Justices Find Courts Can Hear Disputes Over Railroad Disability Benefits

The nation’s highest court ruled 5-4 that federal courts can review an administrative board’s refusal to reopen a case in which it denied disability benefits to a railroad worker.  

Railroad trestles, a stream and wildfire smoke in Idaho. (Courthouse News photo/Chris Marshall)

WASHINGTON (CN) — The refusal to reopen a benefits determination by a board that oversees decisions on railroad workers’ pensions can be challenged in federal court, a divided Supreme Court ruled Wednesday.

“We hold that the board’s refusal to reopen a prior bene­fits determination is a ‘final decision’ within the meaning of [the Railroad Unemployment Insurance Act] and therefore subject to judicial review,” Justice Sonia Sotomayor wrote for the majority in a 13-page opinion.  

The case was originally filed by former railroad worker Manfredo Salinas, who suffered debilitating spine injuries during his 15-year career as a carpenter and assistant foreman with the Union Pacific Railroad. 

While on the job in 1989, a co-worker dropped a sledgehammer from a bridge, hitting Salinas on the top of his hardhat. Four years later, a wooden railroad tie fell from a truck and struck Salinas in the head. 

The workplace injuries forced Salinas to undergo two spinal fusion surgeries. He began requesting disability benefits from the U.S. Railroad Retirement Board in 1992, but the board denied his claims three separate times before finally granting his fourth request in 2013.

At that point, Salinas asked the board to review the claim he had previously filed in 2006, alleging that it failed to consider certain medical records. An intermediary for the board said Salinas was too late and denied his request to reopen because he did not make the request within four years of the benefits determination. 

He appealed the denial to the Fifth Circuit, which dismissed his claims for lack of jurisdiction, holding that “federal courts cannot review the board’s refusal to reopen a prior benefits determination.” 

Salinas appealed to the Supreme Court, which reversed the Fifth Circuit in a 5-4 ruling Wednesday.  

“Judicial review plays a modest, but important, role in guarding against decisions that are arbitrary, inconsistent with the standards set by the board’s own regulations, or otherwise contrary to law,” Sotomayor wrote.

Salinas brought his claims under the Railroad Retirement Act, which allows approved claimants to receive disability benefits. According to the ruling, judicial review is available under the RRA to “the same extent” that it is available under the Railroad Unemployment Insurance Act.

To qualify for judicial review under a provision of the RUIA, the board’s refusal to reopen Salinas’ 2006 application must constitute “any final decision of the board,” Sotomayor wrote. 

“It does,” the Barack Obama appointee found, noting that turning to the federal court system was Salinas’ only recourse after exhausting his administrative options.

The board argued that the opportunity to seek reopening is “a matter of administrative grace, and such solicitous discretion should not be discouraged by allowing judicial review,” according to the opinion.

But Sotomayor said the fact that the board can decline to reopen does not mean that it can dodge the “final decision” provision of the RUIA. 

“Whether the availability of judicial review will affect how the board exercises its discretion is a question properly reserved for Congress,” she wrote.

But Justice Clarence Thomas, a George H.W. Bush appointee, took issue with the majority’s application of the RUIA provision. He wrote in a dissenting opinion Wednesday that the case concerns judicial review provisions under the RRA, not under the other law cited by Sotomayor.

“And though the RRA references the RUIA to explain how to obtain judicial review, it defines separately what may be reviewed—the key issue here,” Thomas wrote. 

He said the majority bypassed the appropriate structure of review by “overlooking the question whether the board’s decision here determined any right or liability at all.”

“It did not,” he wrote, arguing language established by Congress leaves it up to the board to decide whether to reopen a case because it did not assess any legal claims or obligations.

The dissenting opinion – joined by conservative Justices Samuel Alito, Amy Coney Barrett and Neil Gorsuch – also states that Salinas had the option to file a petition for review in a court of appeals within 90 days of the 2006 determination. 

Thomas wrote that Salinas “simply did not take advantage of it.” 

“To require a court to review a reopening denial now— 15 years after the statutory time for review expired—transforms a default presumption into a tool to ‘frustrate the statutory purpose of imposing a [time] limit on judicial review,’” Thomas wrote.   

He also said the majority opinion is “doubly incorrect” because it created “a new form of judicial review in a context where it is not clear how it can be exercised.”

“Were courts to try to impose standards governing when the board can deny reopening, the unintended effect may be to discourage the board from offering reopenings in the first place. I would not distort the RRA’s judicial review provision to force courts to review a decision where no standards of review are evident,” Thomas wrote.

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