Stephens v. U.S. Railroad Retirement Board

The Railroad Retirement Board erred when it denied the petitioner disability benefits based on his history of employment, because short-lived, unsuccessful attempts at employment after the age of 22 only create a presumption that the child of a railroad worker under the Railroad Retirement Act is not eligible for disability benefits.

Samuel Stephens petitioned for review of the Railroad Retirement Board’s decision denying him benefits under the Railroad Retirement Act, which gives an annuity to disabled children of railroad workers. In order to be eligible for benefits, children must be deemed disabled before the age of 22. The Board ruled that Stephens did not qualify for benefits, because in the last 30 years prior to his application, he had held three “menial” jobs. Despite the fact that he was fired from each of those jobs, the Board determined that they constituted “gainful employment," which rendered him ineligible for benefits. The Board did not take into account other evidence, such as medical records of disability from an early age, in making its decision to deny Stephens benefits. The Ninth Circuit found that the Board committed error, because the regulations are not meant to be applied so rigidly. The Court held that, under circuit case law, a minimum earning threshold creates only a presumption that an individual is disabled and the Board must look not only to the amount that was earned, but also at the context to determine disability. The Court held that so long as Stephens met the other requirements, he would be entitled to benefits under the Act, because the evidence, taken as a whole, showed that Stephens has been unable to hold “substantial gainful employment" since age 22. REVERSED and REMANDED.