In a 5-4 decision delivered by Justice Sonia Sotomayor on Wednesday, the US Supreme Court held that a refusal by the US Railroad Retirement Board to reopen a prior benefits determination is subject to judicial review.
In 1992, the petitioner, Manfredo Salinas, began seeking disability benefits under the Railroad Retirement Act of 1974 (RRA) for serious injuries he sustained during his 15-year career with the Union Pacific Railroad. As a former carpenter and assistant foreman, Salinas suffered two serious injuries on the job. In 1989, “a co-worker dropped a sledge hammer from an overhead bridge, hitting Salinas on the top of his hardhat.” A few years later, in 1993, “a wooden railroad tie fell from a truck and struck Salinas in the head.” Salinas’ injuries required two spinal fusion surgeries and after receiving treatment, Salinas became depressed and anxious and continued to suffer great pain. Salinas’ first two applications were denied, and he did not seek reconsideration of either. Salinas filed a third application for benefits in February 2006.
The Board denied the application in August 2006, “concluding that his impairments were not severe enough to qualify for relief.” Salinas’ fourth application was finally granted after he applied again in December of 2013. However, Salinas challenged the “amount and start date of his benefits.” The Reconsideration Section denied relief. On appeal, Salians also argued that his 2006 application should be reopened. The Bureau denied Salinas’ request to reopen the 2006 decision. Salinas appealed that decision to the Board which affirmed the Bureau’s decision. Salinas then sought judicial review with the US Court of Appeals for the Fifth Circuit. The Fifth Circuit dismissed the petition for lack of jurisdiction.
The Supreme Court ultimately reversed and remanded to the Fifth Circuit. Sotomayor first explained that the RRA “makes judicial review under the RRA available to the same extent that review is available under the [Railroad Unemployment Insurance Act] RUIA.” While the RUIA allows any person “aggrieved by a final decision under subsection (c) of this section” to “obtain a review of any final decision of the Board.”
The court determined that because the Board’s refusal to reopen Salinas’ 2006 application was (1) a “‘terminal event’ in the Board’s administrative review process” (2) “‘by which rights or obligations have been determined, or from which legal consequences will flow'” it was a “final decision” within the meaning of the statute. Therefore, subject to judicial review on an abuse of discretion standard.
