When the five-step disability evaluation process reaches step 4, Social Security considers whether a claimant can do his past work. When a claimant can do his past work, he is found not disabled. When a claimant cannot do his past work, the analysis moves on to consider whether the claimant can do any other work.
Work which exists in the national economy is defined by the statute to mean work which exists in significant numbers either in the region where the individual lives or in several regions of the country.
In this case, the Supreme Court agreed with Social Security that the phrase, “which exists in the national economy,” applied only to the second part of the paragraph, namely to “any other kind of substantial gainful work.” “Any other work” is step 5 of the Social Security disability analysis.
“[A]ccording to which a limiting clause or phrase (here, the relative clause ‘which exists in the national economy’) should ordinarily be read as modifying only the noun or phrase that it immediately follows (here, ‘any other kind of substantial gainful work’).”