” within the meaning of 20 C.F.R. § 416.920(c). A severe impairment is one that “significantly limits” a claimant’s “physical or mental ability to do basic work activities.” Id. An ALJ must consider all the evidence at step two to determine whether a medically determinable impairment significantly limits the claimant’s ability to perform basic work activities.Read the full opinion on CourtListener →
At step two, § 416.920(a)(4)(ii) directs SSA to assess the medical severity of a claimant's impairments, and § 416.920(c) treats an impairment as non-severe when it does not significantly limit basic work activities.
Solomon v. Saul · filed 2020-09-29(a)(4)(ii), (c)
At the second step, the SSA considers “the medical severity of [a claimant’s] impairment(s).” 20 C.F.R. § 416.920(a)(4)(ii). ... An impairment is not severe if it does not significantly limit a claimant’s physical or mental ability to do basic work activities. See Kirby, 500 at 707; 20 C.F.R. § 416.920(c).Read the full opinion on CourtListener →
Section 416.920(c) treats an impairment as nonsevere when it does not significantly limit basic work abilities or does not meet the twelve-month duration requirement, and § 416.920(a) directs the ALJ to proceed to the next step when a severe impairment is found.
HILL v. BERRYHILL · filed 2020-10-19(c), (a)
To be clear, 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). If a claimant is found to have a severe impairment, then the ALJ proceeds to the next step. 20 C.F.R. §416.920(a).Read the full opinion on CourtListener →
At step two, the ALJ determines whether the claimant has a severe impairment; if the impairments are not severe, the claimant is not disabled.
Berke v. Commissioner of Social Security · filed 2020-11-20(a)(4)(ii)
As discussed above, at step two, the ALJ decides if the claimant’s impairments are severe. 20 C.F.R. § 416.920(a)(4)(ii). If the impairments are not severe, then the claimant is not disabled. Id. An impairment is not severe if it does not significantly limit a claimant’s “physical or mental ability to do basic work activities.” Id. § 416.920(c). The ability to do basic work activities means the ability and aptitude necessary to perform most jobs. Bowen, 482 U.S. at 141 (quoting 20 C.F.R. §§ 404.1521(b), 416.921(b)).Read the full opinion on CourtListener →
Section 416.920(c) requires an impairment to significantly limit a claimant’s ability to perform basic work activities to be considered severe at step two.
Nelson v. Kijakazi · filed 2020-11-25(c)
Furthermore, for that medically determinable impairment to be considered ‘severe’ at step two of the sequential analysis, it must significantly limit an individual’s ability to perform basic work activities. 20 C.F.R. § 416.920(c); Smolen v. Chater, 80 F.3d 1273, 1290 (9th Cir. 1996). ... For all of these reasons, the Court finds the ALJ erred by failing to consider chronic pain impairment at step two.Read the full opinion on CourtListener →
At step two, the ALJ determines whether the claimant’s impairments are severe; an impairment is not severe if it does not significantly limit the claimant’s ability to perform basic work activities.
Berke v. Commissioner of Social Security · filed 2020-11-20(a)(4)(ii)
As discussed above, at step two, the ALJ decides if the claimant’s impairments are severe. 20 C.F.R. § 416.920(a)(4)(ii). If the impairments are not severe, then the claimant is not disabled. Id. An impairment is not severe if it does not significantly limit a claimant’s “physical or mental ability to do basic work activities.” Id. § 416.920(c).Read the full opinion on CourtListener →
Section 416.920(c) requires an impairment to significantly limit an individual’s ability to perform basic work activities to be considered severe at step two, and an ALJ must consider a claimed impairment at that step before proceeding through the sequential evaluation.
Nelson v. Kijakazi · filed 2020-11-25(c)
Furthermore, for that medically determinable impairment to be considered ‘severe’ at step two of the sequential analysis, it must significantly limit an individual’s ability to perform basic work activities. 20 C.F.R. § 416.920(c); Smolen v. Chater, 80 F.3d 1273, 1290 (9th Cir. 1996).Read the full opinion on CourtListener →
Section 416.920(c) requires the ALJ at Step Two to determine whether a medically determinable impairment is severe by assessing whether it significantly limits the claimant’s ability to perform basic work activities.
Borrero v. Commissioner of Social Security · filed 2020-11-30(c)
At Step Two of the sequential evaluation process, an ALJ must determine whether a claimant suffers from any “medically determinable” impairments. 20 C.F.R. § 416.921. If the claimant suffers from one or more such impairments, the ALJ then determines whether any of those impairments are “severe.” 20 C.F.R. § 416.920(c). To be “severe,” an impairment or combination of impairments must “significantly limit[]” the claimant’s “physical or mental ability to do basic work activities . . . .”7 See20 C.F.R. § 416.922. ... In summary, the Court concludes that the ALJ was not required to consider the Plaintiff’s unalleged mental impairments at Step Two or in his RFC analysis.Read the full opinion on CourtListener →
Section 416.920(c) requires the ALJ at Step Two to determine whether a medically determinable impairment is severe, meaning it significantly limits the claimant’s ability to perform basic work activities.
Borrero v. Commissioner of Social Security · filed 2020-11-30(c)
At Step Two of the sequential evaluation process, an ALJ must determine whether a claimant suffers from any “medically determinable” impairments. 20 C.F.R. § 416.921. If the claimant suffers from one or more such impairments, the ALJ then determines whether any of those impairments are “severe.” 20 C.F.R. § 416.920(c). To be “severe,” an impairment or combination of impairments must “significantly limit[]” the claimant’s “physical or mental ability to do basic work activities . . . .”7 See20 C.F.R. § 416.922.Read the full opinion on CourtListener →
Section 416.920 requires a five-step disability analysis and, at step two, directs the ALJ to assess whether the claimant has a severe impairment that significantly limits basic work activities.
MARKOCH v. COMMISSIONER OF SOCIAL SECURITY · filed 2020-12-22(a)(4)(ii), (c)
At step two, the ALJ has to “consider the medical severity of a claimant’s impairment(s).” 20 C.F.R. § 416.920(a)(4)(ii). “The severity test at step two is a ‘de minimis screening device to dispose of groundless claims.’” McCrea v. Comm'r of Soc. Sec., 370 F.3d 357, 360–61 (3d Cir. 2004) (citation omitted). The severe impairment “must have lasted or must be expected to last for a continuous period of at least twelve months.” 20 C.F.R. § 416.905(a). In order to have a severe impairment, the impairment or combination thereof must significantly limit a person’s “physical or mental ability to do basic work activities.” 20 C.F.R. § 416.920(c). The burden at step two is on the claimant to show “something beyond 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 →
At step two, § 416.920 requires the ALJ to assess the medical severity of the claimant’s impairment or combination of impairments, which is severe only if it significantly limits the ability to perform basic work activities.
MARKOCH v. COMMISSIONER OF SOCIAL SECURITY · filed 2020-12-22(a)(4)(ii), (c)
At step two, the ALJ has to “consider the medical severity of a claimant’s impairment(s).” 20 C.F.R. § 416.920(a)(4)(ii). ... In order to have a severe impairment, the impairment or combination thereof must significantly limit a person’s “physical or mental ability to do basic work activities.” 20 C.F.R. § 416.920(c).Read the full opinion on CourtListener →
At Step Two, § 416.920(c) requires the ALJ to determine whether an impairment significantly limits the claimant’s physical or mental ability to perform basic work activities; an impairment that does not do so is not severe.
Rojas v. Commissioner of Social Security · filed 2020-12-10(c)
As a general matter, in Step Two of the analysis, the ALJ is required to determine whether an impairment or combination of impairments that has lasted or is expected to last for a continuous period of at least 12 months limits claimant’s physical or mental ability to perform basic work activities. See 20 C.R.F. §§ 416.909, 416.920(c). ... Plaintiff argues that the ALJ should have considered his PTSD and cluster B traits to be severe impairments at Step Two of the analysis because he was diagnosed with both impairments by Dr. Ghosh, his treating mental health provider. ECF No. 9 at 11-12. Even though Plaintiff correctly notes that the ALJ did not make specific references to his PTSD or cluster B traits in his opinion, Plaintiff's argument is, nonetheless, without merit because the limited medical evidence relating to his PTSD and cluster B traits does not support Plaintiffs position that either impairment significantly limited his ability to do basic work. See 20 C.F.R. § 416.920; see also Woodmancy v. Colvin, 577 F. App’x 72, 74 (2d Cir. 2014).Read the full opinion on CourtListener →
Section 416.920(c) requires the ALJ at step two to determine whether a claimant has a severe impairment that significantly limits the claimant’s physical or mental ability to do basic work activities.
Hall v. Saul · filed 2021-01-19(c)
At step two of the sequential process, the ALJ must determine whether the claimant suffers from a “severe” impairment, i.e., one that significantly limits her physical or mental ability to do basic work activities. 20 C.F.R. § 416.920(c).Read the full opinion on CourtListener →
Section 416.920(c) requires the Commissioner at step two to determine whether an impairment significantly limits a claimant’s physical or mental ability to do basic work activities.
Hall v. Saul · filed 2021-01-19(c)
At step two of the sequential process, the ALJ must determine whether the claimant suffers from a “severe” impairment, i.e., one that significantly limits her physical or mental ability to do basic work activities. 20 C.F.R. § 416.920(c). To establish a severe impairment, the claimant must first demonstrate the existence of a physical or mental impairment by providing medical evidence consisting of signs, symptoms, and laboratory findings; the claimant’s own statement of symptoms alone will not suffice. 20 C.F.R. § 416.921. ... There is substantial evidence to support the ALJ’s finding that carpal tunnel syndrome is not 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 perform basic work activities.
Volbert v. Commissioner of Social Security Administration · filed 2021-01-19(c)
At Step Two of the sequential analysis, an ALJ must determine a claimant’s “severe” impairments. A severe impairment is one “which significantly limits” an individual’s ability to perform basic work activities. 20 C.F.R. § 416.920(c). An impairment is only considered non-severe if it is a “slight abnormality that minimally affects work ability regardless of age, education, and experience.”Read the full opinion on CourtListener →
At step two, an impairment is severe when it significantly limits a claimant’s mental or physical ability to perform basic work activities; an impairment causing only a slight abnormality with no more than a minimal effect on work ability is not severe.
Guerrero v. Commissioner of Social Security · filed 2021-01-21(c)
At step two of the sequential evaluation, the ALJ must determine if the claimant suffers from any medically determinable impairments that are “severe.” 20 C.F.R. § 404.1520(a)(4)(ii). An impairment is not considered to be “severe” if it does not “significantly limit” a claimant's mental or physical abilities to do basic work activities. 20 C.F.R. § 416.920(c); Social Security Ruling (“SSR”) 96-3p, 1996 WL 374181, at *1. Basic work activities are those “abilities and aptitudes necessary to do most jobs.” 20 C.F.R. § 404.1522(b); SSR 85-28, 1985 WL 56856, at *3. An impairment is not severe if the evidence establishes only a slight abnormality that has “no more than a minimal effect on an individual[’]s ability to work.” SSR 85-28, 1985 WL 56856, at *3; Smolen v. Chater, 80 F.3d 1273, 1290 (9th Cir. 1996).Read the full opinion on CourtListener →
Section 416.920(c) treats an impairment as severe when it significantly limits a claimant’s ability to perform basic work activities; emergency treatment is not required.
Braden v. Commissioner of Social Security · filed 2021-01-26(c)
Rather, a severe impairment is one which significantly limit the claimant’s ability to perform basic work activities. 20 C.F.R. §§416.920(c); 416.921(a). Nowhere in the regulations does it state that an impairment must require emergency treatment in order to significantly limit one’s ability to perform basic work activities. The ALJ erred in finding Ms. Braden’s Sjögren’s syndrome was nonsevere simply because there was no emergency treatment in the record.Read the full opinion on CourtListener →
Section 416.920(c) treats an impairment as severe when it significantly limits a claimant’s ability to perform basic work activities.
Braden v. Commissioner of Social Security · filed 2021-01-26(c)
Rather, a severe impairment is one which significantly limit the claimant’s ability to perform basic work activities. 20 C.F.R. §§416.920(c); 416.921(a). Nowhere in the regulations does it state that an impairment must require emergency treatment in order to significantly limit one’s ability to perform basic work activities. The ALJ erred in finding Ms. Braden’s Sjögren’s syndrome was nonsevere simply because there was no emergency treatment in the record.Read the full opinion on CourtListener →
At step two, § 416.920 requires the ALJ to determine whether the claimant has a severe impairment that significantly limits the ability to perform basic work activities.
Pereira v. Commissioner of Social Security · filed 2021-01-29(a)(4)(ii)
At step two of the evaluation, the ALJ must determine whether the claimant has a “severe impairment” that “significantly limits [the claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. §§ 416.920(a)(4)(ii), (c). ... In this case, any step-two error by the ALJ in failing to separately consider plaintiff’s headache impairment was harmless because the ALJ proceeded through the sequential evaluation and explicitly considered plaintiff’s headaches during the subsequent analysis. ... Accordingly, I conclude that any error at step two was harmless.Read the full opinion on CourtListener →
Section 416.920(c) treats an impairment as non-severe when it does not significantly limit basic work abilities or does not meet the required duration, and the court applied that step-two standard in affirming the ALJ’s findings.
ZAGARI v. SAUL · filed 2021-02-22(c)
At step two of the analysis, an ALJ must determine whether the claimant has a medically determinable impairment that is severe or a combination of impairments that is severe. ... To be clear, 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). ... If a claimant is found to have a severe impairment, then the ALJ proceeds to the next step. 20 C.F.R. §416.920(a).Read the full opinion on CourtListener →
At step two, the ALJ must determine whether the claimant has a medically determinable impairment or combination of impairments that is severe; a severe impairment advances the sequential analysis to step three.
Bonilla v. Saul · filed 2021-02-25(a)(4)(ii)
As mentioned supra, at step two the ALJ is required to consider whether a claimant's impairments are (1) medically determinable and (2) severe. 20 C.F.R. § 416.920 (a)(4)(ii). This severity inquiry is a de minimis screening device used to discard meritless claims. See Newell v. Commissioner of Social Security, 347 F.3d 541, 546 (3d Cir. 2003); McCrea v. Commissioner of Social Security, 370 F.3d 357, 360 (3d Cir. 2004). If an ALJ determines that a claimant has a severe condition at step two, then the sequential analysis proceeds to step three. 20 C.F.R. § 416.920 (a)(4)(ii).Read the full opinion on CourtListener →
Section 416.920(c) treats an impairment as nonsevere when it does not significantly limit basic work activities or does not meet the required 12-month duration.
WOLF v. COMMISSIONER OF SOCIAL SECURITY · filed 2021-02-25(c)
To be clear, 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). If a claimant is found to have a severe impairment, then the ALJ proceeds to the next step. 20 C.F.R. §416.920(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.
Ramos v. Saul · filed 2021-03-01(c)
An “impairment or combination of impairments” 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). ... Here, the ALJ erred at step two by failing to consider any evidence of Plaintiff’s COPD when determining that Plaintiff had no severe physical impairments. ... Accordingly, because the ALJ failed to consider or discuss any of the evidence relating to Plaintiff’s COPD related impairments when finding that Plaintiff had no physical limitations whatsoever, the Court finds that the ALJ’s step two finding is not supported by substantial evidence in the record.Read the full opinion on CourtListener →
At step two, § 416.920(c) treats an impairment as severe when it significantly limits a claimant’s ability to perform basic work activities; the severity screen is only a de minimis threshold.
Needham v. Commissioner of Social Security · filed 2021-03-05(c)
A severe impairment or combination of impairments is one which significantly limits the physical or mental ability to perform basic work activities. 20 C.F.R. §416.920(c).Read the full opinion on CourtListener →
Section 416.920(a)(4)(ii) makes Step Two a de minimis screening inquiry for medically severe impairments; once the claimant meets that threshold, the ALJ must proceed to the next step.
Parrish v. Saul · filed 2021-03-16(a)(4)(ii)
It is well established that the evaluation of claimed impairments at Step Two of the sequential evaluation process is a de minimis test intended to weed out the most minor of impairments, as well as functioning as a screening device to dispose of patently groundless claims.Read the full opinion on CourtListener →
Section 416.920(a)(4)(ii) makes Step Two a de minimis screening inquiry into whether the claimant has a medically severe impairment, and requires the evaluation to proceed when that threshold is met.
Soulis v. Saul · filed 2021-03-17(a)(4)(ii)
The evaluation of claimed impairments at Step Two of the sequential evaluation process is a de minimis test intended to weed out the most minor of impairments, as well as functioning as a screening device to dispose of patently groundless claims. ... Thus, a finding of non-severity at Step Two must be “clearly established by medical evidence” (see id.), and if a claimant meets her evidentiary burden under Step Two’s de minimis standard, an ALJ “must find that the impairment is ‘severe’ and move to the next step” in the five-step evaluation process.Read the full opinion on CourtListener →
At step two, an impairment is not severe unless it significantly limits the claimant’s ability to perform basic work activities and satisfies the required duration period.
WOOD v. SAUL · filed 2021-03-23(c)
To be clear, 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).Read the full opinion on CourtListener →
Section 416.920(c) treats an impairment as non-severe when it does not significantly limit a claimant's mental or physical ability to perform basic work activities.
Dandridge Bacon v. Commissioner of Social Security · filed 2021-04-27(c)
At step two of the sequential evaluation, the ALJ must determine if the claimant suffers from any medically determinable impairments that are “severe.” 20 C.F.R. § 404.1520(a)(4)(ii). An impairment is not considered to be “severe” if it does not “significantly limit” a claimant's mental or physical abilities to do basic work activities. 20 C.F.R. § 416.920(c); Social Security Ruling (“SSR”) 96-3p, 1996 WL 374181, at *1. Basic work activities are those “abilities and aptitudes necessary to do most jobs.” 20 C.F.R. § 404.1522(b); SSR 85-28, 1985 WL 56856, at *3. An impairment is not severe if the evidence establishes only a slight abnormality that has “no more than a minimal effect on an individual[’]s ability to work.” SSR 85-28, 1985 WL 56856, at *3; Smolen v. Chater, 80 F.3d 1273, 1290 (9th Cir. 1996). ... Accordingly, the ALJ erred in evaluating Plaintiff’s mental health impairments at step two of the sequential evaluation.Read the full opinion on CourtListener →
At step two, § 416.920(c) treats an impairment as severe only if it significantly limits a claimant’s ability to perform basic work activities.
Scott v. Commissioner of Social Security Administration · filed 2021-05-14(c)
As for carpal tunnel syndrome and tendinopathy, the ALJ explained the basis for her conclusion that the non-severe impairments did not impact the RFC, writing “the record failed to reveal an aggressive course of treatment for any alleged physical condition since the application date.” (Id., PageID #83–84.) She therefore acknowledged the limitations in the RFC and provided some explanation why they did not account for additional functional limitations. ... She described both limitations as mild or transient and well-controlled with treatment. (Id.) Additionally, the ALJ noted that “exams in the treatment records otherwise failed to reveal any motor, strength, sensory, or right wrist/left shoulder use deficits or abnormalities.” (ECF No. 11, PageID #72.) Accordingly, she concluded the impairments “do not more than minimally limit the claimant’s ability to engage in work-related activities.” (Id.) ... Mr. Scott asserted the ALJ erred in finding that carpal tunnel syndrome and left shoulder rotator cuff tendinopathy are not severe impairments at step two of the evaluation process under 20 C.F.R. § 416.920(c). The Magistrate Judge found the ALJ did not err in explaining why carpal tunnel syndrome and left shoulder rotator cuff tendinopathy are non-severe impairments. (ECF No. 18, PageID #1531.) ... The Court disagrees for the reasons already discussed.Read the full opinion on CourtListener →
Section 416.920(a)(4) requires a claimant to have a severe impairment at step two; an impairment is not severe when it has no more than a minimal effect on the ability to perform basic work activities.
Osmon v. Saul · filed 2021-06-09(a)(4)
At step two of the evaluation, an ALJ will conclude that a claimant “is not disabled if his [or her] impairments are not ‘severe.’” ... “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.” ... “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.” ... “It is the claimant’s burden to establish that his [or her] impairment or combination of impairments are severe.” ... “Severity is not an onerous requirement for the claimant to meet . . . but it is also not a toothless standard.”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 twelve consecutive months to be severe at step two.
Wiley v. Saul · filed 2021-06-21(c)
Generally, in order to find a severe impairment or combination of impairments in step two, the impairment(s) must significantly limit the claimant’s physical or mental ability to perform basic work activities for at least twelve consecutive months. See 20 C.F.R. §§ 416.920(c) & 416.922(a). ... Because the ALJ found some severe impairments and went on to consider Spring’s impairments in her RFC analysis, any error in not naming rheumatoid arthritis as a severe limitation at step two was harmless.Read the full opinion on CourtListener →
Section 416.920(c) requires the Commissioner at step two to determine whether an impairment significantly limits basic work activities, with an impairment considered non-severe only when it is a slight abnormality that does not significantly limit those activities.
Presson v. Kijakazi · filed 2021-06-22(c)
Second, if the claimant is not engaged in substantial gainful activity, the Commissioner looks to see whether “the claimant has a severe impairment . . . which significantly limits [claimant’s] physical or mental ability to do basic work activities.” Hurd v. Astrue, 621 F.3d 734, 738 (8th Cir. 2010) (quoting 20 C.F.R. § 416.920(c)). “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); see also 20 C.F.R. §§ 416.920(c), 416.920a(d). ... The Court agrees with Plaintiff’s contention that substantial evidence in the record as a whole does not support the ALJ’s conclusion that his OSA was well controlled with CPAP treatment. Thus, the Court finds the ALJ erred by failing to properly evaluate the severity of Plaintiff’s OSA at Step Two. The Court will remand this case for reconsideration of whether Plaintiff’s OSA is a severe or non-severe impairment.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 at step two.
Mette v. Saul · filed 2021-06-25(c)
An impairment is “severe” if it “significantly limits [Plaintiff’s] physical or mental ability to do basic work activities.” 20 C.F.R. §§ 416.920(c), 416.921(a). ... First, the mere diagnosis of post-traumatic stress disorder, post-acute withdrawal-amphetamine syndrome, and major depressive disorder is not sufficient to demonstrate severity at step two of the evaluation process.Read the full opinion on CourtListener →
At step two, § 416.920(c) requires the Commissioner to determine whether the claimant has an impairment that significantly limits the ability to perform basic work activities; an impairment that does not meet that severity threshold is non-severe.
Lynn v. Saul · filed 2021-07-06(c)
At step two of the sequential process, the ALJ must determine whether claimant suffers from a “severe” impairment, i.e., one that significantly limits her physical or mental ability to do basic work activities. 20 C.F.R. § 416.920(c).Read the full opinion on CourtListener →
At step two, § 416.920(a)(4)(ii) requires the ALJ to identify impairments that significantly limit a claimant’s ability to do basic work activities.
Yolanda Catalina Miller v. Saul · filed 2021-07-06(a)(4)(ii)
At step two, the ALJ identifies a claimant’s severe impairments, i.e., impairments that significantly limit his or her ability to do basic work activities. 20 C.F.R. § 416.920(a)(4)(ii); Smolen, 80 F.3d at 1290.Read the full opinion on CourtListener →
Section 416.920(c) requires the ALJ to determine whether an impairment significantly limits a claimant’s physical or mental ability to perform basic work activities.
Munoz v. Commissioner of Social Security · filed 2021-07-20(c)
At step two of the sequential evaluation process, the ALJ must determine whether Plaintiff has a severe impairment that significantly limits her physical or mental ability to do basic work activities. See 20 C.F.R. § 416.920(c)2.Read the full opinion on CourtListener →
At step two of the sequential evaluation, § 416.920(a)(4) requires consideration of impairment severity and directs a finding of not disabled when the claimant lacks a severe impairment or combination of impairments meeting the duration requirement.
Groomes v. Social Security Administration · filed 2021-07-27(a)(4)
At step two, the ALJ must “consider the medical severity of [the claimant’s] impairment(s). If [the claimant] do[es] not have a severe medically determinable physical or mental impairment that meets the duration requirement . . . or a combination of impairments that is severe and meets the duration requirement, we will find that [the claimant is] not disabled.” 20 C.F.R. § 404.1520(a)(4); id. § 416.920(a)(4).Read the full opinion on CourtListener →
Section 416.920(c) requires an impairment to significantly limit basic work activities to be severe at Step Two, but any one severe impairment is enough to advance the claimant beyond that step, after which the ALJ must consider the claimant’s entire medical condition, including non-severe impairments.
Turner v. Kijakazi (CONSENT) · filed 2021-07-30(c)
The finding of any severe impairment, based on either a single impairment or a combination of impairments, is enough to satisfy Step 2 because, once the ALJ proceeds beyond Step 2, 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 →
Section 416.920(c) allows the sequential evaluation to proceed past step two when an impairment or combination of impairments significantly limits a claimant’s physical or mental ability to perform basic work activities.
Cupp v. Kijakazi · filed 2021-08-02(c)
At step two of the sequential evaluation process, the ALJ considers the severity of the claimant’s impairment. 20 C.F.R. § 416.920(a)(4)(ii). If the claimant suffers from “any impairment or combination of impairments which significantly limits [his or her] physical or mental ability to do basic work activities,” the analysis proceeds to step three. 20 C.F.R. § 416.920(c). Step two is “a de minimis screening device [used] to dispose of groundless claims.” ... “Thus, applying our normal standard of review to the requirements of step two, [the Court] must determine whether the ALJ had substantial evidence to find that the medical evidence clearly established that [Plaintiff] did not have a medically severe impairment or combination of impairments.” ... The ALJ’s finding was supported by substantial evidence in the record.Read the full opinion on CourtListener →
Section 416.920(a)(4) requires the ALJ at step two to assess the severity of the claimant’s medically determinable impairment or combination of impairments and find the claimant not disabled if no severe impairment or combination meets the duration requirement.
Groomes v. Social Security Administration · filed 2021-08-04(a)(4)
At step two, the ALJ must “consider the medical severity of [the claimant’s] impairment(s). If [the claimant] do[es] not have a severe medically determinable physical or mental impairment that meets the duration requirement . . . or a combination of impairments that is severe and meets the duration requirement, we will find that [the claimant is] not disabled.” 20 C.F.R. § 404.1520(a)(4); id. § 416.920(a)(4). ... Thus, if back pain is an “impairment”—whether severe or not—the ALJ was required to consider it in combination with her other impairments.Read the full opinion on CourtListener →
At step two, an impairment is severe only if it significantly limits the claimant’s ability to perform basic work activities.
Haynes v. Kijakazi · filed 2021-09-03(c)
Furthermore, for that medically determinable impairment to be considered ‘severe’ at step two of the sequential analysis, it must significantly limit an individual’s ability to perform basic work activities. 20 C.F.R. § 416.920(c); Smolen v. Chater, 80 F.3d 1273, 1290 (9th Cir. 1996).Read the full opinion on CourtListener →
Section 416.920(c) treats an impairment as severe when it significantly limits a claimant’s ability to perform basic work activities, and a finding of any severe impairment permits the sequential evaluation to proceed.
Tate v. Commissioner of Social Security · filed 2021-09-07(c)
At step two, an ALJ considers the severity of a claimant’s impairments. 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii). An impairment or combination of impairments is not severe “if it does not significantly limit [a claimant’s] physical or mental ability to do basic work activities” 20 C.F.R. §§ 404.1522(a), 416.922(a). In other words, a severe impairment is an impairment or combination thereof that significantly limits a claimant’s abilities to perform basic work activities. See SSR 85-28, 1985 WL 56856, *4 n.1; 20 C.F.R. §§ 404.1520(c), 404.1522(a), 416.920(c), 416.922(a).Read the full opinion on CourtListener →
Section 416.920(c) requires a medically determinable impairment to significantly limit a claimant’s ability to perform basic work activities to be considered severe at step two.
Hagen v. Kijakazi · filed 2021-09-15(c)
Furthermore, for that medically determinable impairment to be considered ‘severe’ at step two of the sequential analysis, it must significantly limit an individual’s ability to perform basic work activities. 20 C.F.R. § 416.920(c); Smolen v. Chater, 80 F.3d 1273, 1290 (9th Cir. 1996).Read the full opinion on CourtListener →
Section 416.920(c) requires an impairment to significantly limit basic work activities and last or be expected to last at least twelve months to qualify as severe at step two.
Demaris v. Kijakazi · filed 2021-09-21(c)
At step two of the sequential evaluation process, the ALJ must determine if the claimant’s impairments are severe. 20 C.F.R. §§ 404.1520(c), 416.920(c). For an impairment to be severe, the impairment must significantly limit the claimant’s ability to do basic work activities and have lasted or can be expected to last for a continuous period of not less than twelve months. Id., 42 U.S.C. §§ 423(d)(1)(A), 1382c(a)(3)(A).Read the full opinion on CourtListener →
Section 416.920(c) requires the ALJ at step two to find an impairment severe only when it significantly limits the claimant’s physical or mental ability to perform basic work activities.
Williams v. Commissioner of Social Security · filed 2021-09-23(c)
To determine if a claimant has a severe impairment, the ALJ must find that an impairment, or combination of impairments, significantly limits the claimant’s physical or mental ability to do “basic work activities.” See 20 C.F.R. § 416.920(c).Read the full opinion on CourtListener →
At step two, an impairment is severe only if it significantly limits the claimant’s physical or mental ability to perform basic work activities.
Cavazos v. Kijakazi · filed 2021-10-04(c)
At step two of the sequential process, the ALJ must determine whether claimant suffers from a “severe” impairment, i.e., one that significantly limits her physical or mental ability to do basic work activities. 20 C.F.R. § 416.920(c). ... The ALJ’s step two analysis does not sufficiently set forth an analysis as to why Dr. Nestler’s opinion was rejected, and it lacks a discussion of any of the abnormal findings in the record outside of Dr. Nestler’s examination. ... Given the ALJ’s failure to address the entirety of Dr. Nestler’s opinion, and to consider relevant evidence in the record, the ALJ’s step two analysis is not supported by substantial evidence.Read the full opinion on CourtListener →
Section 416.920(c) requires the Commissioner to proceed beyond step two when an impairment or combination significantly limits the claimant’s ability to perform basic work activities, but requires a finding of not disabled when that severity threshold is not met.
Hadley v. O'Malley · filed 2021-12-08(c)
If the claimant suffers from “any impairment or combination of impairments which significantly limits [his] physical or mental ability to do basic work activities,” the analysis proceeds to step three. 20 C.F.R. § 416.920(c). If the claimant’s impairment does not satisfy this severity threshold, however, the Commissioner must find that the claimant is not disabled. 20 C.F.R. § 416.920(c).Read the full opinion on CourtListener →
At step two, § 416.920 requires the ALJ to determine whether the claimant has a severe impairment; finding any severe impairment satisfies step two and permits the evaluation to proceed to step three.
Sanchez v. Commissioner of Social Security · filed 2021-12-10(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 this standard in mind, even if the ALJ should have characterized Plaintiff’s unspecified neurodevelopmental disorder as a severe impairment, any error is harmless because the ALJ characterized other impairments – diabetes mellitus; obesity; mild persistent asthma; depressive disorder; and bipolar disorder – as severe. (Tr. 37). The ALJ then advanced to step three of the sequential evaluation.Read the full opinion on CourtListener →
At step two, the Commissioner evaluates whether an impairment significantly limits basic work activities; if it does, the claim proceeds to step three, and if not, the claimant is found not disabled.
England v. Commissioner of Social Security · filed 2021-12-13(a)(4)(ii), (c)
At step two of the sequential evaluation process, the ALJ considers the severity of the claimant’s impairment. 20 C.F.R. § 416.920(a)(4)(ii). If the claimant suffers from “any impairment or combination of impairments which significantly limits [his or her] physical or mental ability to do basic work activities,” the analysis proceeds to step three. 20 C.F.R. § 416.920(c). “Thus, applying our normal standard of review to the requirements of step two, [the Court] must determine whether the ALJ had substantial evidence to find that the medical evidence clearly established that [Plaintiff] did not have a medically severe impairment or combination of impairments.” ... The Court cannot say that the ALJ’s conclusion that Plaintiff’s bilateral CTS was non-severe was clearly established by medical evidence and that it is a groundless claim at this de minimis screening step. ... Therefore, this case is remanded to readdress Plaintiff’s bilateral CTS at step two and thereafter.Read the full opinion on CourtListener →
Section 416.920(c) requires the step-two inquiry to determine whether a claimant has a severe impairment that significantly limits physical or mental ability to perform work activities; the severity threshold is de minimis and screens out only the weakest cases.
Harper v. Commissioner of Social Security · filed 2022-01-13(c)
At the second step of the sequential analysis, the ALJ must determine whether the plaintiff has a severe impairment that significantly limits the plaintiff's physical or mental ability to do certain work activities. Trombley v. Berryhill, 1:17-CV-00131, 2019 WL 1198354, at *5 (WDNY Mar. 14, 2019); 20 CFR. § 404.1520(c), 416.920(c). The step-two severity standard “is de minimis and intended only to screen out the very weakest cases.”Read the full opinion on CourtListener →
At step two, § 416.920(c) requires the ALJ to determine whether the claimant has a severe impairment that significantly limits basic work activities.
(SS) Amador v. Commissioner of Social Security · filed 2022-01-14(c)
At step two of the sequential process, the ALJ must determine whether the claimant suffers from a “severe” impairment, i.e., one that significantly limits her physical or mental ability to do basic work activities. 20 C.F.R. § 416.920(c). ... As the record stands, the Court finds the ALJ relied on substantial evidence to find Plaintiff’s alleged impairments were not severe at step two.Read the full opinion on CourtListener →
Section 416.920(c) treats an impairment as severe when it causes more than a minimal limitation on the claimant’s ability to perform basic work activities and requires the sequential evaluation to continue when a severe impairment is found.
Norman v. Commissioner Social Security Administration · filed 2022-01-20(c)
The step two inquiry is a de minimis screening device to dispose of groundless claims. ... An impairment or combination of impairments is “not severe only if the evidence establishes a slight abnormality that has no more than a minimal effect on an individual’s ability to work.” ... If the ALJ determines that a claimant is severely impaired at step two, the ALJ continues with the sequential analysis, considering all of the claimant’s limitations, whether or not they are severe. ... On this record, this Court cannot say the ALJ erred in his conclusion that Plaintiff’s knee impairments do not cause more than a minimal limitation in her ability to perform basic work. ... any error is harmless. First, Plaintiff points to diagnoses contained in the medical record, but does not tie these diagnoses to any functional limitations that the ALJ failed to consider in his sequential analysis. ... Second, the ALJ assessed certain severe limitations at step two. When he proceeded with the sequential analysis, the ALJ considered the impact of all of Plaintiff’s alleged conditions, both severe and not, in evaluating her RFC, rendering the omission at step two harmless.Read the full opinion on CourtListener →
Section 416.920(c) requires the Commissioner to determine at step two whether an impairment significantly limits the claimant’s physical or mental ability to do basic work activities.
Ponce v. Kijakazi · filed 2022-02-04(c)
At step two of the sequential process, the ALJ must determine whether the claimant suffers from a “severe” impairment, i.e., one that significantly limits her physical or mental ability to do basic work activities. 20 C.F.R. § 416.920(c). ... Plaintiff does not point to any specific limitations caused by the impairments that the ALJ failed to account for in the RFC. As such, Plaintiff has not met her burden in demonstrating her impairments are severe nor that the ALJ harmfully erred in finding the impairments non-severe. Plaintiff is not entitled to remand on these grounds.Read the full opinion on CourtListener →
At step two under § 416.920(a)(4)(ii), a claimant must show a medically determinable severe impairment or combination of impairments, and an impairment is not severe only if it has no more than a minimal effect on basic work activities.
Morrison v. Saul · filed 2022-03-09(a)(4)(ii)
At Step Two, the claimant bears the burden of showing that he has a medically determinable severe impairment or combination of impairments. See 20 C.F.R. § 416.920(a)(4)(ii), (c). ... Second, the court must remind the Commissioner (and by extension, the ALJ) that “[s]tep two . . . is a de minimis screening device [used] to dispose of groundless claims, and an ALJ may find that a claimant lacks a medically severe impairment or combination of impairments only when his [or her] conclusion is clearly established by medical evidence.” ... At bottom, however, it cannot be argued that the ALJ’s Step Two errors in this case were harmless because Plaintiff’s chronic pain and arthropathies clearly result in functional limitations that were not taken into account at Step Three or beyond.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, and failure to designate an impairment as severe at step two is not reversible error if the ALJ considers its limitations at the later steps.
Zingale v. Commissioner of Social Security · filed 2022-03-18(c)
A “severe” impairment, according to Social Security regulations, is “any impairment or combination of impairments which significantly limits [a claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. § 416.920(c). ... Thus, an ALJ’s decision not to designate an impairment as “severe” at step two does “not constitute reversible error,” so long as the ALJ considers all of a claimant’s limitations caused by both severe and non-severe impairments at the remaining steps of the sequential evaluation.Read the full opinion on CourtListener →
Section 416.920(c) treats an impairment as severe when it significantly limits a claimant’s ability to perform basic work activities within the five-step disability evaluation.
St. John v. Kijakazi · filed 2022-03-21(c)
A severe impairment is one that significantly limits the plaintiff’s physical and/or mental ability to do basic work activities. See 20 C.F.R. §§ 404.1520(c)), 416.920(c); see also 20 C.F.R. §§ 404.1521(a), 416.921(a) (noting that an impairment is not severe at step two if it does not significantly limit a claimant’s ability to do basic work activities). ... Plaintiff contends that remand is necessary because his diagnosed HS and recurring cysts caused significant physical pain and thus the ALJ should have considered them to be a severe impairment at step two and accounted for the resulting functional limitations in his RFC determination. ... The Court agrees that these medically determinable physical impairments should have been considered at step two and as part of the RFC determination, and that remand for further administrative proceedings is necessary.Read the full opinion on CourtListener →
Section 416.920(c) requires evidence that a diagnosed impairment significantly limits a claimant’s physical or mental ability to perform basic work activities for at least 12 consecutive months to establish severity at step two.
Solano v. Kijakazi · filed 2022-03-21(c)
To establish severity, the evidence must show the diagnosed impairment significantly limits a 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, an impairment is severe when it significantly limits a claimant’s physical or mental ability to perform basic work activities and has lasted or is expected to last at least twelve months; it is non-severe only when it is a slight abnormality with no more than a minimal effect on the ability to work.
Carthen v. Commissioner of Social Security · filed 2022-03-28(a)(4)(ii), (c)
At Step Two, the ALJ determines whether any of the claimant's impairments is severe and has lasted or is expected to last a continuous period of at least twelve months. 20 C.F.R. § 416.920(a)(4)(ii) (2017) (citing 20 C.F.R. § 416.909 (2017)). An impairment is severe if it “significantly limits [the claimant's] physical or mental ability to do basic work activities.” 20 C.F.R. § 416.920(c) (2017). ... As demonstrated above, the ALJ erred in finding Plaintiff’s headaches and related conditions, including insomnia and medication side effects, were not severe for well in excess of one year. ... As such, the decision is reversed and remanded for consideration of all of the medical-evidence.Read the full opinion on CourtListener →
At step two, the ALJ considers whether the claimant has a medically determinable impairment that is severe or non-severe, and severity must be analyzed separately from the twelve-month duration requirement.
Naylor v. Commissioner of Social Security · filed 2022-03-28(a)(4)(ii)
At step two of the sequential evaluation process, the ALJ considers whether a claimant’s impairment is (1) medically determinable or non-medically determinable, and (2) severe or non-severe. 20 C.F.R. § 404.1520(a)(4)(ii); 20 C.F.R. § 416.920(a)(4)(ii); SSR 85-28, 1985 WL 56856. ... Under the Commissioner’s regulations, an impairment is “non-severe” if it “does not significantly limit [a claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1521; 20 C.F.R. § 416.921. Conversely, an impairment is “severe” if it does significantly limit a claimant’s physical or mental ability to do basic work activities. The phrase, “significantly limits,” however is not synonymous with “disability.” Rather, the ALJ’s analysis at step two is a threshold test designed to screen out de minimis claims. ... In this case, the ALJ appears to conflate the two analytically distinct concepts of severity and duration. Unlike the severity analysis, the question of impairment duration requires the ALJ to evaluate whether the impairment has lasted, or is expected to last, for a continuous period of at least twelve (12) months. ... Because ALJ improperly conflated the issues of impairment duration with impairment severity at step two, I find that the ALJ’s step two finding on Plaintiff’s gout was a legal error.Read the full opinion on CourtListener →
Under § 416.920(c), an impairment is severe only if it significantly limits the ability to perform basic work activities; a diagnosis alone does not establish severity, and absent evidence of work-related limitations the ALJ need not classify the impairment as severe.
Mallaley v. Commisioner of Social Security · filed 2022-03-29(c)
The Court’s references to DIB regulations should be read to incorporate the corresponding and identical SSI regulations for purposes of this Order. ... A severe impairment or combination of impairments is one which significantly limits the physical or mental ability to perform basic work activities. 20 C.F.R. § 404.1520(c). ... There is, however, no evidence of record that plaintiff's diabetic neuropathy limits plaintiffs ability to do work and this diagnosis, standing alone, is insufficient to establish that the impairment is severe. ... Therefore, the ALJ committed no error in failing to categorize plaintiffs diabetic neuropathy as either a “severe” or “nonsevere” impairment.Read the full opinion on CourtListener →
Section 416.920(c) requires the Commissioner at step two to determine whether an impairment significantly limits a claimant’s physical or mental ability to perform basic work activities.
Young v. Kijakazi · filed 2022-03-31(c)
At step two of the sequential process, the ALJ must determine whether the claimant suffers from a “severe” impairment, i.e., one that significantly limits her physical or mental ability to do basic work activities. 20 C.F.R. § 416.920(c).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 that significantly limits basic work abilities.
Hutchison v. Kijakazi · filed 2022-03-31(c)
At step two of the sequential process, the ALJ must determine whether claimant suffers from a “severe” impairment, i.e., one that significantly limits his physical or mental ability to do basic work activities. 20 C.F.R. § 416.920(c). ... As such, Plaintiff has not met his burden in demonstrating a harmful error at step two.Read the full opinion on CourtListener →
Section 416.920(a)(4)(ii) requires an ALJ at step two to consider the medical severity of each impairment.
CORDERO v. KIJAKAZI · filed 2022-04-04(a)(4)(ii)
At step two, the ALJ is required to consider the medical severity of any impairment. See 20 C.F.R. § 416.920(a)(4)(ii). Here, the ALJ’s reason for rejecting Dr. Lim’s medical records and opinion that document Ms. Cordero’s intractable epilepsy are legally invalid, as the ALJ did not, and indeed could not, satisfy the requirements of SSR 82-59, concerning noncompliance.Read the full opinion on CourtListener →
At step two, a severe impairment or combination of impairments satisfies the step-two requirement and permits the disability claim to proceed to step three.
Dearman v. Commissioner of Social Security · filed 2022-04-25(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). ... If any impairment or combination of impairments qualifies as “severe,” step two is satisfied and the claim advances to step three.Read the full opinion on CourtListener →
Section 416.920(c) treats an impairment as severe when it significantly restricts the claimant’s ability to perform basic work activities; the step-two determination also requires a twelve-month duration.
Williams v. Commissioner of Social Security · filed 2022-05-02(c)
In general, at step two of the disability analysis, the ALJ determines whether the plaintiff has an impairment, or combination of impairments, that is “severe” within the meaning of the regulations, in that it imposes significant restrictions on plaintiff’s ability to perform basic work activities. 20 C.F.R. § 416.920(c)1. ... In addition, to be severe, the impairment must satisfy a durational requirement of twelve months. See id. §§ 416.909, 416.920(a)(4)(ii).Read the full opinion on CourtListener →
Section 416.920 requires disability claims to proceed through a five-step evaluation, and an error in finding an impairment non-severe at step two is harmless when the ALJ identifies another severe impairment and continues the sequential analysis.
Valles v. Commissioner, Social Security Administration · filed 2022-05-05(c)
At step two, the ALJ must determine whether plaintiff has a medically determinable impairment or combination of impairments that is “severe.” 20 C.F.R. § 416.920(c). ... Even if the ALJ erred at step two when he determined that plaintiff did not have a severe impairment of CTS or headaches, this error would have had little independent impact on the ultimate disability determination. At step four, an ALJ is to consider all of a claimant’s impairments and limitations, even those that are not severe. See 20 C.F.R. § 416.945(a)(2) (“We will consider all of your medically determinable impairments of which we are aware, including your medically determinable impairments that are not ‘severe,’ as explained in §§ 416.920(c), 416.921, and 416.923, when we assess your residual functional capacity.”). ... Therefore, whether the ALJ improperly found plaintiff’s CTS and headaches to be non-severe is appropriately addressed at step four, not at step two. See Dixon v. Astrue, No. 08-cv-01879-PAB, 2010 WL 4853393, at *4 (D. Colo. Nov. 19, 2010).Read the full opinion on CourtListener →
Section 416.920(c) requires a claimant at Step Two to show that a medically determinable impairment significantly limits physical or mental ability to perform basic work activities for the required twelve-month duration.
Pisciotta v. Kijakazi · filed 2022-05-09(c)
To meet the Step Two “severity” requirement, Plaintiff had the burden of showing his CTS was (1) a “medically determinable” impairment which (2) significantly limited his physical or mental ability to perform basic work activities without regard to age, education, or work experience for the required twelve-month duration. 20 C.F.R. §§ 416.920(c), 416.921(a); King v. Astrue, 564 F.3d 978, 979 n.2 (8th Cir. 2009).Read the full opinion on CourtListener →
Section 416.920(a)(4)(ii) requires the step-two adjudicator to consider the medical severity of the claimant’s impairment(s).
Avalon v. Social Security · filed 2022-05-27(a)(4)(ii)
“Step two of the sequential evaluation process requires the ALJ to “consider the medical severity of [the claimant’s] impairment(s).” 20 C.F.R. § 416.920(a)(4)(ii).”Read the full opinion on CourtListener →
Section 416.920(a)(4) sets out the five-step disability evaluation, including a step-two inquiry into whether the claimant has a severe impairment.
Gabriel v. Kijakazi · filed 2022-06-09(a)(4)(ii)
The Commissioner uses a five-step evaluation to determine if a claimant is disabled. 20 C.F.R. § 404.1520(a)(4); 20 C.F.R. § 416.920(a)(4). Step two of the evaluation states that a claimant is not disabled if his impairments are not “severe.” § 404.1520(a)(4)(ii); 20 C.F.R. § 416.920(a)(4)(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.” ... The Court finds that the ALJ properly considered and evaluated the record in concluding that Plaintiff’s mental impairments were not severe.Read the full opinion on CourtListener →
At step two, § 416.920(c) requires a severe impairment or combination of impairments that significantly limits basic work activities; otherwise, the claimant is not disabled.
Rice v. Commissioner of Social Security · filed 2022-06-10(c)
As noted in Step 2, above, to be found disabled, a claimant "must have a severe impairment." 20 C.F.R. § 416.920(c). If a claimant does "not have any impairment or combination of impairments which significantly limits [his] physical or mental ability to do basic work activities," then he does not have a severe impairment and is not disabled. Id. ... Based on the foregoing, the Court finds that ALJ Hoffman clearly considered Plaintiff's mental impairments, determined that they were non-severe, and took them into account when crafting Plaintiff's RFC. Furthermore, the Court finds that the substantial evidence in the record supports ALJ Hoffman's finding that Plaintiff's mental impairments were non-severe as they showed that his depression and anxiety were well-treated with Celexa and marijuana and would have no more than a minimum effect on his ability to work; Plaintiff also did not see a counselor or need in-patient psychiatric treatment.Read the full opinion on CourtListener →
At step two, § 416.920(c) requires the ALJ to determine whether the claimant has a severe impairment that significantly limits the ability to perform basic work activities; a diagnosis alone does not establish severity.
Evens v. Commissioner of Social Security · filed 2022-06-30(c)
At step two of the sequential evaluation process, the ALJ must determine whether the plaintiff has a severe impairment that significantly limits his physical or mental ability to do basic work activities. See 20 C.F.R. §§ 404.1520(c), 416.920(c).Read the full opinion on CourtListener →
Section 416.920(a)(4)(ii) requires an ALJ, at step two of the sequential evaluation, to consider the medical severity of the claimant’s impairment(s).
Shiegel v. Saul · filed 2022-07-01(a)(4)(ii)
“Step two of the sequential evaluation process requires the ALJ to “consider the medical severity of [the claimant’s] impairment(s).” 20 C.F.R. § 416.920(a)(4)(ii). ... The Court finds that significant probative evidence exists that Plaintiff had a medically determinable impairment of PTSD that the ALJ failed to address at step two of the disability analysis. ... Given that significant probative evidence exists that Plaintiff had PTSD and that the condition persisted for at least a twelve-month period, the Court finds that it was error for the ALJ to not discuss his reasons for disregarding the evidence of PTSD at step two of the disability analysis.”Read the full opinion on CourtListener →
At step two, § 416.920(c) requires the claimant to submit evidence that an impairment significantly limits physical or mental ability to do basic work activities.
Mueller v. Commissioner of Social Security Administration · filed 2022-07-13(c)
Additionally, the burden is on the claimant to submit evidence that his impairments are of a severity that would “significantly limit [his] physical and mental ability to do basic work activities.” 20 C.F.R. § 416.920(c). ... Here, the ALJ reviewed the record evidence, medical opinions, and the lay witness statement before him to determine that Plaintiff had the following severe impairments at Step Two: left leg neuropathy, status post left knee replacement, and ADHD. ... The Court does not find that Plaintiff raises any substantiated claim of error at Step Two that warrants reversal.Read the full opinion on CourtListener →
Section 416.920(c) requires the ALJ to determine whether the claimant has a severe impairment that significantly limits physical or mental ability to perform basic work activities.
Holden v. Kijakazi · filed 2022-07-26(c)
At step two, the ALJ must determine whether a claimant has one or more “severe” impairments; i.e., a condition that “significantly limits” his physical or mental ability to do “basic work activities.” 20 C.F.R. §§ 404.1520(c), 416.920(c).Read the full opinion on CourtListener →
At step two, § 416.920 requires the ALJ to assess the medical severity of impairments, treating an impairment as severe when it significantly limits basic work abilities and disregarding age, education, and work experience.
Caballero v. Kijakazi · filed 2022-08-15(a)(4)(ii)
Step two of the sequential evaluation requires an ALJ to “consider the medical severity of [the claimant’s] impairment(s).” 20 C.F.R. § 416.920(a)(4)(ii). A severe impairment “significantly limits [the claimant’s] physical or mental ability to do basic work activities.” Id. § 416.920(c). Age, education, and work experience are not considered. Id. “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.”Read the full opinion on CourtListener →
At step two, § 416.920(a)(4)(ii) requires the ALJ to determine whether the claimant has a severe medically determinable impairment, and § 416.920(c) defines non-severity by whether the impairment significantly limits basic work activities.
Colon v. Saul · filed 2022-08-26(a)(4)(ii), (c)
In step two of the evaluation process, an ALJ is required to consider whether a claimant's impairments are (1) medically determinable3 and (2) severe. 20 C.F.R. §§ 404.1520(a)(4)(ii), 404.1521; 20 C.F.R. §§ 416.920(a)(4)(ii), 416.921. An impairment is not considered severe if it does not significantly impact a claimant's physical or mental ability to do basic work activities. See 20 C.F.R. § 404.1520(c); 20 C.F.R. § 416.920(c). ... However, finding that an impairment is non-severe at step two “does not obviate the need for a separate analysis of how Plaintiff's impairment affects her RFC.” ... Indeed, under the regulations, an ALJ is required to assess all of a claimant's medically determinable impairments – including those that are not severe – in combination when making the subsequent RFC determination.Read the full opinion on CourtListener →
At step two, the Commissioner proceeds to the next step when an impairment or combination of impairments significantly limits the claimant’s ability to perform basic work activities.
Powell v. Kijakazi · filed 2022-09-13(a)(4)(ii), (c)
At step two of the sequential evaluation process, the ALJ considers the severity of the claimant’s impairment. 20 C.F.R. § 416.920(a)(4)(ii). If the claimant suffers from “any impairment or combination of impairments which significantly limits [his or her] physical or mental ability to do basic work activities,” the analysis proceeds to step three. 20 C.F.R. § 416.920(c). Basic work activities include walking, standing, sitting, lifting, pushing, pulling, reaching, carrying, or handling. Id. ... The ALJ’s finding at step-two is supported by substantial evidence. ... The Court finds that the ALJ did not err at step two.Read the full opinion on CourtListener →
Section 416.920 requires a five-step disability evaluation, including a de minimis step-two screen under which an impairment is non-severe only if it has a minimal effect on the claimant’s ability to work.
Collins v. Kijakazi · filed 2022-09-13(a)(4)(ii)
The ALJ must consider all evidence in the claimant’s case record to determine disability (see id. § 416.920(a)(3)), and must use a five-step sequential evaluation process to determine whether the claimant is disabled (id. § 416.920; see also id. at § 404.1520). ... To backtrack for a moment – the court will note that by its own terms, the evaluation at step two is a de minimis test intended to weed out the most minor of impairments. ... An impairment is non-severe at step two only if the evidence establishes a slight abnormality that has only a minimal effect on an individual’s ability to work. ... Having credited the opinions of Drs. Wolfert, Bott, and Renfro, Plaintiff’s mental impairments must be considered to be “severe” for step two’s purposes. ... As for the upshot of the ALJ’s step two error, it cannot be argued that the error was harmless because Plaintiff’s mental impairments were not considered at step three, nor were their limitations encapsulated in the RFC.Read the full opinion on CourtListener →
At step two of the five-step disability evaluation, § 416.920(c) treats an impairment as severe only if it significantly limits the claimant’s physical or mental ability to perform basic work activities.
Robinson v. Saul · filed 2022-09-21(c)
At step two in the sequential evaluation, the Social Security Administration (“SSA”) considers the medical severity of the claimant’s impairment. 20 C.F.R. § 416.920(a)(4)(ii). To be found disabled, a disability claimant must have a medically determinable physical or mental impairment or combination of impairments that is severe. Id. A 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; 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. Id. § 416.922(b) (2019). It is the claimant’s burden to establish that she has a medically severe impairment or combination of impairments.Read the full opinion on CourtListener →
Section 416.920(c) requires a claimant at step two to show that an impairment or combination of impairments significantly limits the ability to perform basic work activities.
Collier v. Social Security Administration · filed 2022-09-22(c)
At step two, Claimant bears the burden of showing the existence of an impairment or combination of impairments which “significantly limits [her] physical or mental ability to do basic work activities.” 20 C.F.R. § 416.920(c).Read the full opinion on CourtListener →
Section 416.920(c) requires the ALJ to determine at Step Two whether a medically determinable impairment is severe, meaning it significantly limits a claimant’s physical or mental ability to perform basic work activities.
(SS) Mittie v. Commissioner of Social Security · filed 2022-09-23(c)
If a claimant has a medically determinable impairment (MDI), the ALJ must determine whether the impairment is severe, which is referred to as Step Two. 20 C.F.R. § 416.920(c). An impairment is severe if it “significantly limits [a claimant’s] physical or mental ability to do basic work activities.” Id. ... In light of the above discussion and the low standard for the de minimis screening required at Step Two, the Court finds that the ALJ’s determination at Step Two that Plaintiff's depression was not severe was erroneous.Read the full opinion on CourtListener →
Section 416.920 requires the ALJ, at step two of the disability analysis, to determine whether the claimant has severe impairments.
Taggart v. Kijakazi · filed 2022-09-26
At step two of the analysis, the ALJ must determine whether Plaintiff has severe impairments. 20 C.F.R. § 416.920. The Supreme Court has held a de minimis standard applies.Read the full opinion on CourtListener →
Section 416.920(a)(4)(ii) directs the Commissioner to consider the severity of a claimant’s impairment at step two, which functions as a de minimis screen for groundless claims.
Sprague v. Saul · filed 2022-09-28(a)(4)(ii)
At step two, the Commissioner considers the severity of the claimant’s impairment. 20 C.F.R. § 416.920(a)(4)(ii). “[T]he step-two inquiry is a de minimis screening device to dispose of groundless claims.”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.
Sailor v. Saul · filed 2022-09-28(c)
An impairment deemed severe within the meaning of the regulations is one that “significantly limits ... [a claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1520(c), 416.920(c).Read the full opinion on CourtListener →
At step two, the ALJ must determine whether a claimant’s impairment is medically determinable and whether it is severe or non-severe.
Rivera v. Saul · filed 2022-09-27(a)(4)(ii)
In a similar fashion to the regulations setting out the five-step sequential evaluation process, the Social Security Regulations set out a two-step process for evaluating impairments at step two. At this step of the sequential evaluation process, the ALJ considers whether a claimant’s impairment is (1) medically determinable or non-medically determinable, and (2) severe or non-severe; this step is essentially a threshold test. 20 C.F.R. § 404.1520(a)(4)(ii); 20 C.F.R. § 416.920(a)(4)(ii).Read the full opinion on CourtListener →
At step two, an impairment is non-severe only if it is a slight abnormality with no more than a minimal effect on the claimant’s ability to work, and the ALJ must evaluate the claimant’s impairments in the sequential analysis.
Angue v. Kijakazi · filed 2022-09-29(a)(4)(ii)
The ALJ must consider all evidence in the claimant’s case record to determine disability (see id. § 416.920(a)(3)), and must use a five-step sequential evaluation process to determine whether the claimant is disabled (id. § 416.920; see also id. at § 404.1520). ... Step two’s evaluation is a de minimis test intended to weed out patently groundless claims and the most minor of impairments. ... An impairment is non-severe at step two only if the evidence establishes a slight abnormality that has only a minimal effect on an individual’s ability to work.Read the full opinion on CourtListener →
Section 416.920 requires disability determinations to use a five-step sequential evaluation, including a step-two inquiry into whether the claimant has a severe impairment that significantly limits the ability to perform basic work activities.
Kelly v. Commissioner of Social Security · filed 2022-09-30(a)(1), (a)(4)(ii)
To determine whether a claimant is disabled under the Social Security Act, the Commissioner utilizes a five-step sequential evaluation process.” 20 C.F.R. § 416.920(a)(1). At step two of this process, the ALJ must “consider[] whether the claimant has a severe impairment which significantly limits h[er] physical or mental ability to do basic work activities.” Talavera v. Astrue, 697 F.3d 145, 151 (2d Cir. 2012) (internal quotation marks omitted) (quoting DeChirico v. Callahan, 134 F.3d 1177, 1179–80 (2d Cir. 1998)); 20 C.F.R. § 416.920(a)(4)(ii).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 do basic work activities.
Kloster v. Commissioner of Social Security · filed 2022-11-15(c)
At step two, the ALJ must determine if the claimant suffers from any medically determinable impairments that are “severe.” 20 C.F.R. § 404.1520(a)(4)(ii). An impairment is not considered to be “severe” if it does not “significantly limit” a claimant’s physical or mental abilities to do basic work activities. 20 C.F.R. § 404.1520(c). Basic work activities are those “abilities and aptitudes necessary to do most jobs.” 20 C.F.R. § 404.1522(b); Social Security Ruling (“SSR”) 85-28. An impairment is not severe if the evidence establishes only a slight abnormality that has “no more than a minimal effect on an individual’s ability to work.” SSR 85-28; Smolen v. Chater, 80 F.3d 1273, 1290 (9th Cir. 1996). ... Given the objective medical evidence and Plaintiff’s reports, the ALJ could reasonably find her lumbar degenerative disc disease not so severe as to “significantly limit” her ability to do basic work activities during the relevant period. See 20 C.F.R. § 416.920(c); SSR 96-3p. As Plaintiff points to no other evidence during the relevant period to refute the ALJ’s finding, the Court finds the ALJ did not err at step two.Read the full opinion on CourtListener →
Section 416.920 establishes a five-step disability evaluation; at step two, an impairment is severe when it has more than a minimal effect on basic work activities, and the claimant’s impairments must still be considered when formulating the RFC.
(SS) Hernandez v. Commissioner of Social Security · filed 2022-11-10(a) (e)
Step two is “a de minimis screening device [used] to dispose of groundless claims.” ... An impairment or combination of impairments should be found to be “non-severe” only when the evidence establishes merely a slight abnormality that has no more than a minimal effect on an individual’s physical or mental ability to do basic work activities. ... Nevertheless, the evidence was sufficient to satisfy the low threshold for severity at step two, and the ALJ’s reasoning to the contrary is not persuasive. ... The error was harmful as the ALJ did not offer any novel discussion at step four, nor did the ALJ include any standing and walking restrictions in the RFC.Read the full opinion on CourtListener →
Section 416.920 uses a five-step sequential evaluation, and at Step Two the disability inquiry ends when the claimant has no impairment that significantly limits basic work activities for twelve consecutive months.
Leeann L. v. Kijakazi · filed 2022-12-01(c)
The disability analysis ends at Step Two if a claimant has a medically determinable impairment that has not been “severe” for a consecutive twelve-month period. 20 C.F.R. § 416.920(a)(4)(ii). ... Step Two is a screening device used to eliminate applicants “whose impairments are so minimal that, as a matter of common sense, they are clearly not disabled from gainful employment.” ... In sum, “[w]hile adjudicators are cautioned to exercise ‘[g]reat care’ in applying the Step Two standard to deny benefits, . . . in this case, the ALJ got it right.” ... Because the resulting decision is amply supported by substantial evidence, the ALJ’s determination should be affirmed.Read the full opinion on CourtListener →
At step two, § 416.920(c) treats an impairment as severe only if it significantly limits a claimant’s physical or mental ability to do basic work activities.
Reyes v. Kijakazi · filed 2022-12-15(c)
At step two of the sequential evaluation process, a claimant must prove that he has an impairment that is so severe that it “significantly limits [his] physical and mental ability to do basic work activities.” 20 C.F.R. § 416.920(c); Keyser v. Comm’r Soc. Sec. Admin., 648 F.3d 721, 725 (9th Cir. 2011); see also 20 C.F.R. § 416.922(a) (“An impairment or combination of impairments is not severe if it does not significantly limit your physical or mental ability to do basic work activities.”).Read the full opinion on CourtListener →
At step two, an impairment is severe only if it significantly limits a claimant’s mental or physical ability to perform basic work activities; a slight abnormality with no more than a minimal effect on the ability to work is not severe.
Snelling v. Commissioner of Social Security · filed 2022-12-21(c)
At step two of the sequential evaluation process, the ALJ must determine if the claimant suffers from any medically determinable impairments that are “severe.” 20 C.F.R. § 404.1520(a)(4)(ii). An impairment is not considered to be “severe” if it does not “significantly limit” a claimant’s mental or physical abilities to do basic work activities. 20 C.F.R. § 416.920(c); Social Security Ruling (“SSR”) 96-3p. Basic work activities are those “abilities and aptitudes necessary to do most jobs.” 20 C.F.R. § 404.1522(b); SSR 85-28. An impairment is not severe if the evidence establishes only a slight abnormality that has “no more than a minimal effect on an individual[’]s ability to work.” SSR 85-28; Smolen v. Chater, 80 F.3d 1273, 1290 (9th Cir. 1996). ... In this case, the ALJ found that Plaintiff’s migraine headaches do not “create any significant limitation in her ability to perform basic work activities.” AR 2054. During the hearing, Plaintiff testified that Plaintiff experiences “unmanageable” migraines” that prevent her from getting out of bed once or twice a month. AR 2089-90. Plaintiff’s record shows she reported about her worsening migraines, but they do not indicate that they were so severe as to “significantly limit” her abilities to do basic work activities. 20 C.F.R. § 416.920(c); SSR 96-3p; AR 2510-12, 2519-21. Without further showing how her migraines could have more than minimally affected her ability to work, Plaintiff has not met her burden in showing the ALJ erred at step two. Accordingly, the Court rejects Plaintiff’s argument.Read the full opinion on CourtListener →
At step two, an impairment is not severe if it does not significantly limit the claimant’s physical or mental ability to perform basic work activities.
Smith v. Social Security Administration · filed 2023-01-19(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) requires the ALJ at Step Two to determine whether a medically determinable impairment is severe, meaning it significantly limits the claimant’s ability to perform basic work activities.
(SS) Carlon v. Commissioner of Social Security · filed 2023-02-17(c)
If a claimant has a medically determinable impairment (MDI), the ALJ must determine whether the impairment is severe, which is referred to as Step Two. 20 C.F.R. § 416.920(c). An impairment is severe if it “significantly limits [a claimant's] physical or mental ability to do basic work activities.” Id. “Basic work activities” is defined as “the abilities and aptitudes necessary to do most jobs,” such as walking, standing, sitting, remembering simple instructions, and responding appropriately to supervision. 20 C.F.R. 416.922(b). ... Regarding the ALJ’s Step Two finding that the Plaintiff’s left upper extremity impairments were non-severe during the period at issue, the Court finds that the ALJ’s determination supported by substantial evidence. Here, the ALJ’s decision reviewed medical evidence prior to the date last insured, including records indicating that Plaintiff experienced numbness in his hand that was “not pressing or present” during a 2012 medical visit. (See A.R. 520 (citing 1160)). Further, the ALJ reviewed Plaintiff’s examination findings from 2013, which noted that “physical examination of the upper extremities was basically unremarkable” with “full range of motion of major joints, no major joint instability, no swelling and no effusions.” (See e.g., A.R. 520 (citing 328, 331)). Thus, the Court concludes that the ALJ’s Step Two finding was supported by substantial evidence.Read the full opinion on CourtListener →
Section 416.920(c) requires a claimant at step two to show that a medically determinable impairment significantly limits the ability to perform basic work activities.
Nesbitt v. Commissioner of Social Security · filed 2023-02-22(c)
At step two, a claimant must make a threshold showing that her medically determinable impairments significantly limit her ability to perform basic work activities. See Bowen v. Yuckert, 482 U.S. 137, 145 (1987); 20 C.F.R. § 416.920(c).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 severe impairment or combination of impairments.
Riccio v. Commissioner of Social Security · filed 2023-03-01(a)(4)(ii)
At step two, the ALJ determines whether the claimant “has a medically severe impairment or combination of impairments.” Smolen v. Chater, 80 F.3d 1273, 1290 (9th Cir. 1996); 20 C.F.R. § 416.920(a)(4)(ii). ... Accordingly, the Court finds the ALJ did not err at step two.Read the full opinion on CourtListener →
Section 416.920(a)(4)(ii) directs the adjudicator to assess impairment severity at step two, and § 416.920(c) treats an impairment as severe when it significantly limits basic work abilities.
Keller v. Kijakazi · filed 2023-03-06(c), (a)(4)(ii)
At step two of the five-step sequential analysis, the ALJ must assess the medical severity of a claimant’s impairments. 20 C.F.R. § 416.920(a)(4)(ii); Webb v. Barnhart, 433 F.3d 683, 686 (9th Cir. 2005). ... An impairment or combination of impairments is considered “severe” if it “significantly limits [a claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. § 416.920(c).Read the full opinion on CourtListener →
Section 416.920 treats severity as step two of the sequential disability evaluation; finding any severe impairment satisfies that step and allows the claim to proceed to step three.
Bard v. Social Security · filed 2023-03-13(a)(4)(ii), (c)
At step two, an ALJ considers the severity of a claimant’s impairments. 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii). ... 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.” ... If any impairment or combination of impairments qualifies as “severe,” step two is satisfied and the claim advances to step three. ... With step two satisfied, the issue then becomes whether the ALJ considered all of Plaintiff’s impairments, including her bilateral knee pathologies and carpal tunnel syndrome/peripheral neuropathy in assessing the RFC.Read the full opinion on CourtListener →
At step two, the ALJ must determine from medical evidence whether an impairment is severe, and the court may remand when the ALJ fails to properly evaluate that issue.
Shultz v. Commissioner Social Security Administration · filed 2023-03-20(a)
At step two, the ALJ determines whether the claimant has any medically determinable impairments that are “severe.” ... Step two findings must be based upon medical evidence. 20 C.F.R. §§ 404.1520(a), 416.920(a). ... In sum, there is error in the ALJ’s evaluation of plaintiff’s IBS at step two, and the error is not harmless because the ALJ did not consider the effects of plaintiff’s IBS in the RFC. On remand, the ALJ shall reevaluate whether plaintiff’s IBS is severe at step two.Read the full opinion on CourtListener →
Section 416.920(a)(4)(ii) requires the ALJ at Step Two to determine the medical severity of the claimant's impairments.
CONNE v. KIJAKAZI · filed 2023-03-29(a)(4)(ii)
At Step Two, the ALJ must determine the medical severity of a claimant's impairments. 20 C.F.R. § 416.920(a)(4)(ii).Read the full opinion on CourtListener →
Section 416.920(a)'s step-two severity assessment appears to use the same evaluation as the corresponding child-SSI assessment under § 416.924(a).
Thompson v. Kilolo · filed 2023-05-01(a)
The Court acknowledges that the three-part test for determining Childhood SSI pursuant to 20 C.F.R. § 416.924(a) is not the same as the five-step evaluation in 20 C.F.R. § 416.920(a) that applies to adult applications. However, the step two severity assessment appears to involve the same evaluation under both regulations.Read the full opinion on CourtListener →
At step two, § 416.920 requires the ALJ to determine whether the claimant has a severe impairment, and any severe impairment is enough to move the claim to step three.
Larson v. Commissioner of Social Security · filed 2023-05-02(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). An impairment or combination of impairments is not severe “if it does not significantly limit [a claimant’s] physical or mental ability to do basic work activities” 20 C.F.R. §§ 404.1522(a), 416.922(a). ... 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.” ... If any impairment or combination of impairments qualifies as “severe,” step two is satisfied and the claim advances to step three.Read the full opinion on CourtListener →
Section 416.920(c) requires proceeding to the next step when an impairment or combination significantly limits basic work activities and requires a finding of no disability when it does not meet that severity threshold.
(SS)Kaur v. Commissioner of Social Security · filed 2023-06-27(c)
If the claimant is not engaged in substantial gainful activity, the analysis proceeds to step two. At this step, the Commissioner considers the severity of the claimant’s impairment. 20 C.F.R. § 416.920(a)(4)(ii). If the claimant suffers from “any impairment or combination of impairments which significantly limits [his or her] physical or mental ability to do basic work activities,” the analysis proceeds to step three. 20 C.F.R. § 416.920(c). If the claimant’s impairment does not satisfy this severity threshold, however, the Commissioner must find that the claimant is not disabled. Id.Read the full opinion on CourtListener →
Section 416.920(a) requires the ALJ to evaluate the medical severity of a claimant’s impairments at step two of the sequential disability analysis.
Steiner v. Commissioner of Social Security · filed 2023-07-05(a)
At step two of the disability analysis, the ALJ considers the medical severity of the claimant’s impairments. 20 C.F.R. § 416.920(a). 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.” Id. at § 416.920(c). “Basic work activities” are “the abilities and aptitudes necessary to do most jobs.” Id. at § 416.920(c). It is the claimant’s burden to present evidence that establishes the severity of his impairment. Id. at § 416.920.Read the full opinion on CourtListener →
Section 416.920 requires a claimant to show at step two that an impairment or combination significantly limits basic work activities; any severe impairment advances the claim beyond step two, where the ALJ must consider the claimant’s limitations in full.
Quinn v. Commissioner of Social Security · filed 2023-07-24(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). An impairment or combination of impairments is not severe “if it does not significantly limit [a claimant’s] physical or mental ability to do basic work activities” 20 C.F.R. §§ 404.1522(a), 416.922(a). In other words, a severe impairment is an impairment or combination thereof that significantly limits a claimant’s abilities to perform basic work activities. See SSR 85-28, 1985 WL 56856, *4 n.1; 20 C.F.R. §§ 404.1520(c), 404.1522(a), 416.920(c), 416.922(a).Read the full opinion on CourtListener →
At step two, the regulation requires an ALJ to assess the severity of the claimant’s impairments; if no severe impairment or combination meeting the duration requirement is found, the claimant is found not disabled and the evaluation does not proceed to later steps.
Porter v. Social Security Administration, Commissioner · filed 2023-07-27(a)(4)(ii)
At step two, an ALJ must consider the severity of a claimant’s impairments. 20 C.F.R. § 416.920(a)(4)(ii). “An impairment or combination of impairments is not severe if it does not significantly limit” a claimant’s “physical or mental ability to do basic work activities.” 20 C.F.R. § 416.922(a). At step two, if an ALJ finds that a claimant does not have a severe impairment or combination of impairments that meets the duration requirement, the ALJ must find that the claimant is not disabled and not proceed to the next steps. 20 C.F.R. § 416.920(a)(4)(ii).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, and the ALJ must consider all evidence bearing on that limitation at step two.
(SS) Pipkin v. Commissioner of Social Security · filed 2023-07-31(c)
At step two of the sequential evaluation, the ALJ determines which of claimant’s alleged impairments are “severe” within the meaning of 20 C.F.R. § 416.920(c). A severe impairment is one that “significantly limits” a claimant’s “physical or mental ability to do basic work activities.” Id. An ALJ must consider all the evidence at step two to determine whether a medically determinable impairment significantly limits the claimant’s ability to perform basic work activities. Id. § 416.920(a); ... Step two was resolved in Plaintiff’s favor when the ALJ determined that her severe impairments included fibromyalgia, osteoarthritis, spine disorder, neuropathy, depression, obesity, and DVT and the ALJ proceeded to the step three analysis. (AR 20–22.) It follows that, since Plaintiff’s claims were not screened out at this step, she was not prejudiced by any error in the step two analysis.Read the full opinion on CourtListener →
At step two, an impairment is severe when it significantly limits basic work activities; it is not severe only when it is a slight abnormality with no more than a minimal effect on the ability to work.
Parker v. Kijakazi · filed 2023-07-31(a)(4)(ii)
As was noted above, at step two of the five-step sequential analysis, an ALJ considers whether a claimant’s impairments are “severe.” 20 C.F.R. §§ 404.1520(a)(4)(ii) & 416.920(a)(4)(ii). An ALJ may deem an impairment “not severe” only if it involves a “‘slight abnormality’” that has “‘no more than a minimal effect’” on the individual’s ability to work. ... Conversely, an impairment is severe where it significantly limits the claimant’s physical or mental ability to do “basic work activities,” including, for example, physical functions such as “walking, standing, sitting, lifting, pushing, pulling, reaching, carrying or handling[.]” ... The United States Court of Appeals for the Third Circuit has described the severity determination at step two as “not an exacting one” for a claimant to meet, and as a “de minimis” inquiry.Read the full opinion on CourtListener →
Section 416.920(c) requires the ALJ to determine whether an impairment is severe, meaning it significantly limits the claimant's physical or mental ability to do basic work activities.
Padilla v. Social Security Administration · filed 2023-08-09(c)
At step two of the Commissioner’s five-step analysis, this requires the ALJ “to determine whether the mental impairment is ‘severe’ or ‘not severe.’” Id. To be “severe,” an impairment or combination of impairments must “significantly limit[] [a claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1520(c), 416.920(c).Read the full opinion on CourtListener →
At step two, § 416.920 requires the Commissioner to determine whether a claimant has a severe impairment, meaning one that significantly limits the ability to perform basic work activities.
Wilson v. Kijakazi · filed 2023-08-03(a)(4)(ii), (c)
At step two of the evaluation process, an ALJ must determine if a claimant suffers from a severe impairment. ... To demonstrate an impairment is severe, a claimant must show he has (1) a medically determinable impairment or combination of impairments, which (2) “significantly limits [his] physical or mental ability to do basic work activities,” without regard to age, education, or work experience. ... An impairment “is not severe if it does not significantly limit [the claimant’s] physical or mental ability to do basic work activities.”Read the full opinion on CourtListener →
Notes 751–900 of 2,028, oldest cases first.
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