Bowen v. Yuckert

1987-06-08

Headline: Upheld federal rule letting the agency deny Social Security disability claims early when impairments are not medically “severe,” making early rejections easier while claimants can still seek review on appeal.

Holding: The Secretary may use the regulatory "step two" medical-severity screen to deny benefits when impairments are not medically severe; the Court reversed the Ninth Circuit and remanded for record review.

Real World Impact:

Allows the agency to deny claims early for nonsevere medical impairments.
Affects processing of millions of Social Security disability claims nationwide.
Remands mean individual claim decisions still require record review.

Topics: Social Security disability, disability benefits, agency rules, benefits eligibility

Summary

Background

A woman named Janet Yuckert applied in 1980 for Social Security disability and SSI, saying she had inner-ear problems, dizziness, headaches, and vision trouble. State reviewers and an administrative law judge found her impairments not medically severe and denied benefits. The Ninth Circuit invalidated the agency’s “step two” rule that allows early denial for nonsevere impairments. The Supreme Court agreed to decide the question and heard the case.

Reasoning

The main question was whether the Secretary may deny benefits at step two by finding an impairment not medically severe. The Court said yes: the Social Security Act and its history allow the agency to require a threshold medical showing that an impairment significantly limits basic work abilities. The Court held the regulation is facially valid and reversed the Ninth Circuit. The case was sent back so the lower court can decide whether the agency’s denial of Yuckert’s claim is supported by substantial evidence.

Real world impact

The ruling confirms that the agency may use an early screening step to reject claims that fail a medical-severity threshold, which speeds decisions in a program that handles millions of claims each year. At the same time, a concurring opinion warned that the rule has been applied in ways that may have improperly denied eligible claimants and noted the agency’s own guidance (Social Security Ruling 85-28) to clarify step two. Because the Court remanded, this decision resolves the rule’s facial validity but not whether Yuckert herself should receive benefits.

Dissents or concurrances

Justice O'Connor (joined by Justice Stevens) concurred in the judgment but warned the rule has sometimes been misapplied and stressed that claimants who may meet the statute must get vocational analysis; Justice Blackmun dissented, arguing the regulation contradicts the statute.