Salinas v. United States Railroad Retirement Board

Judicial review is available, under the Railroad Retirement Act of 1974 (RRA), to the same degree available under the judicial review provision of the Railroad Unemployment Insurance Act (RUIA). Therefore, the qualification for judicial review under the RRA is contingent on the meaning of the phrase “any final decision” as used in §355(f) of the RUIA.

The RRA establishes benefits of disability, retirement, and survivorship for railroad employees, administered through the U.S. Railroad Retirement Board (Board). Petitioner, a former railroad employee, was denied benefits in 2006, but the Board later granted him benefits upon reapplication in 2013. The Board denied petitioner’s request to reopen its 2006 denial. The Fifth Circuit dismissed his petition because it lacked jurisdiction. The Supreme Court held that a refusal to reopen a prior determination of benefits is a final decision by the Board and subject to judicial review. The Court relied on its previous interpretation of similar language found in the Administrative Procedure Act—specifically, that the phrase “any final decision” refers to agency action that “both (1) mark[s] the consummation of the agency’s decision-making process and (2) is one by which rights or obligations have been determined, or from which legal consequences will flow.” Smith v. Berryhill, 587 U.S. ___, ___ (2019) (slip op., at 6). The Court found that the Board’s refusal to reopen petitioner’s denial of benefits satisfied both criteria. Moreover, the Court reasoned that any ambiguity must be resolved in petitioner’s favor under the “strong presumption favoring judicial review of administrative action.” Mach Mining, LLC v. EEOC, 575 U.S. 480, 486 (2015). The Board failed to rebut that presumption by showing the statutory language or structure prevents judicial review. REVERSED and REMANDED.