2003 Supreme Court term

JO ANNE B. BARNHART COMMISSIONER OF SOCIAL SECURITY v. PAULINE THOMAS.

Dockets 02-763Argued
AI-generated independent summary

This educational guide is based on the linked primary sources. It is not a Court publication, is not affiliated with the Court, and is not legal advice.

In brief

Overview

The case concerns how the Social Security Administration determines disability eligibility, focusing on the criteria at step four (previous work) and step five (age factor).

According to Petitioner, the Commissioner’s longstanding construction requires that a claimant be unable to perform previous work and also be unable to engage in any other substantial gainful work given age, education, and experience.

According to Petitioner (Jeffrey A. Lamken), according to Petitioner (Jeffrey A. Lamken), according to Petitioner (Jeffrey A. Lamken), according to Petitioner (Jeffrey A. Lamken), petitioner argues that step four is a measure of severity and that the Commissioner’s construction has been consistently applied for decades, affecting millions of claims.

Respondent contends that at step four, age, education, and prior work experience are not considered.

The case raises questions about whether the regulations are ambiguous and whether the Commissioner’s interpretation is reasonable.

Background and question before the Court

According to Justice O'Connor, justice O'Connor questioned how circuits and judges view the regulation’s ambiguity and reasonableness.

What each side argues

Petitioner (Commissioner of Social Security)

According to Petitioner, the Commissioner’s construction requires two conditions: inability to perform previous work and inability to perform any other substantial gainful work given age, education, and experience.

According to Petitioner (Jeffrey A. Lamken), according to Petitioner (Jeffrey A. Lamken), according to Petitioner (Jeffrey A. Lamken), according to Petitioner (Jeffrey A. Lamken), step four (previous work) is a measure of severity; the claimant must be unable to do previous work.

Respondent (Pauline Thomas)

According to Respondent, at step four, age, education, and prior work experience are not factors in the disability determination.

What happened at oral argument

According to Petitioner (Jeffrey A. Lamken), according to Petitioner (Jeffrey A. Lamken), according to Petitioner (Jeffrey A. Lamken), according to Petitioner (Jeffrey A. Lamken), the oral argument featured extensive discussion of step four as a severity measure and the long‑standing application of the Commissioner’s construction.

The parties debated whether the regulations are ambiguous and whether the Commissioner’s interpretation is reasonable.

What the Court decided

Pending This section will be added when the relevant Court material is available.

Why it matters

The interpretation of the disability eligibility rules affects millions of claimants and has been applied to approximately 200,000 step‑four denials each year.

Terms to know

No glossary terms are available for this guide.

Primary sources

Read the source materials on the official site or open the immutable repository copy used for this guide.

  • 6f7b5188f4a96cf6988f-r1-6f5980bc6560075a.pdforal argument transcript

Guide generated September 20, 2026. Automated validation accepted this version.