Salinas v. Railroad Retirement Board

Justia Summary

In 1992, Salinas began seeking disability benefits under the Railroad Retirement Act (RRA) based on serious injuries he suffered during his 15-year railroad career. He was granted benefits after his fourth application in 2013. He timely sought reconsideration of the amount and start date. After reconsideration was denied, he filed an administrative appeal, arguing that his third application, filed in 2006, should be reopened because the U.S. Railroad Retirement Board had not considered certain medical records. The Board affirmed the denial of the request to reopen because it was not made “[w]ithin four years” of the 2006 decision. The Fifth Circuit dismissed an appeal for lack of jurisdiction.

The Supreme Court reversed. The Board’s refusal to reopen a prior benefits determination is subject to judicial review as a “final decision of the Board.” The decision was the “terminal event” in the Board’s administrative review process. Salinas’ only remaining recourse was to seek judicial review. A reopening decision is one “by which rights or obligations have been determined, or from which legal consequences will flow.” Any ambiguity in the meaning of “any final decision” must be resolved in Salinas’ favor under the “strong presumption favoring judicial review of administrative action.” The Board could decline to offer reopening but, having chosen to provide it, the Board may not avoid the plain text of 45 U.S.C. 355(f ).