Bowen v. Yuckert
Annotate this Case
482 U.S. 137 (1987)
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U.S. Supreme Court
Bowen v. Yuckert, 482 U.S. 137 (1987)
Bowen v. Yuckert
Argued January 13, 1987
Decided June 8, 1987
482 U.S. 137
The Social Security Act (Act) defines "disability" as the "inability to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment. . . ." 42 U.S.C. § 423(d)(1)(A). The Act also provides that an individual
"shall be determined to be under a disability only if his . . . impairment [is] of such severity that he is not only unable to do his previous work but cannot, considering his age, education, and work experience, engage in any other . . . substantial gainful work. . . ."
§ 423(d)(2)(A). The Secretary of Health and Human Services (Secretary) has established a five-step sequential evaluation process for determining whether a person is disabled. In step two of that process, the "severity regulation" provides:
"If you do not have any impairment . . . which significantly limits your . . . ability to do basic work activities, we will find that you do not have a severe impairment and are, therefore, not disabled. We will not consider your age, education, and work experience."
Respondent applied for disability benefits, but the appropriate state agency determined that she was not disabled. In light of the medical evidence and evidence of her activities, the Social Security Administration (SSA) Administrative Law Judge concluded that her medically determinable impairments were not severe under the severity regulation, and the SSA's Appeals Council denied her request for review. The Federal District Court affirmed, but the Court of Appeals reversed and remanded, holding that the Act does not authorize benefits denials based solely on a determination that the claimant is not severely impaired, and that § 423(d)(2)(A) requires that both medical and vocational factors such as age, education, and work experience be considered in determining disability. The court rejected the Secretary's contention that the 1984 amendments to the Act endorsed step two of the disability evaluation process, and invalidated the severity regulation.
1. The severity regulation is valid on its face under the language of the Act and the legislative history. 482 U. S. 142-152.
(a) The severity regulation is not inconsistent with § 423(d)(1)(A), which defines "disability" in terms of the effect an impairment has on a
person's ability to function in the workplace. The regulation adopts precisely this functional approach to determining the effects of medical impairments, when it requires the claimant to show that he has an "impairment . . . which significantly limits" "the abilities and aptitudes necessary to do most jobs." If the impairment is not severe enough to so limit the claimant, by definition it does not prevent the claimant from engaging in any substantial gainful activity. Moreover, § 423(d)(5)(A) expressly gives the Secretary the authority to place the burden of showing a medically determinable impairment on the claimant. The requirement of a threshold showing of severity also is consistent with the legislative history of § 423(d)(1)(A). Pp. 482 U. S. 146-147.
(b) The severity regulation is not inconsistent with § 423(d)(2)(A), which restricts disability benefit eligibility to claimants whose medically severe impairments prevent them from doing their previous work and any other substantial gainful work in the national economy. If a claimant is unable to show that he has a medically severe impairment, he is not eligible for benefits, and there is no reason for the Secretary to consider his age, education, and work experience. The legislative history reinforces this understanding of the statutory language. 482 U. S. 147-149.
(c) In enacting § 4(a)(1) of the Social Security Disability Benefits Reform Act of 1984, 42 U.S.C. § 423(d)(2)(C), Congress expressed its approval of the severity regulation both in the statute and in the accompanying Reports, recognizing that the Secretary may make an initial determination of medical severity, and that he need not consider the claimant's age, education, and experience unless he finds "a medically severe combination of impairments." 482 U. S. 149-162.
2. The severity regulation increases the efficiency and reliability of the disability evaluation process by identifying at an early stage those claimants whose medical impairments are so slight that it is unlikely they would be found to be disabled even if their age, education, and experience were taken into account. 482 U. S. 153-154.
774 F.2d 1365, reversed and remanded.
POWELL, J., delivered the opinion of the Court, in which REHNQUIST, C.J., and WHITE, STEVENS, O'CONNOR, and SCALIA, JJ., joined. O'CONNOR, J., filed a concurring opinion, in which STEVENS, J., joined, post, p. 482 U. S. 155. BLACKMUN, J., filed a dissenting opinion, in which BRENNAN and MARSHALL, JJ., joined, post, p. 482 U. S. 159.