Bowen v. Yuckert
United States Supreme Court
482 U.S. 137 (1987)
Janet Yuckert (plaintiff) applied for Social Security disability benefits, citing dizziness, vision problems, and headaches. Under the Secretary's five-step sequential review regulations, step two required a claimant to show a severe impairment limiting basic work activities before the SSA would proceed to consider vocational factors like age, education, and work experience. An administrative law judge found Yuckert's impairments were not severe and denied benefits at step two; the SSA denied further review, and the district court affirmed on substantial-evidence grounds. On appeal, the Ninth Circuit reversed, holding the Social Security Act required considering vocational factors in every case regardless of severity findings. The Supreme Court granted certiorari.
Whether a federal agency may terminate review of a claimant's eligibility for disability benefits at an early step if the claimant fails to meet a baseline severity requirement, without proceeding to consider vocational factors.