Bowen v. Yuckert

Janet Yuckert (plaintiff) applied for disability benefits from the Social Security Administration (SSA), alleging disability due to dizziness, vision problems, and headaches. The Social Security Act (Act), 42 U.S.C. § 301 et seq., provided that a claimant was entitled to disability benefits if she had medical impairments so severe that she was unable to perform her past work or, considering her age, education, and work experience, she was unable to perform any other available work. Regulations promulgated by Secretary of Health and Human Services Bowen (Secretary) (defendant) provided for a five-step review process. At the second step, under the severity regulation, a claimant was required to show that a severe impairment rendered her unable to perform basic work activities. Otherwise, the evaluation process would terminate at step two, and the SSA would not consider the remaining steps in the sequential review process. Yuckert’s application was denied initially and on reconsideration. Following a hearing, an SSA administrative law judge (ALJ) concluded that Yuckert was ineligible for benefits because her impairments were not severe. After the SSA denied Yuckert’s request for further review, Yuckert sought review of the denial in federal district court. The district court affirmed, ruling that the SSA’s determination was supported by substantial evidence. Yuckert appealed. The United States Court of Appeals for the Ninth Circuit reversed, reasoning that the Act required the SSA to consider both a claimant’s medical issues and the relevant vocational factors of age, education, and work experience before making a disability determination. The United States Supreme Court granted review on this issue.