SCOTUS Opinion: Judicial Review Available For Claims Under Railroad Retirement Act

 

In Salinas v. United States Railroad Retirement Board, a Union Pacific Railroad employee applied for disability benefits under the Railroad Retirement Act of 1974. His first three applications were denied, but he was awarded benefits on the fourth. He then moved to reopen his third application, but the Board denied the request. The employee sought judicial review, but the Fifth Circuit held that it had no jurisdiction to hear it, noting the split among the circuits on the issue.

The Court, in a 5-4 opinion by Justice Sotomayor, reversed. First, the majority noted that the Act permits judicial review to the same extent as the Railroad Unemployment Insurance Act, which itself permits judicial review of any “final decision of the Board.” The majority then determined that the Board’s refusal to reopen a prior application was such a “final decision” because it ended the review process and determined the employee’s disability rights. Justice Thomas, joined by Justices Alito, Gorsuch, and Barrett, dissented, arguing that the RRA’s judicial review language did not encompass purely discretionary matters like whether to reopen a prior application.

A link to the opinion is here: https://www.supremecourt.gov/opinions/20pdf/19-199_o7jq.pdf