In Bowen, Secretary of Health and Human Services v. Yuckert (1986), the U.S. Supreme Court upheld a five-step sequential evaluation process used by the Social Security Administration to determine disability benefits eligibility under the Social Security Act. The plaintiff, Hazel Yuckert, argued that this process was invalid because it required claimants to prove they could not perform their previous work before considering other factors such as age or education level in determining whether they were capable of performing any other jobs available in significant numbers in the national economy. However, the court ruled 9-0 against her argument stating that Congress intended for these considerations only after an initial finding of medical disability had been made based on objective evidence from treating physicians' reports and laboratory findings rather than subjective symptoms alone.

In the dissenting opinion for Bowen, Secretary of Health and Human Services v. Yuckert, Justice Thurgood Marshall argued that the majority's decision to uphold a sequential evaluation process for determining disability benefits eligibility was flawed. He contended that this approach could unjustly deny benefits to individuals who are genuinely unable to work due to their disabilities but do not meet specific listed impairments in the regulations. The justice also criticized the majority's interpretation of "severity regulation," arguing it allowed denial of claims based on trivial impairments without considering an individual’s vocational factors such as age, education and work experience which is contrary to Social Security Act provisions. Furthermore, he expressed concern about how this ruling might affect future cases by setting a precedent where administrative convenience takes precedence over fairness and accuracy in adjudicating social security disability claims.