Salinas v. Railroad Retirement Board

Manfredo M. Salinas, a former Union Pacific Railroad employee, applied for disability benefits under the Railroad Retirement Act of 1974 after suffering serious on-the-job injuries. His first three applications were denied, but he was granted benefits after a fourth application in 2013. Salinas then sought reconsideration of the amount and start date and requested that the Board reopen its 2006 denial, arguing that certain medical records had not been considered. The Board refused to reopen because the request fell outside the four-year regulatory window. The Fifth Circuit dismissed Salinas's appeal for lack of jurisdiction, holding that federal courts cannot review the Board's refusal to reopen a prior benefits determination. The Supreme Court reversed, holding that such a refusal constitutes a "final decision of the Board" subject to judicial review.

The Supreme Court reversed the Fifth Circuit in a 5-4 decision, holding that the Board's refusal to reopen a prior benefits determination is subject to judicial review. Justice Sotomayor authored the majority opinion, joined by Chief Justice Roberts and Justices Breyer, Kagan, and Kavanaugh. Justice Thomas filed a dissenting opinion, joined by Justices Alito, Gorsuch, and Barrett. The case was remanded for further proceedings.

Whether the Railroad Retirement Board's refusal to reopen a prior benefits determination constitutes a "final decision of the Board" subject to judicial review under the Railroad Unemployment Insurance Act's judicial review provision.

The decision resolves a long-standing circuit split on the reviewability of Railroad Retirement Board reopening denials. It provides railroad workers with a judicial avenue to challenge agency refusals to reconsider prior benefit determinations, reinforcing the strong presumption favoring judicial review of administrative action. The ruling represents another in a string of decisions rebuffing agencies' efforts to shield their decisions from judicial review and has significant implications for claimants who depend on disability benefits.